United States
      Environmental Protection
      Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 7
Number 10
November-December 1981
      EPA JOURNAL
      Chemicals and
      the Environment
I


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Chemicals
and Choices
T
    his issue of EPA Journal takes a look
    at some of the problems of
management in general and managing in
particular the wastes from chemicals
which have brought modern society so
many benefits.
  EPA Administrator Anne M. Gorsuch
explains how she hopes to tighten and
improve management of the Agency's
programs. Part of a new emphasis on
efficiency, she said, will include
"avoidance of the extraordinarily complex
rules and excessive number of permits
required under past programs."
  Dr. John A. Todhunter, EPA Assistant
Administrator, Pesticides and Toxic
Substances, explains in an interview that
there is a new awareness "that not every
human interaction with the environment
constitutes an adverse impact. Living
with, cherishing, conserving, and passing
on to our heirs the environment does not
require that we embalm the environment
in a morass of useless paperwork."
  The complexities of dealing with the
problem of acid rain and other forms of
deposition are reviewed in an article by
Kathleen M. Bennett, EPA Assistant
Administrator for Air, Noise and
Radiation.
  Two articles give a report on EPA
and State efforts to deal with the problem
of chemical and other hazardous wastes
around the country.  Another article notes
that while waste chemicals can be a
blight, some chemical companies have
proved they can live  successfully with
their natural environment.
  Other articles on chemicals include a
report on aid being provided to the city of
Niagara Falls to help with treatment of
chemical and other wastes, a report on an
EPA decision to extend a deadline
involving chemicals to keep the trains
running, and a review of information
about the impact of chemicals on the
ozone shield.
  This issue also contains a report on new
EPA appointments and honors awarded
Agency officials. Also included is a chart
on the Agency headquarters, giving the
names and phone numbers of EPA's top
leadership, and a map showing the states
in each EPA region and listing the
Regional Administrators.

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                             United States
                             Environmental Protection
                             Agency
                             Office of
                             Public Affairs (A-107)
                             Washington DC 20460
                             Volume 7
                             Number 10
                             November-December 1981
                         &EPA JOURNAL
                             Anne McGill Gorsuch, Administrator
                             Byron Nelson III, Director, Office of Public Affairs
                             Charles D. Pierce, Editor
                             Truman Temple, Associate Editor
                             Articles
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 between human activities and
the ability of natural systems to
support 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.
Contributions and inquiries should be
addressed to the Editor (A-107).
Waterside Mall, 401 M St., S.W.,
^/ashington, D.C. 20460. No
»rmission necessary to reproduce
Rntents except copyrighted photos
and other materials.

Text printed on recycled paper.

Front Cover: A marine shorebird,
the black skimmer, wings by a
Dow Chemical plant in Freeport,
Tex., where some of these birds
nest.  (See P. 19)

Photo  Credits:  Steve  Delaney,
Photri, Amtrak, Parks & Recreation
Dept, Jacksonville, Ark.; NOAA,
Dow Chemical, Niagara Gazette, D.
Wilson, Louisville Courier Journal,
DuPont

Design Credits Robert Flanagan.
.ind Ron Farrali
Tighter EPA Management
Planned  2

Administrator Anne M.
Gorsuch outlines how EPA is
trying to improve management,

Living with Chemicals 5

The beginning of a special
section on chemicals.

Investigating Acid Rain 6

A top EPA official explains the
scientific questions involved.

Risks and Challenges  10

An interview with Dr. John A.
Todhunter, Assistant
Administrator, Pesticides and
Toxic Substances

Aid for City of
Niagara Falls 13

EPA will help improve treatment
of wastes, including chemicals,
discharged into Niagara River.
Sites Ranked  14

A total of 115 hazardous waste
sites have been rated as the
worst in the country.

Who's Who on the List  16

The listing of the waste sites
around the country.

Birds, Flowers and
Chemicals 19

Some chemical plants have
proved they can live
successfully with their natural
surroundings.

Keeping the  Trains
Running  21

EPA extends a deadline for
reducing PCB's in rail
transformers.

Questions in the
Stratosphere 23

EPA is helping investigate
whether chemicals are
destroying the ozone shield.
Chemical Waste Cleanup  26

Consent decree filed to correct
Arkansas waste disposal
problems

EPA Collects Overdue
Bills  27

Claims officers to  ensure
that money owed  Agency
is paid.

Appointments and
Awards 28

News of honors and filling of
top EPA posts.

EPA Headquarters
Leadership  30

A chart giving the names and
phone numbers of the Agency's
top leadership.

Around the Regions   32

A map showing EPA's new
regional administrators and the
States in each region.
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Tighter  EPA
Management
Planned
  In recent testimony before
  Congressional committees, EPA
Administrator Anne M. Gorsuch has
spelled out how the agency is moving
rapidly to improve management of its
major functions.
  In the regulatory program under the
Resource Conservation and Recovery
Act, Mrs. Gorsuch promised a
"comprehensive management approach"
rather than targeting specific problems for
specific actions.
  This approach, she said, will include
more cooperation with the states, an
emphasis on enforcement, and avoidance
of the extraordinarily complex rules and
excessive number of permits required
under past programs.
  The EPA Administrator has also:

  •  Pledged to require more efficient
allocation and expenditure of EPA's funds
to continue protection of the
environment.

  •  Announced plans to revamp EPA's
Office of Research and Development to
relieve scientists who are burdened "by
an astoundingly complex and
cumbersome management system and
budget planning process that seems more
to frustrate than support their efforts."
  Testifying before the Senate
Committee on Environment and Public
Works, Mrs. Gorsuch said that the
agency will undergo spending and
personnel reductions to help achieve the
President's goal of a balanced budget.
  "One of the most challenging and
important aspects of managing EPA
today and in the years ahead is to ensure
that resources are concentrated on
programs producing the greatest
environmental benefits," Mrs. Gorsuch
said. "The agency can and must fulfill its
Congressional mandate, with reduced
funding. That will occur with better
management."
  Mrs. Gorsuch cited these actions as
ways in which the agency will rely on
better management techniques:

  • Development of a new accountability
system that will track every senior agency
manager's performance according to
predetermined goals and production
levels;

  • Improved case management, better
use of more than $50 million annually in
automatic data processing equipment and
tighter oversight of contractor costs and
performance;

  • New enforcement procedures to
eliminate a backlog of cases, reduce
paperwork and eliminate stale and
premature cases;

  • Reform of the construction grant
program for sewage treatment plants that
will reduce the volume of original
regulations by one third;

  • Simplification of the National
Pollutant Discharge Elimination System
so that it is more cost-effective and
responsive, thereby improving the abj
of States to take over operation of th
program;
                                                                                            EPAJOURNAL

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A major reform is planned for the regulations which governed construction
of sewage treatment facilities such as these in the District of Columbia on
the Potomac River.
   •  Implementation of a peer review
process for the agency's scientific
research to improve its consistency and
improved management techniques to
assure that a greater percentage of
research funds goes into actual research;

   •  Increased priority to handling State
Implementation Plans for improving air
quality to dispose of a large backlog of
proposed plan amendments.

   •  Management improvements in EPA's
radiation office so that inactive uranium
mill tailing standards originally set to be
promulgated in January 1983 will now be
issued by March of 1982.

   •  An improved correspondence
management system that will ensure
timely and responsive answers to inquiries
about EPA and its programs.

   In remarks before the House
Subcommittee on Environment, Energy
and Natural Resources, Mrs. Gorsuch
said that the agency will initiate new cost
accounting procedures to track
Superfund expenditures, and will use
available enforcement mechanisms to force
responsible parties to clean up sites where
possible.
   "Both the (Superfund) statute and the
legislative history indicate that the Fund
should be used wisely and for the most
critical remedial actions," said Mrs.
Gorsuch. For that reason, "vigorous
enforcement is essential to a successful
Superfund program. The agency fully
intends to make maximum use of
enforcement authorities, both to secure
site cleanup by responsible parties as an
alternative to fund-financed cleanup and
to pursue cost recovery actions ... to
reimburse the government."
   "Success in establishing an effective
and comprehensive (Superfund) response
NOVEMBER/DECEMBER 1981

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program lies in state participation," said
Mrs. Gorsuch. "The states can function
as true partners in our implementation
effort... we have already entered into
partnership with nine states through
cooperative agreements for remedial site
cleanup" in which "the States and the
Federal government work together in
response actions."
  "EPA and States are also implementing
and enforcing (RCRA hazardous waste)
standards," Mrs. Gorsuch continued.
"As of the end of September, 25 States
and territories have received interim
authorization for Phase I (general
standards). For those states not yet
authorized, we have entered into
cooperative arrangements with a total of
28 states and territories."
  Mrs. Gorsuch noted that under
Superfund, considerable work has
already been completed by EPA, the
Coast Guard, state agencies and
responsible private parties. Over 10,000
sites have been identified, 6,400
preliminary assessments have been
undertaken and over 3,000 on-site
inspections have been completed.
  Enforcement under RCRA to date has
resulted in the filing of 61 federal judicial
actions, 11  negotiated consent decrees
and preliminary judicial relief in another 10
cases. "We estimate that $53 million
worth of privately financed site cleanup is
currently completed, underway or legally
committed as a result of these actions,"
said Mrs. Gorsuch.
  In testimony before the House
Committee on Science and Technology,
Mrs. Gorsuch said that problems with
EPA's research program include "a lack
of responsiveness to the agency's real
research needs, ineffective and
unreasonably complex planning
processes, excessively cumbersome and
top-heavy management, a failure to
properly balance long-term research
against short-term problem solving
scientific and technical activities, and a
lack of consistent scientific quality."
  Mrs. Gorsuch noted that these
problems have been identified in the past
by Congress, the General Accounting
Office, the National Research Council and
others. She added that an evaluation by
the new administration at EPA started in
June has confirmed the existence of
these problems.
  At the same time, she said, the agency
has "the basic materials for a fine
program" including "considerable
scientific and technical staff talent, good
indications of professional dedication,
and many excellent research facilities and
equipment." But the program's
operations must be improved to produce
"significantly better research and
contribute more effectively to EPA's
decision-making," she stated.
  "Although many people in ORD do
their job well, the present system seems
to encourage building or protecting
existing organizations and activities
without regard to real research needs,"
the EPA Administrator added.
  "... ORD had created complex layers
of headquarters managers whose
interactions often result in a higher
priority on paperwork than on research,"
Mrs. Gorsuch said. "An astonishing 31
percent of the 230 permanent full-time
employees in ORD headquarters are
managers at the Senior Executive Service
or GS-15 level, as compared with only
seven percent of the 1,440 people in our
laboratories .... Up to 26 percent of
EPA's total personnel are devoted to
administrative matters, rather than to
substantive agency missions."
   Mrs. Gorsuch described current
research planning as a "labyrinth" and
said "the official who originally requested
the research must wait an average of 18
months from the time of the request until
the laboratory can begin work on it. . ."
   Mrs. Gorsuch said she and an advisory
group, consisting of EPA senior
scientists and career managers, have
identified goals for improving the
program. These include:

   • a stronger peer review process and
an evaluation of ORD's present incentive
system;

   • more attention to the relevance of
research to the agency's regulatory
mission;

   • a faster response time "with a
greater portion of resources devoted to
real research, and less to paper-pushing
and administrative trivia."

   Final changes in the program will not be
made until the advisory group completes
its findings, Mrs. Gorsuch indicated. Q
                                                                                                      EPAJOURNAL

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                          Living
                          With
                          Chemicals
 Man can learn nothing unless
 he proceeds from the known
 to Hie unknown.

