• Agency
    United States

    Environmental Protectn


A  Review  of
What gains has the country
made since 1970 in dealing
with its environmental prob-
lems? That was the year
marking the surge of public en-
vironmental concern  and the
establishment of EPA.
  What does the remaining en-
vironmental agenda look like?
What kind of problems will we
face and will they be easier for
the country to solve?
  In a comprehensive
assessment of environmental
progress since EPA was cre-
ated, the agency discusses
these questions, basing its
comments and conclusions on
the best data and expertise
available. This issue of EPA
Journal previews a draft of this
major report which will be
published soon.
  Including another topic of
broad public concern, the Jour-
nal publishes excerpts from a
recent speech by Administrator
William Ruckelshaus on the
agency's experience and policy
with regard to risk assessment
and risk management. These
are basic tools the agency  is
using as decisions are made
on  difficult environmental mat-
  Other subjects covered are
the most recent major actions
being taken to deal with  en-
vironmental problems the
country faces. Included are arti-
cles on EPA's phaseout of the
pesticide EDB in citrus fruit,
steps by the agency to curb
asbestos contamination in
schools and other public build-
ings, a proposed update of ait
quality standards for pollution
particles in air and a  suit by
the Justice Department to
compel cleanup of PCB pollu-
tion from a Chicago area elec-
tric utility's equipment.
  A new EPA policy
encouraging more pollution
tests using biological tech-
niques such as measuring the
effects of wastewater on fish is
explained. Findings from a
nationwide assessment of
water quality conditions for
fish are reported. Another ar-
ticle reports on a battle the
agency is waging against the
rigging of bids in the
wastewater construction grants
  Pollution from nonpoint
sources around the country
and solutions to the problem
are explained in excerpts from
an EPA report on the subject.
  New appointments and a
new mission by an EPA scien-
tist are reported along wild
summaries in the regular fea-
ture, Update, of other recent
developments  at the agency.
Environmental Almanac con-
cludes the issue with a focus
on a special spot in nature—
Fern Valley. (
                                                          Youngsters paddle their rubber
                                                          raft on lake near Ely, Minn,,
                                                          an adventure helped by
                                                          clean water.

                               United States
                               Environmental Protection
                               Office of
                               Public Affairs (Al 07)
                               Washington DC 20460
                                                           Volume 10
                                                           Number 3
                                                           April 1984
                          oEPA JOURNAL
                               William D. Ruckelshaus, Administrator
                               Josephine S. Cooper, Assistant Administrator for External Affairs
                               Jean Statler, Director, Office of Public Affairs

                               Charles D. Pierce, Editor
                               John M. Heritage, Managing Editor
                               Susan Tejada, Contributing Editor
EPA is charged by Congress to
protect the Nation's land, air and
water systems Under a mandate of
national environmental laws, the
Agency strives to formulate and
implement actions which lead to a
compatible balance between human
activities and the ability of natural
systems to support and nurture life.
  The EPA Journal is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the publication
of this periodical is necessary in the
transaction of  the public business
required by law of this Agency. Use
of funds for printing this periodical
has been approved by the Director
of the Office of Management and
Budget. Views expressed by
authors do not necessarily reflect
EPA policy. Contributions and
inquiries should be addressed to the
Editor (A-107). Waterside Mall,  401
M St.,  S.W., Washington. D. C.
20460. No permission necessary to
reproduce contents except
copyrighted photos and other
Environmental Progress
and Challenges 2

Risk in a
Free Society 12

Public Meeting Set on
Asbestos in Buildings  16

EPA Assesses Penalty for
Asbestos Violations  17

Further Steps Taken
to Eliminate EDB  18
                             New Air Rules Proposed
                             for Paniculate Matter  19

                             Government Files
                             PCB Cleanup Suit 22

                             Biological Tests Okayed
                             for Toxics Control 23

                             Report Surveys Water
                             Quality for Fish 25

                             EPA Battles
                             Bid Riggers 26

                             Nonpoint Source
                             Pollution in the U.S. 27
New Appointments,
New Missions at EPA  32

Recent EPA Actions  34

Almanac: Exploring
Fern Valley  36
Cover: Young couple strolling amid
the splendor of a beach on Ore-
gon's rugged coast. Photo by C.
Biedel of Photri,
                            Photo Credits: Steve Delaney; C.
                            Biedel of Photn; U.S. Soil Conserva-
                            tion Service; E. James White. U.S.
                            Department of Agriculture; Rex
                            Gary Schmidt from painting by Bob
                            Mines; Library of Congress Col-
                            lections; Thomas R. Chittenden;
                            and U.S. Forest Service.
Design Credits: Robert Flanagan;
Ron Farrah
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                                   Airborne test tor wo/;.
Over the past 13 years a State-Federal
partnership has made substantial ad-
vances in controlling pollution in this
country, yet increasingly complex and
costly new challenges loom ahead in the
Nation's quest for a cleaner environment.

  This assessment is contained in a
soon-to-be released report on environ-
mental progress made since EPA was es-
tablished in 1970 and the most significant
environmental challenges ahead.
  The report, entitled "Progress and
Challenges: An EPA Perspective on the
Nation's Environment," traces the results
of early environmental control measures,
examines the nature of current and
emerging problems, and describes EPA's
strategy for dealing with these problems.
  Intended as an educational document
for the public, the report is designed to
foster a better public understanding of
the complex nature of environmental
control and decision-making. Another
purpose of the report is to focus atten-
tion on the Agency's effectiveness in
achieving real environmental gains.
  An important reason for the massive
effort made by the Agency to assemble
the information in the report was the
recognition by EPA's leadership of the
need to establish a baseline for measure-
ment of future environmental effective-
ness and to anticipate emerging prob-
  EPA Administrator William D. Ruckels-
haus said the report will provide an ac-
counting to the American public of the
Agency's stewardship of the Nation's air,
land and water  during the past 13 years.
  "The environmental challenges of the
1980s are much more complex than the
                                                                                           EPA JOURNAL

ones we tried to address in the 1970s
and they will not yield quickly to our
efforts," Ruckelshaus said,
  "In setting out to find solutions to the
environmental issues of the eighties and
nineties, we start with a keen apprecia-
tion of the difficulties involved. Finding
the evidence of contamination, assessing
the threat, correcting the damage, setting
up preventive measures, and paying the
price of protection—all raise questions of
science, technology, and public policy
that are as difficult as they are important.

  "In a number of cases, we must decide
whether the very fear of risk is sufficient
cause to act, or whether we must await
more certain evidence that the risk is
real.  In these and other cases, we lack
both certainty as to the degree of risk
and proven technology to remove it. In
nearly  every case the cost  of protection
gives pause to any public servant who
must weigh the investment of public
funds against the value of  the protection
to be purchased. We must make judg-
ments  with whatever information we
have and expect to learn more as we go.
  "I believe that EPA's highest priorities
in the years ahead are to maintain prog-
ress, improve our understanding and
knowledge, and anticipate  new chal-
lenges. All this must be done while
strengthening our partnership with State
and local governments and maintaining
public  support and trust."
  The new report explores the pollution
problems and corrective efforts.
  The report was prepared by the  EPA
Office of Management Systems and
Evaluation, with the cooperation of the
Agency's program offices.
  This article reviews highlights of the re-
port's findings on the progress and chal-
lenges in four major environmental
areas:  water, air, land, and control of
pesticides and toxic substances. Key find-
ings  in the report follow:
When EPA was established in 1970, the
Nation was painfully aware of the pollu-
tion of its public waters. For example:

• The Izaak Walton League described the
Willamette River in Oregon as a "stinking
slimy mess, a menace to public health,
esthetically offensive, and a biological

• In the Nation's capital, huge mats of
smelly, floating algae clogged the Poto-
mac River.

• Escambia Bay, East Bay, Pensacola
Bay, and Santa Rosa Sound, Florida,
were so polluted that frequent fish kills
were measured in  terms of square miles
of dead fish.

  During the  years since, individual
citizens, businesses, industries, and
governments have achieved  important
successes in  restoring water quality.
Sport fishermen again tine the banks of
the Willamette, the Potomac has raft
races, fishing derbies and waterfront fes-
tivals, and  rather than massive fish kills,
shrimp and oysters are back in Pensacola
  These are not isolated instances of im-
provement. The best available State and
Federal data indicate that the quality of
most of the Nation's streams has held
constant or improved over the last 13
years  despite increases in pollution dis-
charges as a  result of the Nation's pop-
ulation and industrial growth.
  A 1983 assessment of water quality im-
provements from 1972-1982 conducted
by the Assocation of State and Interstate
Water Pollution Control Administrators
and the States showed that of 444,000
miles  of rivers and streams surveyed,
water quality  of 47,000 miles of streams,
measured against conventional pollu-
tants,  improved; 11,000 miles declined,
and 297,000 miles showed no major
change. Information on 90,000  miles of
streams surveyed was not available.
  Similar trends were reported for lakes.
These water quality improvements reflect
the  success of the approaches to pollution
control prescribed  under the Clean
Water Act.  Increases  in  pollution from in-
dustries and municipalities as a result of
industrial and population growth have
been offset in most places by improved
treatment of wastewater.

  Ground  water is  a major source of
water for agriculture and  industry. In
addition, about half of all Americans,  and
 up to 95 percent of those in rural areas,
 rely on ground water as their principal
 source of drinking water.
   Once contaminated, ground water may
 be impossible to clean up. It moves
 slowly—typically only 5 to 50 feet a
 year—through porous aquifers that may
 be several hundred feet underground.
 Plumes of highly concentrated con-
 tamination may remain  in ground-water
 aquifers for years. Little is known at this
 time about the extent of ground water
 contamination or the health effects
 associated with its contamination.
   States have identified the following
 sources of ground-water contamination
   Major problems:  Industrial and munic-
 ipal  landfills and lagoons; leaking  under-
 ground storage tanks; and chemical, oil
 and  brine spills.
   Intermediate problems: well injection;
 pesticides; fertilizers; and septic tanks.
   Minor problems:  salt water and  brack-
 ish water  intrusion; road salts and feed-
   Variable problems by site: wastewater
 treatment; land application of municipal
 sewage; and mining.
   Of all these problems, those caused by
 leaking storage tanks have been drawing
 the most attention recently. These tanks
 are used to store various types of liquids,
 including  gasoline, hazardous and toxic
 chemicals, domestic fuels, process  chem-
 icals and wastes.
   The  waste from such leakage is tre-
 mendous. For example, in just one  State,
 Maine, it is estimated that as many as 25
 percent of the underground gasoline
 storage tanks at the 10,000 or more retail
 gasoline outlets in the State may be
 leaking. The estimated waste discharged
 each year from  these leaking tanks  in
 Maine  is 11 million gallons.


