United States
Environmental Protection
Agency •
Office of
Public Affairs (A-107)
Washington. DC. 20460
Volume 8
Number 2
March-April 1982
&EPA JOURNAL
-------
:: -TION
1. j. .. ',- 6 H Y •
A Water
Review
In this issue of EPA Journal,
we report on several different
aspects of water use and abuse
by people.
EPA Administrator Anne M.
Gorsuch reviews drinking
water problems and the
legislation designed to help
cure these ills. Deputy Ad-
ministrator John W. Hernandez
outlines the administration's
views on aspects of the Clean
Water Act.
Eric A. Eidsness, EPA's new
Assistant Administrator for
Water, explains the approach
he is taking to improving the
agency's water programs. An
article on the Charles River in
Boston outlines progress made
by a citizen-state-federal team
in curbing the environmental
maladies of this ancient
waterway.
An article on the lake trout
in the Great Lakes explains
how these fish could help serve
as indicators of the water
quality for these lakes. Another
article gives a report on how
hot water discharges from a
municipal power plant helped
Canada geese survive a bitterly
cold winter.
Other stories on water and
pollution include one about a
nationally recognized waste
treatment pilot plant in Mis-
souri and a survey on the effec-
tiveness of some drinking
water filters.
In an interview, Dr. Earnest
F. Gloyna, chairman of EPA's
Science Advisory Board, gives
his views about environmental
problems and opportunities.
This issue also reports on a
number of new appointments
which have been made at EPA.
D
An aerial view of a spectacular
section of the California coast
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington, D.C. 20460
Volume 8
Number 2
March-April 1982
&EPA JOURNAL
Anne McGill Gorsuch, Administrator
Byron Nelson III, Director, Office of Public Affairs
Charles D. Pierce, Editor
Truman Temple, Associate Editor
Articles
protect
the Nation's land air and water systems
(,ile of national environ-
is to for-
•i TIS which lead
in human
' nuiture Me
The EPA Journal is published bi-monthly
by the U S Environmental Protection
,if funds for punting this
.;rov:nl by the
the Office of Management
M;d by authors
lie noT* necessarily reflect EPA policy
-dons and inquiries should be ad
i i)7] Waterside
Mall 401 M Si . SW . Washington. DC
20460 No permission necessary To
tents except copyrighted
Drinking Water Problems
and Solutions 2
EPA Administrator Anne M.
Gorsuch analyzes the Safe
Drinking Water Act
Clean Water Act Improve-
ments 5
Proposed amendments seek
mid-course corrections
Water for Living
Assistant Administrator
Eidsness outlines his ap-
proach to the water program
Better Days for the Charles
River 13
A report from Boston on
progress made by a citizen-
State-Federal team
o
Science for the Future 15
An interview with a noted
scientist, Dr. Earnest F
Gloyna
Lake Trout: Bellwether for
the Great Lakes 18
Trout could help indicate the
future quality of water in the
lakes
Superfund Contingency
Plan Announced to help
Clean up Sites 22
Administrator Gorsuch
proposes new guidelines for
hazardous wastes
Appointments and
Awards 24
New woman assistant ad-
ministrator among those
named
Missouri Treatment Plant
Recognized 27
Waste treatment facility
honored in national contest
Conference on Fire Ants 28
Ways of curbing the fire ant
will be examined at a June
meeting
Giant Geese Survive
Another Winter 30
Hot water discharges from
power plant help geese
through frigid winter
Some Drinking Water
Filters Found Effective 32
New tests done for EPA show
filters can remove chemicals
O
Front Cover. Little girls feeding ducks on
Washington Lake near Seattle. Wash
Photo Credits Steve Delaney. John
Goerg. Charles River Watershed Associa-
tion. Margaret Faulkner, Harvard Un-
iversity, U S Fish and Wildlife Service.
USDA. Phoin, Ted Rozumafski
Design Credits Robert Flanagan and Ron
Farrah
EPA. JOURNAL
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Drinking Water Problems
and Solutions
By Anne M. Gorsuch, EPA Administrator
The Safe Drinking Water Act. whose
authorization expires September 30. has
been an important part of the body of en-
vironmental protection laws since its enact-
ment eight years ago. The Act authorized
EPA to set uniform drinking water standards
nationwide, requires drinking water systems
to notify their customers of failures to meet
standards and monitoring requirements, and
also deals with controls on underground in-
jection wells to protect drinking water
aquifers.
Like other laws, of course, the Act may
need to be revised from time to time to
reflect changing conditions. EPA is now
weighing a number of proposed changes
following public comment and meetings held
earlier this year.
Among those questions:
How should EPA and States use exemp-
tions and variances for small drinking water
systems that have trouble meeting stan-
dards?
Should the pubiic be notified of every
standard violation, no matter how minor, af-
fecting drinking water supplies?
Should, the standards be separated into
categories, i.e., those applying to all systems.
those applied flexibly by the States, and
those of a non-regulatory nature such as
"health advisories?"
In considering these proposals and the
broader question of how EPA can best meet
its responsibilities to taxpayers, it should be
kept in mind that several objectives of Presi-
dent Reagan's administration are highly rele-
vant to the Agency. These include regulatory
reform, protection of the environment
without impeding economic progress, a
closer partnership with the States, and better
controls on Federal spending.
Regulatory reform does not mean
deregulation, the wholesale abandonment of
rules. Rather it describes the simplifying of
the regulatory process, lifting the burden of
paperwork and attendant delays and costs to
industry and the public.
We already have made substantial
progress in this area. An example was the
settlement last July of lawsuits dealing with
EPA JOURNAL
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protection of underground drinking water
supplies from contamination by fluids from
injection wells. Briefly, the history of this case
is that in 1980 EPA issued rules requiring
States to develop programs to protect these
water supplies from such contamination.
Subsequently a number of companies and
the State of Texas sued EPA over the regula-
tions. The settlement we reached last year
provided protection of valuable underground
drinking water sources without imposing ex-
pensive, unnecessary requirements on in-
dustry. The agreement is expected to save
the affected companies $65 million to S75
million over five years, and does away with
certain repetitive testing requirements
related to injection wells, reduces the number
and frequency of reports required, and
clarifies regulatory language. EPA proposed
some of the settlement's terms as amend-
ments to State Underground Injection Con-
trol programs, and after receiving public com-
ment, these became effective March 5 this
year.
The drinking water program is an out-
standing example of what we mean by a
close partnership with the States. Forty nine
out of 57 States and jurisdictions such as
U.S. territories and possessions have primacy
now in this area, where they have adopted
EPA standards or imposed more stringent
ones of their own, and are responsible for en-
forcement. (EPA directly runs the other eight
but is encouraging them to assume primacy
where possible.)
In fact, the increasing role of State govern-
ments in the drinking water program has
made it possible in part to scale down our
1 983 proposed budget by $14.1 million and
44 personnel to a total of $69.8 million and
456 employees. The economies also reflect
simplified administrative requirements,
reduced regulatory demands, and a focus on
the most serious State problems.
Congress clearly envisioned that the
States should play a major part in the control
and regulation of drinking water supplies
when the law was enacted, as indeed
legislators intended in other environmental
legislation now on the books. Historically,
State and local governments have undergone
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 years not in
Washington, D.C. but at the State and local
level. Since 1960, the number of employees
in the latter categories has more than
doubled, from six million to 13 million. They
now outnumber their Federal counterparts by
more than four to one. It only makes sense
that the nation should take advantage of this
increase in staffing and competence and-give
more responsibility and control to the local
level, where officials often have a better
grasp of problems and conditions.
At the same time EPA will continue to
provide support of our regulatory office's
promulgation of revised drinking water stan-
dards. This includes studies on the oc-
currence and health effects of contaminants
in drinking water, including underground
sources of such supplies. Our research also
will continue to support the development of
treatment technology that is both cost-
effective and technically feasible.
As a measure of the changing nature of
environmental problems, EPA now is con-
sidering various ways of controlling a group
of chemicals known as volatile synthetic
organic chemicals (VOCs) frequently found in
drinking water supplies, especially ground
water. The chemicals get into such supplies
as a result of improper industrial discharges.
by leaking from underground storage tanks,
or by seepage from landfill disposal sites.
Efforts to curb these toxins in our drinking
water have been uncoordinated in the past.
We are considering a number of ways to con-
trol these compounds. Whichever course we
choose, it will come only after a thorough
scientific and public review of the issues.
EPA is considering several options to br-
ing some national order to this situation.
These include continuing to give guidance to
the states on controlling these compounds;
requiring regular monitoring for the com-
pounds, again relying on the states for im-
plementing controls; or issuing EPA-
enforceable standards for some or all of the
compounds. Whatever course we choose, it
will come only after a thorough scientific and
public review of the issues.
EPA currently is considering controls on
up to 14 volatile organics, but other, similar
compounds also may be of concern to the
agency.
Traces of volatile organics have been
found in about 10 percent of drinking water
wells studied by various groups, including
EPA. Rivers, lakes and other surface waters
subject to industrial discharges also are likely
to contain the compounds but usually at
levels considerably lower than those found in
contaminated ground water. Slow-moving
ground water lacks the ability of a flowing,
surface waterway to flush itself of pollutants.
Levels of contaminants like trichlorethy-
lene and tetrachloroethylene in ground water
can be up to 1 or more parts per million.
Typical readings in contaminated surface
water usually are much less than five parts
per billion.
Water treatment methods effective in con-
trolling volatile organics include aeration and
filtering through granular activated carbon.
The choice of a cleanup method would be left
up to the water utilities,
Preliminary EPA estimates indicate that
the cost of controlling these organics in
larger drinking water systems (10,000 or
greater population) could add roughly $1 or
$2 to customers' monthly water bills. The
monthly increase to users of smaller systems
with this type of contamination could range
from $5 to $14.
EPA plans to hold technical workshops in
several parts of the country on the best ap-
proach to curbing these organics in drinking
water.
After reviewing comments at these
gatherings and any other written comments
received, the agency will propose a course of
action sometime later this year. In the mean-
time, EPA will continue to give guidance to
the states on acceptable levels of these con-
taminants in emergency situations, d
MARCH/APRIL 1982
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Clean Water Act
Improvements
Excerpts from testimony by
Deputy Administrator John W. Hernandez
before the House Subcommittee
on Water Resources
EPA and the Administration are fully commit-
ted to the Act's fundamental objective of
restoring and maintaining the chemical.
physical, and biological integrity of the Na-
tion's waters. We believe that the Clean
Water Act is basically a sound statute. Most
of the problems associated with the Nation's
clean water program we believe have
resulted from the way in which the Act has
been implemented, not from the Act itself,
I would like to focus on some of those
problems, primarily relating to effluent limita-
tions, pretreatment, and the national permit
system.