 Claude Bernard
Claude Bernard was a noted
French scientist.

 Rerican Chemical Society posters
 Sprinted arc part of a set. Further
information on the posters is available
from the American Chemical Society,
Room 210, SciQuest posters.
1155 16th St., N.W.,
Washington, D.C., 20036.
trim'in''¥HtlMiiiiiHiiiil''llii1ilii1i1Tr'

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Investigating
Acid  Rain
                                      A country church in Highland County, Va., seen through a rain-streaked window.
     The depth of our concern about acid
     deposition should be reflected in
 public policies that are based on sound
 science, EPA's top air pollution control
 official has explained to a Congressional
 Committee.
   Kathleen M. Bennett, Assistant
 Administrator for Air, Noise and
 Radiation, told the U.S. Senate
 Committee on the Environment and
 Public Works that there are major
 "uncertainties" in many critical areas
 about the transportation and causes of
 acid rain.
   The major uncertainties include, she
 said, "the transportation and
 transformation of possible precursor
emissions into acid deposition, the
effects, and the policy implications of acid
deposition. In passing the Acid
Precipitation Act of 1980, Congress itself
established a comprehensive
intergovernmental and interdepartmental
research plan so that the complexity of
acid precipitation could be more fully
addressed.
  "Without such a firm foundation on
which to base our decisions on whether
controls are necessary, in what areas and
to what degree, any regulatory action at
this time would  involve guessing."
  In view of the many unknowns about
acid rain, and the possible substantial
cost burden of additional controls,
Bennett said that EPA is proceeding with
its program to investigate this
environmental malady over a 10-year
period, as directed by Congress.
  Reviewing the history of this problem,
Bennett explained that "acid deposition"
is a general term for the deposition of
acidic materials, whether wet or dry, from
the air onto the surface of the earth or
upon structures or objects.
  Neither acid deposition itself nor the
terminology by which we describe it is
of recent origin. Although  references date
back to 1661, most relevant research
through the 1950's was conceived
originally for other purposes. Historical
lake surveys were done to assess fishery
or water quality resources. Large-scal^^B
precipitation chemistry networks werejj
established by agricultural scientists to
study precipitation as a source of plant
                                                                                                 EPAJOURNAL

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 nutrients, and atmospheric scientists
 even studied rain as a method of
 removing air pollutants.
   A synthesis of information from such
 independent disciplines by Swedish soil
 scientist Svante Oden in 1967 sparked
 scientific and public interest. Later, re-
 analyses of earlier precipitation chemistry
 data and studies of fish populations in the
 Adirondacksand Sudbury, Ontario,
 lakes stimulated North American interest.
 This led to the development of
 government and industry sponsored
 research programs in both the United
•tates and Canada. Thus, the scientific
^tudy of acid deposition as a separate
 field is scarcely more than a decade old,
 and our understanding has improved
 considerably in the last five years.
Acid Deposition — Knowledge
and Uncertainties

While acid deposition exists, and causes
varying effects, there is considerable
debate over the circumstances of its
formation and the feasibility of potential
controls. Scientists may see the same
data on acid deposition and
circumstantially associated pollutant
emissions and reach quite different
conclusions, Bennett noted.
  "Currently, we do know something
about the emissions of oxides of sulfur
and nitrogen which can be the precursors
of acid deposition. The majority of man-
made emissions of sulfur oxides in the
United States comes from utilities; the
remainder comes from other combustion
sources, non-ferrous smelters, and
transportation sources. U.S. nitrogen
oxide emissions come mainly from
transportation and from utilities and
industrial boilers.
  "We know that emissions tend to be
highly interactive, and that multiple
emissions must be considered
simultaneously.
  "Both sulfur and nitrogen oxides can
be transformed into nitrogen and sulfuric
acids by reacting with the moisture as
well as other substances in the
atmosphere. These transformations can
take place in cloud or rain droplets or after
deposition. Depending on a number of
variables, emissions may be deposited
relatively near their sources or transported
over long distances."
  Bennett said one of a number of major
uncertainties in our current knowledge
about acid deposition is the pH level at
which precipitation should be considered
acid.
  The conventional definition is based on
pure water saturated with atmospheric
carbon dioxide. It has a pH of 5.6 which is
therefore, the theoretical level of  "normal"
rainfall. Naturally occurring precipitation
may be considerably more or less acidic.
  "In addition, although oxides of sulfur
and nitrogen are precursors of acid
deposition, the transformation processes
are still not understood. While there are
significant differences in the composition
and acidity of rain between seasons,
geographical regions, and even during
and between storms, no clear evidence is
yet available which can explain or predict
accurately how precursors are
transformed or why the observed
variations occur.
  "Yet another uncertainty exists with
regard to the transport and distribution of
precursor emissions. Remote regions of
the globe have rains with a low pH, as do
Hawaii and Alaska, and there is
controversy over the role that localized
emission sources may play. To resolve
such controversies, both better data and
more accurate modeling techniques are
necessary."
  Additional uncertainties that point to
the need for better data, she said, include
the relative impact of local sources as
compared to more distant sources and
the role of other photochemical pollutants
and how they affect acidity levels.

Need for
Responsible Action

"Any Administration action must be
based on a reasonable degree of certainty
that it will, in fact, accomplish its
intended purpose. The American people
have the right to expect that their
government will not impose an additional
multi-billion dollar program without first
determining with some assurance that the
intended environmental benefits will be
achieved.
  "In this case, quick and simple
solutions are unlikely. Given the length of
time it has taken to recognize the
magnitude and complexity of the problem
 NOVEMBER/DECEMBER 1981

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and the many fundamental questions that
remain to be answered, Congress wisely
authorized a comprehensive research
program.
  "Currently, in an effort to reduce
uncertainties so that meaningful and
effective program options can be
considered, EPA is working on a number
of projects.
  "EPA alone has committed more than
$9 million in FY 1982 just to its research
efforts on acid deposition; other Federal
efforts will bring the total to more than
$18 million.
  "The three major areas of uncertainty
toward which EPA's portion of the
research program is directed are:

"(1) transport, transformation, and
deposition processes;

"(2) effects of acid deposition; and

"(3) assessments and policy studies."

Other Federal Acid Deposition
Research Activities
"When in 1980, Congress passed the Acid
Precipitation Act, it established an
interagency Acid Precipitation Task
Force to prepare a ten-year
comprehensive research plan to identify
the causes and effects of Acid
Deposition. Congress directed that an
annual report be submitted 'which shall
detail the progress of the research
program under this subtitle and which
shall contain such recommendations as
are developed'."
  "The comprehensive research plan,
entitled the National Acid Precipitation
Assessment Plan, is currently being
updated to incorporate public comments.
EPA has been designated as the "lead
agency" for three of the research areas,
including aquatic effects, control
technology, and data assessments and
analysis.
  "Furthermore, the results of research
from all sources, public and private, are
compiled and evaluated in assessments
that provided research support for
regulatory decision making."

Anticipated
Research Results
Bennet said "over the next three to five
years, we anticipate that many
ambiguities and uncertainties will be
reduced." Specifically, she said, we expect
to have the following information:

• Additional studies of historical lake,
stream, and reservoir data.

• The results of five models for predicting
sulfate deposition on an annual basis.

• Status reports on acid deposition
effects on agricultural crops.
• A new report on the role of clouds and
storm fronts in formulating and
scavenging acids in the atmosphere.
• The results of pilot tests and a
completed demonstration of new
combustion processes for controlling
oxides of nitrogen and sulfur dioxide at
significantly reduced costs.

• A summary report on the impacts of
acid deposition on materials.

• Additional results from Sweden on
forest productivity.

• A progress report by the National
Oceanic and Atmospheric Administration
on acid rain in remote locations.

• An aquatic model for predicting the
rate of acidification occurring in lakes.

• A series of second-generation models
for predicting the transport and
deposition of sulfur and nitrogen over
long distances.

• Field studies validating laboratory
experiments of the effects of acid
deposition on selected major crops.
Global Transboundary Air
Pollution
Because transboundary air pollution is a
global concern, Bennett continued, EPA
has been consulting with other interested
countries, particularly Canada, and will
continue to do so.
  "With the August 5, 1980,
Memorandum of Intent on
Transboundary Air Pollution, Canada and
the United States agreed to begin
cooperative steps to deal with
transboundary air pollution and to
develop a bilateral agreement. Formal
negotiations began in June.
  "Within this structure. Work Groups
are preparing the technical summaries on
currently available information. The Work
Groups are comprised of representatives
from EPA; the Departments of State,
Agriculture, Interior, and Energy; the
Council on Environmental Quality, the
National Oceanic and Atmospheric
Administration; and other agencies as
well as representatives from
corresponding Canadian departments.
Interim Work Group reports currently
under review and revision are due to be
completed early next year."

Senate Amendments
Addressing Long-Range
Transport
"The amendments proposed by Senators
Mitchell, Moynihan, and Dodd each
provide mechanisms for dealing with acid
deposition or, more broadly, the
interstate transport of air pollutants,"
Bennett said.
8
                                                              EPAJOURNAL

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   "Although the Mitchell and Moynihan
 bills are based on different equations,
 each basically calls for substantial
 reductions in sulfur dioxide emissions
 over the next decade, in general, the
 impact of these reductions would fall
 primarily on those few states whose
 emission sources rely most heavily on
 locally available high sulfur coals. Thus,
 some states will experience large (perhaps
 over 10%) increases in their utility bills
 while many other states will be virtually
 unaffected. This uneven impact could
 increase the tension already evident
 between states and make it more difficult
 to secure state cooperation in developing
 a cost-effective control strategy for acid
 deposition.
   "Although the regional impact of the
 proposed bills is obvious, EPA has not
 had an opportunity to analyze the
 consequences of these bills in detail.
 Therefore, I am not prepared to address
 the specific effects of the types of
^fcasures mandated in these bills. I would
  Ws to reiterate that the scientific
 uncertainty surrounding the causes and
 effects of acid deposition at this time
demands that we proceed cautiously and
avoid premature action, unless we have
some confidence that the intended
environmental benefits would be
produced.
  "Since the passage of the Clean Air Act
of 1970, it is estimated that our nation has
spent approximately $150 billion on air
pollution control. Those expenditures
have been driven by our attempts to meet
the health and welfare requirements of
the Act. We estimate that the approach
proposed in these bills could increase
expenditures by roughly $2 to $4 billion
per year. Further, the implementation
scheme for both bills is unclear and could
be exceedingly difficult to administer.
These bills involve a radical new concept
in pollution control based on a total
loadings approach. Such an approach
would represent a sweeping departure
from our current national program which
is based on protection  of health and
welfare through control of local ambient
air quality levels. Before proceeding with
such a dramatic and expensive overhaul
of the underpinnings of our air cleanup
efforts, we must better understand the
need for and impact of a loadings
reduction approach."
                                                                                A drenching rain pours from a
                                                                                towering storm cloud.
  Bennett also addressed a pending bill
proposed by Senator Dodd to improve
the decision-making process concerning
state petitions to EPA on interstate
pollution problems. She said, "While we
support the goal and general approach of
the bill, we are concerned about some of
its specific provisions.
  "The most troubling aspect of the bill is
the new penalty provision which requires
the court to assess a penalty of $100,000
against the United States, if the
Administrator fails to act on a petition
within  120 days," Bennett noted. "I am
deeply disturbed by the concept that the
general taxpaying public would be
punished for the Agency's failure to act
within the short statutory period. This
provision could serve as an incentive for a
state to complicate the process — at the
expense of taxpayers in other states. This
provision could divert the attention and
resources of the agency from other
statutorily mandated responsibilities.
Delays already result from many factors,
including the demands of meeting other
statutory obligations, the complexity of
interstate pollution questions, and the
vagueness of the current statutory
guidelines."
  The Assistant Administrator said the
bill also "provides for control of pollutants
for which no national ambient air quality
standard has been set. In essence, it
grants the Administrator broad discretion
to require potentially costly emission
reductions for pollution control, without
provision for the type of scientific review
and procedural protection provided in the
national standard-setting process." Q
NOVEMBER/DECEMBER 1981