When the  Safe Drinking Water Act be-
came law, there was public uncertainty,
 not only about purity, but in some cases
about who provided the water and was
 responsible for its quality.
  The Federal Government knew of
about 19,200  public  water systems in
 1969. At present more than 59,000 sys-
tems provide water  on a daily basis. In
addition, more than  164,000 other sys-
tems operate seasonally or serve the
traveling public. Almost two-thirds of the
59,000  community water systems in the
APRIL 1984

country serve 500 or fewer persons.
Many such systems are privately owned.
  The number of water supply systems
meeting monitoring requirements has
risen steadily. In 1969,  only 15 percent of
community systems routinely monitored
drinking water for microbial contamina-
tion. This is the main indicator of organ-
isms that cause water-borne disease in
humans. By 1982, 85 percent of the sys-
tems were doing regular microbial anal-
yses and meeting the national  standard.
  State efforts to protect drinking  water
quality have increased  significantly. All
but five States and the  District of Colum-
bia now take primary responsibility for
enforcing Federal safe-water rules. Under
the law, EPA must enforce the rules if
States do not. Increased State  partici-
pation has been accomplished by an in-
crease in State capability to measure and
analyze low concentrations of con-
taminants. System operators now are
better trained and more attention  is
being paid to helping small systems that
produce most of the continuing viola-
  While most water systems currently
provide high quality drinking water in
conformance with national standards,
greater compliance with existing stan-
dards is needed, particularly in small sys-

Water Pollution
In the 1970s, EPA sought to control ma-
jor sources of "conventional" pollutants,
such as organic wastes, sediments, bac-
teria and viruses, oil, grease, and ex-
cessive heat from man-made causes.
Those efforts focused on obvious  sources
of very large volumes of pollution, in-
cluding primarily "point sources"  of mu-
nicipal sewage and industrial waste.
Many gains have been  made, but  this
work is not complete.
  Progress in controlling conventional
pollutants from point sources has meant
that nonpoint sources and other pollu-
tants, such as toxic contaminants, con-
tribute a greater proportion of the Na-
tion's water pollution problem. EPA and
the States also are looking more carefully
at problems in ground  water,  in es-
tuaries, and at the destruction of inland
and coastal waters.
 'tyo-j   .         •                    i'.ronmcnt
  The following are six of the most sig-
nificant long-run water quality challenges
where EPA will place high priority in
years to come:

• Toxic pollution: Although industry  has
made great strides in controlling con-
ventional pollutants, the problem of tox-
ics contamination and the degree to
which industrial sources can achieve  fur-
ther clean-up requires continued atten-

• Ground water contamination: This  is
potentially the most serious water prob-
lem due to the variety of possible
sources and to the difficulty of detecting
contaminants and of remedying ground
water pollution after it has occurred.

• Contamination of drinking water: Pub-
lic health problems related to water sup-
ply still  persist, particularly in small sys-
tems. Contamination by synthetic chem-
icals may require new techniques to treat
and monitor drinking water.
• Wetlands: Many of these important lo-
cal ecosystems have been destroyed for
farming and forestry, disposal of waste
and other land development activities.
Although the economic, environmental,
and esthetic value of wetlands is better
understood, losses of these valuable
lands still  continue.

• Pollution from sewage: Problems re-
main  in assuring continuous adequate
treatment  at existing treatment plants
and in providing plants to ensure ade-
quate capacity to  handle population and
economic  growth.
• Non-point sources: The challenge of
restoring and protecting streams de-
graded by pollution  from agriculture and
other non-point sources can be met only
by a major Federal,  State and local effort.
                                                                                                             EPA JOURNAL

 The effects of air pollution are sometimes
 overshadowed today by other environ-
 mental threats that seem not  to be as
 well controlled. However, it does not take
 much effort to remember what air pollu-
 tion problems  existed before  the
 strenuous efforts of the  last thirteen
 years were made:

 • There were areas in the late 1940s
 and early 1950s, both in the United
 States and  other countries, where air
 pollution levels were so bad that many
 people were hospitalized and  several

 • Many cities were  perpetually en-
 veloped in  a smoky haze, as industries
 emitted thousands of tons of  pollutants
 into the air with few or no controls.

 • Dirt and grirne from the air  were com-
 monplace in homes, on  laundry left  out-
 side, and on buildings, cars, and vegeta-

   Dramatic progress has been made over
 the last 13 years. Levels of pollution in
 the air are lower, and unhealthful days
 from the standpoint of air pollution  are
 far less frequent. In  addition,  most in-
 dustries have put pollution controls  in
 place, and practices like  open burning
 that were common are no longer per-
 mitted in many areas. However, many air
 quality problems still remain and others
 are emerging.
   Many areas of the country still have air
 quality that is far below  national stan-
 dards. We now know that our strategy of
 allowing facilities to emit pollutants  high
 into the atmosphere from tall  stacks has
 contributed to  the formation of de-
 positions that could cause damage in
 many parts of the country.
   Air pollution of some sort is found in
 nearly every area of the  United States
 and is particularly severe in urban areas.
 It causes both health and environmental
 damage. Some of the health problems
 brought on or aggravated by air pollution
 include lung diseases, such as chronic
 bronchitis and  pulmonary emphysema;
 cancer, particularly lung cancer; neural
 disorders,  including brain damage; bron-
 chial asthma and the common cold,
 which are  more persistent in places  with
 highly polluted air; and eye irritation,
 particularly caused by smog. Adverse en-
 vironmental effects also  damage crops
 and vegetation.
   Two major types of air pollutants are
 regulated under the Clean Air Act:
 criteria pollutants and hazardous air pol-
• The Clean Air Act Amendments re-
quired EPA to set National Ambient Air
Quality Standards for the most common
air pollutants which endanger human
health. EPA has set standards for six
such pollutants—called "criteria pollu-
tants." For each criteria pollutant, stan-
dards are set to protect both  human
health and what the Act refers to as
"welfare," primarily crops and vegeta-
tion, buildings, and visibility.  The six
criteria pollutants for which National
Ambient  Air Quality Standards have been
set are: ozone, suspended particulates,
carbon monoxide, sulfur dioxide, lead,
and nitrogen  dioxide.

• The Clean Air Act Amendments also
require EPA to review and regulate
hazardous air pollutants. These pollutants
are defined as those  pollutants not
already regulated as  criteria pollutants
but that can contribute to an increase in
mortality or in serious illness. EPA has
set hazardous air pollutant standards for
asbestos, beryllium, mercury, and vinyl

  Both criteria and hazardous air pollu-
tants come from two major categories of
sources, mobile sources and stationary
sources. Mobile sources include passen-
ger cars, trucks, motorcycles, boats and
aircraft. Stationary sources include a
wide range of large industries such as
iron and steel plants and oil  refineries;
small businesses  like dry cleaners and
gas stations;  and  residences.


Mobile sources of air pollution produce
more than half of all air pollution emis-
sions. Principal pollutants generated by
mobile sources are carbon monoxide,
volatile organic compounds,  nitrogen ox-
ides, and lead. Volatile  organic com-
pounds  and nitrogen oxides, when ex-
APRIL 1984

posed to sunlight, can form another
criteria pollutant, ozone.
  These pollutants are formed as a result
of the burning of gasoline. Carbon mono-
xide and volatile organic compounds are
formed when engines burn fuel in-
efficiently; nitrogen oxides are formed
when fuel is burned efficiently, causing
high temperatures.
  EPA has controlled the emission of
these pollutants through the Federal
Motor Vehicle Control Program (FMVCP).
Under this program, EPA sets national
emission levels for each pollutant type,
and requires manufacturers of new cars
to design their cars to meet them. EPA
and the States also support and operate
inspection and maintenance programs to
test operation and  emission  levels of cars
in use. In addition States and local gov-
ernments develop transportation control
measures such as carpooling programs
and express lanes for buses  to reduce
mobile source emissions.


Stationary sources generate  air pollutants
as a  by-product of  industrial processes or
as a  result of burning fuel. These two
types of activity generate about equal
amounts of air pollution, although the
types and amounts of specific pollutants
they generate are quite different. Electric
utilities, industrial facilities, and residen-
tial and commercial buildings are the pri-
mary sources of pollution from fuel com-
bustion. Sulfur dioxide, nitrogen oxides,
and particulates are generated from the
burning of coal, fuel oil, natural gas,
wood, and other fuels. Industrial  proc-
esses produce sulfur dioxide, nitrogen
oxides, and particulates, but also gener-
ate carbon monoxide and volatile organic
  Stationary sources that generate
hazardous air pollutants are  numerous:
industrial processes, particularly those of
the  chemical  industry; fuel oils con-
taminated with toxic chemicals;
hazardous waste handling and disposal
facilities; municipal incinerators; and
electric utilities, among others.
  EPA's approach to controlling air pollu-
tion from stationary sources relies heavi-
ly on the States. Each  State must draw
up, for EPA review and approval, a State
Implementation Plan (SIP)  describing
how it intends to control emissions from
stationary and mobile sources in order to
meet National Ambient Air Quality Stan-
dards in each of its counties,
  In  addition  to setting National Ambient

Air Quality Standards, EPA also sets stan-
dards that limit the pollutant emissions a
source may generate. Once emission
standards are set, EPA and the States
write specific permits, monitor the facility
to ensure that it complies with permit
limits, and take enforcement action when

to Date

EPA and  State and local governments
have taken many of the  necessary steps
to control air pollution. Motor vehicle de-
sign has  been  modified to reduce pollu-
tion emissions. Because the principal de-
sign changes made to reduce emissions
require use of  unleaded  gasoline, a side
effect of design changes has been signifi-
cant reductions in lead emissions. Most
industries also now have air pollution
control equipment  in place.
  EPA and the states measure levels of
criteria pollutants in the outdoor air by
using a network of monitors across the
  Data from this network for the period
from 1975 to 1982 show that ambient
levels of all criteria pollutants are down

Particulate levels decreased 15 percent
between 1975 and 1982. The difference in
the emissions trend (27 percent during
this period) and the ambient trend can be
accounted for by the farge amount of
natural wind-blown  dust.

Sulfur dioxide levels, primarily from fuel
combustion  and industrial processes, de-
creased 33 percent.

Nitrogen dioxide levels increased be-
tween 1975 and 1979, but dropped be-
tween then and 1982.  The 1982  level was
the same as the level in 1975, and well
below the ambient standard.

Ozone levels decreased 18 percent, and
exceedances of the ambient standard
during the ozone season  (July-
September) during these years dropped
even more dramatically: 49 percent.

Carbon monoxide levels dropped 31 per-
cent between 1975 and 1982. Even more
noteworthy is the fact that exceedances
of the ambient standard dropped 87 per-
cent during this period.

Lead levels decreased nationally 64 per-
cent between 1975 and 1982, primarily
because  of a  drop in the use of  leaded

Air Quality

Though progress has been made in con-
trolling air pollution from both mobile
and stationary sources, much still needs
to be done. Five of the six criteria pollu-
tants, all except nitrogen  dioxide, are cur-
rently of major concern in many areas of
the country.  There are  many counties
where health related standards were not
met in  1982 for one or  more of the
criteria pollutants. In addition, certain
areas still have levels of pollution on
some days above levels considered safe.
  Another problem that needs to  be bet-
ter controlled is air toxics, a pollution
source of growing importance.
  As EPA and the States grapple with
these continuing problems, they  will also
need to cope with emerging problems
like acid deposition and indoor air pollu-
  Eight of the most  significant air quality
challenges that now face  EPA and the
States are:
                                                                                                              EPA JOURNAL

Ozone: Ozone is the Nation's most
serious criteria pollutant problem. The
pollutants which form it, nitrogen dioxide
and volatile organic compounds, are emit-
ted approximately equally by mobile and
stationary sources.