We face a major responsibility in at-
tempting to continue the many positive and
constructive initiatives begun under the Act
while correcting those aspects that have not
worked out as intended. The challenge before
us is to draft reasonable requirements while
avoiding the extremes of over regulation or
under regulation. This requires a willingness
to examine new approaches and to re-ex-
arnine existing and old ones.
industrial Effluent Guidelines
The Clean Water Act requires compliance
with technology based industrial effluent
guidelines in two phases. Industries were re-
quired to comply with the first level of control
known as Best Practicable Control
Technology (BPT) by 1977. BPT standards
were met by approximately 81% of the affec-
ted industrial categories by the July 1. 1 977,
deadline, and a full 94% of industries have
now met the appropriate requirements.
A second level of control. Best Available
Technology Economically Achievable (BAT),
is required for "toxic" pollutants by 1984.
Control of "non conventional" pollutants
must be achieved no later than 1987. Best
Conventional Technology (BCT) for the
traditional "conventional" pollutants must be
met by industry in 1984
Progress toward the second level of
BAT/BCT controls has been less successful.
We do not believe that industry can meet the
1984 compliance deadlines, chiefly because
the Agency has encountered substantial dif-
ficulties and time delays in promulgating
these guidelines. The reasons for these
delays are discussed at greater length in my
statement for the record. Briefly stated here
these delays developed because no com-
prehensive information for toxic materials ex-
isted requiring development of an extremely
large data-collection and analysis program
On the basis of our experience with the
BPT level of control, we have found that well-
operated biological treatment systems can
effectively control many of the toxic materials
of concern. Because BPT effluent guidelines
for controlling conventional pollutants
provide treatment that is also effective in
controlling toxic organics and heavy metals.
in some cases further control measures may
be unnecessary.
The substantial progress already achieved
through BPT was not achieved without in-
curring major costs however Industry may
ultimately spend as much as $18 billion in
complying with BPT requirements.
While we believe the basic content of the
Act is sound, some revisions deserve serious
consideration. First, we agree with the
generally held opinion that the Agency's BAT
promulgation schedule cannot provide for an
orderly industrial implementation program by
the July 1 1984. compliance deadline. We
believe, therefore, that an extension of this
deadline is warranted to provide industry
with adequate lead time in which to comply
with additional treatment requirements.
Second, we recognize that we cannot
tailor broad-based regulations to cover all
site-specific environmental conditions.
Therefore consideration should be given to a
waiver of BAT/BCT requirements where BPT
standards are left in place and where dis-
chargers can demonstrate that their current
level of treatment provides for meeting water
quality standards, and fully provides for
meeting water quality standards, and fully
provides the necessary environmental
protection.
Some have suggested that we eliminate
BAT altogether in favor of a water quality
control program with a BPT floor. Although
we believe that water quality based control
programs can be used down the road, we do
not think that we can rely strictly on the
water quality based control approach in the
immediate future.
MARCH/APRIL 1982
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Pretreatment
The Clean Water Act requires EPA to es-
tablish pretreatment standards for indirect in-
dustrial dischargers to keep their waste flows
from interfering with the operation of publicly
owned treatment works (POTWs), to prevent
the pass through of inadequately treated
wastes to receiving waters, and to avoid the
contamination of municipal sludges.
EPA has adopted two kinds of pretreat-
ment standards, general and categorical The
general pretreatment regulations were
promulgated June 28, 1978 and established
the administrative and procedural framework
for the National Pretreatment Program.
Some categorical standards have been
promulgated by EPA and others are being
developed. The most far-reaching of these,
tin: (ili:clto|)l;itin(| Mnndcim. was amended in
January 1981 and is currently in force for
parts of the industry.
However, the program has been the target
of extensive criticism. Cities contend that
variations in discharge standards for the
same pollutant between industrial categories
is unjustified and administratively confusing.
They also argue that mandatory national
categorical standards do not give enough
flexibility to cities who already have exten-
sive and successful local programs. Industry
asserts that the removal credits provision of
the general standard is unworkable and
results in treatment for treatment's sake.
The Administration's review of the
program indicates many of these criticisms
are legitimate. We have already initiated
some remedial actions. To address others we
will be requesting that Congress make some
modifications in the Act. Our goal is to have
an environmentally sound, genuinely
workable, and cost effective program.
Basically, we believe that more flexibility is
needed in the Act, and that more control and
responsibility for pretreatment must be given
to local government.
To promote certainty and facilitate
municipal planning, the Agency is moving
ahead with development of its comprehen-
sive sludge policy. Taken together, these and
other actions should result in real progress
and avoid the extremes of over regulation
and under regulation.
Permits and Enforcement
The National Pollutant Discharge Elimination
System (NPDES) provides for the issuance
of permits to all direct point-source dis-
chargers. The Act provides for permit
issuance both by EPA or by State authorities
where EPA has approved a State's permit
issuance program. To date, there are 33
States with approved NPDES programs.
EPA and the States have issued 65,000
"First round" BPT permits. Many of these
permits were reissued, but only for two or
three year terms and have again expired
Progress has been made in municipal permit
issuance where 75% of the majors and 30%
of the minors have been issued. Also, over
EPA JOURNAL
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1 1.000 five-year industrial permits have
been reissued. Nonetheless, at present,
30.400 permits have expired and need to be
reissued, and over the next three years, the
remainder of the first round permits will ex-
pire.
Most of the expired permits remain in ef-
fect under provisions of the Administrative
Procedures Act which allows for automatic
extension pending reissuance, provided
timely and complete permit applications are
submitted. However, the combination of the
volume of permits that need to be reissued
plus the uncertainty involved in developing
BAT limits in the absence of promulgated
guidelines poses the largest implementation
problem for the NPDES permit program.
Effluent guidelines for all industry
categories will be promulgated in FY 1982
and 1983 and this will significantly reduce
the time required to develop permits for the
industries covered. In addition, EPA plans to
evaluate making greater use of general per-
mits, especially for minor facilities. This will
ailow permitting authorities to cover classes
of facilities in a single permitting action and
thereby conserve resources for major, com-
plex facilities that need individual permits
without loss of environmental protection.
Finally, we are revising the Consolidated
Permit Regulations to streamline our permit
issuance procedures. The major benefits will
be an increase in State flexibility in ad-
ministering permit programs, a reduction in
costs and reporting burdens for permittees
and the States' operating permit programs,
and an expedited permit process through
streamlined regulations and application
forms.
Beyond these regulatory and ad-
ministrative actions, we believe consideration
should be given to extending the life of an
NPDES permit from a maximum of 5 years to
a maximum of 10 years. This statutory
change would allow more efficient and effec-
tive use of current levels of permitting
resources and provide more certainty over
time for wastewater treatment requirements
determined by permit limitations.
In addition, the concept of partial State
NPDES permit program approval is being
considered. Partial approval may provide
further incentive for certain States to assume
elements of the NPDES program.
With respect to enforcement of permits.
EPA's activities prior to FY 1981 focused
primarily on industrial compliance and enfor-
cement. As a result of these efforts and in-
dustry's response, there is presently a 90 per-
cent major industrial compliance rate. Begin-
ning in FY 1 981 increased emphasis has also
been placed on municipal compliance and
enforcement, and there is now a 76 percent
compliance rate for major facilities. We are
also considering significant changes to our
discharge inspection techniques that we
believe will make our water enforcement ef-
fort more effective and efficient.
Other Issues
In view of the complexity of the Act, and the
history of its implementation, even lengthy
testimony will not cover all of the issues.
Management of municipal sludge is of
course one area that will be receiving in-
creasing attention as the problems of sludge
treatment and disposal grow every day with
the implementation of more sophisticated
control measures.
A further issue of special concern involves
a recent court decision designating dams as
point sources under the Clean Water Act. As
we do not believe that most dams and reser-
voirs pose a significant threat to water
quality, and in view of the over two million
dams in the United States, thousands of
which might require permits under this deci-
sion, we are looking at possible legislative
amendments to address this situation.
Development of State Water Quality stan-
dards and the application of national EPA
water quality criteria to local conditions will
also be examined closely.
Th'e section 404 dredge and fill program is
another area that will receive close scrutiny
in the months ahead. Presently, the program
is under review by an Administration
regulatory reform task force. This group will
assess the problems in the program and
provide recommendations at a later date.
Conclusion
In conclusion, we believe the Clean Water
Act can and will remain the principal effec-
tive means for achieving clean water across
the Nation. Cleaning up our streams and
rivers, our ponds and lakes, our harbors and
estuaries is indeed a sound, necessary and
practical national objective. Most of the
problems we have encountered can be
resolved efficiently and effectively through
the administrative and regulatory
mechanisms available under the Clean Water
Act However, greater flexibility in im-
plementing the Act will add significantly to
our effectiveness and will reduce the costs of
compliance. D
MARCH/APRIL 1982
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t
EPA JOURNAL
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Water for Living
An Interview with Frederic "Eric" A. Eidsness Jr.
EPA Assistant Administrator for Water
vJ What are your main goals
in your new post as Assistant
Administrator?
r\ I am firmly committed to the
goals of environmental protec-
tion and a strong economy.
These are goals I share with the
President and the Administrator.
While I will be working to help
achieve these overall goals
through regulatory reform, I have
two management goals of my
own which are essential to
meeting the broader goals.
One is to open up our
regulatory development process
from the beginning and to work
cooperatively with state and
local governments and the
regulated community in the
process. The second goal is to
get control of resources in the
Office of Water and to better
manage those resources from
the top down. From what I've
witnessed since I've been here
there is fertile ground for doing
that.
Li What approach do you plan
to take to achieve thesegoals?
A I hope that by setting clear
policy direction and by constant
dialogue with my top managers
and mid-level managers that I
can instill in them a perspective
of environmental protection that
reflects my local orientation I
hope to show the people in the
Office of Water that EPA in
Washington is not the center of
the universe. The center of our
attention should be that par-
ticular lake or stream out there
whose water quality must be im-
proved or protected. We need to
recognize that those who are
closest to those bodies of water
are just as concerned as we are
about the protection of the en-
vironment in general and water
quality in particular.
On my second goal of manag-
ing resources more effectively,
we have initiated a number of
new management policies. One
of these policies is the develop-
ment of annual work plans for
each of the administrative units
in the Office of Water. These
work plans will be developed and
used by the lower and mid-level
managers and not by the Assis-
tant Administrator for Water.
Soon after coming here last Sep-
tember. I became keenly aware
that EPA's management and
resource planning documents
have been designed for the prin-
cipal purpose of letting the
agency comptroller and the Con-
gress know where the money's
going. The old system did not
serve the purpose of managing
our resources to meet our com-
mitments. In the future, our work
pJans will be used to provide in-
formation for the manager to un-
derstand his commitments, how
his resources are to be used and
in what priority, what outputs are
expected and when.
Another initiative is the in-
stitution of a lead role concept.
As an example, we have various
branches and divisions within the
Office of Water doing the same,
if not similar, work with little or
no cross fertilization of ideas, ex-
periences, and approaches. As
an example, the lead role con-
cept applied to risk assessments
for human health would assign
the responsibility for develop-
ment of methodology and data
analysis to the Office of Drinking
Water. One of the benefits of this
concept is that when I have a
problem. I can call my office
directors in the room and ask just
one of them "What happened?
