United States
  Environmental  Protection
  Agency
Office of
Public Affairs (A-107)
Washington DC 20460
  A Look Ahead
   :-.:
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• . :

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                                          Snow blankets the rolling hills in High/and County, Va.. part of America's scenic legacy.
Goals  and
Accomplishments
  In this issue of the Journal, we take a look at
  future directions for EPA and the  Federal
environmental programs.
  A significant portion  of the future will be
shaped  by a new act signed by President
Reagan to turn the  massive  federal grant
program for  sewage treatment construction
"away from  public works for the sake of
public works" and rededicate it to environ-
mental goals.
  The fate of bipartisan legislation now be-
ing  considered by Congress on ways to im-
prove the Clean  Air Act could  also  have a
major impact on the country's environment.
  EPA  Administrator Anne M. Gorsuch
reviews the progress made by EPA since its
inception and emphasizes the  need for new
directions to meet the environmental goals of
the 1 980s.
   "We are nearing the end of a period in the
United States in  which legislative responses
to environmental problems proliferated
rapidly," Administrator Gorsuch comments in
her article.  "The  laws are now in place, and
the administrative structure now must catch
up both scientifically and organically to
assure that these programs are carried out
with care and frugality."
   This issue of the Journal also carries an in-
terview with Dr.  John P.  Morton, Assistant
Administrator for Administration. He explains
how his office is working to make the opera-
tions of the agency  more effective.
   Another  article reviews accomplishments
by EPA during the past year and reports
gains  in both environmental protection and
cost savings
  The burning of huge amounts of PCB
wastes in  an  incinerator ship in the Gulf of
Mexico  is  the subject  of  another article.
  Also in  this issue is information  on  major
new appointments and the reorganization of
the Agency's  enforcement program, in-
cluding the establishment of a new Criminal
Enforcement Unit
  Actions by EPA  to protect the drinking
water for Atlantic City, N.J., and to ease
procedures for individuals importing foreign
cars are also  reported. D

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                               United States
                               Environmental Protection
                               Agency
                              Office of
                              Public Affairs (A-107)
                              Washington DC 20460
                              Volume 8
                              Number 1
                              Jan.-Feb. 1982
                               SEPA 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 environ-
 mental laws, the Agency strives to for-
 mulate 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
 (to not necessarily reflect EPA policy
 Contributions and inquiries should be ad-
 dressed to the Editor (A-107). Waterside
 Mall. 401 M St . S W . Washington, D C
 20460 No permission necessary to
 reproduce contents except copyrighted
 photos and other materials
t
New Clean Air Bill Wins
Administration Support
Administrator  Gorsuch backs
bipartisan legislation

The 1980's—A Decade of
Challenge
EPA Administrator discusses
goals for the future

Reagan Commitment to
Environment Fulfilled in
EPA's '81  Success   10
A review of management and
operation  improvements

Achieving Better
Management   12
An  interview with Assistant
Administrator  Horton
Grants Program Refocused
on  Environment       16
President  signs legislation
authorizing grants for
treatment plants

EPA Acts to Protect
Atlantic City Water  HI
Agency allocates $500.000
to help stem contamination
threat

EPA  Paves Way for
PCB Burning   20
Agency monitors incineration
on  the ship Vulcanus

New Criminal Enforcement
Unit Established at EPA  21
Agency Enforcement Office
reorganized and strengthened
                  Key Appointments
                  Move  Forward   26
                  Two  new Assistant
                  Administrators, Science
                  Advisory Board chairman
                  Private Cleanup
                  Sought    2!)
                  Private parties  warned  must
                  act

                  Waste-to-Steam Plant
                  Slated for New York  :»)
                  Modern  refuse  burning
                  facility to be built in Brooklyn

                  Paperwork Cut for Car
                  Imports  .!2
                  Paperwork to be reduced for
                  foreign cars
                               Front Cover: A new day begins as the
                               sun rises behind the Washington Monu-
                               ment and the U S Capitol
                              Photo Credits Steve Delaney. Photn.
                              Rollins Environmental Services, Inc..
                              Frank Aleksandrowicz. Charles O'Rear,
                              PPG Industries, Gene Daniels. Rolls-
                              Royce
                              Design Credits Robert Flanagan and
                              Ron Farrah
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New
Clean   Air   Bill
Wins
Administration
Support
   The Administration is "very pleased" with
   new bipartisan legislation  designed to
improve the Clean Air Act, Anne M. Gorsuch,
EPA  Administrator,  recently told a national
industry-labor group meeting in Washington.
  The  legislation. H. R. 5252, was in-
troduced by Congressman Thomas A. Luken
(D.-Ohio), Bob Traxler (D.-Mich.) and Elwood
Hillis (R.-lnd.).
  In his state of the union message.  Presi-
dent Reagan declared:
  "We look forward to the enactment of a
responsible Clean Air  Act  to increase jobs
while continuing to improve the quality of our
air. We are encouraged by the bipartisan in-
itiative of  the House and are  hopeful of
further progress as the Senate continues its
deliberation."
   Mrs. Gorsuch indicated support for the
new measure at  a meeting of the National
Environmental  Development Association.
  The EPA Administrator  has said that "the
introduction of H. R.  5252 represents ex-
cellent progress, and we hope House markup
will begin  as soon as possible.  This
proposed legislation appears to comport
generally with the Administration's principles
announced in August and to address most of
the major concerns voiced  to the Administra-
tion  by the governors, labor unions, industry
and other  groups. We look forward to work-
ing with members of the Committee after we
have had a chance to study the bill in detail."
   Congressman Luken described the  bill as
"bipartisan legislation to focus attention  on
certain practical and necessary legislative
reforms . .  ." which should be  acted on early
this  year.
   The Ohio Congressman predicted that the
bill  would  "help us  move toward forceful ef-
fective air pollution control by the federal
government, the states, industry, interested
citizens and affected  employees.
   "With appropriate  refinements  and
modification of the Clean Air Act by  H.  R.
5252, the nation will continue its progress in
the control of  air pollution. These revisions
will  help remove the  uncertainty and com-
plexity of the law. At the same time, they will
serve to strengthen the national  economy,
protect jobs and provide further employment
opportunities."
   Luken said that "we anticipate substantial
labor and  industry support for this bill. We
hope that this bill will  alleviate the serious
concerns of our friends in environmental
organizations who have expressed fears that
changes Congress may make to the law
would be too  extensive."
  John Brown, Legislative Director of the In-
ternational Union of Operating Engineers,
warned that "many problems of economic
slippage and unemployment can be traced
directly to the Clean Air Act."
  Brown declared that Congressional action
is needed to remove "some of the confusion
and complexities from  the Clean Air Act
without  compromising  the clean air goals.
We need to get moving on settling the
legislative questions which will assure  air-
pollution control, jobs and a stronger
economy. The Luken bill  is, I believe, the
proper approach, and our union is  100 per-
cent behind it."
  John  Queries, former EPA  Deputy Ad-
ministrator who  is now serving as chairman
of the National Environmental Development
Association's Clean Air Project, stated:
  "The Luken bill appears to be the right ap-
proach  at the right time with regard to the
Clean Air Act. It is aimed at those provisions
in the law which represent obstacles to
needed energy production and industrial
growth but produce little or no improvement
in air quality  Our organization favors this
practical, thoughtful approach."
  The National  Environmental Development
Association is a coalition of more than 35 in-
dustrial companies and 1 7 building and con-
struction trade unions
  The National  Environmental Development
Association  described the Luken bill as "a
moderate approach" designed to "streamline
many of the procedural requirements and to
provide extremely limited relief from certain
substantive  requirements where the actual
air quality benefits are remote.
  While "providing important relief from the
unnecessary and largely unproductive
regulatory burdens," the association said the
measure would "simplify and expedite the
approval of permits to allow industrial
expansion and the creation of  new  jobs.
  "In short, while continuing the progress of
the national air  pollution control effort, the
Luken bill would also make a welcome con-
                                                                                                          EPA JOURNAL

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tnbution to the vitality of our nation's
economy."
   The statement noted that "the
national  effort launched under  the  1970
Clean Air Act has had a major impact on both
industrial operations and air quality. It has
caused a redesign  of industrial  facilities and
an installation of pollution-control equipment
at industrial plants across the country to cut
emissions of air contaminants.  It has forced
new construction to incorporate  top-of-the-
line pollution control equipment.  It has
brought about a reduction in pollutants from
automobiles of up to 96 percent as compared
to uncontrolled vehicles  It  has generated a
variety of other efforts by industry, motorists,
and other segments of the  general  public to
reduce air pollution.
   "The aggregate effect of all  these  efforts
has been profound.  The  national trends
toward  ever-increasing air  pollution have
been  reversed.  In  most areas and for most
pollutants, it is clear that the air is getting
cleaner.  Generally  throughout the country
current air quality levels are  normally far bet-
ter than the air quality standards require, and
in other  areas the  frequency and seventy of
any violations of the air quality standards are
being steadily reduced.
   "As current efforts continue,  as clean new
cars replace  older  vehicles,  and as obsolete
plants which cause  heavy  emissions  are
replaced by clean modern industrial facilities,
the current  improvements  in air  quality will
grow. The national goal  is that air quality
standards which assure protection  of public
health with a margin of safety be achieved in
every area of the country all of the time. With
the limited exception of a  few areas where
extremely severe problems exist the country
is  rapidly closing  in on  that goal.
   "The Clean Air  Act program  has been
costly. Current  estimates indicate that
national expenditures  for air poliution control
alone approximate S20-22 billion per year.
Those levels of expenditure are  expected to
grow to approximately S35  billion per year by
the end of the  1980s, at which time the
country will have spent a cumulative total of
roughly S350-400 billion in the national air
quality effort. An  additional hidden  cost
caused by this ambitious regulatory  program
results from the complexity of its require-
ments which in many cases confuses and
delays any company planning new capital in-
vestment. The Act exerts a drag on economic
growth and the creation of additional jobs  "
   However, the Natural Resources Defense
Council  and the National Audubon  Society
defended the present  Clean Air Act  and con-
tended that H.  R.  5252  represents a con-
tinuation of earlier extreme industrial
proposals.
   Their statement charged, in part, that the
measure would:
   "Extend the  deadline for achieving
healthful air quality to as late as 1993,
eliminate most  of the Act's  specific State im-
plementation plan requirements that assure
progress towards healthful air quality and
eliminate virtually all of the sanctions presen-
tly available for failure to submit or carry out
a state plan."
   Major provisions in the  measure  H. R
5252, according to the  National Environ-
mental Development Association, include:

Standards—The bill  would make no change
in the National Ambient Air Quality Stan-
dards which  would continue to provide the
                                                                                       EPA scientists use a helicopter and air
                                                                                       samplers to check on pollution conditions.
foundation for the overall program. Both the
existing air quality standards and the
procedures for setting  further standards
would  remain unaltered.

Implementation Plans—The bill would make
no significant change in the substantive re-
quirements which must be  satisfied by the
state implementation plans, but it would
eliminate the necessity for federal approval of
routine, inconsequential changes  to these
plans and would set a  six-month deadline  to
complete federal action on all other state im-
plementation plan provisions,

New Source Review—The bill would provide
major regulatory reform in the processing  of
permits for industrial construction projects,
retaining federal requirements that  all pro-
jects include  Best Available Control
Technology to  limit air emissions but
significantly reducing other  technical com-
plexities which now slow down the  approval
of permits and encumber beneficial economic
growth.