Particulates: Though not as serious a
problem as ozone, the paniculate prob-
lem is quite widespread and, in some
areas, quite severe. Much  of the problem
is due to large amounts of wind-blown

Carbon Monoxide: Like ozone, the car-
bon monoxide problem is most severe in
large  urban areas. This is due to the
large  number of cars in cities, which are
the primary source of this pollutant.

Lead: While the national levels of lead
are well below the ambient standard, this
pollutant is still a great concern in certain
areas, especially around lead smelters.

Sulfur Dioxide: Sulfur dioxide is a con-
cern both because of its effects on
human health and because of its role in
acid rain. The primary source is electric

Air Toxics: There is increasing evidence
of human exposure to toxic  chemicals in
the air and concern that some of these
chemicals may pose immediate and long-
term health problems, including cancer
and birth defects. In many cases, EPA
lacks  adequate information on what toxic
chemicals are being released into the air
and what quantities of chemicals are
being generated. Information is also lack-
ing on what health effects they have in
the concentrations found in outdoor air.

Acid Deposition: State programs under
the Clean Air Act emphasize the local
effects of pollution, and not environmen-
tal effects hundreds of miles away. Now
greater attention is being focused on the
transport of sulfur and nitrogen dioxides
that contribute to acid deposition, and
there  is concern about the long-range
transport of ozone from large industries.

Indoor Air Pollution: The quality of in-
door air is affected by individuals who
smoke, by fumes given off by some
building materials, by fumes from
heating and cooking devices, and by a
variety of other activities and sources.
Levels of criteria and other air pollutants
inside buildings are in some cases much
higher than levels at which standards are
set for pollution outdoors.  EPA is
focusing its efforts on carefully assessing
whether indoor air pollution  presents
health risks, a potentially serious concern
because Americans spend  an average of
70 to 90 percent of their time indoors.
Environmental protection has focused
historically on air and water pollution.
While the Federal government has been
involved in protecting wildlife and other
special areas from development since the
turn of the century, it was not until the
1970s that there was much public con-
cern about pollution of the land. Now it
is apparent that contamination of the
land not only threatens to restrict future
uses of the land  but also affects the qual-
ity of the surrounding air and water. Love
Canal in New York State, the Valley of
the Drums in Kentucky, and Times Beach
in Missouri are notorious examples of
this. All have been severely damaged by
careless disposal of hazardous waste.
  While these sites are among the worst,
similar situations across the country have
raised public awareness of the environ-
mental and health  hazards that  can be
caused by hazardous waste problems.
One of the Nation's top environmental
priorities is to clean up these problems
and to regulate hazardous waste han-
dling to prevent similar problems in the
  Most  of the six billion tons of wastes
dumped onto the land each year are rela-
tively non-hazardous. Half of these
wastes, for example, are agricultural
wastes, including the unharvested por-
tions of crops. However, a signifi-
cant portion of the non-agricultural
wastes, particularly those from  industrial
sources, can pose significant hazards to
public health and the environment when
they are carelessly disposed of. An es-
timated 165 million tons per year of
these wastes are subject to regulation as
hazardous waste under current  law.
  Hazardous wastes can cause fires and
explosions, corrosion and acid burns.
Health effects range from headaches,
nausea, and rashes to serious im-
pairment of kidney and liver functions,
cancer, and genetic damage.
  Recognizing problems in the genera-
tion and disposal of such wastes, Con-
gress enacted several laws to protect
health and the environment. These laws
are aimed at two basic objectives:

• Proper management and disposal of
wastes being generated now and that
will be generated in the future.

• Cleanup of sites  where the results of
past disposal practices now threaten sur-
rounding communities and the environ-

  Wastes are seemingly inevitable by-
products of virtually all activities people
pursue in their daily lives. Every major
sector of the economy contributes.
  The kinds of wastes produced and their
effects vary greatly, As a result, they
need different levels and types of control.
These wastes are primarily from five
sources: agriculture (50  percent of total),
mining and milling (39 percent), industry
(7 percent), municipalities (3 percent),
and  utilities (1 percent).

and Forestry
  Of the six billion tons  of waste each
year, half is from farming and forestry.
The  threat posed by most of this waste is
relatively small.  Much forestry waste is
now burned for energy and agricultural
waste is mostly plowed  back into  fields
or burned. Some wastes, like unused
pesticides and empty pesticide con-
tainers, do present special hazards. EPA
sets  requirements for the disposal of pes-
ticide containers and unused pesticides.


Another 39 percent of the total waste
generated is from mining. These wastes
consist primarily of  "overburden," the
soil and  rock cleared away before
mining, and "tailings," material dis-
carded during ore processing. Mining
wastes are generally classified as a low
hazard waste, but are a problem because
of the large volumes generated. Federal
law limits EPA to identifying potential
health, safety and environmental hazards
of mining wastes and  determining the
need for further regulation.


Industries are the major  source  of
hazardous wastes. While it is not yet
known what portion of the 400-million-
ton annual total of industrial wastes is
hazardous, a recent  EPA survey es-
timated that roughly about 165 million
tons of hazardous waste subject to cur-
rent  Federal requirements are generated
by industry each year. Although this
hazardous waste is generated by the full
range of major American industries, the
chemical industry accounts for over 70
percent of the total.
  EPA and the States share responsibility
for managment of newly generated
hazardous wastes under the Resource
Conservation and Recovery Act — a "cra-
dle to grave" effort covering the genera-
tion, transportation, storage, treatment
and disposal of today's hazardous
APRIL 1984

  The Comprehensive Environmental Re-
sponse, Compensation and Liability Act,
known as the Superfund program, au-
thorizes EPA to act directly to clean up
those sites where hazardous wastes from
abandoned or inactive waste sites endan-
ger public health or welfare. It provides a
special fund for cleanup of abandoned or
inactive hazardous waste sites. A total of
SI.6 billion has been made available for
that work.


Municipal wastes include household and
commercial  wastes, demolition  materials,
and sewage sludge. Some household
and commercial wastes, such as house-
hold cleaners and pesticides, are clearly
hazardous. They are so intermingled with
other wastes that specific control of such
materials is virtually impossible. Also,
"leachate" resulting from  rain water
seeping through municipal landfills may
contaminate underlying ground water.
Although the degree of hazard presented
by this leachate is relatively low, such a
volume of it is produced that it may be a
significant contributor to ground-water

Sewage sludge is a solid, semisolid, or
liquid material that remains after sewage
has been treated by municipal water
treatment plants. Nearly seven million
dry tons of sludge are generated each
year. Improper on-land disposal of some
present-day sludges can transfer a pollu-
tion problem from water to land.

The principal wastes produced by electric
power plants are sludges from air and
water pollution treatment  processes.
Some of these plants  also produce high-
level radioactive wastes. RCRA assigns
EPA the responsibility for  determining
whether there is a need to regulate the
sludges from air pollution control
methods at these plants.

to Date
   Stringent controls are now in place to
regulate the treatment, storage  and dis-
posal of currently generated hazardous
wastes to ensure that they do not create
problems in the future. EPA has also
moved forward in addressing the  prob-
lems posed  by inactive hazardous sites.
In the three  years since the Superfund
program was established, EPA and the
Annul vivw of a coal st/ip mine in the Western U.S.
States have worked to inventory the ex-
tent of the  problem across the country
and to establish procedures for cleaning
up these sites. More than 540 sites are
currently included for action on the
National Priority List, and the necessary
steps to clean up the worst of these sites
are now underway.

and Inactive
Hazardous Sites

EPA and the States  have identified over
16,000 abandoned or otherwise inactive
sites that may contain hazardous waste.
The total number of identified sites is ex-
pected to reach 22,000 by the end of
1985. EPA is now carrying out a multi-
step assessment procedure to determine
which of these sites actually pose a dan-
ger to public  health or the environment
and, if so, what clean-up actions are
  Since December  1981, Federal and
State authorities have reached settle-
ments under  which  responsible parties
will spend $177.6 million in clean-up at
such sites. To date, Federal and State au-
thorities have also sued responsible par-
ties to recover $16.7 million in clean-up
costs paid from Superfund. Recovered
funds are returned to the Superfund for
use at other sites.
  EPA has issued orders for clean-up at
72 uncontrolled or inactive sites, 110
cases have been referred to the De-
partment of Justice, and 91 of these have
been filed in the courts.

Hazardous Wastes

The basic approach to managing
hazardous wastes under the Resource
Conservation and Recovery Act  is to track
such wastes through a  system of records
called "manifests." The system  of man-
ifests for tracking the processing of
hazardous wastes from "cradle to grave"
is now in place. What remains to be done
is to continue improving the operations
of the existing  treatment, storage, and
disposal facilities to  decrease  the
possibility that improper waste handling
at these facilities might present  a hazard
to public health or the environment.
                                                                                                             EPA JOURNAL


Hazardous waste, cleanup challenge of the 80s.
                                                  ,    '
   EPA and the States are taking steps to
 ensure that currently generated waste
 will not result in additional multi-million-
 dollar ctean-up problems. Specifically:

 • EPA has taken steps to identify every
 active hazardous waste facility.

 • Regulations setting standards for in-
 dustries generating hazardous waste and
 for facilities treating, storing or disposing
 of such wastes are now in place. All
 treatment, storage, and disposal facilities
 are subject to these "interim status" re-
 quirements until they can be issued final

 • EPA has begun to issue site-specific
 permits with priority given to land dis-
 posal facilities and incinerators which pre-
 sent the greatest environmental risks.
 These permits include more stringent re-

 Land Protection

 The most important achievement in-
 volving land contamination is that there
 is now widespread recognition  of the
health and environmental problems that
may result from indiscriminate dumping
of wastes on the land. Such practices in
the past have left a legacy of air, ground-
water and surface water contamination
as well as land contamination. Coopera-
tive efforts by the States  and industry are
bringing  about a dramatic improvement
in the management of hazardous waste.
  The actual  clean-up of past problems,
however, has only begun, and many
problems will remain as long-term chal-
lenges. The four most significant current
land pollution challenges are:

• Cleaning Up Abandoned Hazardous
Sites. One of EPA's highest priorities is
the cleanup of the  many abandoned or
inactive hazardous sites across the coun-
try. EPA's attention is now focused on
how to speed up the rate at which these
sites are cleaned up without compromis-
ing the quality or permanence of these
• Controlling Newly  Generated
Hazardous Wastes. EPA and States are
taking  steps to ensure the proper man-
agement of these wastes. They are
focusing on major hazardous waste
generators and major treatment, storage
and disposal facilities.