Why wasn't the job done right?"
This approach to fixing respon-
sibility will also reduce overlap.
duplication of effort and max-
imize the use of our resources.
(-1 What is the basic
philosophy that will guide you
in your new post?
AI don't believe that EPA is
wiser, more powerful or more
motivated in protecting the en-
vironment than anyone else. I
think that generally the average
citizen, small town, big city, in-
dustry, and State will do the right
thing if they understand what the
probfem is. I view as unfortunate
the attitude exhibited in the past
by certain EPA officials that
everybody is presumed guilty un
til proven innocent and that the
only organization that can define
and solve environmental
problems is EPA. This has
resulted in a reputation of
arrogance that is ill deserved by
most EPA employees and in
regulations that are overly com-
plicated with procedure and
MARCH/APRIL 1982
-------
which get in the way of state and
local initiatives. I guess that to
sum up my philosophy, I believe
that by opening up on internal
processes, working cooperatively
with others and simplifying our
regulations we will make greater
strides in protecting the
environment
What parts of the water
program in your view are in the
most urgent need of
redirection?
M Perhaps the greatest
challenge that faces both EPA
and the States is to bridge
the enormous guff between in-
dustrial and municipal pollution
control regulations and discharge
permits which translate these
regulations into reality for the in-
dividual municipalities and in-
dustry. We know that permits
have been written that do not
reflect good scientific and
economic analysis, or are based
on regulations that have not
been subjected to adequate peer
review and public debate. In
other instances no regulations
exist. Permit writers are put in
the most untenable position of
making fundamental public
policy, public finance or industry
investment decisions without
policy oversight, without peer
review, and without public
debate. So we're going to take
steps to try to identify the
specific problems and remedies
associated with this gap so that
the permit writers won't be de
facto rule makers.
What are your views on
regulatory reform?
A Reforming environmental
regulations is an absolutely es-
sential piece of the President's
overall national agenda. The Of-
fice of Water's basic approach
taken in the past was to write
into regulations all that the Acts
would allow. The result of this
approach has been a mountain of
rules, regulations and guidance
which attempt to identify every
possible situation that a State or
local government or member of
the regulated community might
find itself in and to prescribe a
remedy. The consequence of this
practice has been to overly com-
plicate and in many cases
obscure the basic intent of the
Acts. Now we're trying to go
back through these complicated
regulations to identify essential
requirements. At the same time
we're trying to reduce procedural
requirements so that we can get
regulations geared to results
rather than to following
procedures. However I want to
point out that the regulations we
are tackling have been built,
defined and redefined over the
past ten years by their applica-
tion and court suits. We are not
revising these regulations with a
meat cleaver but are carefully
going through them with surgical
tools to cut out the fat and leave
behind regulations which are
lean, clearly reflective of the
statutory requirements and
which demonstrate an attitude
that those who read them are at
least as intelligent and fair min-
ded as those who wrote them.
Most importantly, the regulations
revised under this Administration
will reflect a strong commitment
to environmental protection
which we believe will withstand
time.
Do you see a need to shore
up leadership and manage-
ment oversight in the Office of
Water?
, Yes. The Off ice of Water
publishes reams of so-called
guidance documents every year.
Frequently, one of these docu-
ments might say something to
the effect that, "it is the agency
policy that. . ." The effect of such
"policy" statements is twofold
on states, local governments,
and regulated community. (1)
They get mixed signals from dif-
ferent program offices. (2) By
declaring something is agency
policy in a rather casual manner
in a guidance document, it
becomes the agency policy even
though it is not set by the
leadership of the agency. In order
to solve this particular problem
we are tightening control over
guidance documents and we
have a policy on "policy".
Although that usually gets a lot
of laughs when I mention it, it's a
pretty serious matter. This policy
on policy in effect states that
there are only three kinds of
policy for EPA Water. One is
regulations, the second is a self-
standing policy document signed
by the Administrator of EPA, and
the third is a self-standing policy
document signed by the Assis-
tant Administrator for Water.
Everything else is guidance.
Guidance, furthermore, should be
construed as EPA's best judg-
ment on one cost effective way
of solving a problem that reflects
the best science and experience
we and the States have had over
the years.
What are your views on the
subject of sludge disposal?
t'\ Sludge management is going
to be one of the great challenges
of the 1980's. The volume of
sludge has increased steadily in
the last decade and is expected
to increase dramatically in the
future. Simultaneously, suitable
disposal sites are diminishing
nationwide and in some areas of
the country are becoming un-
available. Nobody wants to have
a sludge management or solid
waste disposal facility in his back
yard.
The problem comes home to
EPA because most of the sludge
is produced by environmental
control equipment that is re-
quired by EPA under the Clean
Water Act, the Clean Air Act, the
Safe Drinking Water Act, and the
Resource, Conservation, and
Recovery Act.
Municipalities are among
those who are pressed hardest to
determine suitable methods for
disposing or reusing sludge. For
example, sewage sludge is a
byproduct of municipal waste
treatment. The chemical proper-
ties of this sludge vary ac-
cording to the type and amount
of industrial waste which is dis-
charged into municipal treatment
facilities. Not knowing what their
regulatory choices are,
municipalities are finding it in-
creasingly difficult to plan for the
cost effective disposal or reuse of
sludge. EPA has a responsibility
under the Clean Water Act to
prepare sludge management
guidance. This has become a ma-
jor priority within the Agency for
the current year. I am confident
that the exercise will not only
provide municipalities with a
wide range of choices for dis-
posal and reuse of sludge as it
relates to the characteristics of
that sludge but will also allow
them to make choices based
upon an understanding of the en-
vironmental and health risks that
may be associated with various
10
EPA JOURNAL
-------
options, i would like munici-
palities to share the burden of
making such determinations with
the regulatory agencies. I believe
they will do so and do so respon-
sibly as they recognize better
than we at the Federal level that
the lower the risk the higher the
cost.
What are your views con-
cerning EPA's responsibilities
to protect the oceans from
pollution?
I must confess that I have a
strong affinity for the oceans
having spent my youthful days
diving on Florida's coral reefs
and in later years serving in the
Navy. I've always viewed the
oceans as the last great
frontier—as a source of
sustenance for a large part of the
world's population, as a reservoir
of ecological wealth and enjoy-
ment and as a medium which
ties "nations together. The oceans
are also vast, complex, and
mysterious to us and it is not
clear what the fate and effects of
pollutants in the oceans are.
Notwithstanding the impor-
tance of the oceans as a resource
and the uncertainty regarding
their ability to assimilate wastes,
I think the oceans should be con-
sidered as a viable option for
waste management, at least for
an interim period. Recent scien-
tific research supports this posi-
tion.
The Agency has begun the
task of revising the regulations
which control the dumping of
sludge into the ocean. In a
general sense I would like to see
two key features in the regula-
tions. One, that a very rigid en-
vironmental test be established
for determination of those
sludges which are suitable for
ocean disposal without causing
unreasonable degradation. Two,
that the burden of proof is placed
on the polluter to show that
there will not be unreasonable
degradation of the marine en-
vironment and that all feasible
land-based alternatives are less
suitable from an environmental
point of view. I think the role of
economics in such determina-
tions will become more impor-
tant where the environmental
risks of a land-based alternative
versus an ocean disposal alter-
native are equivalent.
What does a regulatory
agency do when it cannot
predict the fate and effects of
pollutants in the ocean or any
other medium?
The environment does not
lend itself to precise predic-
tability. This is true whether one
is considering waste disposal in
the air, on land, or in the ocean.
The answer to your question lies
in science and in process. We get
as much factual data and infor-
mation as we can; we apply the
most sophisticated analytical
procedures and analysis that we
have available to us; and we
discuss and debate the facts and
hypotheses in open public
forums. Once having made a
decision we rely upon monitoring
and further research to assure
that adequate protection is being
provided. Finally, we review the
situation periodically and adjust
decisions according to the
evidence using a similar process.
Our various planning and per-
mitting tools serve this need to
review past decisions.
I believe that the EPA can do
a better job in coordinating with
other Federal, state, and local
agencies in conducting research,
and in developing analytical
procedures and monitoring
programs which will reduce the
uncertainty with respect to the
fate and effects of pollutants in
our waters,
I like to think of pollutants as
resources waiting to be
rediscovered. As we plan for the
management of our sludge,
whether it is for ocean dumping
or some land disposal method,
we should give equal if not
greater attention to resource
recovery and reuse. I am op-
timistic that as resources
become more scarce, as cost ef-
fective technologies become
available, and as the public
becomes more demanding of
reutilization of resources, that
the focus of the future will be
more on the side of resource
recovery than it will be on waste
disposal. I am optimistic about
the future in this regard.
Are any new steps needed
at the Federal level to assure
that Americans have a safe
supply of drinking water?
A major objective of this ad-
ministration generally, is to
delegate fully the authority and
responsibility for the administra-
tion of various environmental
programs to the States where the
environmental laws permit. The
Safe Drinking Water Act en-
visioned a primary role and
responsibility for States in the
regulation of public water sup-
plies and controlling injection of
contaminants into ground water
aquifers. In keeping with this
overall policy we will be working
very hard to fully delegate these
responsibilities to state agencies.
With respect to public water
supply systems, I believe that the
Agency should develop with
states strategies which are more
effective at anticipating and deal-
ing with the special problems
faced by the 62,000 rural com-
munity systems. In the past,
EPA's attention and resources
have been focused primarily on
the 2.000 or so major water sup-
ply systems. These urban
systems provide potable water
for the vast majority of the
American people. For the most
part they are professionally
managed and they are and will
continue to be subjected to
microscopic oversight by state
regulatory agencies and their
customers.
Groundwater is another area
where the Agency should focus
more of its attention and
resources. Old timers have said
of the hardness of the water that
comes from the well at my
Colorado homestead "you can
scarce get a bite to drink " My
personal concern with well water
is more a matter of aesthetics
and convenience, but as the
Assistant Administrator for
Water, I cannot help but be con-
cerned with the existing and
potential future contamination of
ground water from a public
health point of view. Statistically,
greater than half of our popula-
tion receives its potable water
from the ground.
Groundwater. once conta-
minated, takes years, if not de-
cades or centuries, to purify.
Groundwater protection is
fundamentally a land use issue.
State and local governments by
far have the greater powers to
make determinations concerning
siting of facilities, designation of
underground sources of water
supply and the like. States also
have extraordinary powers under
their various health laws to pre-
vent and control ground water
pollution. I believe that the EPA
should work with the States in
the continued development of
state ground water protection
strategies. Our principal focus
should be on assuring that our
regulations governing water
supply systems, underground in-
jection, dump sites and the like
are well coordinated and that
our enforcement posture supports
state strategies concerning
ground water protection.
Are water quality stan-
dards still a useful tool in
protecting and enhancing our
water ways?