Auto Requirements—The bill would ease re-
quirements to  control  emissions from new
cars of carbon monoxide and oxides of
nitrogen, but retain requirements sufficiently
stringent to assure that total  emissions of
those two  pollutants will continue  to be
reduced. Practically  all  areas of the country
are already in  full compliance with the air
quality standards for these  two pollutants
The bill would make no change,  however,
with standards applicable to the primary auto
pollutants associated with ozone, or "smog,"
the principal  air pollution problem related  to
autos.
   "The aggregate effect of all changes
proposed by  the Luken bill would be to per-
mit an extremely limited increase in  air emis-
sions . . .,"  the organization commented.
However, the organization adds that it is
possible that these emissions might be offset
by improved  effectiveness in the  administra-
tion of air pollution control programs and
stimulation of industrial capital investment
to replace  obsolete polluting facilities. D
JANUARY/FEBRUARY 1982

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The   1980's—
A   Decade   of   Challenge
By EPA Administrator Anne M. Gorsuch
    Ten years ago, the year of the United Na-
    tions Conference on the Human Environ-
ment, only  1 1  developing countries had en-
vironmental ministries or similar high-level
agencies concerned  with this subject. Today
more than one hundred such countries have
them. The People's Republic of China recent-
ly established  an Office of  Environmental
Protection. In Brazil, the Ministry for the En-
vironment, established a decade ago with a
staff of three people, now  has 200.
   And so it goes. Around the world, environ-
mental protection has become an in-
stitutionalized part of government,  accepted
and supported much like agencies dealing
with health, industry, and public works.
   Since its inception December 2, 1970, the
U.S. Environmental  Protection Agency has
been at the center of the global environmen-
tal movement. It has provided leadership to
many countries in its initiatives and research
in environmental problems. Environmental
legislation adopted by the  U.S. Congress in
the past decade  has been far-reaching in its
scope. The laws  include the Clean Air Act,
Federal Water Pollution Control  Act; Federal
Insecticide, Fungicide and  Rodenticide Act;
Resource Conservation and Recovery Act;
Marine  Protection,  Research and Sanctuaries
Act; Toxic Substances Control Act; Safe
Drinking Water Act,  and most recently, the
Environmental  Response. Compensation, and
Comprehensive Liability Act, popularly known
as "Superfund."
   As a result of its efforts, the United States
can point to a  remarkable series of achieve-
ments  in environmental cleanup. An exam-
ple is the  record in  air pollution. Between
1940 and 1970 emissions of air pollutants
increased by 40 percent. In that period, little
was known about the effects of air pollution,
or even how to define clean air. Regulatory
schemes, where they existed, were largely in-
consistent from state to state.
  Today the situation is markedly improved.
Spurred by new legislation and technological
advances by industry, the United States
overall has experienced a  50 percent reduc-
tion in the past decade in soot and dust emis-
sions, known  as particulates, and a  20  per-
cent improvement in particulate air  quality
levels. Most industrial sources have installed
control technology that captures more  than
90 percent  of their particulate emissions,
and many capture over 99 percent.
  In addition, ambient concentrations in ur-
ban areas of  carbon monoxide and  sulfur
dioxide, two important pollutants, have
decreased about 40 percent.  The number of
days rated unhealthful in  major metropolitan
areas has fallen 1 8 percent. Levels of ozone,
commonly known as smog, have held steady
despite a 30 percent increase in vehicle miles
travelled from 1970 to 1978.
  In commenting on  this progress,  the
National Commission  on  Air  Quality, an in-
dependent body established by the U.S.  Con-
gress to oversee air pollution  control
measures, declared in  1981:
  "More significant than  the  level of ab-
solute reductions ... is the difference bet-
ween current  pollution levels  and those that
would have occurred if major control efforts
had not been required during the 1970s.
While it is impossible to state precisely what
pollution levels would be  if the Clean Air Act
had not been passed, it is clear that for a
number of pollutants  the  level of emissions
would now be several  times as great in many
areas "
  The financial effort to  clean up the Na-
tion's waterways has been prodigious—$30
billion in the  past decade in  Federal funds.
Unfortunately, somewhere along the line the
program lost its focus. What started out as an
effort to cleanse waterways was broadened
into  the largest non-defense  public  works
program in the U.S. The Federal government
became responsible for 75% of the  cost of
sewer pipes being laid. Delays were endemic
and costly.  Of more than  19,000 sewage
treatment projects only about 2,700 actually
have been completed.
   Fortunately this program is now back un-
der control and on track. Reforms signed by
President Reagan Dec. 29 not only  reduce
the Federal long-term commitment from $90
billion to S36 billion but will reduce the
Federal share of projects from 75% to 55%.
The legislation also gives more discretion and
control to States and cities on growth needs.
   As our knowledge of pollutants and the
ramifications of their effects on the environ-
ment has increased, our efforts have
broadened.  One area is  the control of hazar-
dous wastes. Spurred by legislation and
public concern, more than 57,000 generators
of hazardous wastes are now properly iden-
tifying these substances, ensuring that they
are sent to  legitimate facilities for  managing
them. More than 1 4,000 transporters of such
wastes are complying with a manifest system
to ensure that shipments are sent to and
received by legitimate hazardous waste
facilities rather than being  indiscriminately
dumped. Over 14,000 hazardous  waste
storage, treatment and disposal facilities are
now registered with EPA, have applied for
appropriate permits, and are obliged to com-
ply with interim standards  until permits are
processed.
   Congress also has enacted the "Super-
fund" Act to deal with  threats  to public
health and  the environment from  uncon-
trolled hazardous wastes.  Under this the
government can respond quickly in emergen-
cies, financed by an unprecedented $1.6
billion five-year trust fund primarily  built up
from taxes  on industrial chemicals.
   However, the cost of environmental
protection  increasingly  had  begun to con-
cern lawmakers, government  administrators.
industry, and the public as the  1970s wore
on. While few doubted  the need for some
pollution controls, many began questioning
the "blank check" approach. Having achieved
major reductions in environmental con-
tamination,  was it wise or prudent to pour
additional billions of dollars in cleaning up a
final few percentage points of pollutants?
While the public was willing to pay a price for
a clean, healthy environment, would this
willingness  be jeopardized if the public
believed that the costs were larger than they
needed to be. and that the benefits were not
worth those costs?
JANUARY/FEBRUARY 1982

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  The President's Council on Environmental
Quality has estimated in its 1981 annual
report, for example, that by 1989 total
government and industry expenditures re-
quired by Federal environmental  measures
would reach approximately $68 billion an-
nually. Air and water pollution control would
be taking the greatest share of this, but other
programs also would make their mark.
   In  fact, CEQ estimated that in the ten
years stretching  from  1980 to 1989,
spending in response to Federal environmen-
tal quality regulations would total more than
$523 billion.  That  exceeds half a trillion
dollars, or about half the Gross National
Product  for the United States today. And if
one adds spending to  meet requirements by
State and local environmental statutes, CEQ
noted, the estimated total would nearly reach
$758 billion during that decade.
   There were other concerns  about the way
the Nation was managing its programs in en-
vironmental protection. Although Congress
had  clearly intended a Federal-State
partnership in carrying out the numerous en-
vironmental laws enacted in the  1970s,  the
flow of power with its layers of managers and
program analysts and regulation specialists
gravitated to Washington. Too often rules
were promulgated  and imposed without due
consideration  for local conditions. The result
was that friction between local and Federal
authorities left a legacy of ill-will and distrust.
   The proliferation of  Federal regulations
from Washington brought other problems.
Cumbersome  procedures grew like vines in
the bureaucracy. An army of specialists came
into being to  administer the labyrinth of
procedures. Costly, burdensome delays
resulted from the  multiple steps that each
change in local clean air plans encountered.
The delays created more friction as some in-
dustries and  State governments perceived
Washington as  remote and insensitive to
local conditions and needs.
   Along with redundant and burdensome
regulations came other costly problems. The
magnitude of the  multi-billion dollar con-
struction grants program, where the Federal
government picked up 75 percent of the cosf
of building wastewater treatment plants, en-
couraged communities to order facilities that
they ordinarily could not have  afforded. A
number of localities spent beyond their
means, and saddled homeowners with heavy
operating and maintenance costs of
elaborate sewage treatment systems, since
the program enticed planners into ordering
exotic hardware  where simpler systems
would have been adequate. Politically, the
program was attractive, since  it funnelled
vast quantities of money and jobs into local
districts.
  These, then, were some of the problems
that had resulted from the unprecedented ef-
fort by the United States in the 1970s to at-
tack pollution on a broad front. The excessive
regulations, burdensome paperwork  for in-
dustry and government. Federal-State fric-
tion, and huge costs at a time  of increasing
economic stringency—all were clear signs
that change  was needed in the 1980s.
The Reagan Administration goals

President Ronald Reagan has campaigned on
a number of broad themes directed at refor-
ming the way the Federal government was
being operated. These included controlling
inflation, expanding  the economy, creating
new jobs,  increasing domestic energy
production, protecting the nation's natural
resources  and the environment, and easing
the burden of government regulations.
   Part of  our responsibilities at EPA is to
keep the Agency in step with this philosophy
of the  Reagan Administration. That means
carrying out our environmental respon-
sibilities while simultaneously enhancing
progress toward these other objectives. Deci-
sions by EPA do not function in a vacuum;
they affect not only the environment but
because of their size and scope they may also
affect inflation, industry, economic and
energy development, jobs, and certainly the
regulatory load. So it is important that we  at
EPA achieve a  balance in our policies and
decisions to protect public health and welfare
but at the  same time move in harmony with
other Administration initiatives.
   If we had to summarize our philosophy as
we move into the 1980s, I would say we are
going to do more with less. This does not
mean EPA is going to disappear. What it
does mean is that this Administration will do
a better job than its predecessors with fewer
resources and find  more  efficient ways of
operating, just as other government agencies
are in these times of budget stringencies. The
changes will  include  these:

• Where EPA has  had an adversarial
relationship with the States, it has impeded
progress in environmental cleanup. We are
changing this climate and will be working in
closer cooperation,  a  move that will enhance
our national opportunity to  reach environ-
mental objectives.

• We are moving forward with regulatory
reform.  In the past, our programs too often
have been developed in isolation from one
another. This can lead to serious errors in en-
vironmental management, where a narrow
concern solely with one area such as  land
can lead to degradation of  water. We have
regulations now on  the books, and it will be a
genuine challenge  to rationalize them  in a
total environmental concept.