• Safe Disposal of Radioactive Wastes.
The safe disposal of high-level radioac-
tive wastes and the management of ura-
nium mill tailings are difficult long-term
problems. Working with other Federal
agencies and with the States, EPA has a
major role in meeting these environmen-
tal challenges.
• Managing Municipal Sludge. Although
sewage sludge is not an environmental
threat as serious as industrial wastes and
radioactive materials, this sludge often
contains hazardous pollutants. Further-
more, it is generated in the greatest
quantities in cities and communities with
the fewest economically and environ-
mentally acceptable alternatives for its
safe use or disposal. As a result, it con-
stitutes  a serious  environmental man-
agement problem.
APRIL 1984

and  Toxic Substances
The extensive use of chemicals has be-
come a way of life in the United States.
Chemical sales currently exceed $182 bil-
lion a year and involve over 60,000 dif-
ferent substances used in an almost
limitless number of products including:

• the fiber and dyes in our clothes;

• the glues, plastics and paints in our
furniture, houses and cars;

• the various solvents, oils and cleaners
we use in our households and industry;

• the paper and inks we use in books,
newspapers and  many other reading
materials; and

• the fertilizers, pesticides and pre-
servatives used to produce and distribute
our food supplies.
  The benefits of our "chemical society"
have not been without costs. Certain tox-
ic chemicals have caused serious public
health and environmental damage. In
some cases  the effects of toxic sub-
stances have been extreme and highly
visible with  immediate death and severe
illnesses, primarily a result of accidents
or gross misuses of chemicals. Perhaps
of greater concern, however, are the
more subtle impacts from very (ow-level
contamination of food supplies and
drinking waters by certain chemical sub-
stances that persist in the environment
for long periods of time. Some of these
substances have  been found to accumu-
late in people, animals and plants. A
number of chemical substances have
been found capable of causing cancers
and genetic  damage at high doses in lab-
oratory animal studies. The  possible im-
pacts of these chemicals at the usually
much lower levels found in the environ-
ment are mostly  uncertain.
  Scientific knowledge does allow for es-
timating the potential risks at these lower
levels, and efforts are made to calculate
these risks in a manner that leans to-
wards the extensive use of safety factors
in public health and environmental pro-
tection efforts. The basic challenge for
sound environmental management is to
limit the risks posed by these toxic chem-
icals but to do so in a reasonable manner
that allows society to continue to enjoy
the many benefits of today's chemical
products and technologies. Pesticides
and other toxic chemicals have posed
major problems in air, water and land
and, in some cases, serious health prob-
lems. EPA,  under the authority of several
laws, has attempted to handle toxic
chemical problems but largely through
pollution abatement efforts, i.e., reducing
air emissions, water discharges or the
dumping of chemical wastes. However,
simply addressing the toxic chemical
problem through  pollution abatement
efforts leaves major gaps including:

•  Cross-Media Pollution Transfer. By
attempting to control separately toxic
pollution in each environmental medium
under three different major laws, transfer
of pollution problems from one medium
to another can occur. The best example
of this is the long practice of dumping air
and water pollution treatment sludge re-
sidues onto the land.

•  Lack of Control Over Other Exposures.
With the pervasive use of chemicals in
our society, there are many opportunities
for exposures to toxic chemicals other
than from the discharges of by-products
by industry. The best example here is the
use of pesticides which results in much
more widespread environmental con-
tamination than manufacture.

•  Lost Opportunities for Most Effective
Control. In many cases, the best
approach  to controlling toxic chemicals is
by limiting the production or uses  of a
chemical product so as to reduce the risk
posed by the product or its wastes
released during production.

   The Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA) and the Toxic
Substances Control Act (TSCA) have pro-
vided EPA with a different approach that
adds to the Agency's pollution  abatement
Health              I   ;ema victim
efforts. These laws give EPA the author-
ity to collect information about chemical
products and, based on that information,
safeguard  public health and the environ-
ment by controlling, when necessary, a
chemical product at the most appropriate
stage in its life cycle — whether that in-
volves banning it completely, controlling
its initial manufacture, or putting con-
ditions on  its use or disposal. These laws
authorize EPA to consider all exposure
routes and potential impact in all en-
vironmental media.


Currently,  there are about 600 active in-
gredients used in about 35,000 registered
pesticide products. These products are
registered  for control of 2,500 unique
pest species. Nearly 1.2 billion pounds of
pesticides  (on active ingredient basis) are
used in the United States each year at a
cost of about $6.5 billion in 1982.
  Farmers are the biggest users of pesti-
cides, accounting for 60 percent of total
U.S. expenditures. The value of pesti-
cides to the farmer is indicated by the  es-
timated losses from  insects alone — a 13
percent reduction in U.S. crop yields.
Agricultural scientists and economists
place the cost of insect control and los-
ses due to insects in excess of $23 billion
per year.
  Since the early 1960s, total  pesticide
usage in the U.S. has about doubled.
Most of the increase is due to expanded
agricultural use, which nearly tripled
since 1964. Non-agricultural usage  has
shown no  consistent tendency to in-
crease  in absolute or percentage terms
since the mid-1960s. During the last few
years, the  growth rate for agricultural
pesticide use has slowed somewhat due
to economic conditions and the influence
of improved pest management programs
which resulted in more efficient applica-
tion of pesticides and the use of alterna-
tive non-chemical pest controls. The year
1982 was the first in recent times when
total U.S. agricultural pesticide use de-

The chemical industry, a large and im-
portant part of the U.S. economy, con-
sists of 12,000 firms employing over one
million people.
  Nearly 90 percent of the chemical in-
dustry is based on petrochemicafs—
chemicals  derived from oil or natural gas.
The remainder of the industry consists of

                                                                                                          EPA JOURNAL

                                                                                  An osprey, one of the predator bird species
                                                                                  now increasing tn numbers because of pes-
                                                                                  ticide restrict;.
 inorganic chemicals, such as alkalides
 and chlorine, industrial gases, and mis-
 cellaneous chemicals, including those de-
 rived from natural products.
  There are about 60,000 chem-
 icals currently being used in a wide
 range' of products with over 1,000 new
 chemicals introduced for commercial use
 each year.
  Under the Toxic Substances Control
 Act, EPA gathers  information about the
 benefits as well as risks posed by both
 new and existing  chemicals. Where a
 chemical is found to pose unreasonable
 risks to health or  the environment, EPA
 acts to limit those risks by banning the
 chemical or placing restrictions  on either
 its production, usage or disposal.

 to Date

 EPA has cancelled many or all of the
 uses of a number of pesticides such as
 DDT, aldrin, dieldrin and toxaphene. As a
 result, the levels of these pesticides have
 declined in a number of wildlife species
 in the U.S. and once threatened pop-
 ulations of predatory birds, such as
 eagles and hawks, are now increasing in
  Major reductions  have also occurred in
the levels of these pesticides in  food.  As
 a result of these declines, the levels of
these pesticides in people have  been di-
  TSCA programs, while relatively new,
have made significant progress  in both
 limiting the risks posed by new  chem-
 icals and reducing unwarranted  risks
from existing chemicals, including PCBs,
dioxins and other  critical toxic sub-


EPA has screened more  than 3,300 new
chemicals. The majority  of these chem-
 icals were not found to present an unrea-
 sonable risk to human health or the en-
 vironment under the conditions of man-
 ufacture and use proposed by the manu-
 facturer. As a result of these reviews,
 however,  exposures to 37 chemicals have
 been banned or stringently controlled  by
 EPA pending the development of data.
  Another 61 new chemicals are now
 undergoing extensive health and environ-
 mental  testing for  possible re-submission
 to EPA's new chemical review process.
  Many of the 60,000  commercial  chem-
 icals now  used in the  U.S. are known to
 be hazardous and  may require some de-
 gree of control. The risks posed by others
 are poorly characterized or unknown.
 EPA is now reviewing the risks posed  by
 63 chemicals or chemical classes that
 appear  the most likely to cause either
 human  health or environmental prob-
  Under the Asbestos-in-Schoof Rule, a
 compliance monitoring program was in-
 itiated in June 1983. Over 200 local
 education  agencies and 653 schools were
 inspected  in 1983,  resulting in the  discov-
 ery of 127 violations. For 1984, EPA has
 begun efforts to inspect  1,047 school dis-


 According to several monitoring efforts,
 EPA restrictions on the use and disposal
 of PCBs have resulted in significant re-
 ductions in the levels of this persistent
 chemical both in the environment and  in
 people.  The decline in PCBs is following
the  similar pattern  established  by DDT
earlier in the  1970s. While trace levels  of
 PCB are now present throughout the U.S.
 population, the number of individuals
with high PCB levels, i.e. greater than 3
parts per million, has declined dramati-
cally to  less than 1  percent of the popula-
Pesticide and
Toxic Substances
Control Challenges

EPA has sought to control environmental
contamination by toxic chemicals by
reducing pollutants in air emissions,
water discharges and chemical waste
dumping. While these important pollu-
tion abatement efforts continue, EPA also
employs major programs, authorized
under both TSCA and FIFRA, to reduce
the unreasonable risks from chemical
products (including pesticides) now in
use and from any new chemicals that
may come onto the market. The task of
balancing the risks against the benefits of
chemicals will always be difficult. The
major challenges EPA faces today in con-
trolling toxic chemicals are:

Protecting Against Unwarranted Risks
from Pesticide Contamination. Significant
efforts to avoid unwarranted public
health and environmental risks from
these valuable chemicals  continue to be
a difficult but necessary challenge for
EPA. A number of pesticides are now on
the market that have  not been tested
against today's public health and en-
vironment standards. The contamination
of ground water by pesticides and the
drift of pesticides during aerial applica-
tion are capable of posing serious risks
to public health and the environment.
EPA will be subjecting "older"  pesticides
to new testing requirements and im-
proving its efforts to reduce contamina-
tion of ground water and  the problems of
Controlling Critical Toxic Substances.
Several toxic  substances require ex-
traordinary regulatory effort by EPA.
Their control  is complicated by either
their pervasiveness in the environment or
by the extremely low-level contamination
that can still pose threats to human
health. These substances  include asbes-
tos, PCBs, and dioxin. EPA has put in
place major inspection and enforcement
programs to further control, or where
necessary, cleanup these toxic chemicals

Screening for Toxic Chemicals. It is high
ly improbable that complete risk assess-
ments can be done for each of the ex-
isting 60,000 commercial chemicals or for
the over 1,000 new commercial chem-
icals developed each  year. The challenge
for  EPA is to improve its ability to assess
which chemicals  should be selected for
more intensive review so  as to reduce
major health and environmental risks
without needless overtaxing of gov-
ernment as well as industry resources. I I
APRIL 1984
                                                                                                                      ! '

Risk  in  a   Free  Society
In a speech at Princeton University Feb-
'ruary 18, EPA Administrator William
Ruckelshaus discussed the subject, "Risk
in a Free Society," as it involves the
chemical products and byproducts of
modern technology. He was speaking  to
1,000 Princeton alumni at Alumni Day at
the University.

Later in  the day, Ruckelshaus received
the highest honor that Princeton can bes-
tow on an alumnus—the Woodrow Wil-
son Award. The award is  presented an-
nually on Alumni Day "to the alumnus of
the undergraduate college whose activi-
ties exemplify Woodrow Wilson's ideal of
Princeton in the Nation's service."