A Water quality standards are
an important and logical next
step to ensuring adequate
protection of beneficial uses of
water nationwide. The Clean
Water Act envisioned that
technology based standards
would be set as a floor below
which municipal and industrial
dischargers could not go. The
Agency is committed to getting
into effect as soon as possible
regulations governing the control
of toxic substances from in-
dustrial dischargers. Even with
these regulations in effect, and
technologies in place, the ques-
tion remains: is there adequate
protection of beneficial uses and
water quality? The answer will lie
in the strength of a state's water
quality standards program.
There is a major effort un-
derway currently to upgrade the
quality of EPA's guidance con-
cerning the states' adoption and
implementation of water quality
standards.
The standards regulations
which EPA will be proposing
stress the designation of
beneficial uses and numeric
criteria sufficient to protect those
uses on a site specific base. The
regulations will also propose a
policy of protection of uses
currently attained with no
allowance for degradation of
those uses.
I am sure some States will be
concerned with the resource im-
plications of revising their stan-
dards along these lines, but I am
convinced that the regulated
community will be more than
MARCH/APRIL 1982
11
-------
willing to bear their fair share of
the burden of developing
monitoring data, analysis, and in-
formation necessary to revise
standards as it is in their self in-
terest to do so. No elected of-
ficial or industry principal wants
to make an investment m pollu-
tion control unless it is well foun-
ded in scientific bases and has
public support To help avoid
some of the confusion and mis-
conception that has grown over
the years regarding water quality
standards, the EPA is trying to
focus attention on five basic
questions which we believe cap-
ture the essence of the standards
setting process. These questions
are: What is the use to be
protected and how is it charac-
terized m physical, chemical and
biological terms and in terms of
social and economic value? To
what extent does pollution im-
pair or support the use relative to
other factors? What level of point
source pollution contro! is
necessary to restore and protect
the use? What level of nonpoint
source pollution control is feasi-
ble that will restore and protect
the use? Is it worth it?
This last question should be
taken in light of a policy of an-
tidegradation but it is an impor
tant question to ask when con-
sidering the costs and benefits of
pollution control technology that
may be required to meet water
quality standards in the future.
In your judgment are
America's waterways getting
cleaner, holding their own, or
deteriorating?
The only honest answer to
that question is that I don't
know Surely its a mixed bag and
I would prefer not to bore your
readers with the same worn out
horror stories and success stories
that have been printed and
reprinted so many times over.
The fact of the matter is, environ-
mental trends are subtle except
in the rare instances of overt
signs of pollution such as fish
kills. I don't think the answer lies
necessarily in collecting more in-
formation. EPA's water programs
currently place approximately
3.9 million work hours of burden
on the regulated community and
state and local governments to
collect information. I think the
answer to the question lies in
how the data is used and who
uses it. I see three ways in which
we can do a better job of deter-
mining environmental results or
trends in environmental quality.
First, assert the need for states to
take a stronger role in assessing
improvements in water quality.
This will be a clear reversal of
past trends where EPA has
always assumed that it was the
appropriate institution to make
such determinations. Secondly,
the focus of analyzing environ-
mental trends and results should
be on specific media on a
geographic basis. States should
review their long term monitor-
ing data and develop qualitative
assessments which address the
physical, chemical and biological
characteristics of the aquatic en-
vironment, the uses made of it
and any pollution events or oc-
currences which have been ob-
served.
The third approach, which is
less satisfactory from a scientific
point of view, is to use surrogate
measures. For example, knowing
that we have reduced the dis-
charge measured in pounds of
pollutants in a particular water
body over a particular period of
time, is an indicator of the effec-
tiveness of pollution control re-
quirements, whereas counting
the number of violations of
NPDES discharge permits does
not relate at all to the environ-
mental consequences of pollu-
tant loadings.
What are your views on
local government and water
quality management planning?
I have a very strong orienta-
tion toward local government as
a result of my past experience as
a health department official, local
planner and a consultant to local
government and industry. Let me
answer that question by first be-
ing very frank about local govern-
ment involvement in water
quality planning under section
208 of the Clean Water Act and
one reason why this Administra-
tion has not shown support for
continual Federal funding of
areawide agencies to carry out
planning. Lack of implementation
of water quality management
plans in my view is a direct result
of the inability of the planning
agency to adequately define the
problem. This inability was due
either to the agency's un-
questioned acceptance of a
problem statement made by a
state or federal agency or from
having taken a one dimensional
approach at defining the
problem.
On the flip side of the coin
there have been numerous local
success stories
In vtew of the lack of
familiarity with the Clean Water
Act at the start of planning and
the lack of focus in EPA's
guidance as to what should be
planned for, local governments
have made substantial gains.
I think we should look ahead
at water quality management
planning in terms of a new
phase: one in which the plan-
ning under Federal grants is
highly focused on specific
streams or lakes which are con-
sidered to be the most valuable
and those that are most
threatened from pollution. Local
governments have an oppor-
tunity for additional funding un-
der the Clean Water Act to carry
out planning provided they can
make the case to the state pollu-
tion control agency that they are
better equipped to conduct the
necessary studies.
On a more philosophical level,
section 208 of the Clean Water
Act provides a very important
handle for local governments to
join together on a voluntary basis
to develop the institutional and
technical capacity to deal eyeball
to eyeball with the regulatory
agencies. This local role is essen-
tial as we move into an era of
reassessing our water quality
goals in the context of revisions
to state water quality standards.
I am confident that many local
planning organizations will con-
tinue to play a major role without
Federal assistance.
r\
Do you see a change in
emphasis on management of
the construction grants
program for publicly owned
treatment works as a result of
the 1981 amendments?
Yes. A new construction
grants bill contained two very
significant messages from my
point of view as a former local
government official. First, that
Federal grant funds are to be
targeted to restoring and main-
taining water quality and
designated beneficial uses of
water. Secondly, that local
governments are to assume a
greater responsibility for assuring
that they have the requisite
financial and management
capability to construct, operate
and maintain waste treatment
facilities.
Many of the horror stories that
you have heard of regarding the
high cost of wastewater service I
believe are attributable to a lack
of attention given to the details
of how a community is going to
implement its capital improve-
ments program from the financial
management point of view. This
in turn is an outgrowth of the
large federal grant share and
over-corn plica ted. regulations.
The construction grants
regulations reflecting the new
amendments are being revised
and shortened to reflect more
clearly the statutory require-
ments set forth in the bill. One
new emphasis that will be placed
in these regulations will be the
requirement that the grantee
demonstrate its ability to finance
and manage the construction,
operation and maintenance of
treatment facilities funded under
this program.
I believe that this is not only a
principle of good local
government—to plan in advance
of a major capital investment—
but also necessary to assure that
the Federal investment in such
facilities is protected. D
EPA JOURNAL
-------
River Basin as seen from Cnmf-
Better Days
for the
Charles River
"It is f> fact that the Charles River serves
its people in many ways a drop to
drink. ;i fish to fry. n teach to row.
Beyond all of these, though, it brings
; ;/ hn.iuty and refreshment find
vf)ft/fi to our /ives. If for no other reason, it
is worth caring for."
The progress in improving the water quality
in the historic Charles River which mean-
ders for 80 miles from its source in rural
eastern Massachusetts to its mouth at
Boston Harbor is a striking example of
cooperation between local citizens and the
State and Federal governments.
A key role in forging this partnership was
played by the Charles River Watershed
Association, a citizen's group dedicated to
the river's protection and improvement. The
association also has been active in pushing
for action to correct environmental ills.
As a result of these cooperative actions,
Rita Barron, association executive director,
reports;
All significant sources of untreated
sewage discharges into the Charles River
have been eliminated.
Treatment of industrial discharges into the
river is required by National Pollutant Dis-
charge Elimination System permits
Operation of municipal landfills on the
banks of the Charles which once spilled
pollution into the river has ended.
The Charles River association has noted
that while "in some areas the water is
seriously degraded anct land use ugly . .
much beauty does exist and more than the
skeptics will acknowledge. The treasure may
be tarnished, but it is no less a treasure."
Commenting on the Charles River im-
provement efforts, Lester A. Sutton, EPA
Region 1 Administrator, said:
"The Charles River is one of our most im-
portant and historic waterways. We have
placed a high priority on its restoration
because of its unique location as a major
recreation resource. The Charles is a major
attraction of the Boston metropolitan area in
all seasons and deserves the significant ef-
forts that local, state and federal govern-
ments, as well as the Charles River
Watershed Association, have invested in
restoring and preserving it."
A major factor in the improvement of the
quality of river water in the Boston Harbor
area was the installation of compressor-
operated air diffusers on the basin bottom in
1 978 which help mix the fresh and salt layers
in the river.
Salt water seeps through locks and dams
into the Charles River Basin starting in the
spring. Before the diffusers were put in, the
salt layer covered the entire bottom of the
basin by the end of August.
Because of its greater density, salt water
remained at the bottom of the river, below
the fresh water flowing continuously into the
river from upstream areas. As a result, the
Charles River Basin was stratified with
horizontal layers of fresh water at the surface
and salt water at the bottom.
While the fresh water layer contained an
ample supply of dissolved oxygen, the bot-
tom layer was a repository for decomposing
MARCH/APRIL 1982
13
-------
•
organic material which consumed oxygen.
The decomposition without oxygen produced
hydrogen sulfide. a compound which when
released as a gas smells like rotten eggs.
Rising air bubbles from the diffusers on
llu; bottom of the river now act as pumps,
raising water from the bottom layer to the
surface for natural reoxygenation. while
churning and mixing both layers. The bubbles
also add oxygen to the water
Now. on pleasant days, canoes, sail boats
and power craft can be seen on the river.
Rowing competitions are frequently held on
the Charles River. Many universities, private
secondary schools, and boating clubs have
racing shells. The annual Head-of-the-
Charles Regatta attracts hundreds of racers
who compete over a three-mile course in
shells of various sizes.
The wide variety of habitats along the
Charles include brush, shrub, swamps.
hardwood groves, and open fields. These at-
tract songbirds, hawks, owls, ducks, geese.
warblers and ospreys, some of them full-time
residents and others migrants. An early
morning canoe trip in May can be a bird
watcher's delight. The diverse variety of
plants is enjoyed by naturalists and others.
White-tailed deer and muskrats are often
seen in the upper and middle reaches of the
river.
Fishermen can catch trout in the upper
portions of the Charles, perch, pickerel and
bass in the middle stretch, and carp, suckers,
and pumpkinseeds in the Charles River Basin.
Other major developments other than
those described earlier which have helped to
improve the conditions of the river include:
• New sewage treatment plants have been
built for several towns, and grant funds are
supporting Milford's current expansion and
upgrading to advance treatment in that
critical reach of the upper Charles.
• Two chlorination/detention centers were
built with federal assistance to handle con-
taminated storm water and sewage over-
flows in the lower Charles Basin.
• The 208 watershed management study
has had the active cooperation of the Charles
River Watershed Association. In fact, the
regional planning agency subcontracted with
the association to conduct public participa-
tion programs around the state to provide the
public with accurate information about the
project.