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Risks and

Challenges
Interview with
Dr. John A. Todhunter
Assistant Administrator
Pesticides and Toxic Substances
 Q
       Why did you take this job?
 ^«  I took it because I've had a long-
standing interest in the whole area of
science as it relates to public policy
decision making. I saw an opportunity to
bring science of good quality into the data
base that the agency uses to make its
decisions, and then actually go one step
further and get into the area of policy
decision. I saw it as a personal challenge
to apply my own personal technical
expertise to the public interest.
 Q
      What opportunities do you see
in your new post?
A
      Opportunities to contribute to two
goals vital to the future of EPA:
protection of the public health and the
environment and the cultivation of sound
science as a data base for regulatory
decision making. EPA is the lead Federal
agency in the protection of human health
as it is affected by the physical
environment. I am personally committed
to these goals. I, with other senior EPA
managers, am also committed to
achieving these goals in ways which do
not overly burden the taxpayer or our
economy relative to the effects realized as
a result of our regulatory stances.
  We enjoy, in the United States, a rich
environmental heritage. We also enjoy a
standard of health in which we can take
pride. Over the last ten years, we have
seen continuing discussion and an
evolving definition of the relationship of
Americans to their environment. We have
come to learn that the environment is at
times benevolent and, at times, less than
benevolent. We have been coming to
grips with the enormity of the
interdependence between humans and
the environment. We have come to a
sensitivity that fouling of the environment
is not a private act but one which can
compromise the rights of our neighbors.
  We have also, I hope, come to an
awareness that not every human
interaction with the environment
constitutes an adverse impact. Living
with, cherishing, conserving, and passing
on to our heirs the environment does not
require that we embalm the environment
                                                                          in a morass of useless paperwork. There
                                                                          is ample room for concordance of the
                                                                          activities of a technological/industrial
                                                                          society with the aim of health and
                                                                          environmental protection.
                                                                          Q
       Do you think that your
background as a scientist will be
useful in this position?

 A
  \ .   I think it's exceptionally useful.
The Toxics Substances Control Act calls
for an Assistant Administrator for Toxic
Substances who is a person with the
training and experience to head up a
program in chemical safety.
                                                                         Q
       What do you think of the
proposed Peer Review Program for
the agency?

/"\ •   I think it's something that we
need. I'm a little suprised, to be perfectly
honest, by the negative reaction in some
sections of the mass media to the
program. Most of the EPA staff views
have been very supportive. There have
been some concerns as to exactly the
volume of documents that may be
processed, which particular types of
things, just general questions as to
will be expected. Obviously, those
haven't been worked out. But I don't
 10
                                                                                               EPAJOURNAL

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know of any first rank research or
technical institution that does not have an
internal peer review process. I've been in
several and I've been through the review
processes, and they can be frustrating
because often times your own colleagues
will call you up short on your mistakes or
your oversights. But that's important
because you don't maintain a reputation
as a first rate scientific institute if you
dojVt have that kind of a process. And I
think that's one thing we really need here.
Q
     .  Do you see it as strictly an
internal peer review or external as
    .  I think that Dr. John Hernandez
(EPA Deputy Administrator) is
envisioning a combination. For some
major documents I think he may use
outside peer reviewers for the simple
reason that these people may at some
point be called to testify on what they
have assessed. It's important in that case
to have people who have standing in the
scientific community and are credible
witnesses. Use of outside reviewers also
prevents  us from becoming captives of
our internal biases. In any institution you
can become inbred in terms of your
thinking.
Q
       One concern about peer
review expressed in the news media
was that there might be excessive
delay or paralysis. Is there some
safeguard that can be used to prevent
that?
A
       Yes, there is. Two things can
   pen. One is, knowing that you have a
   ew cycle ahead, you can start putting
     package together sooner. Your front
end work has to be better done.  Also you
do have to give peer reviewers a guideline
                                       that they must return documents by such
                                       and such a date. And I think if you have a
                                       sufficient number of people reviewing, no
                                       one person will be so overburdened that
                                       he can't meet those deadlines.
                                       Q
                                       Q
     .  Do you think that in the future
EPA will be less likely to make strong
correlations between animal studies
and potential  human effects?

r\ m  No, I don't think so. I think that
what we will be more likely to do is to
make better correlations. I don't think
anyone in this agency or outside who has
a lot of experience in toxicology,
pharmacology and related disciplines
which rely on animal experimentation has
any discomfort with using animals as test
models. But for certain types of effects
there has been  a tendency not to factor in
some of the considerations that one uses
in going from the animal model to the
human. In the area of carcinogenesis, for
instance, which is the area where we
probably make the weakest types of
correlation, we simply make what is
essentially a leap of faith. If you look at
the way one establishes, let's say the
safety of a drug, there are a whole series
of tests that are carried out. You test not
just a rat but a rat and a mouse. You
check beagle dogs, rabbits, or guinea
pigs. And these procedures give you
some confidence in how general a
particular effect is. You may observe a
particular toxic effect which could affect
humans. You normally take into account
any differences in physiology or anatomy,
differences in specific biochemistry and
things like this. So far the only thing we
take into account in making the
correlation for a carcinogen is simply the
body surface area — which is, of course,
one fundamental  thing you have to take
into account, but it leaves out all the other
things that really let you understand
where you are going.
       Do you think it changes the
way you consider benefits vs. risk in
deciding whether a chemical should
stay on the market?
A
       I think what we have to do is to do
a better job on identifying benefits. We
don't have many economists in this
agency. And so we depend very much for
benefit information on other Federal
agencies or on trade groups and, as a
result, we don't have the best quality
control over that information. We
probably need to do a better job in-house
on that benefit side of the equation.
                                                                              Q
       How about on the risk side,
are you satisfied with the work that's
done there?
                                                                              A
       Well, Congress designed both the
Toxic Substances Control Act and the
Federal Insecticide, Fungicide and
Rodenticide Act as risk balancing
statutes. They do not speak of absolute
risk or zero risk but of reasonable vs.
unreasonable risk. Therefore, we have to
move to the system where we're getting a
better picture of what the risk actually is. I
think some of the comments I made
before with regard to translating animal
studies are pertinent. When we do a risk
calculation, we probably do need to sit
down and  instead of running just one
model, run several and see how well they
agree or disagree. Some of these risk
models can disagree with each other by
several orders of magnitude. And the
question is where does the risk really
seem to be. If you happen to pick the one
model that gives you an inappropriate risk
number, then you're not basing your
decision on a good analysis.
  We need a better data base. We
need to see a return of informed
professional judgment to an area which
NOVEMBER/DECEMBER 1981
                                                                                                                1 1

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has been abdicated to "risk" numbers
generated by computer curve fitting
programs. And we need to see an attempt
to apply our developing knowledge of
toxicological and physiological principles
to the interpretation of risk data.
Q
    • •  Is it true that perhaps one of
the most potent carcinogens is a
natural product?

A
       Oh yes, aflatoxin is among the
most potent of carcinogens. It's out
there. But we can't do anything about it.
The only way to get to zero risk on
aflatoxin is simply to ban peanut products
and certain grain products. FDA is not
going to do that. There are tolerance
levels for aflatoxin that mitigate the risk to
what FDA feels is a safe level.
Q
       How many new chemicals
have been registered under TSCA
now?
A
       The Pre-Manufacturing Notice
Program has been in effect for about
three years, and I think we're talking
approximately 1,000 chemicals at this
point. Next year we anticipate maybe an
additional thousand notices.
Q
       Have we had any problems
accepting any of these so far?
A
       We have had problems in that a
lot of the manufacturers basically don't
give us enough information to evaluate
whatever level of risk may be present.
They may just let us know they have
compound X and sometimes they'll leave
off the tonnage or the structure or things
like that. However, it's been getting
better. A lot of manufacturers generate a
great deal of data as part of their product
                                       liability and product stewardship
                                       programs. And a lot of manufacturers
                                       have been getting into the habit of
                                       sending the data along with the material.
                                       That makes our life very easy when they
                                       do that.
                                       Q
       How is the generic registration
for pesticides proceeding?
                                       A
       You mean the registration
standard? It's proceeding pretty much on
schedule. In 1981 we have gotten out 15
registration standards. We anticipate
getting out a similar number in 1982 and
more again in 1983. We are changing
somewhat the structure of a registration
standard to put more reliance on having
the industry do some of the work involved
there. There's no reason since we do
provide them a service of licensing a
product, that we should be doing all the
searching out of where the studies are
and things like that. We're moving in the
direction at EPA of simply identifying the
product that we want to re-register,
seeing what is in our files, identifying
where we have data gaps and then simply
telling the registrants that it's up to them
to supply this information, and if they can
tell us that we have it somewhere or if it's
in the literature or if they have to do a new
study. That's their business.

o
  t«  In retrospect, would you say
that the decision made by the agency
to ban DDT was a wise one ?
                                       A
       I think that right now the DDT
question probably is insignificant because
DDT is something that most domestic
insects have developed quite a lot of
resistance to. Even back when DDT was
first banned, it was in many cases losing
its effectiveness. I'm informed that in
some experimental uses that were
granted after the DDT ban was instituted,
they actually got higher yields in the non-
DDT treated fields than they did in the
DDT-treated fields for the simple reason
that the DDT knocked out the natural
predators of the pests they were trying to
get rid of, but the pests were reasonably
resistant to DDT. Looking back at the
record, I'm not sure that the decision
could have gone but the way that it did.
Q
                                                                                    What will be your philosophy
                                                                             in administering the Toxic
                                                                             Substances Control Act and the
                                                                             Federal Insecticide, Fungicide, and
                                                                             Rodenticide Act?
                                                                             A
       I arn seeking the opportunity to
administer TSCA in an integrated fashion
which will provide a greater measure of
public and environmental protection as
well as a reduction in the complexity of
toxic substances regulation and the
burden of these regulations on the
regulated community. I am committed to
bringing more credibility to the science
used in decision making.
  With FIFRA, I am again seeking the
opportunity to administer the law so as to
improve public and environmental safety
while ensuring that FIFRA regulations are
structured so as to not discourage the
development of those products needed to
support our efforts to raise food and
protect our citizens from certain of
nature's less than benevolent creatures.
  I am also supportive of Administrator
Gorsuch's policies regarding greater
involvement by the states. EPA has had a
long history of looking down its nose at
state agencies. I would like the
opportunity to change that attitude in the
Office of Pesticides and Toxic
Substances. D
I.'
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                                     Aid   for
                                     City  of
                                     Niagara  Falls
                                     Water thunders over Niagara Falls                               here
                                     thousands of gallons of poorly treated iv,;.
                                          ra River.
         has announced that it will
         increase a construction grant
to the city of Niagara Falls, N.Y,, by $4
million to improve treatment of poorly
treated wastes now being discharged into
the Niagara  river below the falls.
  Money from this grant will be used to
rebuild carbon filtration beds which have
been inoperable since 1978.
  The award of the increased sum is
conditioned on acceptance by the city of
a state discharge permit requiring control
of the waste it accepts and the  successful
operation of the plant.
  While an increased grant is being
awarded to the city,  a claim by  the city for
  .4 million  spent for the design and
  nstruction of the carbon beds to be
        is being disallowed.
  An investigation is under way to
determine what, if any, action EPA can
take to recover funds spent or damages
from parties involved in the design,
engineering or construction of the original
carbon filtration beds.
  The decision to provide additional
funding for correction of the carbon bed
problem is the first action resulting from a
comprehensive review of the
environmental problems in Niagara
County started by EPA in mid-August.
  The Inspector General of EPA, together
with EPA's National  Enforcement
Investigation Center located in Denver,
the EPA Water Programs Office, the EPA
Enforcement Center and the Agency's
Regional Office in New York City is
completing an investigation of other
deficiencies in the Niagara treatment
plant and will present a report and
recommendation to the  EPA
Administrator shortly.
  Based on the findings of this study,
EPA will decide whether to provide up to
an additional $8 million to the city of
Niagara Falls for improvement of the
treatment plant.
  EPA began surveying the Niagara area
in August as a first step in developing a
more comprehensive approach to
pollution abatement in Niagara and its
neighboring counties.
  The survey includes a review of existing
wastewater discharges, air emissions and
some 330 hazardous waste sites,
including approximately 150 which are
less than three miles from the Niagara
River.
  Scheduled for completion soon, the
survey will guide a stepped-up and
carefully targeted enforcement program
now under development, fj
NOVEMBER/DECEMBER 1981
                                                                       13