Here are excerpts of the Administrator's
remarks on the issue of risks from chem-
icals today:
  "When I began my current, and
second, tenure as Administrator of EPA,
my first goal was the restoration of pub-
lic confidence in the Agency, and it was
impressed upon me that straightening
out the way we handled health risk was
central to achieving  it. Needless to say,
EPA's primary mission is  the reduction of
risk, whether to public health or the en-
vironment. Some in America were afraid.
They were afraid that toxic chemicals  in
the environment were affecting their
health, and more important, they sus-
pected that the facts about the risks from
such chemicals were not  being accurately
reported to them, that policy con-
siderations were being inappropriately
used in  such reports, so as to make the
risks seem less than they were and ex-
cuse the Agency from  taking action. Even
worse, some people thought that the
processes we had established to protect
public health were being  abused for
crass political gain.

  Whether this was true or not is almost
beside the point; a substantial number of
people believed it. Now in a society such
as ours, where the people ultimately de-
cide policy—what they want done about
a particular situation—the fair exposition
of policy choices is the job of public
agencies. The public agency is the re-
pository of the facts; you can't operate a
democratic society, particularly a com-
plex technological one, unless you have
such a repository. Above  all, the factual
guardian must be trusted: a failure  of
trust courts chaos. Chaos, in  turn, creates
its own  thirst for order, which craving in
its more extreme forms threatens the
very foundation of democratic freedom.
So in a democracy a public agency that
is not trusted, especially where the  pro-
tection of public health is concerned,
might as well close its doors.
  "I described a possible solution to this
problem last June in  a speech to the
National Academy of Sciences. The
Academy had stated  in a recent report
that Federal agencies had often confused
the assessment of risk with the man-
agement of risk. Risk assessment is the
use of a base of scientific research to de-
fine the probability of some harm coming
to an individual or a population as a re-
sult of exposure to a  substance or situa-
tion. Risk management, in  contrast, is the
public process of deciding  what to do
where risk  has been determined to exist.
It includes  integrating risk assessment
with considerations of engineering
feasibility and figuring out how to ex-
ercise our imperative to reduce risk in the
light of social, economic and political fac-
  "The report proposed that these two
functions be formally separated within
regulatory  agencies. I said  that this
appeared to be a workable idea and that
we would try to make it happen at EPA.
This notion was attractive because the
statutes administered by many Federal
regulatory  agencies typically force some
action when scientific inquiry establishes
the presence of a risk, as, for example,
when a  substance present  in the environ-
ment, or the workplace or the food chain,
is found to  cause cancer in animals. The
statutes may require the agency to act
according to some protective formula: to
establish 'margins of safety' or 'prevent
significant  risk' or 'eliminate the risk.'
  "When the action so forced  has dire
economic or social consequences, the
person who must make the decision may
be sorely tempted to  ask for a
'reinterpretation' of the data. We should
remember  that risk assessment data can
be like the  captured spy: if you torture it
long enough, it will tell you anything you
want to  know. So it is good public policy
to so structure an agency that such
temptation  is  avoided.
  "But we  have found that separating the
assessment of risk from its management
is rather more difficult to accomplish in
practice. In  the first place, values, which
are supposed to be safely sequestered in
risk management, also appear as impor-
tant influences on the outcomes of risk
assessments.  For example, let us sup-
pose that a chemical  in common use is
tested on laboratory animals with the ob-
ject of determining whether it  can cause
cancer. At the end of  the test a propor-
tion of the  animals that have been ex-
posed to the substance show evidence of
tumor formation.
   "Now the problems begin. First, in
tests like these, the doses given are ex-
tremely high, often close to the level the
animal can tolerate for a lifetime without
dying from toxic non-cancer effects. En-
vironmental exposures are typically
much lower, so in  order to determine
what the risk of cancer is at such lower
exposures—that is, to determine the
curve that relates a certain dose to a cer-
tain response—we must extrapolate
down from the high-dose laboratory
data. There  are a number of statistical
models for doing this, all of which fit the
data, and all of which are open to debate.
We simply do not know what the shape
of the dose-response curve is at low
doses, in the sense that we know, let's
say, what the orbit of a satellite will be
when we shoot it off.
   "Next, we must deal with the un-
certainty of  extrapolating cancer data
from animals to  man, for example, de-
termining which of the many different
kinds of lesions that may appear in an-
imals are actually indicative of a  prob-
ability that the substance in question
may be a human carcinogen. Cancer is
cancer to the public, but not to the patho-

  I inally, we must deal with uncertainty
about exposure. We have to determine,
usually on the basis of very scant data,
and very elaborate mathematical models,
how much of the stuff is being produced,
how it is being dispersed, changed or de-
stroyed by natural processes, and how
the actual dose that people get is
changed by  behavioral or population
  "These uncertainties inherent in risk
assessment combine to produce an enor-
mously wide range of risk estimates in
most cases.  For example, the  National
Academy of Sciences report on saccharin
concluded that over the next 70 years the
expected number of cases of human
bladder cancer resulting from daily expo-
sure to 120 mg of saccharin might range
from 0.22 to 1,144,000. This sort of range
is of limited  use to the policy maker and
risk assessment scientists are at some
pains to make choices among possibili-
ties so as to produce conclusions that are
both scientifically supportable and us-
  "Such choices  are influenced by val-
ues, which may be affected by pro-
fessional training, or by ideas about what
constitutes 'good science,' and, of course
by the same complex of experience and
individual traits that gives rise to per-
sonal values in all of us. An oncologist,
                                                                                                           EPA JOURNAL

                  DE    SVB  NVMINE
                           3 » *^        	      "
for example, who values highly the abil-
ity to distinguish between different sorts
of lesions, may discount certain test re-
sults as being  irrelevant to decisions
about human carcinogenicity. A public
health epidemiologist may look at the
same data and come to quite different
  "Historically at EPA it has been thought
prudent to make what have been called
conservative assumptions; that is, our
values lead us, in a situation of unavoid-
able uncertainty, to couch our con-
clusions in terms of a plausible upper
bound. This means that when we gener-
ate a number that expresses the potency
of some substances in causing disease,
we can state that it is unlikely that the
risk projected is  any greater.
  "This is fine when the risks projected
are vanishingiy small: it's always nice to
hear that some chemical is not a national
crisis. But when  the risks estimated
through such assessments are sub-
stantial, so that some action  may be in
the offing, the stacking of conservative
assumptions one on top of another, be-
comes a problem for the policymaker. If I
am going to propose controls that may
have serious economic and social effects,
I need to  have some idea how much con-
fidence should be placed in the estimates
                                                                                  board of '             <   the Woodrpw
                                                                                  D R.:
                                                                                  ment in fiS        s service. "
                                          of risk that prompted those controls. I
                                          need to know how likely real damage is
                                          to occur in the uncontrolled and partially
                                          controlled and fully controlled cases.
                                          Only then can I apply the balancing judg-
                                          ments that are the essence of my job.
                                          This, of course, tends to insert the policy-
                                          maker back into the  guts of risk assess-
                                          ment, which we've agreed is less than
                                            "This is a real quandary. I now believe
                                          that the main road out of it lies through a
                                          marked improvement in the way we
                                          communicate the  realities of  risk analysis
                                          to the public. The  goal is public under-
                                          standing. We will  only retain the adminis-
                                          trative flexibility we  need to effectively
                                          protect the public  health and welfare if
                                          the public believes we are trying to act in
                                          the public interest. There is an argument,
                                          in contradiction, that the best way to pro-
                                          tection lies in increased legislative
                                          specificity, in closely directing the Agen-
                                          cy as to what to control and how much
                                          to control it.  If we  fail to command public
                                          confidence, this argument will prevail,
                                          and in my opinion it would be a bad
                                          thing if it did. You can't squeeze the com-
                                          plexity inherent in managing environ-
                                          mental risks between the pages of a sta-
                                          tute book.
    low then do we encourage confi-
dence? Generally speaking there are two
ways to do it. First, we could assign
guardianship of the Agency's integrity—
its risk assessment task—to a panel of
disinterested experts who are above re-
proach in the public eye. This is the
quasi-judicial, blue-ribbon approach,
which has a strong tradition in our soci-
ety. If we  have  a complex issue, we don't
have to think about it very much, just
give it to the experts, who deliberate and
provide the answer, which most will ac-
cept because of the inherent prestige of
the panel.
  "The discomfort associated with im-
agining, in 1984, a conclave of Big
Brothers to watch over us only streng-
thens my  conviction that such panels
cannot serve the general purpose of
restoring and maintaining confidence. It
turns  out that the experts don't agree, so
instead of an unimpeachable and dis-
interested consensus you get dissenting
advocacy. Once again, experts have val-
ues too.
  "Alternatively, we could all become a
lot smarter about risk. The Agency could
put much  more effort into explaining
what it is doing and what it does, and
does not, know. Here I do not mean
"public involvement" in the usual and
APRIL 1984

formal sense. This is embodied in ad-
ministrative law and has always been
part of our ordinary procedure in pro-
mulgating rules. Nor do I mean a mere
public relations campaign to popularize
Agency decisions. Public relations
smoothes over; I think we need to dig
up. We have to expose the assumptions
that go into risk assessments. We have to
admit our uncertainties and confront the
public with the complex nature of de-
cisions about risk.

  Living in a technological society is like
riding a bucking bronco. I don't believe
we can afford to get off, and I doubt that
someone will magically appear who can
lead it about on a leash. The question  is:
how do we become better bronco bus-
ters? I think a great part of the answer is
to bring about a major  improvement in
the quality of public debate on environ-
mental risk.
  "This will not be easy. Risk assessment
is a probabilistic calculation, but people
don't  respond lo risks "as they should" if
such calculations were  the sole criterion
of rationality. Most  people are not com-
fortable with mathematical probability as
a guide to living and the risk assessment
lingo  we  throw at them does not increase
their comfort. Tell somebody that their
risk of cancer from a 70-year exposure to
a carcinogen at ambient levels ranges  be-
tween 10"fa and 10 7, and they are  likely
to come back at you with, 'Yeah, but will
I  get cancer if I drink the water?' Also,
attitudes  toward risk are subjective and
highly colored by  personal experience
and other factors not fully captured by
risk assessments.
  "We have some  research on this,
which points out that people tend to
overestimate the probability of un-
familiar, catastrophic and well-publicized
events and underestimate the probability
of unspectacular or familiar events that
claim  one victim at a time. Many people
are afraid to fly commercial airlines, but
practically nobody is afraid of driving in
cars, a victory of subjectivity over actua-
rial statistics.
  "In  general, response to risks is most
negative  when the degree of risk is un-
known and the consequences are  particu-
larly dreaded.  Expert assessment does
not seem to help here.  People will fight
like fury to keep a hazardous waste facil-
ity out of their neighborhood, despite ex-
pert assurances that it is safe, while peo-
ple living under high dams  located on
earthquake faults  pay scant attention to
expert warnings.
  "Other hazard characteristics influence
public perceptions of risk. For example,
the voluntary or involuntary nature of  the
risk is important. People will accept far
greater risks from driving an automobile
than they witi from breathing the emis-
sions that come out of its tailpipe; the
former is voluntary, the latter, in-
voluntary. People also take into con-
sideration whether the risk is distributed
generally throughout the population or
affects only a small identifiable  group.
Public response to the discovery of a tox-
icant that may result in 200 additional
cancers nationwide is liable to be quite
different from public response to the
same number of cases in one county
with a population of say, 3000.
  "The way risks and options are pre-
sented also influences perceptions. You
might be worried if you heard that
occupational exposure at your job doubled
your risk of some serious disease; you
might be less worried if you heard that it
had increased from one in a million  to
two in  a million. Surveys using  physi-
cians as subjects found that their prefer-
ences for treatment options changed
markedly when the risks of these options
were expressed in terms of lives saved
rather than in terms of deaths occuring,
even though the two forms of expression
that were compared were  mathematically
identical. Finally, research  has shown
that beliefs about risk are slow to
change, and show extraordinary persist-
ence in the face of contrary evidence.
  "Many people interested in environ-
mental protection, having  observed this
mess, conclude that considerations of
risk lead to nothing useful. After all,  if the
numbers are no good and  the whole
issue is so confusing, why not just
eliminate all exposure to toxics  to the ex-
tent that technology allows? The problem
with such thinking is that,  even  setting
aside what I have just said about the
necessity for improving the national de-
bate on the subject, risk estimates are the
only way we have of directing the atten-
tion of risk management agencies toward
significant problems.