• The Land and Water Conservation Fund,
which is partially supported by the Depart-
ment of Interior, helps localities buy local
recreation land by reimbursing them for part
of the cost. This program has helped provide
the incentive to local communities to buy
public lands The Charles River Watershed
Association has participated actively in this
project. It received a grant to prepare a
detailed greenway plan for a major segment
of the Charles River Corridor, and this project
has now been completed. The association
encourages communities to buy river front
lands and emphasizes the importance of
shoreline protection and intelligent land use.
"The Charles River Watershed Association
has achieved many fine results, but its efforts
could not have succeeded without the
cooperation and active assistance of the Divi-
sion of Water Pollution Control of the Com-
monwealth of Massachusetts." according to
the association's executive director, Rita
Barron.
A publication issued by the Charles River
Watershed association asks the question:
"What's ahead for the people's river?"
The answer given by the association
"Much depends on the river's people. In
every city and town in the watershed, deci-
sions are being made that determine the
quality of the watershed environment.
Dramatic issues meet the public eye readily
enough, but few land use choices and few of-
ficial attitudes fail to be reflected in the well-
being of the Charles. Perhaps no better op-
portunity exists to help the Charles than be-
ing part of those local decisions." D
EPA JOURNAL
-------
Science
for the Future
An Interview with
Dr. Earnest F. Gloyna
Chairman,
EPA Science Advisory Board
EPA Administrator Anne
M. Gorsuch is insisting on bet-
ter scientific review to improve
the quality of the Agency's
regulatory decisions. What role
can the Science Advisory
Board play in improving EPA's
scientific work?
We live in a technologically
oriented society. Therefore, it is
imperative that the EPA
decision-making process in-
cludes a serious scientific review
procedure. Regulatory controls
must be based upon proven
scientific concepts, adaptable
technology and achievable goals.
This administration has
recently established a new
process for improving the scien-
tific adequacy of agency
regulatory and standard setting
actions. Numerous examples ex-
ist in which the scientific basis of
the agency's decisions has been
challenged by individuals or
groups who have charged that
either the scientific evidence did
not justify a particular standard
level or that the process of
agency review did not ade-
quately address public concerns
over the quality of the data used
in standard setting.
Administrator Gorsuch has
noted that the consequences of
such challenges are that the
agency's credibility has suffered
a serious erosion and the public
is far less inclined to regard
agency action as balanced and
objective.
To help remedy this problem
the Science Advisory Board has
been given a significant role in
reviewing scientific data sup-
porting key regulatory actions
being developed by EPA.
Drawing on your ex-
perience as a college dean and
your extensive work as a
researcher and engineer, how
do you think the Agency can
receive the best results from
research dollars invested?
The level of scientific and
technological input that can be
brought to bear in a decision-
making process ultimately de-
pends upon the research accom-
plishments within a given area.
The responsibilities of the En-
vironmental Protection Agency
are unique in that not only must
there be a scientific basis for
pollution control applications,
but new methodologies must be
developed for the future. Conse-
quently, research is of utmost
importance.
For research to be useful
within the decision-making
process of the EPA, it is logical
that the research be directed to
resolving the longer-range objec-
tives of the agency, A large
potential pool of available
researchers exists within the
national laboratories, academic
community and industrial
research complexes. For most ef-
fective utilization of these com-
bined talents, it appears that
there should be a judicious deci-
sion by government to use the
best of all available human
resources and nurture these
pools of expertise. Certainly, if
academic research is abandoned,
the seed com for future research
competence will disappear
Do you see any conflicts
between EPA's sponsorship of
research and its respon-
sibilities as a regulatory
agency?
As EPA's role as a
regulatory agency becomes more
defined, the need for additional
scientific input and tech-
nological innovation will become
more pronounced. Regulations
concerning environmental ques-
MARCH/APRIL 1982
15
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V -
\
'. -
-------
tions must have a sound scien-
tific basis. Regulations that im-
pact upon the future cannot be
clearly developed nor understood
without an ongoing research
component and readily un-
derstood technological im-
plementation program.
\Ji How can the quality of
undergraduate and graduate
school engineering students
and faculties, particularly those
working on environmental
issues, be maintained and im-
proved?
f\ A former Committee, of
the National Research Council of
the National Academy of
Sciences which I chaired, found
that there were four reasons for
special concern with environ-
mental manpower. These are
• time schedules and specific
goals that are imposed by en-
vironmental legislation;
• specific directions in environ-
mental legislation which call for
federal study of the appropriate
labor markets and stimulation of
manpower development in cer-
tain occupations;
• high levels and patterns of ex-
penditures that are anticipated in
achieving environmental goals;
and
• the fact that environmental
pollution control programs are
highly reliant on the public
sector.
The Committee
concluded that a large-scale
shortage of pollution control
manpower was not apparent nor
was a shortage likely to develop
in the near future. However,
shortages will occur in selected
and highly specialized environ-
mental engineering and science
areas. The true environmental
manpower problem will not oc-
cur because of an inadequate
number of bodies but because
the educational level of people
available to work effectively just
will not be up to the task.
Let there be no mistake about
the fact that the flow of top-level
graduate students into environ-
mental programs has declined
because the competition for
undergraduate engineers by em-
ployers continues to withdraw
some of the most talented from
graduate studies. The
professional leadership, research
and the teaching pools are at a
critical level.
A major newspaper
commented;
"It is beginning to be seen in
official Washington that the
United States has absent-
mindedly permitted decay to
seep into the system for training
the "engineers" who are
indispensable to an ambitious,
high-technology problem-laden
society.
(_i What is the relationship
between scientifically ade-
quate regulations and cost-
effective regulations?
f\ Scientific adequacy,
technical feasibility and cost ef-
fectiveness are terms that really
should convey the same ultimate
meaning in environmental pollu-
tion control. However, some peo-
ple sometimes forget that there
are judgmental factors that must
enter the decision-making
process, and even such terms as
scientific adequacy may convey
some grey areas of
understanding.
V-i What is your view of
EPA's peer review process?
r\ The Executive Committee of
the Science Advisory Board
reviewed the Administration's
peer review process when it was
in draft form. The board believes
this process represents a reason-
able compromise between con-
cerns over the scientific quality
of EPA contracts, publications,
and informational materials and
the need for the dissemination
of data among interested pro-
fessionals and the general public.
What issues will the
Science Advisory Board review
in 19827
f\ High level radioactive waste
disposal standards, national am-
bient standards for sulphur diox-
ide and particulates, national
emission standards for hazar-
dous air pollutants, health
assessment for organic solvents,
exposure assessment guidelines,
research outlook, effluent
guidelines for organic chemicals,
critical assessment document for
acidic deposition, criteria for
sludge disposal, and maximum
contaminant level for organics in
drinking water, D
MARCH/APRIL 1982
17
-------
-
,
Lake Trout:
A Bellwether
for the
Great Lakes
•Hlllt
, /-
f *
•V ~ . • ' f
.
- V
-'
'
:
18
EPA JOURNAL
-------
IV] illions of young lake trout are again being
slocked in the Great Lakes this spring as
part of a long-range effort to restore this
native species to a self-sustaining fishery of
great commercial and recreational value
The stocking of these fish is being done by
the U.S. Fish and Wildlife Service in coopera-
tion with State and Canadian conservation
agencies as part of an experimental process
which could have extraordinary conse-
quences.
While many factors could be involved in
the fate of these young fish, their future will.
to some degree, provide a significant in-
dicator of the quality of water in the Great
Lakes.
A recent U.S Fish and Wildlife Service
report noted that the lake trout species "is
becoming widely respected and accepted as
a symbol of ecoystem well-being—at once a
bellwether of improvement, a 'miner's
canary' to warn of new threats, and an in-
dicator of conditions generally."
The population of the lake trout which
swam in the Great Lakes was once in the
millions. However, this resource crashed in
the late 1940s and early 1950s after it had
supported a highly profitable commercial
fishery industry for almost a century.
The factors which caused the collapse of
this fishery, according to the Fish and Wildlife
Service, were:
• Overfishing, greatly aggravated by the de-
mand for more food during World War II.
• Heavy predation by the parasite sea
lamprey.
• Deteriorating water quality in the Great
Lakes.
In order to deal with these problems the
United States and Canada formed the Great
Lakes Fishery Commission in 1956 which.
with funds from both governments, un-
derwrites control of the sea lamprey, coor-
dinates fishery research and management,
•nartment of Environmental ;
Ontario as pan of ,i stockir\<
and promotes rehabilitation of damaged fish
resources like the lake trout
The commission has brought the sea lam-
prey under control primarily with the use of
chemical lampricrdes and is now stimulating
the rehabilitation of various species of fish
such as the lake trout.
A serious problem still being fought by
EPA and the Great Lakes states is toxics
pollution The state departments of natural
resources or state public health departments
for Michigan, Indiana, Wisconsin, Illinois, and
New York have issued health advisories for
people who eat Great Lakes fish. Each state
has specific recommendations as to species
to be concerned with (all include salmon and
lake trout) and size categories (the larger fish
contain higher contaminant levels). Each of
these states ts concerned about PCB pollu-
tion and the New York advisory for Lake On-
tario also warns against eating any lake trout
over 21 inches in length because of a mirex
contamination problem. While the U.S. Food
and Drug Administration has the legal
authority to regulate interstate sale and dis-
tribution of commercial fish, it is the states
which issue advisories for sports fishermen.
MARCH/APRIL 1982
19
-------
•>i/ii
,7 Us ft.
pip feecitng on
was evidence of the plentiful
supply of large lake trout fishermen used to
Great Lakes.
Right Younci lake trout being placed in Lake
(Vlichi
The lake trout, which spawn in the lakes
rather than traveling up a tributary stream
like many other fish, thrive best in the three
upper Great Lakes which have deeper and
colder water than the shallower and warmer
Lake Erie and Lake Ontario. These silvery fish
are avidly sought by spoft fishermen and the
average catch weighs between three and six
pounds
While efforts to improve the lake trout
populations have been underway for many
years in the Great Lakes, it was not until last
fall that the U.S. Fish and Wildlife Service
found conditions sufficiently encouraging to
warrant reaffirming the concept of restoring
the lake trout population as a self-sustaining
resource
The Service stated that "the feasibility of a
restored, self-sustaining lake trout resource
in the Great Lakes was viewed with some
skepticism when lake trout stocking began in
earnest 20 years ago. More than a little
doubt prevailed then about the ability of
stocked trout, and even more so of their
possible offspring, to endure a degraded en-
vironment.
"In recent years, however, suppression of
the lamprey and improvement in habitat
quality have considerably brightened
prospects for lake trout restoration.
Biological research and environmental
monitoring have also convinced many that
trout restoration deserves renewed attention
as a valid concept, and that the goal of a self-
sustaining resource in a rejuvenated environ-
ment is not only achievable, but economically
desirable as well . . . the lake trout, apart from
its well-established economic value, is
perhaps the species most capable of fully
tapping the productive potential of the Great
Lakes because of its superior adaptability to
available habitat.