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                                                                          Sites  Ranked
  Administrator Anne M. Gorsuch fields
questions at a press conference
announcing the 115 worst hazardous
waste sites.
A    total of 115 hazardous waste sites
    have been ranked as the worst in the
country in the first stage of a $1.6 billion
Superfund Federal cleanup campaign.
  Anne M. Gorsuch, EPA Administrator,
declared:
  "This is a milestone in the development
and implementation of Superfund. The
list we have developed represents a
program to which we have given the
highest priority, and one we are
determined to make successful."
  Mrs. Gorsuch emphasized that the
Reagan administration is "committed to
the cleanup of hazardous waste sites as
quickly and effectively as possible."
  Superfund, known formally as the
Comprehensive Environmental Response,
Compensation and Liability Act, provides
funds from industry and the Federal
government to clean up hazardous waste
sites when responsible parties cannot be
found or cannot afford to pay for cleanup.
  The ranking of sites was based on a
hazard-scoring system developed by EPA
and one of its contractors, with extensive
input from states and industry. The
greatest emphasis was on potential threat
to public health, but the threat to the
environment was also taken into account.
  Pollution via three "pathways" — air,
groundwater and surface water — was
measured for potential impacts. Fire,
explosions and the possibility of direct
contact received separate evaluation as
more appropriate for emergency action.
  In some cases, EPA authorized an
emergency removal action based on
information uncovered during the
hazard-scoring process.
  The list of 115 sites was developed from
an initial list of 585 sites evaluated by the
                                                                            Metal barrels are removed in program
                                                                          to reduce hazards at the "Valley of the
                                                                          Drums"site in Kentucky.
                                                                                                EPAJOURNAL

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states and EPA's 10 regional offices this
summer. The final quality-assurance
phase of the process was conducted by
EPA Headquarters.
  The sites announced will be candidates
for inclusion on the list of 400 national
priority "response targets" that the
Superfund law required EPA to identify.
  That list will be made final after public
participation and after the results of
further study and data collection are
incorporated into the hazard scoring.
  Under Superfund, states must
contribute at least 10 percent of the actual
long-term costs of cleanup per site,
unless the site is publicly owned. On
publicly owned sites, the state is required
to pay or assure at least 50 percent of the
costs.
  Detailed plans for cleanup will be
worked out in conjunction with the
states. Cleanup can occur through three
mechanisms: direct Federal contracts;
cooperative agreements under which the
state takes the lead in directing cleanup,
and private cleanup through voluntary or
court-ordered action.
  "The Agency will continue to press
responsible parties — through legal
action, if necessary — to clean up sites
threatening public health or the
environment," Mrs. Gorsuch said.
"Where this cannot be done, or if it
cannot be accomplished in a timely
manner, EPA and the states will finance
remedial action under Superfund."
  To date, EPA has spent some $17
million in Superfund money on emergency
action for 41 sites. It has also awarded
$17 million for design and engineering
studies on 25 other sites in 19 states.
NOVEMBER/DECEMBER  1981
                                                                                                                  15

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                                                                                Who's Who
                                                                                on  the  List
    ENTERING
   CLEAN  AREA
         LEAVE
 CONTAMINATED
    GEAR  HERE
  Worker crosses an important boundary
at the "Valley of the Drums" Tayloi site in Brooks. Ky.
Of the 44 States and territories which
have the 115top-priority sites, Florida
heads the list with 16. New Jersey is
next with 12 sites.
  Other States with more than one site
are:
  New York, 8; Pennsylvania, 8;
Minnesota, 5, Massachusetts, Texas,
Arkansas, and Ohio, 4; California, New
Mexico, New Hampshire, Rhode Island
and Delaware, 3; and Virginia,
Oklahoma, Indiana and Missouri,  2.
  The following list contains the sites,
listed  in groups of 10, with the most
serious hazard groups listed first:

  Commencement Bay, Tacoma Industrial
Complex, Tacoma, Wash.; Keefe Environmental
Services, Exeter Rd., Epping, N.H.; Lipari
Landfill, Mantua, Gloucester County, N.J.; Mark
Phillip Trust, North Woburn IndustriPlex,
Woburn, Mass.; McAdoo Associates, McAdoo,
Pa.; Nyanza Chemical Waste Dump, Ashland,
Mass.; Pollution Abatement Services, Oswego,
N.Y.; price Landfill, Pleasantville, Atlantic
County, N.J.; Tar Creek, Pitcher Mining District,
Ottawa County, Okla., and Tybouts Corners,
New Castle, Del.
  Biscayne Aquifer, Hialeah, Fla., along with
Miami International Airport and Miami Drum
Services; Bruin Lagoon, Bruin, Pa.; Burnt Fly
Bog, Tylers Land, Marlboro Township,
Middlesex County, N.J.; Delaware Sand and
Gravel-Ltangollen Army Creek Landfills, New
Castle, Del.; Goose Farm, Plumsted Township,
Ocean County, N.J.; Lone Pine Landfill, Burke
Rd., Freehold Township, N.J.; Motco, La
Marque, Tex.; Pijack Farm, Plumsted Township,
Ocean County, N.J.; Spence Farm, Plumsted
Township, N.J., and  Vertac Inc., Jacksonville,
Ark.
  Bridgeport Rental and Oil Services,
Bridgeport, N.J.; D'lmperio Property, Hamilton
Township, Atlantic County, N.J.; French
Limited Disposal Site, Crosby, Tex.; Love  Canal,
Niagara Falls,  N.Y.; Old Bethpage Landfill,
Oyster Bay, N.Y.; Picketville Road Landfill,
Jacksonville, Fla.; Reeves Southeastern Corp.,
Tampa, Fla.; Seymour Recycling Corp.,
Seymour, Ind.; Sikes Disposal Pits, Crosby,
Tex.; South Carolina  Recycling and Disposal
Company, Richland County, S.C.
16
                        EPAJOURNAL

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                           Hawaiian Islands
 ^Mari


 Guam
                       • American Samoa
   Aerojet-General Corp., Sacramento County,
 Calif.; American Creosote Works, Pensacola,
 Fla.; Charles George Land Reclamation Trust,
 Tyngsborough, Mass.; Iron Mountain Mines
 Inc., Keswick, Calif.;  Kin-Buc Landfill, Edison,
 N.J.; Oakdale Dump Sites, Oakdale,  Minn.;
 Olean Well Fields, Olean, N.Y.; Picillo Farm Site,
 Coventry, R.I.; Stauffer Chemical Company,
 Delaware City, Del., and Taylor Road Landfill,
 Tampa, Fla.
   Andover Sites, Andover, Minn.; Broward
 County Solid Waste Disposal Facility, Davie,
 Fla.; Butler Tunnel, Pittston, Pa.; Facet
 Enterprises Inc., Elmira, N.Y.; Fulbright Landfill,
 Springfield, Mo.; Ottatiand Goss-Kingston Steel
 Drum, Kingston, N.H.; Pioneer Sand Company,
 Warrington, Fla.; Timber Lake Battery Disposal,
 Tampa, Fla.; Whitehouse Waste Oil Pits,
 Whitehouse,  Fla., and Whitewood Creek,
 Deadwood, S.D.
   Chem-Dyne Corp., Hamilton, Ohio; Chemical
 Control, Elizabeth, N.J.; Coleman-Evans Wood
 Preserving Company, Whitehouse, Fla.; Davis
 Liquid Chemical Waste Disposal Site,
^oiithfield, R.I.; Fritt  Industries, Walnut Ridge,
•Be.; Hollingsworth Solderless Terminal
 r.prnpany.  Fort Lauderdale, Fla.; Re-Solve Inc.,
 North Dartmouth, Mass.; Laurel Park Landfill,
 Naugatuck, Conn., Reilly Tar and Chemical
 Corp., St. Louis Park, Minn., and Stringfellow
 Acid Pits, Glen Avon, Riverside County, Calif.
  Allen Transformer, Fort Smith, Ark.; Alpha
Chemical Corp., Galloway, Fla.; Fields Brook,
Ashtabula, Ohio; Koppers Gas and Coke Plant,
St.  Paul; Mid-South Wood Products, Mena,
Ark.; Meal's Landfill, Bloomington, Ind.; United
Nuclear Corp., Churchrock, N.M.; Upper
Freehold, Monmouth County, N.J.; Zellwood
Ground Water Contamination Site, Zellwood,
Orange County, Fla., and 19th Avenue Landfill,
Phoenix, Ariz.
  Batavia Landfill, Batavia, N.Y.; Gold Coast Oil
Corp.,  Miami, Fla.; Homestake Mining
Company, Milan, N.M.; Hranica Landfill, Buffalo
Township,  Butler County, Pa.; A.L. Taylor Site,
Brooks, Ky.; Lord-Shope Landfill, Piper Road,
Girard Township, Pa.;  National Lead-Taracorp
Site, St. Louis Park, Minn.; Outboard Marine
Corp., Waukegan, III.; Sapp Battery Salvage,
Jackson County, Fla.,  between Alford and
Cottondale, Fla., and Tower Chemical
Company, Clermont, Fla.
  Abm-Wade, Chester, Pa.; Ellisville area sites,
near Ellisville, Mo.; Chemicals and Minerals
Reclamation, Cleveland;  Gratiot County Landfill,
St.  Louis, Mich.; Lehigh  Electric and Engineering
Company, Old Forge, Pa.; Marathon Battery
Corp., Philipstown, N.Y.; Mathew's
Electroplating, Roanoke County, Va.;
Sylvester's, Nashua, N.H.; West Virginia Ordnance,
Point Pleasant, W. Va.; Western Sand and Gravel
Site, Douglas Pike, Burrillville, R.I.
  Atchison, Topeka and Santa Fe Railroad
refueling and car washing site, Clovis, N.M.;
Bioecology Systems Inc., Grand Prairie, Texas;
Chisman Creek Disposal, York County, Va.;
Criner Waste Disposal Site, Criner, Okla.;
Denver Radium Sites, Denver; Lindane Dump,
Harrison Township, Natrona, Pa.; Niagara
County Refuse Site, Wheatfield, N.Y.; Summit
National  Liquid Disposal Services, Deerfield,
Ohio; Triana, Triana, Ala., and Winthrop Town
Landfill, Winthrop, Maine.
  Aidex Corp., Council  Bluffs, Iowa; Arkansas
City Dump Site, Arkansas City, Kan.; Arsenic
Trioxide Disposal Site, southeastern North
Dakota; Chemical Metals Industries Inc.,
Baltimore; Fort Lincoln Barrel Site, Washington,
D.C.; Luminous Processes Inc., Athens, Ga.;
North Hollywood Dump, Memphis; Ordot
Landfill, Guam; PCB wastes, Trust Territories of
the Pacific;  PCB spills, multiple sites on 210 miles
of highway shoulder in 14 counties in North
Carolina; PCB Warehouse, Saipan, Northern
Mariana Islands; Rose Park, Salt  Lake City;  Pine
Street Canal, Burlington, Vt.; Taputimu Farm,
American Samoa, and Walcott Chemical
Company warehouses, Greenville, Miss.  O
 NOVEMBER/DECEMBER  1981
                                                                                             17