• EPA needs better management. Our
studies have  shown that there is approx-
imately  one manager for every three em-
ployees performing EPA work. In Research
and Development,  the ratio  is about one
supervisor for every two people. We  need to
change this top-heavy pattern. We also have
found that EPA has more on-line computer
capability than any civilian  agency in the
Federal government. We can and will  remedy
this situation.
  When we  mention the need for doing
more  with  less, one thing that springs to
mind  is the need for fewer and simpler
regulations. One does not have to look far at
EPA to find areas where this aspect of pollu-
tion control can  be  improved. Under the pre-
sent Clean Air Act  in the United States, the
agency must approve virtually all details of
                                                                                                               EPA JOURNAL

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                                                                                       Saucer dome of a storage tank and missfe-
                                                                                       like distillation columns give a "space center"
                                                                                       appearance in this night photo of a modern
                                                                                       chemical plant built by PPG Industries at
                                                                                            .".harles. La., to manufacture  vinyl
                                                                                       chloride monomer.
                                                                                       State and local air pollution control plans.
                                                                                       Any subsequent changes in individual emis-
                                                                                       sion limits must be reviewed and approved
                                                                                       by EPA before they can take effect. This
                                                                                       process requires States to submit each  year
                                                                                       thousands of individual actions. All in all,
                                                                                       from start to finish. Federal approval requires
                                                                                       24 separate steps, requiring more than  10
                                                                                       months.
                                                                                         We have  taken  a number of steps to
                                                                                       streamline this and other procedures.
                                                                                       Without encumbering the reader with details.
                                                                                       I will simply say that we are eliminating red
                                                                                       tape and  delays in many noncontroversial,
                                                                                       routine matters. And the same  applies  to
                                                                                       programs in wastewater clean-up, hazardous
                                                                                       waste management, and other areas, where
                                                                                       we are re-writing,  simplifying or abolishing
                                                                                       unnecessary regulations.  This promises to
                                                                                       save both time and taxpayers' money.
                                                                                         EPA also is encouraging the "bubble"  con-
                                                                                       cept, where a plant's total emissions are con-
                                                                                       sidered as if the plant were under a  giant
                                                                                       dome or bubble, rather than seeking controls
                                                                                       strictly  on an emission  point basis. The  ad-
                                                                                       vantage of this to  a company is that it  can
                                                                                       reduce  its overall  cost of controlling emis-
                                                                                       sions at whichever emission point it desires,
                                                                                       so long as the  net effect of a trade does  not
                                                                                       exacerbate air quality, and thus often can use
                                                                                       a  more cost-effective approach.
                                                                                         We look with favor on a greater applica-
                                                                                       tion of  the bubble  policy, which takes EPA
                                                                                       out  of the area of  controlling techniques in
                                                                                       attaining  clean air. It's  important  to look at
                                                                                       results. The bubble policy lets industry, not
                                                                                       government, make the  decision  on how to
                                                                                       reach the goal, an  approach that can be far
                                                                                       cheaper and can use better control techni-
                                                                                       ques.
                                                                                         Too often in the past EPA has pursued a
                                                                                       confrontational course with industry.  This
                                                                                       Administration believes that rather than
                                                                                       devote endless time and  effort to litigation,
                                                                                       government and industry often can reach
                                                                                       reasonable accords over environmental
                                                                                       clean-up through negotiations. We anticipate
                                                                                       that more emphasis on this philosophy will
                                                                                       prevail  in the 1980s.
JANUARY/FEBRUARY 1982

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   Another of  President Reagan's priorities
has been to shift control of public programs
to State governments whenever possible.
Not only will this help to reduce the need for
funds and personnel at the Federal level, but
will delegate responsibility and control to ad-
ministrators who are closer to the problems
and needs of the public.  Many environmental
decisions require weighing of factors that are
more effectively and democratically decided
at a local level
   State and local  governments have un-
dergone a remarkable maturing in their ability
to manage a wide range of problems.  The
fastest expansion in government work forces
has been  under way for some time not in
Washington, DC. but  at the State and  local
level.  Since 1960, the number of employees
in the  latter categories has more than
doubled, from  six to thirteen  million. They
now outnumber their Federal counterparts by
more than four to one.  In air pollution control.
the shift has been even more dramatic; in the
past decade the number of State and  local
personnel in this specialty has risen  so fast
that there are now nine  for every one at the
Federal level. It makes sense that the nation
should take advantage of this situation  by
giving  more responsibility to areas where
staffing has been so heavily increased. Con-
gress always intended that the States play a
major  role  in environmental enhancement,
and we are now moving  to give them more
control in this respect.
   Part of our efforts to improve performance
at EPA include a reorganization of our Office
of Research and  Development. While  the ad-
ministrative details  of this would not be of
major interest in an article of this nature, its
significance here is simply that it will mean a
more efficient use of our  science dollars  and
an upgrading of the quality of work through a
peer review system.
   We  will  need good science in the  years
ahead. There are many areas about which
scientific uncertainties exist, including
problems of an international nature. The Un-
ited States  is one of several nations studying
the question of acid precipitation, for exam-
ple  tn 1980 Congress passed  the Acid
Precipitation Act establishing an interagency
task force and authorizing a ten-year com-
prehensive research plan for this subject
EPA is the lead agency for three research
areas, which  are aquatic effects,  control
technology, and data  assessments and
analysis.  EPA has committed more than $9
million in the current fiscal year for research
on this topic, and other Federal efforts will br-
ing the total  to more than  $18  million.
   Another area we will  continue to study is
the effect of  chlorofluorocarbons (CFCs). In
the mid-1970s, scientists hypothesized  that
continued world CFC emissions might lead to
depletion  of stratospheric ozone. Since  this
layer of ozone helps to limit the amount of ul-
traviolet radiation reaching the earth from the
sun. there was  concern  that damage to the
layer might cause  adverse  health and en-
vironmental effects.
   After receiving an assessment from  the
National  Academy of Sciences and  holding
public hearings, EPA and the Food and Drug
Administration  prohibited nonessential
aerosol uses of  CFSs in the  United States, In
1981 EPA funded  a new assessment by the
National  Academy of Sciences of the most
recent scientific information on stratospheric
ozone changes. The final NAS report is ex-
                                                                                                                 EPA JOURNAL

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pected to be completed soon. EPA
also  has participated with industry, environ-
mental organizations, and other agencies  in
an assessment of the question by the
Organization  for Economic Cooperation and
Development, The OECD work will contribute
to future international deliberations and will
help  give direction to further study. EPA also
has been participating in  UNEP's Coor-
dinating Committee on the Ozone Layer and
will continue its current international
program focused on sharing information, im-
proving cooperation, and  pursuing inter-
national understanding.  EPA. the State
Department,  and other interested agencies
are also participating in the drafting of an in-
ternational framework convention on protec-
tion  of the  ozone layer. The  first Ad Hoc
meeting was held in Stockholm in  January,
1982
   As our knowledge and understanding of
environmental problems increases.  EPA will
be able in the 1 980s to focus more clearly on
these and other questions dealing with trans-
boundary pollutants  One  can rarely predict
where research will  lead, but we can be sure
of one assumption: Action must be preceded
by study Our first task is to clarify  and
resolve the many uncertainties that still sur-
round  various global environmental ques-
tions
   The solution of these global problems ob-
viously must be a  cooperative venture. The
United States cannot shoulder the task alone.
We are therefore especially encouraged by
the creation of environmental ministries and
agencies in  so many  developing countries,
which I mentioned at the outset of this arti-
cle. Many of the world's  environmental
problems depend on Third World cooperation
if we afe to surmount them. And if we ail face
economic stringencies in the decade ahead,

Gulls flock to hunt (or insects and other food

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Reagan  Commitment  to
Environment  Fulfilled
in  EPA's  '81  Success
   President Reagan came  into office a little
   over a year ago firmly  committed to the
husbanding of this nation's natural resources
and to the improvement and enhancement of
the environment.
   EPA Administrator Anne M. Gorsuch
recently noted that the President "has not
wavered in that commitment.
   "As his administrator of the Environmental
Protection Agency. I share the President's
commitment  to the preservation  of our en-
vironmental  heritage. And I have not
wavered in my determination to make EPA a
more efficient, more effective force  in carry-
ing out our environmental programs."
   While it is  true that EPA has not been ex-
empt from the President's program to cut
federal  spending and federal employment, a
smaller budget and fewer  employees do not
necessarily mean less environmental protec-
tion. Mrs. Gorsuch said.
   And,  Mrs. Gorsuch pointed out,
easing the burden of government regulation
is  not synonymous with abandonment of
progress  toward cleaner air, cleaner water.
the safer handling of toxic substances and
other important environmental goals.
   The challenge at EPA is to do an  effective
job of environmental protection through the
more efficient use of limited  resources.
Some of the areas of  progress by EPA and
the Administration during  the past  year
include:

Superfund
The Superfund program, which Congress
enacted at the end of 1980 to provide
authority and money to clean up abandoned
hazardous waste dumps, has been quickly
implemented. For example:

• 115 dump sites across the nation have
been identified as high  priority targets for
cleanup under Superfund.

• S30 million has been approved for cleanup
work at 30  sites.
• $18 million has been allocated for
emergency work at 64  other sites.

  The Superfund program continues to be
one of the Administration's highest environ-
mental priorities. Because the program is
new, a high  degree of Federal involvement is
necessary but states will assume more and
more of the administrative responsibility as
time goes on.

Hazardous Waste Disposal
A vigorous enforcement program is un-
derway to assure safe disposal of hazardous
wastes on an ongoing basis, and this effort
will  be expanded  in the current fiscal year.
EPA and the states have  inspected more than
5.800 hazardous waste facilities. Compliance
orders, with penalties where appropriate,
were issued at  178 facilities. Two actions
were filed in Federal  court.
  EPA is also pressing  constantly for in-
dustry action to clean up  abandoned sites
themselves to avoid expensive court
action later seeking reimbursement for
government cleanup programs. Major
breakthrough agreements were reached in
recent months with firms in California,
Pennsylvania, Arkansas and Ohio.
   Hazardous waste regulations, applicable
to some 60,000 generators, transporters,
and facility owners and operators, also are a
prime target for  regulatory reform. The
regulations have  been likened to the Internal
Revenue Code in complexity. About 20
technical amendments were issued  in 1981
to solve some of  the major bugs. Another 20
to 40 amendments will be put forward  in
1982

Clean Water
Congress has enacted into law major reforms
sought by the Administration in the construc-
tion grants program for wastewater treat-
ment facilities. The reforms will permit con-
tinued funding of projects that contribute to
cleaner water,  but get the  federal govern-
ment out of the business of financing sewer
construction for future population growth.
When the program started in 1970, it was
estimated that federal assistance to  upgrade
wastewater treatment systems would cost
$1 8 billion. Ten years later, spending alloca-
tions had soared to $30 billion, and they
were expected to reach S90 billion in the
next  decade.
   The new legislation limits spending
authority to $2.4 billion in  each of the next
four years. And starting October  1, 1984,
federal funding generally will be restricted to
construction of treatment plants, main sewer
lines, and the repair of lines. States will put
up a greater share of construction costs.
   The shift  in  emphasis  from subsidizing
development to the improvement of water
quality was strongly supported by environ-
mental groups  as well as the administration.