"Recognizing the great potential of the
lake trout as a food source and of the lakes to
again produce it in volume for the benefit of
all, the Fish and Wildlife Service accordingly
reaffirms its belief that restoration of this
native species to self-sustainability in the
Great Lakes remains a vital, attainable goal
with considerable social and economic
merit,"
At the same time, the Service emphasized
that unrelenting efforts must be continued to
curb the population of the parastic sea lam-
prey and to restore and enhance the quality
of the waters of the Great Lakes.
"Evolving Service participation with the
U.S. Environmental Protection Agency (EPA)
and other agencies in water quality sur-
veillance . . . must therefore continue to be
supported if not accelerated.
"For without a basis by which to gauge
water quality and the effectiveness of pollu-
tion abatement programs now underway, the
goal of reestablishing stocks of environmen-
tally sensitive fishes could be pursued unwit-
tingly as a futile, waste exercise."
Since the late 1950s, approximately 100
million young trout, generally 10- to 15-
month-old fish, have been planted in the
20
EPA JOURNAL
-------
Great Lakes, primarily in the three upper
lakes. Superior, Michigan, and Huron. Most
of these fish have been provided by Federal
fish hatcheries.
The Fish and Wildlife Service has said that
"there is reasonable expectation that, given
the chance, these fish would survive to
maturity and accumulate in numbers even-
tually sufficient to sustain the species' own
regeneration throughout most of the lakes."
Yet, the Service notes, the goal of self-
sustainability is elusive.
"Several factors, most notably environ-
mental and genetic, are properly viewed with
suspicion as impeding reestabtishment. Of
progeny that may be produced in the wild by
the sparse brookstocks so far created, few if
any seem able to survive their first year.
"No factor would seem to be as per-
vasively suspect, however, as that of the
planted trout's widespread, rapid, excessive.
and premature withdrawal by fishing. Of the
planted trout that otherwise prosper, dis-
tressingly few survive for long the obviously
too-high fishing pressure to which they are
subjected in many areas during their pre-
adult years and early adulthood "
Since lake trout do not generally begin to
breed until they are seven years old, the high
mortality rate in their youth prevents the
development of adequate broodstocks.
The Service has pointed to "premature
and excessive" catches of the stocked trout
as "the major obstacle to the species' poten-
tial reestablishment as a self-sustaining
resource."
While Federal hatcheries can continue to
produce millions of young lake trout, the Fish
and Wildlife Service has noted that once the
fish are planted in the lakes, they become the
trust responsibility of the State or other
jurisdiction into whose waters they are
placed.
Since the Federal agency has little
regulatory authority, it has urged the States
and other agencies with jurisdiction to at-
tempt to curb the over-fishing which it con-
tends has played the major role in frustrating
attainment of the goal of developing trout
stocks which can regenerate the species.
In addition to tighter fishing controls, the
fate of the lake trout will also depend heavily
on continued stocking programs, progress in
sea lamprey control, and improvement in cur-
bing the discharge of toxic substances and
other pollutants into the Great Lakes.
Because of the magnitude and enormous
cost of coping with these problems, the com-
plexity of jurisdictional controls, and the long
time required for these fish to breed, the Fish
and Wildlife Service does not expect any
swift successes.
Even under the best of circumstances, the
Fish and Wildlife Service believes it will be
another 1 0 to 15 years before lake trout will
be breeding again in large numbers in many
areas of the Great Lakes. D
MARCH/APRIL 1982
21
-------
The Super-fund
Contingency
Plan To Help
Clean Up Sites
nitecJor. • . -,k l't>n:t! on Hi:t/n!,t!t>ty
•'A Administrator Anne M Gorsuch tit pi e niinattncriii/ the n.it/on.
Irtn.
EPA is proposing, in the Superfund National
Contingency Plan, guidelines for coordinating
federal and state responses to hazardous
substance spills and for cleaning up hazar-
dous waste sites. Administrator Anne M.
Gorsuch recently announced the proposed
national guidelines for cleaning up wastes.
In December 1980, Congress passed the
Comprehensive Environmental Response,
Compensation, and Liability Act authorizing
federal action in cleaning up older, aban-
doned dumps. (Four years earlier, the
Resource Conservation and Recovery Act
had already authorized federal regulation of
still-operating dumps.) The 1980 law—
known as Superfund because of its unwieldy
official title—required EPA to develop a new
National Contingency Plan.
The Superfund law itself outlines federal
responsibilities forresponse to spills of hazar-
dous substances and for cleanup of aban-
doned hazardous waste sites. It sets up a $1.6
billion trust fund over five years, consisting of
taxes on the manufacture of certain
chemicals and general revenues appropriated
by Congress.
"Safe and effective toxic waste manage-
ment is one of the primary environmental
goals of this Administration," said Mrs. Gor-
such. "This plan reflects our commitment.
"The NCP, which outlines government
response to the difficult problem of hazar-
dous waste cleanup, exemplifies regulatory
reform in the Reagan Administration. Its
provisions are concise, its language non-
technical, and its requirements flexible," said
Mrs. Gorsuch.
Christopher DeMuth. Executive Director,
Presidential Task Force on Regulatory Relief,
said, "In the 14 months since President
Reagan was inaugurated, this Administration
EPA JOURNAL
-------
has been striving—successfully, I believe—
to make government more responsive and ef-
ficient. Our main means of accomplishing
this is through regulatory reform Today's
proposed NCR proves that federal regulations
need not be cumbersome or costly."
The new plan authorizes response to
waste sites and oil spills on air, land, and
water. This includes responding to explosions
or fires, massive releases of toxic chemicals
into streams or rivers, and spills caused by
train derailments.
tn conjunction with the plan, EPA is com-
piling a national inventory of state-selected
hazardous waste sites. The agency will select
400 priority sites for possible action. The first
1 1 5 of these sites were announced last Oc-
tober.
The proposed National Contingency Plan
sets criteria for determining where, when,
and how Superfund monies will be spent. It
describes two categories of cleanup: im-
mediate removal in response to acute
emergencies, and more limited, planned
removal in response to less serious threats It
also sets up an eight-step process for deter-
mining the extent of cleanup, beginning with
a determination of whether or not a site is on
EPA's inventory and thus eligible for remedial
action. Sites are "scoped" to see what action
is needed. Then alternatives based on en-
vironmental, economic, and engineering
criteria are developed.
The final remedy will be the most cost-
effective that protects public health, welfare,
and the environment.
The Plan allows for extensive state and
local participation in cleanup activities by giv-
ing States the necessary guidance and
authority to manage their own site cleanups.
EPA is planning to use both cooperative
agreements and contracts to allow the states
to assume as much responsibility for field
response as they are capatle of undertaking
and are willing to accept. EPA estimates that
in 1983 some $34 million will be transferred
to the states for field activities.
The National Contingency Plan recognizes
that cleanup needs vary significantly from
site to site. "On one site, drums may be
removed, the surface scaled, graded and
revegetated. In another, a system may be
built for trapping and treating leachate so
that pollutants do not escape the site. We
have learned that every feasible alternative
must be examined to see if it can be tailored
to the unique problems of the particular site.
The remedy will depend on many variables
such as the substances present, hydro-
geology, soil conditions, climate, size and
proximity of population," said Mrs. Gorsuch.
"Superfund was intended by Congress to
be a non-regulatory, non-standard setting
law—because the Congress realized, as we
all realize, that cleanup of these sites is very
new. There are no easy answers to the issues
confronting us. In some cases, we may be
asking for answers which the state of the art
or science are not yet ready to provide. We
must ensure that the state of the art and
science are given the maximum amount of
flexibility in which to give us these answers.
We can find the answers by initiating an
aggressive cleanup program—and by learn-
ing and refining as we gain experience. In this
regard, I am confident that the National Con-
tingency Plan can be used to usher in a new
era of environmental technology and applica-
tion
"The Reagan Administration believes that
a policy of straightforward regulation and
careful resource management, combined
with an unshakable environmental commit-
ment, is our mandate from the American
people. And I believe that this policy will
result in a swift cleanup of existing environ-
mental hazards. Waste site cleanup will be
our environmental legacy to future
generations." D
MARCH/APRIL 1982
23
-------
Appointments
and Awards
A Presidential appointment for an EPA
assistant administrator post and selections
for three key EPA jobs were announced
recently.
President Reagan appointed Rita M.
Lavelle to be assistant administrator for solid
waste and emergency response. She will
direct the hazardous waste control program
and the $1.6 billion "Superfund" program
which provides for emergency cleanup of
chemical spills and hazardous waste dumps.
Named by EPA Administrator Anne M.
Gorsuch as Associate Administrator for Legal
Counsel and Enforcement was Robert M.
Perry, who had been serving as the agency's
general counsel.
Appointed by EPA Administrator Anne M.
Gorsuch as Regional Administrator for EPA's
Region 2 Office in New York City was Jac-
queline E. Schafer, a former professional staff
member of the U.S. Senate Committee on
Environment and Public Works and former
legislative assistant to U.S. Sen. James L.
Buckley of New York
Named by Administrator Gorsuch as
director of the Office of Intergovernmental
Liaison was Brad Gates, a former member of
the New Mexico Legislature.
Selected by Administrator Gorsuch as
EPA's new chief administrative law judge
was Edward B. Finch, who has been acting in
this capacity since November, 1981, and has
been an administrative law judge with the
agency since September, 1975.
Meanwhile, Heather Mackey Ford, a civil
engineer with EPA's Region 4 Office in
Atlanta, has been recognized by the National
Society of Professional Engineers as one of
the federal government's top engineers.
Commenting on the appointment of
Lavelle, Administrator Gorsuch said:
"Rita Lavelle brings over 12 years of
professional experience in state government
and private industry to the agency," said EPA
Administrator Gorsuch. "She has
demonstrated expertise in getting results, as
shown by her record with the executive
branch of government in California, with a
mid-sized chemical firm and with a large
diversified international corporation." Lavelle
will direct all EPA's work on hazardous and
other solid wastes.
Since 1 978, Lavelle has initiated, directed
and managed several programs for Aerojet-
General Corporation subsidiaries, including
ones for divisions which manufacture
chemicals and industrial and chemical inter-
mediates, nuclear and chemical waste treat-
ment systems, liquid rocket engines for the
aerospace industry, and high-speed marine
propulsion systems for defense applications.
Lavelle, 34, earned her bachelor's degree
in biology and mathematics, with a minor in
chemistry, from College of Holy Names,
Oakland. Calif,, in 1969 and continued
graduate work at the University of California
at Berkeley in physiological chemistry and
stoichiometry (the study of biological cell
shapes and functions). She earned a master's
degree cum laude in business administration
from Pepperdine University in Los Angeles in
1980.
From 1969 to 1976, she was the con-
sumer affairs department information officer
with the State of California, state director of
consumer education, and publications assis-
tant in the office of then-Governor Reagan.
She was director of marketing for Inter-
continental and Continental Chemical Cor-
poration in Sacramento. Calif., from 1976 to
1978. Lavelle's responsibilities included
development of corporate guidelines to com-
ply with the Resource Conservation and
Recovery Act. At EPA. one of her tasks will
be to administer nationwide compliance with
this law by both business and government
sectors.