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         V'  *
            v-

           . •*«.<..
                             *
NIW


                                                                          «•
                                                                          *
18
           EPAJOURNAL

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Birds,
Flowers
and
Chemicals
                                    Azaleas and other flowering plants thrive in Cypress Gardens.
     While carelessly dumped chemical
      wastes have scarred the landscape
 in parts of the country, some chemical
 plants have proved they can coexist
 successfully with their natural
 surroundings.
  Examples of the latter include the
 DuPont polyester fiber plant on the
 Cooper River near the noted Cypress
 Gardens in Charleston, S.C., and the
 Dow chemical facilities at Freeport, Tex.,
 where black skimmers, long-winged
 marine birds, nest on a former company
 parking lot.
   The Dupont polyester fiber plant can be
 seen behind a screen of trees near the
 famed Cypress Gardens in Charleston,
 S.C.
  The DuPont plant occupies only about
200 acres of the 2,000-acre site owned by
DuPont near Charleston. The remaining
1,800 acres of wood and marshland act as
a buffer to shield the plant from the
outside world.
  During construction of the DuPont
plant elaborate precautions were taken to
minimize any adverse impacts on the
beauty of the surrounding marshes,
swamps and woodlands.
  ". .  . deer have continued to thrive on
the site, feed on the newly planted grass
along the swales leading to the river," a
company report noted. "Alligators sun
themselves within sight of the main gate
while ospreys and egrets nest in the old
rice fields along the Cooper. Fishermen
and hunters steer their craft along the
winding course of the river, oblivious to
the work that goes on behind the tree
screen."
  Thousands of people visit the azaleas,
camellias and other exotic plants that
grow around the large stand of cypress
trees at Cypress Gardens. Most of them
are unaware that around the next bend in
the road is one of the world's largest fiber
manufacturing plants.
  Charleston Mayor Joseph P. Riley Jr.
has said that the city and the DuPont
plant on the Cooper River "have been
very compatible." He added that DuPont
has been "extremely supportive of the
city-owned Cypress Gardens."
  At the Dow plant in Freeport, black
skimmers have been nesting at an old
oyster shell parking lot area for several
years.
  These uncommon marine birds, with
odd-shaped bills, are noted for their
unusual feeding habits.
 NOVEMBER/DECEMBER 1981
                                                                   19

-------
  A skimmer soars over the Dow plant
on the coast of the Gu/f of Mexico.

  When looking for food they drop their
lower bill so that it plows the water as the
bird maintains position by beating its long
uplifted wings and slowly flying forward.
  After knifing through the water with its
lower mandible, the bird suddenly
doubles back on its trail and snatches up
the small shrimp and fish which may have
been disturbed or attracted by the ripple.
  Officials of the Dow plant, fascinated
by these unusual birds and anxious to keep
them near their  plant, attempted one year
to improve their parking lot nesting site by
digging drainage channels. One of the
results was an increase in growth of
plants.
  However, when the skimmers then
rejected the site, the Dow officials learned
later from a bird authority that these birds
prefer to nest on bare and uncluttered
shorelines.
  So for the next nesting season the Dow
bird watchers, acting on the advice of an
ornithologist, scraped off the site and
installed some painted skimmer decoys to
attract these birds again.
  This plan worked and the skimmers
now spend their summers once again
skimming over the Gulf coastal waters
near the Dow plant. D
  Black Skimmers flying and landing near
     'nwCht-:         >t at Frecport, Tex.
 20
                                                                                                        EPAJOURNAL

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Keeping
the Trains
Running
                                      An Arntrak passenger train, the Senator, crosses the Mystic River, at Mystic,
                                      Conn., on its way to New York and Washington, D. C. The train changes its
                                      diesel locomotive for an electric one at New Haven for the rest of the trip to
                                      Washington, D.C. Amtrak hopes eventually to provide electric service for the
                                      entire Boston-Washington service.
     To avoid halting commuter rail service
     in the northeastern U.S., EPA has
extended the deadline for reducing the
^vels of polychlorinated byphenyls
 (PCBs) in transformers used in 792
 electrically powered railroad locomotives
 and self-propelled cars.
   Without the 21-month extension, EPA
 officials noted, most of the daily
 commuter service in the Northeast would
 have come to a halt in January, 1982.
   Despite efforts by the railroads to find
 substitute fluids, EPA found in November
 that the railroads would not be able to
 meet the Jan. 1, 1982, deadline for using
 alternative substances.
   Since almost all the rail transformers
 would have been out of compliance by
 Jan.  1, the railroads would not have been
 able to use the locomotives and cars
 containing them.
   The result, EPA found, would have
 been more auto traffic, more  air pollution,
 greater risk of traffic accidents, lay-off of
 railroad employees and revenue losses to
 the railroads.
   PCBs belong to a broad family of
 organic chemicals known as chlorinated
 hydrocarbons. Their primary  use is in
  ectrical transformer cooling liquids and
    acitor dielectric  fluids.
   Because  PCBs present risks through
 chronic exposure at extremely low levels,
 EPA on May 31, 1979, banned their
 manufacture, distribution and use in non-
 totally enclosed units. However,
continuance of some non-totally enclosed
uses were authorized.
  For one of these uses — PCB
transformers in railroad locomotives and
self-propelled cars — EPA ordered that
the level of PCBs not exceed 60,000 parts
per million (6 percent) by Jan. 1, 1982,
and 1,000 ppm (0.1 percent) by Jan. 1,
1984.
  Noting that the railroads operate on
their own restricted rights-of-way, have
spill and clean-up programs and provide
employee protection, EPA preliminarily
concluded that the risks associated with
extending the deadline are outweighed by
the benefits of continued operation of the
northeastern railroad system and of
taking the time to develop an appropriate
substitute for PCBs.
  Five railroad organizations have PCB
transformers in service: Southeastern
Pennsylvania Transportation Authority;
Connecticut Department of
Transportation; New York Metropolitan
Transportation Authority; National
Railroad Passenger Corp. (Amtrak); and
New Jersey Transit Corp. The
Consolidated Rail Corp. (Conrail) and
Maryland Department  of Transportation
also have PCB equipment, but these units
have been retired from service.
  EPA said that mineral oil, a common
substitute for PCBs in non-railroad uses,
poses an unacceptable safety hazard on
passenger trains because its fire point is
170 degrees centigrade. The minimum
standard for passenger service application
is 300 degrees centigrade.
  During early tests, EPA said, several
other non-PCB dielectric fluids
overheated or caused pumping problems
in railroad transformers. Four new
dielectric fluids passed the tests, but the
railroads have expressed concern that the
chlorinated benzenes contained in three
of these fluids may themselves be
hazardous and make them subject to
possible future government regulation.
The fourth substance has a fire point of
310 degrees centigrade, only slightly
above the minimum standard.
  EPA estimated that the total retrofilling
cost of reducing the PCB concentration
to 60,000 ppm could be as high as $12.5
million. This estimate assumes a one-time
refilling cost of $15,000 per car and
$30,000 per locomotive. EPA noted that
the alternative step of replacing the
transformers would cost about $108
million ($130,000 per car and $250,000 per
locomotive).
  Southeastern Pennsylvania Transit
Authority, which has the largest number
of affected cars, has told EPA that the
earliest it could complete the first stage of
retrofilling would be October 1, 1983. In
view of the circumstances, EPA said it is
proposing to extend the date for
complying with the 60,000 ppm
requirement until Oct. 1, 1983. LJ
 NOVEMBER/DECEMBER 1981

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•
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                                                                           EPAJOURNAL

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Questions in  the
Stratosphere
   Any decision on EPA's future course
     of action regarding
chlorofluorocarbon emissions suspected of
depleting stratospheric ozone will need
"to reflect the fundamental problem of
coping with the scientific uncertainties,"
a key EPA official recently stated.
  Don R. Clay, Director of the EPA Office
of Toxic Substances, told a House Energy
and Commerce Subcommittee that
chlorofluorocarbons, also known as
CFCs, are a family of chemicals that have
found extensive use as aerosol
propellents, solvents, heat transfer media
in air conditioning and refrigeration and
various other uses.
  In  the mid-1970's, he noted,
atmospheric modeling and laboratory
studies indicated that continued world
CFC emissions might lead to depletion of
stratospheric ozone. Since stratospheric
pzone limits the amount of solar
ultraviolet radiation reaching the earth's
surface, there was concern that reduction
of the ozone layer might cause adverse
health and environmental effects.
  Solar ultraviolet (in particular UV-B)
radiation  contributes to the approximately
300,000 cases a year of non-melanoma
skin  cancer.
  However, Clay told the subcommittee
that  "uncertainties about the impact,
extent and direction of stratospheric
ozone changes due to CFC emissions still
remain. EPA recognizes that some
uncertainities  regarding whether
depletion will occur, and what its
magnitude would be, will probably remain
for years.
  "Domestic and international research
efforts will continue to improve our
understanding of the causes, magnitude,
and potential effects of changes in
stratospheric ozone.
  "EPA intends to monitor and
encourage support of research efforts by
other nations, international organizations,
industry,  academia, and other agencies,
   fere feasible. The data available from
   ise many sources, carefully