Multi-billion Dollar Savings in
Regulation Costs
Changes recently implemented by EPA to
ease the burden of regulation should save in-
dustry and the public a total of $350 million
in capital costs and $1 80 million in operating
expenses. Future savings under  regulation
amendments proposed by EPA could total an
10
                                                                EPA JOURNAL

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                                           f"^
                                           S,  -- -
                                           «?•>          ,      x
estimated $5  billion in operating costs.
   Some examples:
   Amending the standards industry will be
required to meet for pre-treatrnent of wastes
alone could save up to $1.8 billion in annual
costs. The possibility of revising the pre-
treatment standards has  already been
proposed by EPA and the Agency is now
considering comments  on possible revision
strategy
   Changes under consideration in the  treat-
ment regulations for the  pulp and paper in-
dustry could total an estimated $1  billion.
   Revisions of the  1984 carbon  monoxide
standards for heavy duty trucks which have
been  proposed could avoid the need for
catalysts for these vehicles These changes
and certain assembly line testing modifica-
tions could save an estimated $360 million in
costs.
   Amendments, deferrals and withdrawals
of proposed noise regulations would result in
an approximately $600 million reduction in
the cost burden of these rules
Clean Air

Although Congress did not complete work
last year on revisions of  the Clean Air Act.
EPA nevertheless was able to initiate several
steps toward more cost effective  pollution
control. The time it takes to act on changes in
state  clean air implementation plans  has
been  substantially reduced. The backlog of
some 1.000 amendments awaiting
action will be wiped  out  altogether by  mid-
year  Eliminating bureaucratic delays  means
faster progress toward clean air. and at lower
cost.
   While  the Administration  seeks revisions
of the Clean Air Act, the goal is to build a
more workable program, not to tear down the
basic  structure that served  this nation  well
during the 1970's

Enforcement

A major reorganization of the enforcement
program has been started  and a new criminal
enforcement unit is being established. Funds
and  manpower are being  concentrated on
cases involving substantial pollution
problems. Minor cases, which absorbed a
great deal of EPA time and money in the
past, will be resolved whenever possible
through out-of-court settlement. Nearly 50
cases which had been pending at the Justice
Department were withdrawn because they
were weak,  old or of little substance. Mean-
while. 45 new stronger cases were referred
to Justice since Mrs. Gorsuch took office.
The  agency  is continuing  its joint program
with the Federal Bureau of Investigation in
probing criminal violations that  may occur in
the handling of hazardous waste, such as
"midnight dumping" or the surreptitious
discharge of hazardous substances into
waterways.

Paperwork  Reduction
Substantial reductions have been made. For
example, reporting  requirements under the
Resource Recovery and Conservation Act
have been cut by an estimated  three million
hours.  EPA is developing strategies for mak-
ing significant paperwork  reductions  in a
number of other areas this fiscal year,  in-
cluding water quality, groundwater monitor-
ing.  National Poilution Discharge Elimination
System consolidated permits, pesticides
registration  and  pre-manufacturing notices
requirements.

Small Business
EPA is making every effort to minimize the
impact of new regulations  on small
businesses, which are particularly vulnerable
to the financial burdens such regulations may
impose. The Small  Business Administration
recently singled out EPA for the high quality
of its economic analyses of regulatory effects
on small business.
   To further aid small businesses in comply-
ing with environmental requirements, EPA is
establishing  a small business ombudsman to
alleviate problems resulting from regulations
whenever possible.  The ombudsman will in-
vestigate and resolve disputes arising from
permitting, grants and  procurement
processes; track the development of stan-
dards and provide small businesses with in-
formation to encourage their participation in
decision-making; answer questions regarding
regulatory requirements, and  refer  small
businesses to other technical assistance of-
fices when  appropriate.

EPA Internal Operations
Internal controls over expenditures have
been tightened, audits have been increased,
efforts  to recover  money owed to EPA have
been greatly intensified, and stiff new con-
tracting and fiscal policies have been adopted
to slash expenses. D
JANUARY/FEBRUARY 1982
                                                                                                                            11

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Achieving
Better
Management
An interview with Dr. John P. Morton,
EPA Assistant tur Adminislr
  '-  What do you hope to achieve in your
leadership position at EPA in the new year?

<  *  I would  hope to see this Agency moving
in the direction to  which the Administrator
is pointing.  We need a better awareness of
our responsibilities to provide a proper
cost/benefit ratio to the American taxpayers.
   In the first 1 1  years at EPA, I don't think
that we were particularly cognizant of cost
effectiveness. Not only the cost in terms of
money the Agency spends, but the cost to
the affected publics. Now we're moving into
a period when we're going to be concerned
with the cost side as well as the benefit side.
   It is within that context that the Office of
Administration is moving  to make the opera-
tions of the Agency more  efficient. To the ex-
tent that we have  control over regula-
tions, we're trying  to simplify these regula-
tions. We are trying to make it less costly for
the affected publics to deal with the Agency.
   By the way, we're trying to make it less
costly for the Agency to  deal with itself.
Sometimes  we're our own worst enemies in
that respect. We promulgate rules and
regulations for conduct of business by our-
selves that  I think  are  sometimes very in-
hibitive.  So  I would hope to see a change
coming  around
   I would hope to develop, particularly
within the Office of Administration, a dif-
ferent sort of feeling on the part of Agency
staff. I think that one of  the biggest dif-
ferences between commercial  and govern-
ment employees is the unwillingness to take
risk. It's an  understandable unwillingness
because the system mitigates against taking
risk. If you  take a  risk and succeed, the
rewards are relatively small. If you take a risk
and fail, the penalises are very severe I
                                                                              would like to change the system so that the
                                                                              milieu in which our people work is more con-
                                                                              ducive to  risk taking. That's where we get
                                                                              creativity,  that's where we get new thinking,
                                                                              that's where we get the type of innovative
                                                                              approaches that are needed  in government
                                                                              today. So  I would hope, first,  in the Office of
                                                                              Administration,  and then  throughout the
                                                                              Agency to develop and change the system so
                                                                              that we could encourage our employees to
                                                                              stretch themselves a bit more in those areas.
12
                                                               EPA JOURNAL

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 Q
    How do you think major economies can
be achieved?
 A I  suspect that there are a number of
 areas where  that could happen.  One of the
 first things that we need to develop is a con-
 sciousness of the value of the dollar. Too of-
 ten we are prone to spend money without
 really thinking about how that money got
 there. Somehow  it's in the  Treasury And. if
 we have it in the budget, we just go ahead
 and spend it  We are  trying in the Office of
 Administration to develop a point of view of
 asking ourselves  "Well, if it were your
 S1000. would you  spend it for that item?"


 (J. Based on your extensive experience  in
 the business  world, do you think EPA can be
 operated more efficiently without sacrificing
 the quality of the Agency's efforts to protect
 the environment?


 f\ I  don't think  there's any question about
 that! I've gone around to visit all the regions
 and talked to people  throughout  Headquar-
 ters. Almost  everybody has said that the
 Agency in past has had almost more money
 than people know what to do with; that the
 objective and effort was  really to  make sure
 that all the money got spent. This is certainly
 not an objective in  a  business environment.
 This Administration wants to introduce
 some fiscal responsibility. Modifying a
 philosophical attitude as I describe does not
 mean shrinking the quality of our  efforts to
 protect the environment
JANUARY/FEBRUARY  1982
                                                                                                                            13

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14
                                                                                    EPA JOURNAL

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    I know you have visited a number of EPA
laboratories and offices around the country.
Is it your impression that these facilities are
generally performing in an effective manner?


r\ I  have visited all 10 regions. I  have
visited EPA facilities in Research Triangle
Park,  N.C.; Cincinnati;  Las Vegas; Edison,
N.J.; and a number of  other places. I would
say that the major problem is that  in many
cases we built more facilities than we really
needed. The capital expended in some of our
facilities for the results  we get is so far out of
line as to be almost unconscionable. I don't
think this was necessarily the fault  of  any
particular EPA employee,  but rather of the
perception  that we needed to duplicate
facilities all over.  The result of this was the
expenditure of large sums  of money where
the workload couldn't justify  that sort of an
expenditure.
   I think that the individual employees, as I
have seen  them,  in the regions and  in the
laboratories, have a good dedication to their
job and an interest in  achieving results I
really  think the problem was of a system
which  created these large facilities  and the
numbers of people assigned to them without
any assessment of the real cost/benefit ratio.
   Of course, the  other thing that's  happen-
ing is that we're transferring more and more
responsibility to the States. We  may find, for
example, that the  regional offices no longer
need as many people in order to achieve the
new trends in  operations.
  '  Do  you think there is a need of con-
solidation or closure of some of these field
units?
  ^  Yes. there's no question in my mind that,
if we're going to  operate effectively, we  do
need to do that sort of thing. The question is
how you do that  and still maintain the ser-
vices that those facilities were providing. In
the  Office of Administration our goal is "Bet-
ter  services  at lower cost." When we con-
sider consolidation of these facilities,  we're
exploring the possibilities for lower costs. But
that does not  mean  we can neglect better
services. And the question  is really how  to
trim expenses without  hurting services. A
particular area we have  been studying is the
Surveillance and Analysis Laboratories which
provide a valuable service to the Regional
Administrators. They allow the Regional Ad-
ministrators  to have  a scientific authority in
the  region. The problem is  if we  take that
laboratory out of  the region, we need  to
replace  it in some fashion so that we don't
damage the  reputation for scientific accuracy
which the Regional Administrator has. And
this is  the problem  we're wrestling with  at
the  moment.
    I  understand that the zero base
budgeting concept is  no longer in vogue.
What was the trouble with this approach?


A  The zero base budget, like many ideas, is
very good in concept—in theory.  The
problem is in the execution. The implementa-
tion generated enormous amounts of work. It
was a great time-consumer in trying to
prepare the  budget. It was just simply un-
manageable in  EPA. And  if it's un-
manageable in  EPA, it's likely to  be un-
manageable in  any  other  government
agency.
   EPA, I think, is willing to move into new
areas more than other government agencies
do. But the amount of time that was commit-
ted to committee meetings, wrestling with
the basic needs for certain services, all of
which were required for zero base budgeting.
just could  not justify the end result. Because
of that, of course, we dropped the concept,
and we moved over on to another  type
budgeting.
   Our budget in EPA  and in government
generally has a much greater significance
than it does in industry. In commerce and  in
industry the budget is a tool that allows
managers  to plan and manage  their func-
tions. In EPA the budget  is a driving force
that dictates what needs to be done. I'm not
sure that that's necessarily good. Generally
speaking, my practice in business has been to
develop, first of all, a business  plan. After
developing a business plan, we  would then
translate the business plan into a budget.  In
other words the budget was a  financial in-
trepretation of the business plan. The budget
was  used  then throughout the year to help
answer a simple four-word question:  is the
plan  working?  I would like to see us move
more  in that direction, toward understanding
the budget as a management tool,  rather
than as a  driving force. I'm not  sure that's
possible within the dictates of Congress and
the White House. D
JANUARY/FEBRUARY 1982
                                                                                                                             15