   I here are thousands of substances in
the environment that show toxicity in an-
imals; we can't work on all of them at
once, even with an EPA ten times  its cur-
rent size. More important,  technology
doesn't make the bad stuff 'go  away;' in
most cases it just changes its form and
location. We have to start keeping track
of the flow of toxics through the environ-
ment, to what happens after they are
'controlled.' Risk management  is the
only way I know to do this.
  "In confused situations one must try to
be guided by basic principles. One of my
basic principles is reflected in a  quotation
from Thomas Jefferson;  'If we think  (the
people) not enlightened enough to ex-
ercise their control with a wholesome
discretion, the remedy is not to take it
from them, but to inform their discre-
tion.' Easy for him to say. As we  have
seen, informing discretion  about  risk has
itself a high risk of failure.
  "However, we do have some recent ex-
perience that supports the belief  that bet-
ter information inclines people to act
more sensibly. In Tacoma, Washington,
we have a situation where a copper
smelter employing around 600 people is
emitting substantial amounts  of arsenic,
which is a human carcinogen. We found
that the best available technology did not
reduce the risk of cancer to levels the
public might find acceptable. In fact, it
looked as  if reducing to  acceptable levels
of risk might only be possible if the plant
closed.  I felt very strongly  that the people
in Tacoma whose lives were to be
affected by my decision  ought to have a
deeper  understanding of the case than
they could get from the  usual public
hearing process.

  /•Accordingly,  we organized an ex-
traodinary campaign of  public eduction
in Tacoma.  Besides the  required  public
hearing, we provided immense quantities
o,f information to all communications
media,  arranged meetings between com-
munity leaders and senior EPA officials,
including  myself, and held three work-
shops  at which we laid  out our view of
the facts.  I think most people  appreciated
this opportunity, and we certainly raised
the level of discussion about  risk. So un-
usual was this kind of event that some
inferred that I was abdicating my respon-
sibility for this decision, or that somehow
the Tacoma people were going to vote
on whether they wanted jobs or  health.
After some  initial confusion on this score
we made  it clear that it  was entirely my
decision, and  that while I wanted to hear,
I was not  committed to  heed.
  "Although I suppose some  would have
been happier  continuing in their  fond be-
lief that we  could provide  absolute safety
with absolute certainty,  and were dis-
turbed  by these  proceedings, in all I
would call it a qualified  success.  Those
who participated came away with a bet-
ter understanding of the anatomy of en-
vironmental decisions, and local  groups
were able to come up with options that
increased protection while allowing the
plant to remain open, options that are
well worth considering as we put
together our final decision.
  "What are the lessons of Tacoma?
Shortly after we began the workshops,
people  started sporting  buttons that said,
' BOTH, ' meaning they  were for  both
jobs and health. I took this as a good
sign, that  people were attending  to the
balance between economic realities and
environmental protection.  'Both' is a
                                                                                                             EPA JOURNAL

good idea, and in most cases we can
have it, if we're smart. Another lesson is
that we must improve the way we pre-
sent risk calculations to the public.
There was too much tendency to trans-
late risks of cancer into cases, with no re-
gard to qualifying assumptions and un-
certainties. Cancer threats make great
headlines and the inclination to infer
certainty where none exists is very
powerful. We must take seriously our
obligation to generate lucid and un-
ambiguous statements about risk. Finally,
Tacoma shows that we have to prepare
ourselves for the other Tacomas. En-
vironmental stress falls unevenly across
the land and we have a special responsi-
bility to people in communities that suf-
fer more than their share. We are pre-
pared to make the extra effort in such
communities, as we did in Tacoma.
  "We must also improve debate on the
national level. This may prove more dif-
ficult, as Washington is a most con-
tentious place. Also,  at the national level
things  tend to polarize perhaps more
than they should, given how much we
know about environmental health ques-
tions. Typically, where we obtain evi-
dence of an environmental threat, opin-
ion divides between those who want to
eliminate the  risk  as quickly as possible,
with little concern about cost, and those
who deny the threat  exists.  Fights be-
tween these groups can go  on for a long
time, time during  which the object of the
battle,  the pollutant, remains in the en-
vironment. Acid rain threatens to become
this kind of dispute.

 f\nd so too was the case of ethylene
dibromide. As you may know, we recent-
ly  banned the major  uses of EDB, a grain
and fruit fumigant that has been identi-
fied as a carcinogen, and which enters
the human diet through residues in food
and via ground water contamination. By
means of that ban, which applied to
grain fumigation, we insured that EDB
would  immediately begin to diminish in
the human food supply. Since there is
still EDB in the grain products already in
storage or on grocers' shelves, we set
maximum acceptable residue levels for
different products, the levels getting low-
er  in products closer to the point of con-
sumption. We will act soon  on the use of
EDB as a citrus fruit fumigant, its only
remaining use in connection with the
human food chain,  fsee sfo/y on p. 18}
  "Needless to say,  we were criticized
both for going too far and for not going
far enough. But in cases such as this, my
personal predilection is to avoid the ex-
tremes and act to  reduce, as quickly as
possible, environmental exposure to  sub-
stances that appear unacceptably risky,
and to  do so with as little social  or eco-

APRIL 1984
nomic disruption as possible. This gener-
ally satisfies no one, but I arn convinced
it is in the long term public interest.
  "What was dissatisfying about the EDB
case was the substantial confusion sur-
rounding the risk issues involved. Some
say that we stir up cans of worms when
we expose the risk judgments we make.
I think we must do better than we have
done, and let the worms crawl where
they may. Let me  now propose some
principles for more reasonable dis-
cussions about risk.
  lirst, we must insist on risk calcula-
tions being expressed as distributions of
estimates and not as rnagic numbers that
can be manipulated without regard to
what they really mean. We must try to
display more realistic estimates of risk to
show a range of probabilities. To help do
this we need new tools for quantifying
and ordering sources of uncertainty and
for putting  them in perspective.
  "Second, we must expose to public
scrutiny the assumptions that underlie
our analysis and management of risk. If
we have made a series of conservative
assumptions within the risk assessment,
so that it represents an upper bound es-
timate of risk, we should try to com-
municate this and explain why we did it.
Although public health protection is our
primary value, any particular action to
control a pollutant  may have effects on
other values, such as community stabil-
ity, employment, natural resources  or the
integrity of the ecosystem. We have to
get away from the  idea that we do quan-
titative analysis to find the 'right' deci-
sion, which we will then be obliged to
make  if we want to call ourselves rational
beings. But we  are not clockwork man-
darins. The point of such analysis is, in
fact, the orderly exposition of the values
we hold, and the reasoning that travels
from some set of values and measure-
ments to a  decision.
  "Third, we must demonstrate that
reduction of risk is our main concern and
that we are not driven by narrow cost-
benefit considerations. Of course cost is
a factor, because we are obliged to  be
efficient with our resources and those of
society in general. Where we decline to
control some risk at present, we should
do so  only because there are better tar-
gets; we are really  balancing risk against
risk, aiming to get at the greatest first.
  "Finally, we should understand the
limits  of quantification; there are some
cherished values that will resist being
squeezed into a benefits column, but are
no less real because of it. Walter
Lippmann once pointed out that in a
democracy  'the people' as in 'We the
 People,' refers not only to the working
 majority that actually makes current de-
 cisions, and not only to the whole living
 population, but to those who came be-
 fore us, who  provided our traditions and
 our physical  patrimony as a nation, and
 to those who will come after us, and in-
 herit. Many of the major decisions we
 make on environmental affairs touch on
 this broader sense of public responsibil-
   "I suppose that the ultimate goal of
 this effort is to get the American people
 to understand the difference between a
 safe world and a zero-risk world with re-
 spect to environmental pollutants. We
 have to define what safe means in light
 of our increasing  ability to detect minute
 quantities of  substances in the environ-
 ment and to  associate carcinogenesis
 with an enormous variety  of substances
 in common use. According to Bruce
 Ames, the biochemist and cancer expert,
 the human diet is loaded with toxics of
 all kinds, including many carcinogens,
 mutagens and teratogens. Among them
 are such foodstuffs as black pepper,
 mushrooms,  celery, parsnips, peanut but-
 ter, figs, parsley, potatoes, rhubarb, cof-
 fee, tea, fats,  browned meat and alfalfa
 sprouts. The  list goes on;  my point is
 that it would  be hard to find a diet that
 would support life and at the same time
 impose no risk on the consumer.