,'4
EPA JOURNAL
-------
Schafer
Gates
When Lavelle joined Aerojet-General Cor-
poration, she became director of communica-
tions for one subsidiary, Cordova Chemical
Co, until 1979, moving to a similar com-
munications position for the largest sub-
sidiary, Aeroiet Liquid Rocket Co.. in 1979
She is a member of several professional
organizations, including the American
Chemical Society, the American Institute of
Chemical Engineers and the California Coun-
cil for Environmental and Economic Balance,
as well as numerous aerospace and defense
organizations. In 1981, she was named one
of the outstanding women in aerospace by
Aerospace Magazine
Commenting on the appointment of Perry
as Associate Administrator for Legal Counsel
and Enforcement, Mrs. Gorsuch said "the
position of Associate Administrator for Legal
and Enforcement Counsel was created to
bring together all of the legal functions within
the agency. A better job can be done with
fewer resources by integrating our legal shop
and eliminating duplication. Bob Perry is a
lawyer's lawyer, who will ensure that top
legal and policy |udgment is applied to strong
enforcement and legal programs."
Perry, 46, served as a trial attorney in the
Land and Natural Resources Division of the
Department of Justice from 1964 to 1969
Between 1961 and 1964, he was on active
duty in the Office of the Judge Advocate
General, U.S. Army Perry currently serves
that office as lieutenant colonel in the U S.
Army Reserves
From 1 969 to 1981, Perry worked as trial
counsel for Exxon Corp
Perry received his master of law degree
from Georgetown Univeristy in 1961. He
earned his J D. degree and bachelor of arts in
history in 1 959 from St. Mary's University in
San Antonio, Texas, his hometown.
Explaining the selection of Schafer, as the
new regional administrator in New York, Ad-
ministrator Gorsuch said:
"Jackee Schafer has a thorough un-
derstanding of the complex laws under which
EPA operates. She also has a broad
knowledge of the special problems of the
New York and New Jersey area, thanks to
her experience with Senator Buckley, EPA is
fortunate to have such a highly qualified per-
son to take over one of the agency's most
challenging regional assignments."
Mrs. Gorsuch also paid tribute to Richard
T. Dewling. who has served as acting
regional administrator in Region 2 for the
past year, "The solid work of professionals
like Dick Dewling and his staff makes it
possible for Jackee Schafer to step into a
region that is already functioning in an effec-
tive, efficient and responsible manner I know
Jackee will be able to count on continuing
support from the regional staff."
Before Senator Buckley's election in
1970. Schafer worked on his campaign and
handled all environmental issues for him
From 1967 to 1970. she was an analyst in
the banking studies department and a
research assistant in the research depart-
ment of the Federal Reserve Bank of New
York.
In recent years, Schafer has worked exten-
sively in Republican organizations. She
researched environment and energy issues
for the Reagan/Bush campaign, prepared a
transition report on the Council on Environ
mental Quality for the Executive Office of the
President, and served on the Arlington
County, Va., Republican Committee
A native of Greenport, N.Y., Schafer holds
an A.B in Economics from Middlebury
College, Middlebury, Vt.
Gates, the new director of the Office of
Intergovernmental Liaison, recently resigned
while serving his fourth term in the New
Mexico Legislature to take the EPA position
He was vice chairman of the House Judiciary
Committee and a member of the Education
Committee. Active in national legislative
matters, he is on the board of directors of the
American Legislative Exchange Council and a
member of the Law and Justice Committee
of the National Conference of State
Legislatures.
In addition to his legislative duties. Gates
has been an Albuquerque lawyer since 1 975
He served as staff attorney for Ranchers Ex-
ploration and Development Corp . a New
Mexico mining company, from June 1979 to
December 1980
After leaving Ranchers. Gates was a
Reagan delegate to the Republican National
Convention and a member of the Reagan-
Bush Campaign staff In the past year, Gates
has spent extensive tune in Washington on
various projects, including serving as a con-
sultant to the EPA Administrator
"Brad brings a unique combination of
legal, natural resources, and inter-
governmental experience to EPA's top
management team." said Administrator Gor-
such in announcing the appointment "EPA is
fortunate to have such a highly qualified per-
son as its intergovernmental liaison at a time
when state and local governments will be
assuming greater responsibility for ad-
ministering federal environmental programs,"
As Director of Intergovernmental Liaison,
Gates will supervise a staff of 10 and coor-
dinate all state and local government liaison
by the agency and with the White House
There are also 50 intergovernmental liaison
employees working in the 10 EPA regional
offices.
In addition to his duties as IGL Director,
Gates will serve as a counsel to the Ad-
ministrator.
MARCH/APRIL 1982
25
-------
Gates received his bachelor's degree in
business management from New Mexico
State University in Las Cruces, N.M.. in
1972 After attending the University of
Arkansas law school in Fayetteville, Ark . he
received his law degree from the University
of New Mexico in Albuquerque in 1975.
As chief adminstrative law judge. Finch
will head a team of law judges who are
responsible for conducting administrative
hearings requested by parties against whom
the agency has brought legal action under
environmental laws. The judges, like all ad-
ministrative law judges for federal agencies,
work independently of the agency to ensure
the fair and impartial adjudication of cases
over which they preside.
Finch, who has had extensive experience
in handling cases for the agency, most
recently presided over the hearings on the
cancellation of the herbicide 2,4,5-T. The
hearings have been recessed and the parties
are currently in settlement negotiations.
Finch also presided over the first case
brought under the Clean Air Act to enforce
emission standards. His decision resulted in
the 1978 recall by an automaker of approx-
imately 250,000 automobiles for the repair
of faulty emission devices.
From 1973 to 1975, Finch was with the
Consumer Product Safety Commission. He
began as director of compliance and was an
attorney-advisor to the chairman of the Com-
mission prior to joining EPA.
Finch was employed as an attorney with
the Federal Trade Commission in 1956 and
was assistant director of its Bureau of Con-
sumer Protection when he left in 1973.
In announcing Finch's appointment, Mrs.
Gorsuch also paid tribute to Herbert L.
Perlman who passed away in October 1981,
while serving his tenth year as the agency's
chief administrative law judge.
"The agency certainly feels the loss of
such a dedicated professional as Herb
Perlman," Mrs. Gorsuch said. "His legacy of
sound environmental decisionmakmg,
however, makes it possible for us to continue
in an effective and responsible manner. We
are indeed fortunate to have someone with
Ed Finch's experience to fill this void."
Finch served in the Navy from 1942 to
1 945 and graduated from Catholic University
School of Law in 1954. He was admitted to
the D.C. Bar in 1955, Shortly thereafter, he
was admitted to the bars of both the U.S.
Court of Appeals for the District of Columbia
Circuit and the Supreme Court of the United
States
Ms. Ford, who won recognition as one of
the federal government's top engineers, has
worked in the hazardous waste program at
EPA's regional office in Atlanta, Ga., since
1979
She was responsible for the technical
review of the first hazardous waste treatment
and storage facility to receive a permit in the
southeastern states. She also is the EPA
regional liaison with the Department of
Transportation, providing technical
assistance on the shipment of hazardous
wastes. D
26
EPA JOURNAL
-------
•
tf-V-
'.*•-
M issouri
Treatment Plant
Wins
Recognition
Ann.ii wmv tit nationally recognis-, •: City. Mo.
The National Society of Professional
Engineers recently named a pilot waste
treatment plant near Kansas City, Mo., as
one of 1981's ten outstanding engineering
achievements in the United States.
EPA funded 85 percent of construction
costs for the demonstration plant in the Little
Blue Valley Sewer District after finding that
the design by Burns & McDonnell Engineer-
ing Co., Inc., was "innovative and alter-
native."
The benefits of the design come primarily
from its simplicity. The system is modular,
self-contained, operates independently and
has only three pieces of machinery with mov-
ing parts
"The system permits small communities
and industries to provide simply operated,
economical treatment facilities which exceed
oxidation ponds in effluent quality on sub-
stantially less land area," according to Burns
& McDonnell. "We see not only domestic ap-
plications but international markets for such
an effective and simply run process.
"It lets nature do the work machinery used
to do. Each module in the system combines
the three step process of conventional
biological wastewater treatment into one
basin. Much of the piping, pumps, tanks and
other equipment associated with conven-
tional treatment plants is eliminated. The
three moving parts in the Burns & McDonnell
design are a compressor, a mixer and a
sludge wasting pump."
The demonstration plant has been in
operation for over a year. The cleaned water
from the plant meets or exceeds all United
States federal and state government se-
condary effluent requirements, according to
Burns & McDonnell.
Data from the demonstration plant in-
dicates the design can reduce capital costs
for new wastewater treatment facilities by as
much as 60 percent from those of conven-
tional biological-treatment facilities and
lower operating costs by as much as 45 per-
cent.
The Little Blue Valley Sewer District plans
to build four ten million gallons per day
modules beginning in 1982. Total treatment
capacity will then be 40 million gallons a day,
enough to clean the water for the 358.000
residents of Jackson and Cass Counties, in
the State of Missouri
The des'gn also makes a municipality eligi-
ble for an 85 percent rather than the 75 per-
cent currently allowed for conventional
wastewater treatment systems
"As wastewater enters the oval-shaped
basin in the demonstration plant, air is injec-
ted into it," explained Cerwick. "Next, the
aerated wastewater flows around the oval
mixing with the microbiological culture in the
basin. As the liquid reaches the clarifier sec-
tion, the pressure of the incoming
wastewater pushes clear effluent water
toward the surface and into a system of
drainage pipes. Solids settle back into the
wastewater under the clarifier by gravity, and
microbiological organisms assimilate these
wastes, too."
"The key element is the design of the
intrachannel clarifier The clarifier, which
operates entirely without moving parts and
which Burns & McDonnell plans to patent, is
the system's heart."
By eliminating much of the equipment
used in conventional wastewater treatment,
the Burns & McDonnell design used only a
fifth to a half of the land area required for
other treatment systems.
The system also is nearly odor free
because the wastewater is continually
aerated and does not stagnate. Micro-
organisms which occur in nature "eat" the
wastes and eliminate the need for chemicals
to treat the sewage, the design company
reports
Because the Burns & McDonnell design is
iTKMiukii .i community oi industry with
seasonal changes in demand for wastewater
treatment could build a sufficient number of
basins to meet peak demand, but then run
only enough modules to meet current de-
mand.
"In the off-season, the modularity of the
system allows a resort community, for in-
stance, to shut down most of the system and
greatly cut its operating costs," said Burns &
McDonnell.
The simplicity of the system could also
make it cost-effective for airports, power
plants, military installations and industrial
facilities that are located miles away from the
nearest municipal sewer system.
The economical design and high effluent
water quality allow the user to process his
wastewater independently and reuse the
wastewater directly into some industrial
processes, an important factor in water
scarce regions. D
MARCH/APRIL 1982
27
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Conference
on Fire Ants
:r;to
'• ,*
. -..- • •»»>.