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Grants  Program
Refocused  on
Environment
   President Reagan  has signed into law new
   legislation authorizing continued Federal
grants to cities and towns to help build
sewage treatment plants to curb water
pollution
   President Reagan declared that this
legislation "represents a rededication to en-
vironmental goals and a turn away from
public works for the sake of public works."
   The new amendments to the 1977 Clean
Water Act authorized  EPA to grant to the
States up to $2.4 billion per year during
1982-1985 to pay 75 percent of the cost of
building sewage treatment plants, interceptor
sewers, and certain other sewage cleanup
projects. The percentage of Federal  aid will
drop to 55 percent  in fiscal 1985
  EPA Administrator Anne M. Gorsuch has
asked Congress to appropriate the full
$2.4 billion for fiscal year 1 982 to carry out
the revamped national  sewage treatment
program
   The amendments will also allow  $200
million per year during 1 983-1 985 to protect
coastal bays and estuaries from the harmful
effects of sewage.
   EPA Deputy Administrator John W.
Hernandez issued the following statement:
   "By signing the Municipal Wastewater
Treatment Construction Grants Amendments
of 1981. the President has expressed his
support for continued progress toward clean
water thtough an efficient, affordable
municipal sewage treatment program.
   "The Congress is to be  congratulated for
incorporating the basic recommendations  of
the Administration into the new law. making
it the most significant environmental legisla-
tion thus far enacted during this session  This
law redirects Federal funds for municipal
sewage  treatment  from a  public works
program to a targeted environmental
program.
   "The new amendments will help achieve
the Administration's goals of enhanced water
quality, greater cost-effectiveness, and more
flexibility  to States and localities in deciding
sewage treatment priorities. EPA looks
forward to working with the States to make
the promise  of the  amendments a reality."
   The new law  includes Administration
reforms intended to  direct sewage treatment
dollars to projects that will significantly im-
prove water  quality, to give local officials
greater flexibility in deciding sewage cleanup
priorities and to reduce Federal involvement
in the program from the S3 to S4 billion level
that existed during the late 1970's.
  No new Federal money for sewage  treat-
ment has been  available to the States since
October 1, 1981 Funding for the  program
under the new  amendments will require
enactment of a supplemental appropriation
to provide the money authorized.
  Under  the previous construction grants
law. EPA would have had  to spend about
S90 billion by the year 2000  to satisfy the
sewage treatment needs of the States, The
new law, because it  reduces the Federal
share and  limits construction eligible for
Federal dollars,  trims this figure to S36 billion
by the year 2000—a  60 percent reduction.
  October 1. 1984.  is a significant date in
the new legislation. Until then, EPA's sewage
treatment program remains much as it has
been under the  1977 Clean Water Act. After
this date, however, the program is  designed
to come closer  to the Administration goal of
a leaner,  but more effective effort
  Since 1972. EPA  has committed about
S33 billion in sewage treatment grants to
help fund roughly 22,000 projects for plann-
ing, design and construction of sewage
facilities. Only an estimated 3,700 of  these
have been completed because of the  seven
to 1 0 years it has taken in the past to  com-
plete a  project  after the initial funds were
awarded. Streamlined procedures in the
1981 amendments are designed to reduce
this lengthy -time period.


Other
Highlights

Projects eligible for Federal funding
Under the old law, Federal grants paid for a
variety  of sewage construction including:
treatment plants: "alternative/innovative"
projects, such as land  application of sewage
liquids:  collector sewers (which run under a
residential street, for example): interceptor
sewers  (larger diameter sewers which tie
collector lines to treatment plants), work to
prevent rainwater or other seepage  from en-
tering sewer lines (known as the "infiltration-
inflow" problem), and work to prevent
16
                                                                 EPA JOURNAL

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                 State  Allotments  for  Fiscal  1982  in Millions  of Dollars
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
-X-'v CONNECTICUT
r ^*i
r\
v_ AK
s* 11
r

DELAWARE
DISTRICT OF
COLUMBIA
FLORIDA
GEORGIA
HAWAII
^J^^^^^Vv IDAHO
JS ^Vv
30
1 1
18
17
187
21
26
1 1

1 1
90
45
18
1 1

ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASS.
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA

122
65
30
20
34
29
17
65
69
97
44
22
59
11

NEBRASKA
NEVADA
N.HAMPSHIRE
NEWJERSEY
NEW MEXICO
NEW YORK
NO. CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SO. CAROLINA
SOUTH DAKOTA
13
1 1
20
84
1 1
251
46
1 1
152
21
30
103
12
27
1 1
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
W.VIRGINIA
WISCONSIN
WYOMING
SAMOA
GUAM
PUERTO RICO
PAC TR. TER.


36
103
1 1
1 1
46
41
42
46
1 1
1
1
27
3


                             Over $25 million
                             Over $50 million
                             Over $100 million
                             Over $200 million
                                                                                Pfl
27
JANUARY/FEBRUARY 1982
                                                                                   17

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stormwater from flushing raw sewage into
waterways (known as the "combined sewer
overflow problem).
   Under the new law, EPA can continue to
make grants for all of this construction until
October 1, 1984.  Afterward, the Agency's
grants will go primarily toward building treat-
ment plants, alternative-innovative projects,
and interceptor sewers. However, a governor
may spend up to  20 percent of  the State's
Federal  allocation for other sewage
construction.

Federal share
The old  share for eligible construction was 75
percent for conventional treatment works
and  85 percent for alternative-innovative
projects. This will  remain true under the new
amendments until October  1. 1984. Af-
terward, the Federal share  will  drop to 55
percent for conventional work  and 75 per-
cent for alternative-innovative projects

Reserve capacity
Under the old  law. EPA sometimes funded
sewage treatment plants larger than im-
mediately needed  in order  to provide extra
treatment capacity for future community
growth. This remains possible under the  new
law  until October  1, 1984. Afterward,  the
Agency can fund  construction only to serve
the residential and industrial flows existing
on the date of grant approval for
construction

Compliance deadline
The old law gave sewage treatment facilities
until July 1, 1983, to meet a "secondary"
treatment level (secondary  generally means
removal of 85  percent of the organic matter
and  suspended solids in sewage). The  new
law  gives these facilities an additional  five
years, until July 1, 1988, to achieve secon-
dary treatment.

Decentralization
The  new amendments encourage all States
to take over the actual operations of the con-
struction grants program, with EPA to
assume a monitoring and guidance role. Thus
far, 44 States have signed agreements to un-
dertake these new responsibilities. D
Another section is lowered for a massive interceptor sewer pipe built to  take
vjnftos tram collector sewers to a sewage treatment plant.
18
                                                                    EPA JOURNAL

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EPA  Acts
to  Protect
Atlantic City
Water
A    six-month study has been launched un-
    der an EPA contract to determine the
best method of protecting the public water
supply of Atlantic City. N.J., from contamina-
tion by chemical wastes migrating out of
Price's Pit, a  nearby disposal site.
  Anne M. Gorsuch, EPA Administrator, has
approved  the allocation of approximately
$500,000 for the study and additional field
investigation activities.
  Mrs. Gorsuch also approved funding for a
standby supply of activated carbon to be
used to treat the city's water  if  it should
become tainted while the long-term program
is being developed
  Estimated cost of the standby carbon sup-
ply  is SI  million
  "Price's Pit ranks among the  top ten
priority Superfund sites in  the  Nation," Mrs.
Gorsuch said. "This action demonstrated
EPA's determination to take effective action
where a potential public health risk is in-
volved."
  A now inactive 26-acre landfill in the town
of Pleasantville. N.J.. Price's Pit  is six miles
northwest of Atlantic City. Chemical wastes
were dumped at this location from 1968 to
1976.
  Leachate from the landfill has con-
taminated nearby  private drinking water
wells serving 37 homes. Tests  show that the
contaminants are  moving  through the
groundwater and have approached a well
field serving Atlantic City.
  On December 22, 1 980, the U.S. Depart-
ment of Justice filed suit  at EPA's request
against the former and present owners of the
landfill. On September 23.  1981, the State of
New Jersey issued an administrative order
directing the  New Jersey  Water Company
and the affected municipalities to extend
water mains to supply the already affected
houses. D

Huge crowds flock to Atlantic City on the New Jersey ocean front.
JANUARY/FEBRUARY 1982
                                                                                                                 19

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                                                                                         More than 700,000 gallons of waste
                                                                                          containing polychlorinated  biphyenyls
                                                                                     (PCBs) were burned in December aboard the
                                                                                     incinerator ship Vulcanus in the Gulf of Mex-
                                                                                     ico about 350 miles southwest of  Mobile,
                                                                                     Ala.
                                                                                       The Vulcanus, a 334-foot converted
                                                                                     tanker,  is one of only three incinerator ships
                                                                                     in the world.
                                                                                       "EPA considers incineration at sea to be a
                                                                                     safe and  reliable method  of disposing of
                                                                                     PCBs," explained EPA Administrator  Anne
                                                                                     M. Gorsuch.
                                                                                       When  the ship's  incinerator reaches a
                                                                                     combustion temperature exceeding 1,200
                                                                                     degrees  centigrade,  more  than 99.9 percent
                                                                                     of the PCBs are destroyed.
                                                                                       EPA previously monitored incineration of
               1000 Fathoms   100 Fathoms
MEXICO
                                                                                      The s/Je where the Vulcanus is burning PCB
                                                                                      wastes is located in deep water off the con
                                                                                      tinental shelf and more than 300 kilometers
                                                                                      from  any  coastal area.
                                                                                                               EPA JOURNAL

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                                                                                      The incinerator ship Vulcanus in port.
wastes  aboard  the Vulcanus  in 1974 and
1977, Incineration at sea has been practiced
successfully in Europe for a number of years
   Chemical Waste Management Inc. and its
subsidiary. Ocean Combustion Service, have
a permit from EPA to  dispose of up to 3.6
million gallons  of PCS wastes this year.
   EPA  is closely monitoring the incineration
process. Automatic recording devices keep a
record of the temperature of combustion and
other data.  A manual log keeps  an hourly
record  of wind  speed and direction,  vessel
position, course and speed.
   An automatic shut-off device  will be ac-
tivated  in case  the incineration temperature
falls below  1,200  degrees
   An EPA official  aboard the Vulcanus has
the authority to shut down the process if
necessary. In addition, the Vulcanus remains
in touch with the 8th District Coast Guard in
New Orleans during  the  incineration of the
wastes.
   The burn site is  in deep water  off the con-
tinental shelf and far from  land,  commercial
and sports fisheries, shipping  lanes,  and
breeding, spawning and nursery areas for fish
and other marine life.
   EPA  receives its authority  to the disposal
of PCBs from the Toxic Substances  Control
Act (1 976) and the authority to issue permits
for incineration at  sea  from the  Marine
Protection,  Research, and Sanctuaries Act
(1972).
  The PCB wastes being burned aboard the
Vulcanus came from a landfill facility in
Alabama, where they were temporarily
stored after being gathered from various
parts  of the country.
  PCBs are toxic and  persistent chemicals
primarily used as insulating fluids in heavy-
duty electrical equipment in power plants, in-
dustries and large buildings.
  The manufacture of  PCBs was banned in
1979. EPA estimates that 750 million
pounds  of PCBs are  still in use. with 290
million pounds located in landfills and an ad-
ditional  1 50 million pounds dispersed
throughout the environment.  Last year EPA
issued permits to two  land-based in-
cinerators, which are disposing of about
200,000 gallons of  PCB wastes per month.
  PCBs have caused birth defects and can-
cer  in laboratory animals, and are a  suspec-
ted  cause of  cancer and adverse skin and
liver effects in humans.
  During the last four years  several EPA
studies have concluded that incineration of
hazardous wastes at incinerators on land can
also be  successful.
   These studies have determined  that in
most cases incineration proved to  be the
best, if not the only environmentally accep-
table, method of hazardous waste  disposal
   Two EPA research and field-scale projects
carried out in 1979 involved several types of
commercial incinerators and 20  different
chemical wastes,  including nine  pesticides.
These wastes were almost totally detoxified
and destroyed by incineration The successful
use of  cement  kilns to destroy the  highly
toxic, halogen-containing organic waste is
one of  the more important and well-
publicized demonstration projects by EPA
   An EPA-sponsored trial burn,  to
demonstrate  the destruction of PCBs in a
high-efficiency boiler, was conducted in May
1980 at the General  Motors Chevrolet plant
located in  Bay City. Mich, It showed that low
levels (50 to  500  parts per million)  of the
toxic PCBs could be safely destroyed by bur-
ning them at approximately 2,000 degrees
Fahrenheit.
   Two benefits from this demonstration
were that it laid to rest public fears about
burning PCBs, and  it encouraged  other com-
panies, especially utilities, to apply for per-
mits to burn their low-concentration PCBs in
a similar manner.
JANUARY/FEBRUARY 1982
                                                                                                                             21