Plane heads  for the stratosphere
through  a cloud-studded sky.
scrutinized, should enable us to
determine whether additional regulatory
measures need to be undertaken and, if
so, when."
   Clay noted that further regulatory
action by the U.S. acting alone would
have only a limited effect in protecting the
world ozone shield.
   Meanwhile, he continued,  "the Agency
will continue its current international
program focused on collecting data,
improving cooperation and pursuing
international understanding. We expect
that, as our knowledge grows, so too will
international agreement  on this issue."
   Reviewing the history  of the issue. Clay
said that after receiving a report from the
National Academy of Sciences in 1976 on
the theory that  damage to the ozone layer
might cause adverse health and
environmental effects, and regulatory
recommendations by the Interagency
Task Force on Inadvertent Modification of
the Stratosphere, the Food and Drug
Administration  and  EPA  prohibited non-
essential aerosol uses of  CFCs in the
United  States.
   EPA  decided to regulate aerosol uses
separately from non-aerosol uses because
substitutes were readily available for most
aerosol applications while alternatives
for many non-aerosol uses were difficult
to identify, Clay explained.
   Since the mid-1970's,  he continued,
scientists at the National Aeronautics and
Space Administration, the National
Oceanic and Atmospheric Administration
and other agencies,  as well as those in
universities and industry, have been
studying the potential effects of CFCs and
other compounds on the stratosphere.
   "These studies have employed
laboratory measurements, atmospheric
observations, and theoretical  analyses
(modeling). Numerous advances have
been made over the  last seven years;
however, scientific uncertainities remain.
We are still unable to predict with
confidence any amount of ozone
depletion for a particular  level of CFC
emissions."
  Clay said that stratospheric scientists
from throughout the world convened in a
NASA/World Meteorological
Organization workshop in May 1981.
Present estimates of their various models
are that continued emissions at present
levels of CFCs-11 and -12 (the most
widely used CFCs) may eventually result
in 5-10% stratospheric ozone depletion,
he added. "Existing uncertainties in
stratospheric chemistry and physics are
such that these values may be in error by
a factor of about two in either direction
(from one-half to double the central
estimates). Historically such estimates
have changed substantially in either
direction as new or better scientific data
emerged but the present estimates have
returned to the initial lower central values.
Consideration of other halocarbon
emissions and their potential impact on
stratospheric ozone may increase the
estimates by about a third.
  "Best existing instrumentation and
statistical methods limit our ability to
reliably determine global average
stratospheric ozone trends to about a 2
percent change per decade. While no
measureable change to date has been
detected, we should not expect to detect
any changes. Current models of ozone
depletion due to CFCs, if correct,
estimate less than a 1 percent decrease in
global average stratospheric ozone should
have occurred to date. Moreover, if the
latest model calculations are correct, the
5-10 percent estimates imply that
stratospheric ozone may be decreasing at
the rate of less than 0.1 percent per year.
Scientific experts of the United Nations
Environment Program's Coordinating
Committee on the Ozone Layer
(UNEP/CCOL) at its annual meeting held
in October 1981 concurred with these
estimates.
  CFCs and other halocarbons, Clay
noted, are not the only chemicals with the
potential to impact on stratospheric
ozone. Nitrogen oxide emissions may
decrease or increase stratospheric ozone.
For example, nitrogen oxide emissions
from aircraft flying in the region of the
tropopause (the boundary between the
NOVEMBER/DECEMBER 1981
                                                                        23

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troposphere and the stratosphere —
about 5 miles at the poles and 11 miles at
the equator) may cause an increase in
ozone in that region, whereas
stratospheric ozone may be decreased by
aircraft flying at higher altitudes. Nitrous
oxide from decayed vegetation diffuses to
the stratosphere where it may also cause
a decrease in ozone.
  "Carbon dioxide is calculated to cause
a decrease in stratospheric temperature,
which in turn may partially amelioriate the
ozone depletion due to CFCs because
many key chemical reaction rates slow
with lower temperatures. The uncertainty
in this effect is large; theoretical estimates
by atmospheric scientists range from a
tenth to a half amelioration with the
doubling of atmospheric carbon dioxide
concentrations expected to occur by early
in the next century due to present levels
of fossil fuel combustion.

Estimated Effects of Ozone
Depletion
  "Ozone filters out most of the
biologically-damaging solar ultraviolet
(in particular, UV-B} radiation. The role of
UV-B radiation in causing non-melanoma
skin cancer (rarely fatal) is well known,
and the changes in non-melanoma skin
cancer and UV-B  exposure as a function
of stratospheric ozone depletion can be
estimated. In the  U.S., there are
approximately 300,000 cases a year of
non-melanoma skin cancer.
  "We don't know whether UV-B
radiation  is linked to melanoma, the
frequently fatal form of skin cancer.
Animal studies are not  possible because
the human being  is the only animal that
gets melanoma skin cancer."
  Only limited data exist on the effects of
increased UV-B radiation on terrestrial
and aquatic plants, fish, and other biota,
especially in their natural environment
where organisms may have the capability
to adapt to small changes, Clay said.
Studies on selected key crops in the field
and on aquatic organisms are underway.
  "Little  knowledge exists on the effect
of CFCs and other atmospheric aerosols
and gases such as carbon monoxide on
climate, although some scientists predict
a warming at the earth's surface.
Changes in ozone distribution with
altitude, even if not in total amount of
ozone, may produce temperature
changes and result in climate changes.
These effects cannot yet be quantified.
  "In sum, present scientific knowledge
is unable to predict accurately the effects
of increased UV-B radiation due to ozone
depletion."

CFC Production and Use
Total CFC production and use has
changed in the last decade, Clay testified.
"In the United States, CFC production
peaked at over 1 billion pounds in 1974,
then dropped sharply to level off at
approximately 835 million pounds in 1979
and 1980. The decline in production
between 1974 and 1979 is the result of a
large decrease in aerosol use of CFCs,
which declined from about 500 million
pounds in 1974 to about 25 million pounds
in 1979 and 1980. Non-aerosol use,
however, including use of CFCs in
refrigeration, air conditioning, foam
product manufacture, solvent
applications, and in a variety of other
uses, grew about 8 percent annually in
the U.S. from 1975to 1979, then fell
slightly in the 1979-80 economic slow-
down . Anticipated recovery of the
economy, combined with the expected
market growth in the use of CFCs for
insulation, solvents, food freezing, and
other applications could lead to an
eventual increase in domestic production
over the 1974 peak.
  "Available statistics indicate that world
production of CFC-11 and -12 also peaked
in 1974. As in the U.S., there was a
significant drop  in aerosol use in the years
following 1974, while CFC demand for
non-aerosol uses increased. World growth
(including the U.S.) in non-aerosol uses in
recent years has varied from 5 to 11
percent per year. Recent data show only
slight growth in  demand for non-aerosol
uses between 1979 and 1980.
  "In the U.S., the major applications of
CFCs include their use as a heat transfer
agent in refrigeration and air conditioning,
a blowing agent in the manufacture of
flexible and rigid foams, and a solvent to
clean and dry metals and electronic
components. Numerous miscellaneous
uses also exist, including sterilization,
food freezing, coal cleaning and personal
protection warning devices.
  "Five manufacturers of CFCs supply
approximately 5,000 direct purchasers of
CFCs and tens of thousands of firms that
purchase CFCs through distributors. At
times the distribution chain involves five
or six different firms, including a
repackager. These distributors and users
of CFCs include both large and small
firms. Many ultimate users of CFCs are
service establishments using small
amounts of CFCs to recharge air
conditioning and refrigeration systems.
Other small businesses that use CFCs
include building contractors, hospitals
and clinics, and  plants using CFCs as a
solvent.
  "Because of the variety of ways in
which CFCs are used, their importance to
the economy, and the complexity of the
markets involved,  EPA has performed and
continues to perform extensive economic
analyses as well as to solicit information
on the cost of alternative technologies
and the economic impact of CFC
regulations, including the impact on small
businesses."

International Activities
All major CFC-producing nations have
taken actions to reduce CFC emissions,
Clay noted. "Canada, Sweden, and
Norway have banned most aerosol
propellant uses of CFCs-11 and -12, as we
did in 1978, and  they are considering
further actions. Other countries have
reduced aerosol emissions without
regulatory action.  The Japanese
government and industry have agreed to
cap CFC-11 and -12 production capa
at current levels.
  "The ten member nations of the
European Economic Community (EEC)
are required to ensure that production
capacity for CFCs-11 and-12 does not
24
                                                              EPAJOURNAL

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increase and to reduce aerosol propellent
uses of these CFCs by at least 30 percent
of 1976 levels by December 31, 1981. The
EEC and several other nations, including
Canada and Japan, are considering
further emission controls and are working
with industry on the technology required
to do so.
   "The Organization for Economic
Cooperation and Development (OECD),
composed of twenty-four industrialized
countries, has been a forum for
exchanging information on science,
technology, economics, and regulatory
aspects of CFCs. The OECD is currently
nearing completion of a comprehensive
report on CFCs.
   "The Coordinating Committee on the
Ozone Layer (CCOL) of the United
Nations Environment Program (UNEP)
IPieets annually to prepare assessments of
scientific information on the ozone
depletion hypothesis, to facilitate the
exchange of information, and to make
suggestions for future research.
   "In April of 1980, the UNEP Governing
Council recommended that member
governments achieve significant
reductions in uses of CFCs-11 and  -12,
not increase production capacity, pursue
further research, and reexamine control
measures already taken  in light of
available data. In May 1981, the
Governing Council initiated work on a
global framework convention for the
protection of stratospheric ozone.  The
first meeting of the the convention's
technical and legal experts will be in
Stockholm, Sweden in January 1982.
   "EPA has been involved in international
cooperation on scientific research and
monitoring, such as the work of the
UNEP Coordinating Committee on the
Ozone Layer, the World Meteorological
Organization (WMO), various
international scientific organizations, and
Jatateral research projects with the
^•Fherlands and Federal Republic of
(fSrmany on effects of UV-B radiation. In
view of the global implications of the CFC
issue, it is important that we continue to
work with other countries to monitor the
science and develop appropriate
governmental responses, and that we
consider our domestic CFC efforts in the
context of the work of the international
community."

Recent and Current EPA
Activities
In October of 1980, EPA issued an
Advance Notice of Proposed Rulemaking
(ANPR) in response to concerns raised by
the findings of the 1979 assessment of the
CFC/ozone depletion issue by the
National Academy of Sciences (NAS)
and other reports. Clay stated. The
purpose of the rule-making notice was to
gather information about the validity of
the ozone depletion theory, the
appropriateness of restricting the  use of
CFCs, and possible alternative courses of
action for the Agency. The notice alerted
the public, Clay explained, that EPA was
concerned about  possible resultant effects
on human health and the environment
due to possible growth in the use  of CFCs,
and that EPA was considering whether it
should issue a proposed rule to limit non-
aerosol use of CFCs.
  "EPA received over 2,000 comments
on the Notice. It is clear that many
segments of industry consider additional
regulatory action — particularly the
regulatory strategies discussed in the
ANPR — to be premature and
controversial. The Agency believes that
the issues raised in these comments
deserve considerable attention and
further analysis which has been initiated.
  "EPA staff are  working closely  with the
experts inside and outside of government,
studying the unresolved scientific
questions and economic implications of
CFC emission reductions. Scientists at
NASA, NOAA, the Federal Aviation
Administration, and other agencies as
well as in academia and industry are
evaluating the potential effects of CFCs
and other compounds on the
stratosphere, employing laboratory
measurements, atmospheric
observations, and theoretical studies
(modeling). The Rand Corporation, under
contract to EPA,  is performing an
assessment of currently available
technologies for reducing CFC emissions
in nonaerosol applications. Under another
EPA contract. Rand Corporation has
examined the economic and policy
implications of restricting domestic CFC
production and is presently examining
innovation in the CFC-manufacturing and
CFC-using industries.
  "On May 1, 1981, EPA entered into a
contract with the National Academy of
Sciences (NAS) for an assessment of the
most recent scientific information
regarding stratospheric ozone changes
and the resultant effects.
  "One part of the study will focus on
new scientific information developed
since the last NAS reports on the subject
in 1979, including the information
reported at the NASA/WMO workshop
on the stratosphere in May, 1981 and
other pertinent reports relevant to
stratospheric processes. There is every
indication that the information from the
NASA/WMO workshop is among the
best available, and it will be fully
considered in the NAS evaluation.
  "Another part of the NAS assessment
will examine the environmental and health
effects due to changes in stratospheric
ozone concentrations. In this part, NAS
will examine and assess current
understanding of UV-B radiation effects
on terrestrial and aquatic plants, fish and
other aquatic organisms, ecosystems,
climate and human health. Their
assessment of human health effects will
include an examination of current clinical
and epidemiological data as well as data
obtained from animal studies.
  "The NAS study was originally
intended to be completed by December
1981; however, EPA is modifying the
contract to allow the NAS additional time
for a more thorough review of their
assessment. At present, EPA anticipates
receiving the NAS report by March
1982." D
NOVEMBER/DECEMBER 1981
                                                                        25