. »*#
"'
- --';.^,^
n heavily infested ureas such its thts field then; may bti is 50 fire ant tt)oun>.
tern
A symposium on the issue of fire ants and
their control will be convened by EPA
and the U.S. Department of Agriculture June
7-10 in Atlanta. Ga. A recent application
from the state of Mississippi to conditionally
register an insecticide called Ferriamicide has
prompted a fresh look at the fire ant problem
The symposium will consider the full range
of fire ant issues, including the resurgence of
ants following treatment control techniques,
the benefits and risks of existing chemicals,
new chemicals now being developed,
and the potential for new management tech-
niques. In addition to EPA and USDA. the
symposium will include scientists and other
experts from the public and private sector.
"It has become clear to me that we cannot
evaluate the Ferriamicide application in isola-
tion from all the many issues surrounding the
control of the fire ant, which has infested
nine southern states and Puerto Rico," said
Dr. John A. Todhunter, EPA's Assistant Ad-
ministrator for Pesticides and Toxic
Substances.
"The control of fire ants has been difficult
for decades and has raised a number of
significant scientific issues. In that light, a
hasty decision to either grant or deny the ap-
plication of Mississippi would be inap-
propriate at this time," he added.
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EPA JOURNAL
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Over 230 million acres in the South are
now infested with fire ants, including parts of
Mississippi, Arkansas, Texas. Alabama,
Florida. Georgia, Louisiana, North Carolina,
South Carolina, and Puerto Rico, They are
currently spreading through Texas at about
25 miles per year
Fire ants, which were accidentally in-
troduced into the United States from South
America in 1918, are combative pests that
inflict painful stings on both people and
livestock. In some cases, they cause serious
allergic reactions to those who are hyper-
sensitive. The fire ant's sting causes an im-
mediate reaction of white blisters
The ants are about a quarter of an inch
long. They are found not only in rural areas
but in urban back yards, recreation areas,
parks, and cemeteries. They build mounds
which can reach 1 8 inches in height and 1 to
2 feet in diameter. The mounds shelter
50,000 to 250,000 ants each. In heavily in-
fested regions there may be as many as
200 mounds per acre.
The mounds interfere with normal farming
operations, such as mowing and harvesting,
and discourage farm laborers from working in
infested fields.
The fire ant is harmful to wildlife and
livestock in many states. Poultry houses are
sometimes plagued by the fire ants During
periods of large amounts of rainfall, the ants
thrive.
Various pesticides have been used to con-
trol these ants, but concern has been raised
about the long term effects of these
chemicals.
Mirex was introduced in 1961 to combat
the fire ant problem, and after 1961 was ap-
plied under the sponsorship of the UDSA-
State fire ant programs in all or parts of
Texas, Florida, Arkansas, Alabama, Mis-
sissippi, Louisiana, Georgia, North and South
Carolina. In 1969 the MRAK report recom-
mended termination of the use of Mirex on
the basis of substantial evidence developed
under the auspices of the National Cancer In-
stitute that Mirex is a potential carcinogen
During EPA's review and subsequent hear-
ings on Mirex from 1973 to 1976, all Mirex
registrations were transferred to the Mis-
sissippi Authority for the Control of Fire Ants,
On August 31. 1976, the Mississippi
Authority proposed a plan providing for the
phaseout of Mirex, On October 21,1 976, the
Administrator of EPA accepted the Mis-
sissippi Plan.
In addition to the cancer risk of Mirex,
studies showed Mirex residues in the tissues
of persons in states where Mirex was used
heavily; studies have demonstrated that
Mirex crosses the placental barrier and has
been found in human milk of nursing
mothers; and it appears that Mirex remains
in the environment and bioaccumulates in
the food chain,
Ferriamicide, developed by the State of
Mississippi, contains the active ingredient
Mirex and a small proportion of amine and
metal salt which causes Ferriamicide to
degrade much faster than Mirex, Ferriamicide
is designed to be applied on a corncob grit
carrier with a soybean oil attractant
Emergency exemptions for Ferriamicide use
in 1978 and 1979 were blocked on
procedural grounds by a court challenge and
because of the need to evaluate new data.
Amdro is a new pesticide designed to con-
trol fire ants. It has been used in large scale
field tests by its manufacturer, American
Cyanamid Company, USDA, the Animal and
Plant Health Inspection Service, the Texas
Department of Agriculture, Texas A & M Un-
iversity, and several other southern univer-
sities. Amdro is registered for use on range
lands The registrant has petitioned the
Agency to establish residues for crop use of
Amdro
Other new materials are also being
developed for control of the fire ant. D
This drawing illustrates flow a fire ant
and stings n hnni,in
MARCH/APRIL 1982
29
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Giant Geese
Survive
Another Winter
T he largest flock of giant Canada geese in
the country has survived another frigid
winter in Rochester, Minn., and with the ex-
ception of a small number of cripples, recent-
ly flew to the lake country in central Canada
to nest
An estimated 1 1,000 of these biggest of
the Canada goose subspecies were con-
gregated on Rochester's Silver Lake in mid-
winter when thermometers showed readings
32 degrees below Fahrenheit and the wind
chill factor dropped the temperatures to as
much as 100 degrees below zero.
A critical factor in the survival of these
geese during such weather extremes is the
discharge of heated water into the lake from
the city-owned power plant. This hot water,
which under other conditions and in other
climates could be a destructive pollutant,
keeps portions of the lake ice-free all winter.
The large size of this subspecies of Canada
goose also enables them to survive cold con-
ditions which the many other smaller sub-
species of Canada geese would find
intolerable.
Biologists had long assumed that the giant
species of this goose had become extinct in
the 1 920's, but in 1 962 some scientists who
were banding and weighing geese at Silver
Lake were startled by the heavy weight of
some of these birds. They later confirmed
that these animals were members of the
giant subspecies.
These large geese normally weigh 12 to
14 pounds compared to an eight-pound
average for western Canadas, for example.
Wildlife officials believe that the
resurgence of the giant Canadas at Silver
Lake began with one private flock started by
Dr. Charles Mayo of the famed family which
launched the Mayo Clinic.
These captive geese attracted wild birds
and soon large flocks began using lakes in
the Rochester area. The growth of the geese
at Silver Lake was aided when a former
patient at Mayo Clinic who had enjoyed
watching the birds left funds in his wilt for the
purchase in 1947 of 12 large Canadas from
Nebraska. These birds placed on the lake
with pinioned wings helped decoy wild geese
to the location.
However, the geese did not begin to
overwinter in large numbers until 1 948 when
the lake began to serve as a discharge point
for heated water from the new city power
plant.
Once the geese were identified as mem-
bers of the giant subspecies, State. Federal
and Canadian officials entered into a
cooperative agreement to protect the
relatively rare subspecies.
The giant Canada is similar in appearance
to other Canada goose subspecies except
Giant Canada geese emerge from the early
morning mists of Silver Lake in Rochester,
Minn. In (he background is the municipal
power plant which discharges heated waste
water into the lake. This hot water keeps the
lake at least partly ice-free for the geese dur-
ing the winter.
30
EPA JOURNAL
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that it is larger. It has the same distinctive
black stocking heads and necks and white
cheek patches.
Early each winter morning in Rochester
most of the geese fly off in long undulating
line formations to feed in nearby fields on
waste corn, soybeans, and smal! grains.
When the flocks return to Rochester later
in the day, downtown shoppers pause to
watch the birds as they swoop out of a winter
sky twisting and rolling to avoid trees and
buildings.
Patients in the taller Mayo Clinic buildings
forget their health problems at least momen-
tarily when these huge birds pass by their
windows. As the geese settle back into the
lake, they gabble furiously.
A public opinion survey a few years ago in
Rochester revealed that about 75 percent of
the city's residents watch or feed the geese
and that about the same percentage feel the
flock is beneficial to their city.
Merchants near the lake who sell shelled
corn in bags for feeding the geese have sold
more than two tons of corn during one winter
month. The sales of photographic and
hunting supply outlets also rise sharply when
the geese are in town.
Although the geese have been protected
by establishment of a 66.5 mile square
refuge which includes the City of Rochester,
hunters hide in the fields on the fringes of the
refuge. Biologists contend that hunting may
be necessary to control the increasingly large
flock from reaching nuisance levels.
Already some cities such as Toronto,
Canada, have been shipping their surplus
Canada geese to other areas because when
these birds become too numerous they eat
ornamental vegetation, destroy lawns, and
despoil park property with their wastes
Yet most people seem to welcome the
Canada geese and many fee! as conser-
vationist-author Aldo Leopold once wrote:
"One swallow does not make a summer.
but one skein of geese, cleaving the murk of a
March thaw, is the spring." D
MARCH/APRIL 1982
31
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Some
Drinking Water
Filters
Found Effective
Mew tests performed for EPA have shown
that a number of home drinking water
filters are highly effective in removing
possibly harmful "halogenated organic"
chemicals from ground water used for drink-
ing.
The tests demonstrated that the effec-
tiveness of the 10 activated carbon filters in
reducing organic compounds ranged from 76
to 99 percent during the filter's claimed
lifetimes.
The organic compounds involved in these
tests included the solvents tnchloroethylene
and tetrachloroethylene. serious contami-
nants of a small portion of the nation's
ground water supplies.
The tests are the third in a series begun in
1 978 for EPA by the Gulf South Research In-
stitute of New Orleans. Twenty other ac-
tivated carbon water filters were studied
earlier by this firm.
The 10 filters most recently examined in-
cluded a pour-through model, faucet-
mounted units, a stationary model placed
below a sink to filter all the water coming
through the faucet, and several line-bypass
models which also are mounted below a sink
but attached to a separate faucet. The useful
life of these filters varies as does their cost:
from about $10 for the pour-through device
to several hundred dollars for the line-bypass
units
EPA, which is charged with ensuring
drinking water safety under a 1974 law. does
not certify or approve home water filters.
However, the agency had the filters studied
both for its own information and as a con-
sumer service Many of the filters were tested
beyond their manufacturers' claims, which in
most cases were limited to improve taste or
odor removal
Other findings from the studies were:
• The performance of activated carbon filters
on the drinking water from four cities was
similar to their performance in a laboratory.
* Non-pathogenic bacteria do accumulate
on the carbon filtering material and do in-
crease in drinking water, but no conclusions
can be drawn as to the health significance of
these facts at this time.
• More exotic fitters, including a reverse os-
mosis/granular carbon device and a filter us-
ing ozone gas and carbon, removed between
70 and 99 percent of halogenated organics
from drinking water.
A fact sheet on the third phase filter
studies is available from EPA's Public In-
quiries Center (PM-215), 401 M St., S.W..
Washington, DC. 20460, phone 202/755-
0707. D
•••ite~ Canaers, (ires..
rers. retrace an historical expedition on
the Wisconsin River.
Back Cover: Early morning ice glaze melts in
s/ir/ny sun on Bull Run, a stream
Washington. D.C., stained with hlood during
tfn; Civil War.
32
EPA JOURNAL
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