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   The Combustion Research Facility (CRF),
which should be completed soon in Jeffer-
son. Ark.,  is expected to provide valuable in-
cineration data that  may have  great impact
on regional incinerator permit programs. That
facility will be the property of EPA, located on
the grounds of the National Center for Tox-
icological  Research, a facility operated jointly
by EPA and the FDA (Food and Drug  Ad-
ministration). The  CRF will be  operated for
EPA to  conduct research into trie safe in-
cineration of hazardous materials.
   It will house two  pilot-scale incinerators.
One unit is a rotary kiln incinerator capable of
handling a wide variety of material at the rate
of 200 pounds per hour. The second unit is a
liquid-injection  incinerator that  will test at
least 10 different hazardous and toxic waste
types from specific waste streams. Rotary
kiln and liquid-injection incinerators account
for 90 percent of all hazardous waste being in-
cinerated  today.
   Last  summer EPA also conducted full-
scale testing of the municipally owned hazar-
dous waste incinerator in Cincinnati. Nearly
one hundred thousand gallons  of hazardous
waste were incinerated during the extensive,
short-term test.  Results were promising; a
report on  the project is being prepared.
   EPA estimates that  about 60 percent of all
 hazardous waste  could be successfully in-
 cinerated, if  incineration were  widely used.
 The Agency's figures show that only six per-
 cent of all hazardous  waste has been dis-
 posed of by controlled incineration
   Unfortunately,  incineration  is one of the
 more expensive methods of hazardous waste
 disposal.  It costs anywhere from $75 to $2,-
 000 to incinerate  a  ton of hazardous waste,
 depending on the type of waste.  Further-
 more, with the exception of a  handful  of in-
 dustrial hazardous waste incinerators
 operated  on company premises, very few
 commercial hazardous waste incinerators
 exist.
   The  Nation's first two commercial in-
 cinerators, which  can destroy  high concen-
 trations of PCBs  (above 500 parts per
The Vulcanus burning wastes at sea Irom the incinerator located at the rear of the sh/p.
Hit/fi temperature rotary kiln incinerator at Deer Park,  Texas, used to destroy PCBs.

million),  have been approved by  EPA,
One facility is in Deer Park, Tex..
and the other is in El Dorado, Ark. Both can
destroy more than  99 percent  of the
PCBs by burning them at high temperature
(above 2,192 degrees Fahrenheit).
   Regulations issued  by EPA under the
Toxic Substances Control Act require that
high-level liquid wastes- -containing PCBs
above 500 parts per million—be disposed of
only in  EPA-approved incinerators.  EPA ex-
pects to approve additional  commercial in-
cinerators in the future, although no such ap-
provals are imminent.
  Two important conditions for proper in-
cineration are temperature and the time
(called residence time) a waste must spend in
the incinerator to be completely destroyed
These conditions vary with  the waste's
 22
                                                                                                                  EPA JOURNAL

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chemical structure and physical form and
type of incinerator. Temperatures can range
from 750.to 3,000 degrees Fahrenheit;
residence time can range from one-tenth of a
second to several hours.
   Other important considerations for burn-
ing of  hazardous waste are oxygen
availability and adequate mixing. Thorough
mixing of air, wastes, and fuel (if required) is
necessary for achieving complete combus-
tion during the time available. Sufficient mix-
ing is especially important for burning liquid
wastes. Incinerators can  handle solid, liquid
or gaseous waste. Some are equipped to
burn all three.
   Incineration  has several  distinct advan-
tages as a hazardous waste disposal method:

• Toxic components of hazardous waste
can be converted to harmless compounds,
or to much less harmful  ones.

• Incineration provides for  the  ultimate
disposal  of hazardous waste, eliminating
the possibility of future problems.

• Some  of the energy produced by the
combustion process can  be recovered.

   Because of these advantages, incineration
is preferable  to  other means of hazardous
waste  disposal.  Unlike land disposal
methods, which can require 30 years of
groundwater  monitoring  after closure of a
facility, incinerators burn clean. This
economic advantage enables incineration to
compare favorably with other disposal
methods, despite an incineration facility's in-
itial high cost for construction.
   Dow Chemical Company has been in-
cinerating chemical wastes for  about 40
years and is  currently operating one rotary
kiln incinerator and one tar burner at its
Midland, Mich.,  plant. The rotary kiln, which
was updated  in 1974, burns solid waste and
sludges. The tar burner incinerates only liquid
wastes; it was a pioneering facility when it
was built in  1968.
   Another successful incineration facility in
the Midwest  has been operated since 1972
by the 3M company in Cottage Grove, Minn.
Most wastes arrive in  55-gallon drums, but
the incinerator can also accept wastes direc-
tly from  a tank truck.  Employees at the
facility have received one of 3M's "Pollution
Prevention Pays" awards  for increasing
operation efficiency, thereby saving the com-
pany $150.000 a year in fuel costs and
reducing pollution.
   A rotary kiln is a brick-lined, cylindrical fur-
nace, mounted horizontally at a slight incline.
that turns slowly as heat is applied to liquid
or solid hazardous waste  inside the unit.
Temperatures can range  from 1.000 to 3,-
000 degrees Fahrenheit. The resulting ash
can  be considered harmless if disposed of
properly.
   Rotary kilns have been  used  to incinerate
PCBs, chemical warfare agents, halogenated
organics. and other chemical compounds.
One of the kiln's disadvantages  is
the high  cost of installation. The cost varies
widely, depending on  the design and size of
the furnace.
   Liquid injection incinerators can  be used
to dispose of virtually  any combustible liquid
waste. The key element of this  type of in-
cinerator is the nozzle, which atomizes the
waste and mixes it with  air. The burning of
waste, at temperatures similar to those in the
rotary kiln, takes place in the combustion
chamber.
   Hazardous wastes  incinerated by this
method can range from solvents and thinners
to liquid PCBs  and various organic com-
pounds. One disadvantage of the liquid injec-
tion incinerator is  that it accepts only fluid
wastes that  can be atomized through a bur-
ner nozzle.
   Other processes for hazardous waste in-
cineration include  the  fluidized-bed. the
multiple-hearth,  and the co-incineration
methods. One of the emerging  technologies
is pyrolysis—the thermal destruction of
solids and sludges in the absence of oxygen.
   The improper incineration of  hazardous
waste may produce air pollutants  as by-
products of  incomplete combustion. These
are primarily carbon monoxide, organics.
halogens, and acids. In well-designed and
properly  operated  incinerators, these air
pollutants are emitted in insignificant
amounts. In  addition, afterburners, which are
part of the incineration system, destroy gas-
eous hydrocarbons not consumed in the in-
cinerator.  Scrubbers  and electrostatic
precipitators are used to remove air pollu-
tants from the stack gases.
   Although  shipboard  incineration has  not
been used widely, it is considered promising.
It can destroy hazardous waste as efficiently
as land-based  incineration, it has a  minimal
impact on the  environment by removing the
destruction site far from populated areas so
that emissions are absorbed  by  the ocean.
and.  according to a  1978  EPA study, it is
cheaper than land-based incineration or
chemical detoxification. As  EPA points out. a
single incinerator ship could  destroy up to
200.000 tons  of hazardous waste per year.
   In October  1980,  EPA  and the Maritime
Administration published the results of  a
study on the building of specially equipped,
high-temperature  incinerator ships. EPA has
also been reviewing incinerator specifications
and cooperating with private firms interested
in  incinerator ships.
   In addition,  EPA's Office of Hazardous
Emergency Response (the  "Superfund"  of-
fice)  has been  studying the possibility of in-
cinerating hazardous waste on offshore
ocean platforms. One such site  has already
been selected. It  is  located in the Gulf  of
Mexico, 60 miles from Mobile. Ala., and 40
miles from the coast of Louisiana. A draft en-
vironmental  impact statement on the site
was released in September 1981.
   If approved, the Gulf platform  will contain
a rotary kiln  with an afterburner and be able
to burn liquid as well as solid hazardous
waste. Land  facilities will have a staging area
where hazardous waste will arrive and leave
in  closed containers.
   A  platform incinerator, armed with an
ocean disposal permit for its residual ash and
spills and not handicapped  by emission con-
trol requirements  that apply to land-based
units, could  become  one of the  most cost-
effective hazardous waste disposal methods
of the future. D
JANUARY/FEBRUARY 1982
                                                                                  23

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                                                                                                 William A.  Sullivan, Jr
New   Criminal
Enforcement
Unit
Established
at  EPA
Ten seasoned  attorneys have been named
 I to key posts,  and 25 criminal investigators
have been hired as  part of a reorganization
designed to beef up EPA's enforcement
operations.
  Anne M. Gorsuch, EPA Administrator, said
that creation of a new  Criminal Enforce-
ment Unit will help the agency to crack
down on such flagrant violations as the illegal
discharge of wastes to waterways,  midnight
dumping  of toxic substances and the
deliberate destruction or falsification of vital
environmental reports.
  "With  this new unit, we will choose our
cases  more carefully, move swiftly  with the
Justice Department  in bringing them to trial,
and increase our prospects for successfully
prosecuting cases that merit this approach."
Mrs. Gorsuch declared.
  She said the criminal invistigators being
hired will be stationed in EPA's 10 regional
offices and in the National Enforcement In-
vestigation Center in Denver, Colo.
  While  still being  assembled. EPA's new
criminal enforcement unit conducted an in-
vestigation which led to the November sen-
tencing of a  Vermont firm. Corning Fibers.
Inc.. for violation of an environmental  con-
sent decree and resulted in a jail term  for  a
corporate officer.
  Explaining the overall reorganization of the
enforcement office,  William A. Sullivan, Jr..
EPA's enforcement counsel, said that eight of
the  1 0 lawyers named to fill the key  positions
are  career civil  servants who previously ser-
ved in  management positions with the
agency. Some of the key appointments in-
cluded the following selections:
   — Peter Paul Broccoletti, deputy enforce-
ment counsel, will exercise day-to-day
operating responsibility for meeting Sul-
livan's charge to conclude cases swiftly and.
where possible, informally so that pollution is
controlled quickly and economically. Broc-
coletti, whose hometown is Ft. Lauderdale,
Fla., has served with the Civil Aeronautics
Board, the Federal Trade Commission's
Bureau of Consumer Protection, and the
Federal Maritime  Commission. He was
supervising attorney for  the Notre Dame
Legal  Aid and Defender  Association from
1976  to 1978 and  then became the first
managing attorney for Legal Services of the
Florida Keys  in Key Largo.
   — Michael S. Alushin, a  native of
Cleveland. Ohio, who has been named direc-
tor of  the Office of  Special Projects, will
direct  activities pertaining to  the Steel In-
dustry Compliance Extension  Act of 1981
and Superfund expenditures for hazardous
waste sites. He also will coordinate other
special activities on a project-by-project
basis.  Alushin gained extensive litigation ex-
perience with the Pennsylvania Department
of Environmental Resources. As an assistant
attorney general, from 1972  to 1977, he
represented Pennsylvania as both plaintiff
and defendant in numerous federal and state
cases  concerning  air and water pollution.
While  director of the Bureau  of Regulatory
Counsel, from 1 978 to 1 980. he supervised a
staff of attorneys who provided legal counsel
on all  state and federal environmental
statutes and  regulations  to state officials.
  — Peter G. Beeson will serve as director of
the Office of Criminal Enforcement. Beeson is
currently on special assignment from the
Department of Justice's  land and natural
resources division. From  1975 to 1977,  he
was a  trial attorney in the criminal division of
the Justice Department. From  1977 to 1979,
Beeson.  a native of Atlanta, served in  the
positions of senior staff  attorney and assis-
tant deputy chief counsel of the select Com-
mittee on Assassinations in the U.S. House
of Representatives.
                                                                                                        EPA JOURNAL