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Chemical
Waste
Cleanup
A     proposed consent decree has been
     filed with the U.S. District Court in
 Little Rock, Ark., conatining an agree-
 ment reached by EPA and the State of
 Arkansas with two chemical companies
 to correct waste disposal problems in
 Jacksonville, Ark.
   The agreement is designed to settle
 suits filed against Vertac Chemical Corp.
 and Hercules Inc. by the Justice
 Department on behalf of EPA in March
 1980.
   The suits were filed to correct chemical
 waste disposal practices at the
 Jacksonville plant site, which is owned by
 Vertac and was formerly owned by
 Hercules.
   Following a hearing held in April of last
 year, Vertac conducted an extensive
 program of remedial work on the plant
 site. The work was designed to contain
 the discharge of any contamination from
 the plant site, and to monitor ground
 water under the site.
   Provisions of a preliminary injunction
 have been fulfilled by Vertac, and
 company officials estimate that in excess
 of $1 million, not including work by
 company personnel, has been spent by
 the company in accomplishing these
 remedial actions to date.
   "The steps that Vertac has agreed to
 take under the terms of the proposed
 decree will, when taken with the remedial
 work which has already been performed
 by the company, constitute one of the
 most thorough remedial programs of its
 type," said Anne M. Gorsuch,
 Administrator of EPA. "Vertac is, by
 agreeing to undertake the responsibilities
 contained in the decree, acting as a
 responsible corporate citizen, and  is
 making a significant commitment to
 reducing any hazard to human health and
 the environment," Mrs. Gorsuch said.
   Under the terms of the proposed
 consent decree, Vertac will:
A fisherman (in the foreground) tries his luck in Lake Dupree. a body of
water in a Jacksonville, Ark., park, before the lake was closed because of
pollution problems EPA is now trying to help solve.
• retain independent consultants to study
conditions on and under the plant site
that may require further remedial work;

• propose and implement remedial
action, if any, necessary to prevent the
discharge of pollutants from the plant site
into the environment;

• develop a plan for orderly management
of the wastes stored on the plant site, by
treatment or off-site disposal;

• conduct a study of the fate and
movement in the environment of any
pollutants in Rocky Branch  Creek and
Bayou Meto;

• propose potential remedial measures
for the removal or stabilization of
pollutants in Lake  Dupree, located in the
Jacksonville City Park;

• establish a trust fund in the principal
sum of $60,000 especially restricted to
assure long-term maintenance of remedial
work performed on the plant site; and

• develop and implement standards for
pretreatment of waste water discharged
from the plant site to the  Jacksonville
sewage treatment plant.
  The proposed decree, when fully
carried out by Vertac, will satisfy
essentially all of the claims raised by
and the state against Vertac. In the
proposed decree, Hercules does not
admit any responsibility for conditions on
or off the plant site, but does agree to
negotiate with Vertac on sharing the
costs of studies and remedial action
which Vertac undertakes. The
government agencies do not release any
claim which they may have against
Hercules, and they may petition the U.S.
District Court at anytime for a
determination of Hercules' responsibility.
  The Vertac plant site was included in a
preliminary EPA list of nationwide waste
sites targeted for action under Superfund,
the federal program for cleaning up
hazardous waste sites.
  "This proposed consent decree will
help assure that it will be unnecessary at
this time to expend federal monies on this
site, thereby making available those
much-needed funds for expenditure on
other sites where there is no responsible
owner or operator to undertake remedial
work,"said Mrs. Gorsuch.
  The proposed decree, which has been
signed by all of the parties to the s
has been filed with the U.S. District
in Little Rock, and will be submitted to the
court for signature after an opportunity
for public comment.
 26
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   EPA  Collects
gOverdue  Bills
A       campaign of collecting its over-
       due bills which could amount to
   as much as $32 million has been
   started by EPA.
     "Until now, the Agency has made
   no concerted effort to collect  its over-
   due bills,"  EPA Administrator Anne
   M. Gorsuch stated. "We now intend
   to make that effort. We want  to make
   the best use of every available tax
   dollar."
     Mrs. Gorsuch said that the  total
   debts owed EPA are now known to
   exceed $1 6 million, but that this
   amount could double when audits
    ow under way are completed.
         of the delinquent accounts
         overpayments in contracts or
   grants awarded municipalities, scien-
   tists, consultants, and others. Money
   is also owed the agency for services
   rendered and employee payback
   obligations.
     A new system is being started to
   collect the bills which will use claims
   officers in Washington, D.C.,  and 10
   EPA regional offices to coordinate the
   campaign.
     While some debts will require only
   the issuance of an  invoice for pay-
   ments, others will need extensive
   collection efforts.
     The  Agency will be collecting
   money due from overpayments on
   grants, such as those that occur
   when  a grantee overstates the cost or
   the federal share of a project.
     In the case of contracts, the
   overpayments  might have been for
   charges for unnecessary parts on a
   project or charges exceeding the
   acceptable rate. In  either case, such
   discrepancies might not become
      arent until  an audit  is conducted.
      xamples of EPA services for which
      agency remains uncompensated
   could include fees for processing a
   discharge or emission permit  or Free-
   dom of Information requests.  Current
                                   or former employees might have
                                   incurred payback obligations on
                                   excessive advance payment for travel
                                   or for moving expenses which are
                                   determined to be unallowable. The
                                   overpayments also could involve
                                   leaving government service after
                                   costly training before fulfilling employ-
                                   ment obligations that were part of the
                                   training agreement.
                                     Mrs. Gorsuch said the agency has
                                   not used vigorous collection proce-
                                   dures in the past. She said the agency
                                   has available to it such procedures as
                                   the use of the Internal Revenue
                                   Service's missing debtors' locator ser-
                                   vice, and the credit reference depart-
                                   ments of commercial credit bureaus.
                                     Interest  can be charged on con-
                                   tracts, grants and employee debts
                                   beyond the negotiated due date at the
                                   rate paid by the federal government
on its obligations, which is currently
17 percent.
  Except for fraud, there is normally a
six-year statute of limitations applied
to debts. If fraud violations are
uncovered, they will be handled under
other legal procedures.
  EPA can agree to accept less than
the full amount of an unpaid debt if
the debt is less than $20,000. If it is
over  that amount, there is a different
procedure for reaching a compromise
involving the Department of Justice or
the General Accounting Office.
Actions by either of these agencies
can result in a legal suit to resolve
the dispute.
  The new system of debt collection
consolidates collection responsibilities
of three separate  agency operations.
  EPA is preparing a new claims
manual for the debt collection cam-
paign, setting forth standards and
procedures for collecting the agency's
outstanding debts.
*'
   NOVEMBER/DECEMBER 1981
                                                                                                      27

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HONORS   AND  APPOINTMENTS
Paul C.Cahill
   Several new appointments have
     been made at EPA recently and
five Agency officials have received
national honors.
Paul C. Cahill, former deputy attorney
general of California,  has been named
Director of the EPA Office of Federal
Activities by EPA Administrator Anne
M. Gorsuch.
  Cahill will be responsible for liaison
with other Federal agencies and will
participate in the Reagan Administra-
tion's sub-cabinet working groups
promoting regulatory  reform. In his
new position he is responsible for
review of all Federal activities to ensure
compliance with environmental laws.
  "Paul Cahill has had extensive legal
and policy-formulating experience in
California government," Mrs.  Gorsuch
said. "As a state attorney and deputy
attorney general he has worked with
diverse governmental  organizations
and has interpreted the application of
laws and regulations  for such organi-
zations. His expertise will  be a great
asset in directing the  Agency's
relations with other Federal govern-
ment operations."
  Cahill had been deputy attorney
general of California since May 1980,
working principally with the State
Lands Commission and the California
Coastal Commission.  From 1973 to
1979, he was attorney-advisor to
Commissioner William Symons Jr. of
the California Public Utilities Commis-
sion. In 1973, he assisted in then-
Governor Reagan's merger of three
state departments into a consolidated
Department of Health.
  He was in private law practice from
1 970 to 1 972. Cahill,  40, is a longtime
,'H
David G. Stephan
participant in the Commonwealth
Club of California. In 1980 and 1981
he served as Secretary of the Club's
Section on Energy and Environment.
  A graduate of Saint Mary's College
and the Boalt Hail School of Law at
the University of California, Cahill has
done postgraduate work  in adminis-
tration, political science and
economics at Michigan State Univer-
sity, the University of California at Los
Angeles an j the University of
Maryland. He has taught graduate
level administrative law at the Golden
Gate University in San Francisco.
  Other recent appointments at EPA
include the selection of William N.
Hedeman Jr., the former director of
EPA's Office of Federal Activities, as
director of the Office of Emergency
and Remedial Response—EPA's
Superfund program—and Gary M.
Dietrich, promoted from Deputy Direc-
tor of the Office of Solid Waste, to
Director.
  Michael B. Cook, former Director of
the Office of Emergency  and  Remedial
Response, was named Deputy Direc-
tor of the Office of Solid Waste.
  "One of our constant goals at EPA
is to improve the efficiency and effec-
tiveness of our varied operational
programs," said Administrator
Gorsuch. "These reassignments in
the Superfund and solid waste pro-
grams constitute a refinement of
existing management structures, and
will result in the more efficient use of
our top managers' talents and
experience."
  EPA officials who have received
national honors in their respective
fields include:

David E. Menotti, EPA Associate
General Counsel for Air, Noise and
Radation, who received a $20,000
Distinguished Presidential Rank
Award for his key role in developing
regulatory reforms. Winners of
$10,000 Meritorious Presidential
Rank Awards were Thomas R
Gallagher, Director, EPA National
Enforcement Investigations Center at
Denver; and Alvin R. Morris, Deputy
Regional Administrator, EPA Region
3, headquartered in Philadelphia.

David G. Stephan, Director of the
Industrial Environmental Research
Laboratory in Cincinnati, has been
named the recipient of the 1981
Environmental Award in Chemical
Engineering of the American Institute
of Chemical Engineers.  He received
the  award for research in air and
water pollution control,  particularly
his work in the areas of wastewater
treatment and water renovation.

Dr.  David McNelis of EPA's labora-
tory in Las Vegas, Nev., has been
chosen as the Federal Environment
Engineer of the year. He is Director of
the  Advanced Monitoring Systems
Division at EPA's Environmental
Monitoring Systems Laboratory.
McNelis was selected from 1 8 out-
standing environmental engineers
nominated by Federal agencies
nationwide for their exemplary work
and accomplishment.

Advisory
Groups
  Other recent appointments at EPA
include the selection of members to
two advisory groups. Named to the
National Drinking Water Advisory
Council were:

Fletcher G.  Driscoll.  Dr. Driscoll
received his undergraduate  degree
from Carleton College and his Ph.D.
in hydrogeology from the University of
Minnesota in 1976. He is a consultant
to the Johnson Division of UOP Inc.,
of St. Paul, Minn., and  an assistant
professor in the Department of Ena
neering and Applied Science at tlfB
University of Wisconsin. Dr. Drisr^T is
chief author and editor of a 550-page
textbook on groundwater geology,
well hydraulics and water well design
and construction that will be pub-
lished in early 1982.
                      EPAJOURNAL

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David Menotti receives award from Administrator Gorsuch
Joanne Howell. Mrs. Howetl is a
graduate of the University of Maryland
and served as mayor of Bernards
Township, N.J.  in 1978 and 1979.
She-is currently a member of the
local environmental commission and
the planning board. She also sits on
the solid waste advisory committee
for Somerset  County, N.J. Mrs.
«well's public service has brought
  r extensive experience in dealing
with groundwater problems at the
municipal government level.