  Oo  what is safe? Are we all safe at
 this instant? Most of us would agree that
 we are, although we are subjected to
 calculable risks of various sorts of catas-
 trophes that can happen to people
 listening to lectures in buildings. We
 might  be able to reduce some of them  by
 additional effort, but in general we con-
 sider that we  have (to coin a phrase) an'
 'adequate margin  of safety' sitting in a
 structure that is, for example, protected
 against lightning bolts but exposed to
  "I think we  can get people to start mak-
 ing those judgments of safety about the
 arcane products of modern technology. I
 don't think we are ever going to get
 agreement about values; a continuing
 debate is the  essence of a democratic
 policy. But I think we must do better in
 showing how different values lead
 rationally to different policy outcomes.
 And we can only do that if we are able to
 build up a reservoir of trust, if people be-
 lieve that we  have presented what facts
 we have fairly, that we have exposed our
values to their view, and that we have re-
 spected their  values, whether or not such
values can be incorporated finally in our
decisions.  We have, I hope, begun to
build that sort of trust at EPA." D

Public  Meeting  Set
on   Asbestos   in  Buildings
f\ public meeting will be held in
Washington, D.C. on May 7 to gather
information on asbestos contamination
in schools and other public buildings.
   EPA recently granted, in substantial
part, a petition from the Service Em-
ployees International Union to begin pro-
ceedings to deal with the asbestos prob-
lem in schools.
   The union specifically asked  in its peti-
tion that the agency 1) establish stan-
dards for determining when friable
(easily crumbled) asbestos-containing
materials in schools are hazardous; 2) es-
tablish requirements for corrective action
when friable asbestos-containing mate-
rials are determined to be hazardous; 3)
establish requirements for inspections
and abatement of friable asbestos-
containing materials in public and com-
mercial buildings; 4) establish standards
for the performance of abatement activi-
ties, including standards for the protec-
tion of persons performing such activi-
   The petition was submitted under Sec-
tion 21 of the Toxic Substances Control
Act. Section 21 allows citizens to petition
EPA to initiate rulemaking.  EPA Adminis-
trator William D. Ruckelshaus granted
most provisions in the petition.
   Ruckelshaus said that "EPA is in full
agreement with the goals of the petition
and intends to ensure that human health
is protected to the fullest extent possible
where asbestos is concerned."
   EPA intends to assure that friable
asbestos-containing  materials in schools
and public buildings which present un-
reasonable risks are identified and prop-
erly abated. Earlier EPA attempts to de-
velop a general rule for all situations
where friable asbestos-containing mate-
rials are present in schools have not
been  possible because of technical limita-
tions  and site variations. However, EPA
will be reexamining  this issue and
seeking new information.
   Accordingly, the agency has granted
the union's request to initiate a pro-
ceeding under section 6 of the Toxic Sub-
An asbestos ceiling with sections torn open-

stances Control Act. Under this Act, any
person may petition EPA to commence
an appropriate proceeding in accordance
with section 6.
  Regarding the petitioner's request that
EPA set standards to protect persons per-
forming asbestos control activities, the
agency said both EPA and the Occupa-
tional  Safety and Health Administration
(OSHA) have issued regulations to re-
duce exposure to asbestos. EPA first
issued regulations in 1973 which speci-
fied methods for removing asbestos-
containing materials from buildings
during demolition. OSHA's regulations
were first issued in 1972 and modified in
1976. They specify airborne exposure
standards for asbestos workers, engi-
neering and administrative contracts,
work practices, medical surveillance and
worker protection requirements. In addi-
tion, both agencies have prepared further
  Since there are existing and or pro-
posed regulations under the Clean Air
Act and Occupational Safety and Health
Act to protect workers during removal of
asbestos-containing materials from build-
ings the agency finds that additional
workplace regulation by EPA under TSCA
is not necessary to protect health or the
environment against unreasonable risk.
  The agency is continuing to gather in-
formation on the extent of compliance
with EPA's asbestos-in-schools rule and
on what subsequent actions are being
taken by schools. The agency is in the
process of increasing resources ex-
pended on technical assistance and en-
forcement of existing regulations.
  Under EPA's  asbestos-in-schools rule
published in  1982, all public and  private
schools were to inspect their facilities for
friable asbestos by June 28, 1983. Those
schools that found asbestos were re-
quired to keep records, inform em-
ployees and Parent-Teacher Associations,
post notices, and distribute a guide for
reducing asbestos exposure to custodial
and maintenance personnel.
  Through its technical assistance pro-
gram, the agency is also continuing to
assist building owners in the detection
                                                                                                       EPA JOURNAL

                                          EPA  Assesses  Penalty
                                         for  Asbestos  Violations
and correction of hazards posed by
asbestos in schools and public and com-
mercial buildings.
  EPA is currently conducting a com-
pliance monitoring program. Approx-
imately 2,500 compliance inspections will
be conducted during a two-year effort. By
June, the agency will have available in-
formation from a national survey of
schools to provide reliable estimates of
compliance as well as the level of abate-
ment activities. The result of these activi-
ties will also be a guide in developing an
appropriate protection program.
  In addition to the public meeting, EPA
is soliciting written comments, due by
April 23. For further information,
Jack P. McCarthy, Director
TSCA Assistance Office (TS-799)
Office of Toxic Substances
U.S.  Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Toll-free: 800-424-9065
In Washington, D.C.: 554-1404. D
In the first administrative civil complaint
ever issued under EPA's school asbestos
rule, the agency is assessing a $24,000
penalty against New Hampshire
Administrative Unit No. 19 for violations
at three of the schools under its
jurisdiction. EPA is also taking similar
actions in some  other parts of the
  The New Hampshire Unit No. 19
operates ten schools in the towns of
Weare, Goffstown, Bow, Dunbarton, and
New Boston.
  The complaint, issued recently under
authority of the  Toxic Substances Control
Act, alleges that Unit No. 19 has failed to
meet the requirements of EPA's asbestos
rules for three of its schools. All these
schools are in Goffstown:  Goffstown
High School, Bartlett Elementary School,
and Upper Goffstown Elementary School.

  "This action shows that  EPA will not
hesitate to fine school officials anywhere
in this country who are negligent in
telling parents about any asbestos dan-
ger faced by their children," said EPA
Deputy Administrator Alvin Aim.
  Scientific evidence points to asbestos
as a cause of lung cancer and of
mesothelioma, a cancer of the mem-
branes that line  the chest and abdomen.
  Under EPA's school asbestos rules,
issued May 27, 1982, all public and pri-
vate elementary and secondary school
administrators were required,  by June
28, 1983, to have inspected their build-
ings, sampled and analyzed any friable
materials for asbestos, notified em-
ployees and parents of  any asbestos de-
tected, and maintained  records certifying
compliance with the regulation. (Friable
materials are those that when dry may
be crumbled, pulverized, or reduced to
powder by hand pressure.)
  "On-site EPA inspections of the three
schools as recently  as November 30,
1983 showed them  all having friable
asbestos-containing materials; yet Unit
No. 19 never performed  proper in-
spections on the three schools or any
sampling, analysis or public notification
as required by the !aw," Aim added.
  Under TSCA, Unit 19 had 20 days from
the receipt date of the EPA penalty notice
to request a hearing on the issues.
  Elsewhere nationally, EPA is taking
other actions over and above its May
 1982 federal rules to reduce school
 asbestos threats.
   Since 1979 EPA has operated a tech-
 nical assistance program which includes
 the following:

 • In all 10 EPA regional offices, Re-
 gional  Asbestos Coordinators,  assisted
 by technical advisors hired under an
 American Association of Retired Persons
 grant.  This team responds to public ques-
 tions, distributes guidance documents,
 conducts training seminars, and gives
 guidance on different alternatives in
 reducing asbestos exposure.

 • A quality assurance program in
 which  175 laboratories participate. The
 program includes a toll-free number
 where  callers can get guidance on an-
 alyzing asbestos  samples (800-334-8571,
 Ext. 6741).

 • A toll-free number where the general
 public  can direct  requests for technical
 assistance (800-424-9065).

 • A guidance document which
 summarizes information on the identifica-
 tion and abatement of asbestos-
 containing materials. This document out-
 lines a  systematic process for building
 owners to follow in selecting a  course of
 action  ("Guidance for Controlling  Friable
 Asbestos-Containing Materials  in Build-
 ings,"  March 1983, EPA Report No. 560 5-

   In addition to the technical assistance
 program, EPA has also taken the
 following action:

 •  Last  fall, EPA began a representative
 sample survey  of local education agen-
 cies to  determine the effectiveness of the
 federal  school asbestos rule.

 •  A comprehensive two-year com-
 pliance monitoring program has been
 under way since June 1983, targeting ap-
 proximately 2400 school districts for in-
 spections.  In some cases, EPA will work
 directly with states to monitor for com-
 pliance with the federal rule.

  EPA recently  got authorization to hire
 16 new full-time employees in its region-
al offices in order to strengthen the
technical assistance and compliance
monitoring programs for asbestos. D
   APRIL 1984

Further  Steps  Taken
to  Eliminate  EDB
/Administrator William D. Ruckelshaus
recently announced a rapid reduction
in residue levels of the pesticide
ethylene dibromide (EDB) in citrus fruits
and papayas that will eliminate all EDB in
such fruit by September 1.
  Ruckelshaus said the lesson that can
be Learned from the experience with EDB
is that while some pesticides can prove
on balance to be beneficial to society,
"we need to be very careful  about under-
standing what we are doing  when we in-
troduce, in a massive way, pesticides into
the environment,..."
  In the phased reduction in EDB residue
levels in citrus fruits, Ruckelshaus pro-
posed interim maximum tolerances of
250 parts per  billion for the whole fruit,
which equates to 30  ppb for the edible
portions of the fruit.
  The phasedown in residue levels will
apply to both domestic and imported
fruits. Once these tolerances are es-
tablished by rulemaking, fruit exceeding
these levels will not be allowed into the
country or in interstate commerce and
will be subject to enforcement action by
the federal government.
  After September 1, any detectable re-
sidues of EDB in  citrus fruit or papayas
will render the commodities adulterated
and subject to enforcement action under
the Federal Food, Drug and Cosmetic Act.

  "This latest action  moves us closer to
my goal of getting EDB out of the Amer-
ican diet in as orderly a way as possi-
ble,"  Ruckelshaus said.
  He  added that he was not  issuing an
immediate emergency suspension order
to ban EDB as a quarantine fumigant on
citrus for two reasons. "First, the use of
EDB on citrus in the  U.S. has essentially
ceased," he said. "Second, the agency
has reached an agreement in principle
with the parties in the EDB cancellation
hearing under which all domestic use of
EDB on citrus for the U.S. market would
end by September I of this year. Based
upon  this understanding, those parties
would withdraw their cancellation
hearing requests."
  Ruckelshaus said that EPA estimates
only two percent of all fresh citrus fruit
consumed in this country is fumigated.
Domestically produced fruit was only
fumigated when going to one citrus-
producing state from another; these
states are Florida, Texas, Hawaii, Arizona,
New Mexico, and California. EDB current-
ly is not being used for this purpose ex-
cept for a small amount of fruit being
treated in Florida before its shipment to
Hawaii. Papayas from Hawaii as well as
imported  fruit are currently being treated
with EDB.
  Ruckelshaus pointed out that in virtual-
ly all cases citrus processed into orange
juice is not fumigated. The fruit is har-
vested and transported to the nearest
processing establishment as quickly as
  He said the recent EPA action does not
include tolerance levels for mangoes be-
cause of a lack of sufficient data. "We in-
tend to make this tolerance consistent
with those for other ready-to-eat foods,"
he commented, saying, "The mango
growing and shipping season is just now
starting and we simply do not have
enough residue data  to take final action. I
will take appropriate  action when I do
have adequate information."
  The EPA Administrator said there  are a
number of alternatives to EDB fumiga-
tion, which is used on fresh fruit to pre-
vent the spread of tropical fruit flies.
Among them are gamma irradiation,
certification of fruit fly free zones, heat
treatment for papayas, and fumigation
with methyl bromide and phosphine gas.
EPA, however, is concerned with the
potential risks of methyl bromide and will
consider the conclusions of several
health studies nearing completion. In
addition, imported and  exported fruit
have also been quarantined in extended
cold storage, which is another .alternative
being considered.
  All alternative treatment methods for
citrus imports need the approval of the
U.S. Department of Agriculture (USDA}
as being effective in preventing importa-
tion of various species of fruit fly.
  Ruckelshaus added that the agency is
working closely with USDA, the State De-
partment, the Food and  Drug Administra-
tion (FDA), the Agency for International
Development and the U.S. Trade Repre-
sentative's office so that "they will aid
affected domestic industries as well as
importing countries in finding suitable
alternatives to EDB."
  Concerning U.S. export markets, Ruck-
elshaus said, "By far the most important
market is in Japan. The Japanese gov-
ernment requires quarantine treatment of
imported citrus, the most common of
which is EDB fumigation to protect
against citrus pests, although it has
allowed several test shipments of cold
treated fruit....The continued  use of EDB