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                    Peter Paul Broccolelti
                       Michael S  Alushin
                          Peter G Beeson
L
   Five deputy associate enforcement coun-
sels have also been named who will take on
responsibility for directing enforcement  of
environmental laws relating to air. water.
pesticides and toxics, and hazardous wastes:
   Louise Jacobs, EPA's regional  enforce-
ment  division director in Kansas City for the
past three  years,  has been named the
agency's deputy associate enforcement
counsel for air enforcement, Jacobs, whose
hometown is Pittsburgh. Pa., was senior staff
attorney for the United  States Court of  Ap-
peals, Third Circuit, in Philadelphia  from
1976 to 1979 She was with the ad-
ministrative offices of the New Jersey courts
from  1971 to 1976, including two years as
court  administrator for  Bergen  County. She
has also been in the general practice of law in
Somerville, N.J
   Sanford Harvey,  a  native of Atlanta,  has
been appointed deputy associate counsel for
toxics and pesticides  enforcement. Harvey,
36. has been with  the  EPA for three years.
He started  in 1 979 as the regional  counsel of
EPA Region 4 in Atlanta and  later  became
the region's enforcement division director In
1980 he moved to EPA Headquarters in
Washington, DC., to take the post of deputy
assistant administrator  for mobile sources.
noise  and  radiation
   Edward  A Kurent, 35, an attorney with
EPA since  1977. has been named the
agency's deputy associate enforcement
counsel for water enforcement, Kurent,  a
native of Cleveland, started working for EPA
as an  attorney with the Office of Water Enfor-
cement, subsequently serving  as  special
assistant to the agency's chief enforcement
officer. He then became legal director of the
hazardous waste enforcement task force. His
most recent position has been director of the
enforcement division of the Office of Water
Enforcement and Permits,
   Julio Morales-Sanchez, a native of Puerto
Rico, has  been appointed deputy associate
enforcement counsel for hazardous waste
enforcement starting in July.  Morales-
Sanchez, 40, started his career with EPA in
its Region 2 office in New York City in 1 970
where  he  served  as enforcement division
director. From 1970 to 1979, he was  the
U.S. attorney for  the Commonwealth of
Puerto Rico. In 1965, upon graduation  from
law school, he became the assistant district
attorney for Puerto  Rico's Department  of
Justice and, subsequently, became general
counsel for the Puerto Rico Communications
Authority.
   James Bunting. 36, a native of Silver Spr-
ing, Md., has been  named interim deputy
associate enforcement  counsel of hazardous
waste  until Morales-Sanchez  assumes  this
post. Bunting has been with EPA for the last
five years, most recently as acting director of
the legal division, office of waste programs
enforcement.  He had served four years  as a
trial attorney in the judge advocate division of
the U.S. Marine Corps.
   Two experimental teams of attorneys
trained to  handle cases in all  types of pollu-
tion will be headed by Charles  M,  Hungerford
and Frederick Stiehl. Hungerford's civil litiga-
tion team  will  be responsible for headquar-
ters involvement  in  all  cases  originating in
EPA's Region  9 (California, Hawaii,  Nevada
and Arizona). Stiehl's team will cover  Region
5 (Illinois,  Indiana. Ohio, Minnesota, Wiscon-
sin, and Michigan).
   Hungerford,  31, a native of Tucson, Ariz.,
began his career with EPA in  1976, working
extensively on  enforcement of the Clean Air
Act, Most recently,  he  supervised 15 attor-
neys and paralegals as chief of the enforce-
ment preceedings branch
   Stiehl, 36. a native of Bound  Brook,  N.J.,
joined EPA in 1979  and was assigned to the
hazardous waste  enforcement task force
Subsequently, he became litigation branch
chief with the office of waste programs en-
forcement.  Prior to that he worked for two
years as an editor at U.S.  Law Week  Stiehl
brings to his  new position eight years of
litigation  experience in federal and local
courts with the District of Columbia's  Office
of Corporation Counsel.
   Sullivan said that Region 5. headquartered
in Chicago, was selected for the experimental
team approach that will deal  with all aspects
of pollution because the region is the largest
and most active in terms of enforcement ac-
tivities
   Region 9. headquartered in San Francisco,
was picked for this experimental program to
compare  the  results with that of a larger
regional area. Sullivan added,
   "We think  this approach might be  the
most effective way to deal with enforcement
problems, but we won't know until we've had
some test runs,"  Sullivan  said
   In addition, two  longtime  career agency
managers have been named to key positions.
Geoffrey Grubbs has been  named director of
the Office of Enforcement  Policy and  Gerald
Sryan will oversee all operational manage-
ment and personnel matters as director of
the Office of Legal Operations, D
JANUARY/FEBRUARY 1982

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Key
Appointments
Move   Forward
   President Ronald Reagan has publicly
   announced his intention to nominate
James W. Sanderson, an attorney,  and has
nominated Frederick "Eric" A.  Eidsness Jr.,
a civil engineer, for two top  EPA posts.
  Sanderson, who formerly served as the
legal counsel for EPA's Regional Office in
Denver, has been selected to be  EPA's assis-
tant administrator for Policy and Resource
Management.
  He will be responsible for policy  analysis.
regulatory reform, legislation,  the budget,
standards, regulations, and management
systems  and  analysis.
  Eidsness, also a former EPA  employee,
has been chosen for the post of EPA's Assis-
tant Administrator  for Water.  In this job.
Eidsness will be responsible for administering
not only the Clean Water Act, which includes
a multi-billion dollar sewage treatment
program, but also the Safe Drinking Water
Act, and the  Marine Protection  Act, which
controls  the dumping of wastes into the
ocean.
   Other appointments include the  selection
by Administrator Anne M. Gorsuch of Ear-
nest F. Gtoyna as  chairman  of  the EPA
Science  Advisory Board, of Richard D.
Wilson to be director of the Office of Mobile
Source Air Pollution Control,  and Samuel
Schulhof as deputy assistant administrator
for administration.
  Commenting on the appointment of San-
derson, EPA Administrator Anne M. Gorsuch
said:
  "The maiority of Jim Sanderson's
professional experience has been in the  ex-
ecutive and legislative areas of government,
in Washington and at the regional  level.
Much of that experience, as well as his
private sector experience, has been in the en-
vironmental area-"
  Sanderson has been an attorney  with the
firm of Saunders, Snyder. Ross and Dickson
in Denver for the past four years, where he
specialized in the legal aspects of air  pollu-
tion, water pollution, solid waste, and natural
resources.  He is vice-chairman of the
American Bar Association's air quality com-
mittee, natural resources section.
  In 1973, Sanderson joined  EPA as  assis-
tant regional counsel  in the agency's Denver
office and was promoted to regional counsel
in 1  975. He was involved in a broad range of
federal, state and local government matters
and gained substantial knowledge of  the
laws under which EPA operates. He went
into private law  practice in 1977.
  Sanderson. 37. worked in the U.S. Con-
gress as legislative assistant to Senator Gor-
don Allott  (R-Colo.) from June 1970  to
January  1973
  He worked as an attorney-advisor  at the
Internal Revenue Service in Washington from
November  1969 to June 1970.
 26
                                                                EPA JOURNAL

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                          A Eidsness Jr
                                                                   Earnest  F. Gloyria
   Regarding  the appointment of Eidsness,
Mrs. Gorsuch said:
   "Eric Eidsness knows the water cleanup
field from several perspectives—as a former
EPA employee, as  a local planning  official
and as a consultant  to government  and in-
dustry  on various water pollution control
problems. This broad experience will be par-
ticularly valuable to the Agency as Congress
considers reauthorization of the Clean Water
Act this year."
   Since September  1981, Eidsness, 37, a
native  of Jacksonville, Fla,. has served as a
consultant to the EPA Administrator on
water issues.  Prior  to serving in this capacity
he had since 1978 been a partner  in the
management consulting  firm of BMML Inc.,
in  Boulder, Colo. He specialized in advising
state and local governments and industry on
the institutional and  financial requirements
involved in carrying out  the federal  water
laws
   From 1975 to 1978, Eidsness  served as
director of water and air quality planning of
the Larimer-Weld Regional Council  of
Governments in  Loveland, Colo, In this
capacity, he directed development of  an
areawide plan for curbing wastewater
discharges.
   From 1973 to 1975, Eidsness was a staff
consultant for the  Biomedical  and Environ-
mental Systems section of Arthur  D, Little,
Inc. of  Cambridge, Mass. He took part in ma-
jor environmental impact studies for in-
dustrial and governmental clients. He also
co-authored a study on the management and
economic  benefits  of the New York
State/EPA  construction grants program  for
sewage treatment.
   During 1 970 to  1 973, Eidsness worked in
the construction grants program at  EPA's
regional office in Atlanta. He helped  prepare
one of the  agency's  first  environmental  im-
pact statements (on a regional sewage treat-
ment project in the metropolitan Atlanta
area). While working on another impact
statement,  Eidsness. a diver,  made several
ocean-bottom  dives off Florida's Atlantic
coast to supervise a survey of pipes discharg-
ing sewage  into the  ocean.
   Eidsness served as a commissioned officer
in  the U.S. Navy from  1968  to 1970,  13
months  of which were spent  with an un-
derwater salvage unit in South Vietnam.
   In 1967,  Eidsness received a bachelor's
degree in civil engineering from Vanderbilt
University, Nashville, Tenn. He  has written
articles and given speeches on numerous en-
vironmental  subjects,
   Eidsness is  married and the father of two
children  He and  his family now reside in
Washington, D.C., and also own an irrigated
farm near Ft. Collins,  Colo.
   The appointment of Eidsness and Sander
son are  both subject to approval by the  U,S
Senate.
   In naming Dr. Gloyna. dean of the
College of Engineering at the University of
Texas in Austin, as chairman of the Science
Advisory Board. Mrs. Gorsuch said "it is ad-
vantageous  in making judgments to  have
the leadership of someone  like Dr. Gloyna.
whose  scientific advisory experience  spans
35 years."
   Deputy Administrator John W.  Hernandez.
former dean of the  engineering school at
New Mexico State  University, said that "in
my own professional and academic ex-
periences, I have observed with great respect
the water resource engineering abilities of Dr
Gloyna in environmental organizations, in the
engineering  profession  and  in higher
education."
   Dr.  Gloyna. who received his  doctor of
engineering  degree from Johns  Hopkins Un-
iversity in Baltimore, has been a consultant to
100 cities, industries and consulting  firms.
He also has been a consultant to the Con-
gress,  nine different federal  agencies, five
foreign governments, the United Nations,
World  Health Organization and World Bank.
   Author of numerous  books and reports on
the control of wastes, Dr. Gloyna is a mem-
ber of  the National Academy of Engineering,
the National Academy  of Sciences in
Venezuela and a corresponding member of
the National Academy  of Engineering of
Mexico. He  is vice  president of the Water
Pollution Control Federation
JANUARY/FEBRUARY 1982
                                                                                                                            27