Nina I. McClelland.  Dr. McClelland
has degrees from the University of
Toledo and received her Ph.D. degree
in environmental chemistry from the
University of Michigan in 1968. She
is currently president and chief
executive officer of the National Sani-
tation Foundation in Ann Arbor,
Michigan. As vice president of the
foundation from 1974-1980, she was
responsible for administering water,
wastewater, research and develop-
ment and testing laboratory programs.
Dr.  McClelland has edited and written
numerous publications and papers on
water quality issues.

E.J. Middlebrooks. Dr.  Middlebrooks
is currently dean of the College  of
Engineering at Utah State University
in Logan, Utah. He received his
bachelor of civil engineering and
   fster of science and engineering
    rees from Mississippi State Uni-
   sity in 1966. He has accepted the
Newman Chair of Natural Resources
Engineering in the Department of
Agricultural Engineering at Clemson
University, S.C. Dr. Middlebrooks is a
chlormation expert with a strong
background in statistical application  in
water and wastewater and the health
effects of contaminants.

Richard Moser.  A graduate in
chemistry from the University of Pitts-
burgh, Moser is vice president for
system water quality at the American
Water Works Service Company in
Haddon Heights, N.J. He is responsi-
ble for drinking water quality for
systems serving  over five million
people in 540 communities, across 20
states. This is the largest privately
owned water utility system in the
country.

  Named to the management  advisory
group to EPA's construction grants
program were:

J. Edward Brown. Mr. Brown
received his B.S. in chemistry from
Marquette  University in 1966, his
M.S. in chemistry from Pennsylvania
State University  in 1969, and  his law
degree from the  University of  Virginia
in 1972. He is director of the water
quality division of the Department of
Environmental Quality for the state of
Iowa. In this position, he provides
leadership for water quality improve-
ment throughout the state. Brown is
president-elect of the Association of
State and  Interstate Water Pollution
Control Administrators, which is com-
posed of representatives from organi-
zations that have administrative
responsibility for enhancement of
water quality, including wastewater
treatment  construction grant projects.
George Erganian. Mr. Erganian
graduated from Purdue University in
1943 and received his M.S. from the
same university in 1947. He has been
a partner in the engineering firm of
Howard, Needles, Tammen and
Bergendoff of Indianapolis, Ind., since
1973. His firm has designed many
wastewater treatment facifities.
Erganian is  a diplomat of the Ameri-
can Academy of Environmental Engi-
neers and is a member of both the
National Society of Professional Engi-
neers and the Water Pollution  Control
Federation.

Eric Erickson. Mr. Erickson received
a B.S. in construction management in
1968 and a  degree in architecture in
1974 from the University of Nebraska.
He is vice president of the engineering
and architectural firm of Johnson,
Erickson, O'Brien  and Associates Inc.
of Wahoo, Neb. His firm specializes in
consulting engineering work for
villages and small towns—areas
where  EPA is making special efforts
to assist in building wastewater treat-
ment facilities. Erickson  is a member
of the American Institute of Archi-
tects, American Consulting Engineers
Council, and the Construction Specifi-
cations Institute.

John Hornback. Mr. Hornback
received his B.S. in engineering from
the University of Michigan in 1956.
He is city engineer for the city  of
Grand Rapids, Mich. Hornback is
experienced in the construction of
efficient municipal wastewater treat-
ment facilities. Hornback is a member
of the American Consulting Engineers
Council, and the National Society of
Professional Engineers. He also has
experience in community planning.

F. Thomas Westcott. Mr. Westcott
received his B.S. in  engineering
degree from the Massachusetts Insti-
tute of Technology in 1946. He is
president of the Westcott Construction
Corp. of North Attleboro, Mass.
Westcott's firm  has  constructed many
wastewater  treatment facilities.
Westcott is on the national board of
directors of the Associated General
Contractors where he has developed
many improvements to the contracting
process, and has served  on many
committees concerned with the
environment. D
NOVEMBER/DECEMBER 1981
                                                                                                           29

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OFFICE OF  THE ADMINISTRATOR
Administrator
Anne M. Gorsuch
755-2700
Deputy Administrator Dr John W. Hernandez
                     755-2711
Chief of Staff
John E Daniel
755-2700
                                                                                 Office of
                                                                                 Inspector General
                                                                                 Matthew N. Novick
                                                                                 755-0425
                      leral
                                 Associate Administrator
                                 for Policy and Resource
                                 Management
                                 Joseph A. Cannon*
                                 755-2900
                                                Associate Administrator
                                                for Legal Counsel and
                                                Enforcement
                                                (Vacant)
                                            Office of
                                            Comptroller
                                            Morgan Kinghorn
                                            755-0675

                                            Office of
                                            Policy Analysis
                                            Jack Fitzgerald*
                                            382-2747

                                            Office of
                                            Legislation
                                            Leland Modesitt
                                            755-0566

                                            Office of Standards
                                            and Regulations
                                            Lewis Crampton'
                                            755-0433

                                            Office of Manage
                                            ment Systems and
                                            Evaluation
                                            Lewis Crampton
                                            755-0433
                                                           Office of
                                                           General Counsel
                                                           Robert M. Perry
                                                           755-2511

                                                           Office of
                                                           Enforcement Policy
                                                           William A. Sullivan Jr.
                                                           755-2511
                   Assistant Administrator
                   for Administration
                                  Assistant Administrator
                                  for Water
Assistant Administrator
for Solid Waste and
Emergency Response
                   Dr. John P. Morton
                   755-2500
                                   Bruce R. Barrett*
                                   755-2800
Christopher J. Capper
755-9170
                             Office of
                             Personnel and
                             Organization
                             Kenneth F. Dawsey
                             755-2562

                             Office of
                             Fiscal and Contracts
                             Management
                             (Vacant)

                             Office of
                             Management
                             Information and
                             Support Services
                             Edward J. Hanley
                             755-2911
                                            Office of
                                            Water Enforcement
                                            Martha Prothro*
                                            755-0440

                                            Office of
                                            Water Regulations
                                            and Standards
                                            Steven Schatzow
                                            755-0402

                                            Office of
                                            Water Program
                                            Operations
                                            Henry Longest
                                            426-8856

                                            Office of
                                            Drinking Water
                                            Victor Kimm
                                            426-8847
          Office of
          Waste Programs
          Enforcement
          Douglas MacMillan
          382-3054

          Office of
          Solid Waste
          Gary Dietrich
          755-9177

          Office of Emergency
          and Remedial
          Response
          William N. Hedeman Jr
          382-2180
                                                                                                         EPA JOURNAL

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       EPA  Headquarters   Leadership
         Office of Adminis-
         trative  Law Judges
         Edward B. Finch"
         755-5509
  Office of Small and
  Disadvantaged
  Business Utilization
  Robert Knox 755-0555
Office of
Civil  Rights
Robert Knox"
755-0555
         Science Advisory
         Board
         Terry Yosie
         755-0263
  Office of Inter-
  Governmental Liaison

  (Vacant)
Office of
Congressional Liaison
Jack Woolley
755-2930
         Office of
         Public Affairs
         Byron Nelson I
         755-0453
  Office of Inter
  national Activities
  Richard Funkhouser
  755-2780
Office of
Federal Activities
Paul C. Cahill
755-0777
Assistant Administrator
for Air, Noise and Radiation

Kathleen M. Bennett
755-2640
Assistant Administrator
for Pesticides Toxic
Substances
Dr. John A. Todhunter
755-0310
     Assistant Administrator
     for
     Research and Development
     (Vacant!
        Office of Air, Noise and
        Radiation Enforcement
        Richard D. Wilson
        755-2977

        Office of Air Quality
        Planning and Standards
        Walter Barber
        919-541-5615

        Office of Mobile Source
        Air Pollution Control
        Laszlo Bockh
        426-2464

        Office of  Noise
        Abatement and Control
        John Ropes
        577-7777

        Office of
        Radiatipn Programs
        Gordon Burley
        557-9710
         Office of Pesticides
         and Toxic Substances
         Enforcement
         Sanford Harvey
         755-2530

         Office of
         Pesticide Programs
         Edwin L. Johnson
         557-7090

         Office of
         Toxic Substances
         Don Clay
         755-8033

         Office of
         Toxics Integration
         Marilyn  Bracken
         382  3375
              Office of Monitoring
              Systems and
              Quality Assurance
              Or. Courtney Riordan
              426-2202

              Office of Environ-
              mental Engineering
              and Technology
              Dr. Herbert Wiser*
              382-2576

              Office of Environ-
              mental Processes and
              Effects Research
              Dr. Allan Hirsch
              426-0803
Office of
Health Research
Dr. Roger Cortesi*
426-2382

Office of Research
Program Management
Samuel Rondberg
755-2606

Office of Health and
Environmental
Assessment
Dr. Elizabeth Anderson
755-3968

Office of Exploratory
Research
Dr. James Reisa
755-7012
                                                                                                    "Acting
NOVEMBER/DECEMBER 1981
                                                                                    31

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                                                  Around The  Regions
 Region 10 (Seattle)
 Alaska, Idaho, Oregon,
 Washington
 206^442-1220
 Regional Administrator
 John R. Spencer
         Region 9 (San Francisco)
         Arizona, California, Nevada, Hawaii
         415-974-8153
         Regional Administrator
         Sonia F. Crow
                  Region 8 (Denver
                  Colorado, Utah, Wyoming, Montana
                  North Dakota, South Dakota
                  303-837-3895
                                                   Region 7 (KansasCity)
                                                   Iowa, Kansas, Missouri,
                                                   Nebraska,
                                                   816-374-5493
                  Regional Administrator
                  Steven J. Durham
                                                                                                     * Dallas


Region 6 (Dallas)
Arkansas, Louisiana,
Oklahoma, Texas, New
Mexico
214-767 2600
                                                   Regional Administrator
                                                   John J. Franke
Regional Administrator
Dick Whittington
32
         EPAJOURNAL

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                                                                         Region 1 (Boston)
                                                                         Connecticut-, Maine, Massachusetts,
                                                                         New Hampshire, Rhode Island, Vermont
                                                                         617-223-7210
                                                                         Regional Administrator
                                                                         Lester A. Sutton
                                                                                                 Region 2 (New York City)
                                                                                                 New Jersey, New York,
                                                                                                 Puerto Rico, Virgin Islands
                                                                                                 212-264-2525
                                                                                                 Regional Administrator (Acting)
                                                                                                 Richard T. Dewling
                                                                                Region3 (Philadelphia)
                                                                                Delaware, Maryland, Pennsylvania, Virginia,
                                                                                West Virginia, District of Columbia
                                                                                215-597-9814
Ilinois, Indiana, Ohio,
Michigan, Wisconsin,
Minnesota
312-353-2000
                                        Region 4 (Atlanta)
                                        Alabama, Georgia,
                                        Florida, Mississippi,
                                        North Carolina, South
                                        Carolina, Tennessee,
                                        Kentucky
                                        404-881-4727
Regional Administrator
Valdas Adamkus
                                        Regional Administrator
                                        Charles R. Jeter
                                                                                Regional Administrator
                                                                                Peter N. Bibko
Back Cover: Sun shines through
snow-dusted trees in winter woodland
setting near Laurel, Md.

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                                                                                                                               -'
United States
Environmental Protection
Agency
Washington D C 20460
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300
              Thud Class
              Bulk
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