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                         Richard D Wilson
                                                                    Samuel Schulhof
   In announcing the appointment of Wilson
as director of the Office of Mobile Source Air
Pollution Control, Mrs  Gorsuch said that
Wilson "has demonstrated  outstanding
leadership while serving  in  the enforcement
and compliance areas."
   Wilson, a career employee, joined EPA
when the agency was  established in 1970.
He has primarily served  in  the enforcement
program dealing with stationary air pollution
and toxic substance enforcement program.
   In his new post, Wilson will be responsible
for such air pollution control activities  in
Washington and Ann Arbor, Mich., as emis-
sions testing, automobile certification and
standards development for vehicle emissions.
   Wilson, who holds an  electrical engineer-
ing degree from Lafayette  College and an
M.B.A. from the University of Pennsylvania's
Wharton School, has been  the recipient of
numerous awards, including the Designation
of Distinguished Executive and the EPA Gold
and Silver medals.
  Commenting on Schulhoff's appointment
as a deputy assistant administrator for ad-
ministration. Dr. John Morton, EPA's
assistant administrator for administration
said:
  "Sam brings a wealth of experience to this
position from the business world and govern-
ment.   He will be of immeasurable
assistance in instituting the sound
management practices we need to
make use of limited  resources in  a more ef-
fective  and  efficient  way."
   Prior to joining ACTION in April 1 981, he
was president and chief operating officer of
Wander Sales Inc. in Pittsburgh,  Pa., a chain
of 10 retail stores, and its subsidiaries, a ser-
vice company and a credit corporation. From
1 975 to 1 978 he was a principal in the Hay
Group,  one  of the world's largest human
resource consulting organizations.
   Schulhof has been  active  in both the
private  and  public sector. His responsibilities
at ACTION  included overseeing press  and
public awareness programs and the
recruiting of volunteers for the Peace Corps
and the agency's domestic volunteer
programs.
   Schulhof served in  both the Nixon  and
Ford administrations  from 1973  to  1975.
playing a key role in recruting and staffing for
non-career  positions  in government. From
 1971  to 1973, he was assistant to the
Secretary of the Department of  Health,
Education and Welfare.
   Schulhof, 39,  is listed in  Who's Who in
American Business and Finance, and is  a
member of the Young  President's Organiza-
tion, an international organization made up of
corporate presidents.
   He is a  1964 graduate of C.  W. Post
College, Long Island University, with a
degree in business administration.Schulhof  is
a native of Pittsburgh, Pa. His wife. Katrina,  is
currently the  assistant  to the chancellor of
the  University of Pittsburgh. D
                                                                                                                 EPA JOURNAL

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Private   Cleanup   Sought
A    special task force has been established
    to speed up  removal of pollutants by
private parties at hazardous  waste sites un-
der the Superfund law,  EPA Administrator
Anne M. Gorsuch has announced.
   Responsible private parties will be given
the opportunity to cooperate in managing
and financing cleanup, Mrs.  Gorsuch said.
However,  she  emphasized, where coopera-
tion  is not forthcoming, she will  use the
agency's legal authority to compel corrective
action and recover costs of  the corrective
government  action.
   The task force, operating under the direc-
tion of EPA Enforcement Counsel William A.
Sullivan Jr.,  is charged with  contacting per-
sons  and firms which may  have  owned.
operated or  used the disposal  sites  or had
wastes taken to the sites for disposai.
   EPA's best estimate,  based  on investiga-
tions  so far,  is that more than  1,500 parties
may be contacted. The  task force will give
these parties a deadline for responding to the
private cleanup request.
  "This should permit the agency to identify
sites at which the prospects for a private
cleanup appear to be good, and those for
which Superfund  money will be required."
Mrs. Gorsuch said.
  Recovered costs from private parties wi)l
be used to supplement government funds or
to reimburse government funds already
spent.
  Sullivan said that  the agency hopes to
notify those parties identified so far by
regional investigations within 90 days.
Similar notice will be given to new parties
identified  through future investigations.
  "Responses will be tracked by computer
so that follow-up action can be triggered if
progress toward cleanup action is  not
forthcoming," he  said.
  He said the initial focus of the task force's
efforts will be 1 1 5 sites placed on an interim
priority list last October. Of these 1 15 sites,
20 were already the object of litigation when
listed. A total of 122 individuals of firms at
16 sites on the priority list have also been
given notice that the site is a candidate for
government cleanup under the Superfund
program.  Sullivan also noted that notices
have been issued to another 20 parties at five
sites not  on the list of  115.
  Sullivan said that some companies have
taken it upon themselves to  contact EPA
about cleanup activities. "I believe there may
be many  more which have simply  been
waiting to be contacted and told how the
agency wants to proceed," he noted.
  Sullivan stated, however, that the Super-
fund law  creates "powerful incentives" for
firms to cooperate. Refusal to abide by
government cleanup orders could cost them
triple damages, he said.
  Since May, Mrs. Gorsuch  has approved
more than $30 million  for cleanup  at 30
sites. In addition, she has authorized more
than S18 million in emergency work at 64
sites. D
 Superfund  Sites—Enforcement  Status
   Responsible parties being notified when possible

   Responsible parties notified


• Enforcement action Initiated
JANUARY/FEBRUARY 1982
                                                                            29

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Waste-to-
Steam  Plant
Slated   for
New  York
    Awaste-to-steam plant is being planned
    for the old Brooklyn Navy Yard site to
help New York City dispose of its massive
garbage loads, New York Mayor Edward I
Koch announced recently.
  "New York City is running out of landfill
space  for its  garbage,"  Mayor Koch ex-
plained. "That is why we are committed to
building waste-to-energy plants in all five
boroughs."
  The  mayor said that  UOP. Inc.. based in
Des Plaines, III., has been selected to design,
build, and operate the proposed waste-to-
steam plant in Brooklyn. UOP is the
American license  holder for the Martin in-
cineration system, which is used in 92 other
plants in operation or under construction
around the world.
  Richard T. Dewling,  EPA's Region 2
Acting  Administrator, said that "EPA has
conducted extensive research and investiga-
tions into waste-to-energy systems operating
in Europe, Asia, and the  United States. These
investigations have shown that the
technology that New York City has proposed
is a well-established, technically reliable, en-
vironmentally acceptable and economical
solution to the problem of disposal of solid
waste/'
  Norman Steisel, New York Commissioner
of Sanitation, said that  before the city  can
sign a contract with UOP "we have to
demonstrate  that  the proposed facility  will
meet all applicable environmental regula-
tions.
  "Preparation of the Environmental Impact
Statement is underway and with the
technical  design that UOP will give us, we
can now  complete our  analysis,"
  The  draft Environmental Impact State-
ment is expected  to be  completed in March.
  Commissioner Steisel estimated that con-
struction would require  39 months from the
date of approval by the New York Board of
Estimate.  He said that if  all goes according to
schedule, full-scale operations could begin in
1986
  The  Department of Sanitation estimates
design and construction costs to be $226
million. The city estimates its  revenues will
be $40 million annually. The steam
generated will be  sold to Con Edison for use
in the utility's Manhattan steam  loop  UOP
will receive a share of the revenues from the
sale of steam and of recovered materials
such  as ferrous metals and aluminum.
   Financing for the construction of this pro-
ject will be private equity, a combination  of
tax exempt industrial revenue bonds expec-
ted to be  issued by  the New York City In-
dustrial Development Agency and a  New
York  State Environmental Quality  Bond Act
grant.
   The proposed facility would handle 3,000
tons  per day of barge-delivered waste. No
trucks will be used to deliver or remove
waste. Commissioner Steisel said  it  would
create between 200 and 250 construction
jobs and employ about 95 operating person-
nel.
   Mayor Koch stressed that the proposed
Navy Yard plant is the first of a number  of
resource recovery facilities slated  for
development throughout the five boroughs.
The State  Power Authority and the Depart-
ment of Sanitation have announced their in-
tention to cooperate in the development of a
similar facility in the  Bronx with Hunts Point
as the proposed site.
   Mayor Koch said,  "The question of siting
is one of the most difficult issues involved  in
implementing  the city's resource recovery
plans. Neighborhoods tend to view resource
recovery facilities negatively, but a rational
city-wide policy demands that resource
recovery plants be built on the sites that are
best suited to such facilities, provided that
proper safeguards can be assured. We will
not build a plant that is not a good neighbor "
D
 30
                                                                                                      EPA JOURNAL

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                                          This is a cutaway of a typical HOP refuse burning plant designed to produce energy from
                                          steam. However,  barges rather than trucks will take garbage to the one proposed for the
                                          old Brooklyn Navy Yard site in  New  York.
JANUARY/FEBRUARY 1982
31

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Paperwork  Cut
for   Car  Imports

 Individuals importing cars will find that EPA
 has helped simplify the procedures for
bringing foreign cars into this country.
   Previously persons importing cars have
been obliged to complete a  form declaring
that the autos  conform  with U.S. emission
standards as required by the Clean Air Act.
   At EPA's request, the U.S. Customs Ser-
vice has suspended this declaration require-
ment, since the vast majority of imported
cars conform to federal  emission standards.
   Customs inspectors are able to distinguish
cars built to meet U.S. standards from those
that do not by  locating EPA  emission labels
in  the vehicles, the agency said.
   The change  will eliminate some 1 13.000
declaration  forms filed annually, therefore
reducing the reporting  procedures required
for importing cars into this country.
   Importers of autos that do not meet US
standards will still have to file declaration
forms. There are  approximately  3,000 such
cars imported annually.
   Persons importing the cars that do not
meet emission or safety standards must post
a cash bond equal to the value of the car or
have the car bonded through a bonding com-
pany. Once the cars are modified to meet the
standards or tested to show compliance, the
bond is returned  to the individual.
   However, to ease the burdens on many
first-time  importers of cars in this category,
who often claim a lack of knowledge of the
importation requirements, the agency will not
require modification or testing if the vehicle is
five years old or older. The agency said that
since there are fewer than 700 cars five years
or older imported annually, air quality will not
Imported from England, this Rolls-Royce convertible, one of the world's most elegant
cars, is being driven on a road overlooking the Golden Gate  bridge in San Francisco.
be adversely affected by these automobiles.
This waiver will apply if the individual has not
imported a non-complying car since 1970.
   Commercial importers of cars will not be
allowed, however, to take  advantage of this
change.
  These procedural changes are being un-
dertaken on an interim basis. The agency is
considering whether to adopt the changes
permanently as part of a revision of its vehi-
cle imports program.  D
32
                                                                  EPA JOURNAL

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              -
                           •

Amateur hockey p/ayers chase the puck on a  Back Cover: Snow geese explode into the air
frozen pond near Laurel. Md.                when alarmed at Pea Is/and Wildlife Refuge
                                           in North Carolina.  Thousands of these geese.
                                           ducks and other water birds winter at this
                                           refuge which is located within the Cape Hat-
                                           teras National Seashore.

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