                                                                                                        EPA JOURNAL

Papaya fruit, one of the products protected
by ERA'S recent action on the pesticide
                                          New  Air  Rules  Proposed
                                         for  Participate   Matter
on citrus exported from this country is in-
tended to provide flexibility for...coun-
tries to meet their own quarantine re-
quirements and to make their own de-
cisions on  acceptable pesticide re-
  "We will ensure that the treatment of
fruit leaving this country will satisfy the
requirements of Japan and other coun-
tries as long as the U.S. workers treating
the fruit are adequately protected," Ruck-
elshaus said.
  Unde'r the Food, Drug and Cosmetic
Act, EPA establishes pesticide tolerances
on food products, with these levels en-
forced by FDA or, in the case of meat
and poultry, by USDA. These agencies
sample both domestic and imported
products and may seize shipments which
exceed residue levels.
  On February 3,  Ruckelshaus suspended
the use of  EDB as a fumigant for stored
grain and grain milling machinery. This
action followed the suspension on Sep-
tember 30  of last  year of the use of EDB
as a soil fumigant for crops, which
accounted  for some 90 percent of its
agricultural uses.
  The 30 ppb level for edible portions of
fruit is the same as EPA's recommended
level for ready-to-eat grain-based prod-
ucts, recommended February 3 as a max-
imum  permissible residue  level. That
grain residue level, and two others rec-
ommended as guidelines for raw grain
and intermediate  level products, have
now been  proposed as federally enforce-
able levels. The agency has also moved
to revoke an exemption to setting EDB
residue levels that had been  granted
grain products. The exemption had pre-
vented EPA from  setting toferance or ac-
tion levels enforceable by FDA.
  EPA's proposed tolerance levels for cit-
rus fruit and papayas were subject to a
30-day public comment period.
  Commenting on EPA's actions on EDB,
Ruckelshaus said, "Again, I want to re-
mind everyone that the risks associated
with exposure to  EDB are chronic risks
that accrue over a long period of time.
EDB does not present an acute short-
term health risk." Li
 I he EPA has proposed major revisions of
the national clean air standards for par-
ticulate matter, changing the focus from
larger total particles to smaller, inhalable
particles that are more damaging to
human health.
  "We're defining the health standards
for particulate matter in a more careful
way so we're getting at the problems
that are really a concern to  us," Adminis-
trator William Ruckelshaus said.
  The Administrator explained that the
smaller particulates that penetrate farther
into the human lung "pose  the greatest
risk and those are the ones  we are trying
to  control with the new standards. They
will provide more effective protection of
public health."
  The proposal calls for replacing the
current primary (health-related) standards
for total suspended particulate matter
(TSP) with a new indicator that includes
only those particles that are 10 micro-
meters or smaller (PM10). The new 24-
hour primary standard  would be a num-
ber selected from a range of 150-250
micrograms per cubic meter of air. In
addition, the annual primary standard
would be a number selected from  a
range of 50-65 micrograms  per cubic
meter of air.
  The new secondary (welfare-related)
standard would  replace the  current 24-
hour secondary standard with an annual
standard selected from a range of 70-90
micrograms per cubic meter of air.
  A thorough three-year review of
thousands of health and welfare studies
contained in the criteria document for
particulate matter ted to significant
agreement among scientists in a number
of areas, including the decision to change
the measurement.
  However, the issue of the numerical
stringency of the 24-hour and annual
standards was a particularly difficult one,
and led the Clean Air Scientific Advisory
Committee, a Congressionally-mandated
committee of scientists and engineers
outside of government which advises the
EPA Administrator on air quality issues,
to agree with EPA staff that the available
scientific information was sufficient to
produce only relatively broad ranges of
possible standard levels.
  "There is no clear statutory guide to
determine what constitutes an adequate
margin of safety within this range," Ruck-
elshaus said. "Our standards are set to
protect the most vulnerable portions of
the population, and so I am proposing
the range that the EPA staff and the
scientific community have given to me,
and am asking for public  participation in
the final decision by inviting public com-
ment not only on the most appropriate or
reasonable number within each range
but also on the factors that EPA may ul-
timately take into account in setting pri-
mary standards with an adequate margin
of safety."
  Particulate matter is the general term
for a broad class of chemically and physi-
cally diverse substances consisting large-
ly of dust, dirt, soot and smoke. Human
activities  and  natural sources are es-
timated to generate a  hundred miltion
tons or more of particulate matter each
year. These pollutants may be emitted di-
rectly or formed in the atmosphere by
transformations of gaseous emissions. At
elevated concentrations, particulate
matter can be harmful to  human health,
visibility,  climate, vegetation, and may
soil materials and otherwise become a
  In 1971, EPA set national ambient stan-
dards for total suspended particulate
matter (TSP) under the Clean Air Act. The
current primary standards for TSP are
260 micrograms cubic meter, averaged
over 24 hours, and 75 micrograms cubic
meter, annual geometric mean. (A micro-
gram (ug), or one-millionth  of a gram, is
equal to 1 28,000,000 of an ounce.] The
current secondary standard for TSP  is
150 micrograms cubic meter for the 24-
   APRIL 1984

hour average, with one allowed ex-
ceedance per year.
  The 1977 amendments to the Clean Air
Act require EPA to review all  national
ambient air quality standards every five
years. The new proposal has  been the
subject of numerous public meetings
held over the last several years.
  The proposal for revising the particu-
late matter standards involves several
changes. First, EPA is soliciting comment
on its decision to measure only particles
of 10 micrometers or smaller for the pri-
mary standards, rather than all sizes of
particles  currently measured.  These
smaller particles are likely to  be respon-
sible for  most of the adverse  health
effects because of their ability to reach
the thoracic or lower regions  of the res-
piratory tract. This standard for parties
late matter of 10 micrometers or smaller
is thus known as  a PM10 standard. [One
micrometer (urn)  is one-millionth of a
meter, or 1 25,000 of an inch. For com-
parison, the thickness of a human  hair is
about 100 or 200  um, and common bac-
teria are  about one to two um in length.!
  A second aspect of the proposal, and
one that  is unique in proposals of
ambient air quality standards, is Ruckel-
shaus's decision not to select a specific
number for the proposed standards but
rather to  propose a range from which to
select that standard. These ranges were
refined following  the advice of the Clean
Air Scientific Advisory Committee to in-
corporate a wider margin of safety for
particulate matter.
  The purpose  in using this approach is
to inform the public of the uncertainties
in the scientific data and to solicit in-
creased public participation in the  proc-
ess of selecting the final standards. Ruck-
elshaus has indicated that, after con-
sidering public comments, he will  select
specific numbers  for the standards within
those ranges.
  EPA is  soliciting comment and informa-
tion from the public to be considered in
formulating  a final regulation which will
identify a specific level for both the pri-
Sources of Particulate Matter
  « Coal
  • Oil
  • Wood
  • Gasoline
• Sulfur Dioxide
• Organics
• Water Vapor
• Highway Traffic
• Industrial Processes
• Storage Silos
• Construction
• Agriculture
• Volcanos
• Dust Storms
• Sea Salt
• Pollen
• Forest Fires
                                                                                                               EPA JOURNAL

mary and secondary standards. Ruckel-
shaus said he is asking the public to
"look at what I look at" and help  in the
process of deciding where that level
ought to be.
  Given the precautionary nature of the
Clean Air Act, Ruckelshaus indicated that
he is inclined to select the levels of the
primary standard from the lower  portions
of the proposed ranges. This would allow
a greater  margin of safety to public
health than those numbers at the high
ends of the ranges.
  Based on studies of human pop-
ulations exposed to historically high con-
centrations of particles, and laboratory
studies  of animals and humans, the ma-
jor health effects are those on breathing
and  the respiratory system, aggravation
of existing respiratory and cardiovascular
disease, alterations in the body's  defense
systems against foreign materials, dam-
age  to lung tissues, carcinogenesis, and
premature mortality. It is difficult  to eval-
uate the extent to which any  or all of
these effects  might occur  in populations
exposed to the much lower con-
centrations prevalent in U.S.  cities today.
  The major  subgroups of the population
that  appear likely to be most sensitive to
the effects of particulate matter include
individuals with chronic obstructive pul-
monary or cardiovascular disease, those
with influenza,  asthmatics, the elderly,
children, and mouth-breathers.
  While available evidence clearly sup-
ports continuing regulation of particulate
matter,  selecting a standard  level  that
provides an adequate margin of safety
involves a number of uncertainties.
Quantitative assessments  have been
based on  a small number  of epidemiolo-
gical studies  (largely done in  London
during the period 1958-1972)  conducted
in times and  places where particulate
composition  and  levels may have varied
considerably  from those currently found
in the United States. Available
epidemiological studies on particulate
matter are subject to difficulties inherent
in all studies  of this type, such as con-
founding variables and somewhat limited
sensitivity. Although some consensus
has been reached on effects, there is a
wide  range of views among scientists as
to the levels at which effects are likely to
occur when assessing current exposure
conditions in the U.S.
  Ruckelshaus pointed out that EPA has
spent well over a million dollars to exam-
ine the potential impact that these stan-
dards will have on our national economy,
as well as the practical problems that
particular localities and  industries may
have  in meeting the standards. But the
agency's interpretations of the current
statute, as well as several court cases,
preclude him from using such informa-
tion in setting the standards, he said.
Consequently, Ruckelshaus  has avoided
reading such studies or being briefed on
their findings by his staff.
  Noting practical difficulties in meeting
the new standards, Ruckelshaus said a
substantial number of areas of the coun-
try are not in attainment with the existing
primary standards for total suspended
particulates. In line with the new pro-
posal, EPA has sent letters to the  state
governors  indicating that the agency will
soon  be providing detailed guidance on
how to address the attainment of particu-
late standards in light of the new  PM10
proposal. The letters also indicate that
the states are still expected to continue
their on-going control programs for par-
ticulate matter.
  Ruckelshaus also mentioned other
aspects of the standard-setting process
that create difficulties. "Based on the risk
assessment information already
gathered, reasonable persons might
choose any of several numbers within
the ranges we are proposing. Once a nu-
merical standard is finally established,
however, a domino effect occurs,
triggering revisions in State Implementa-
tion Plans, forcing EPA,  states, localities
and industries into potentially dramatic
confrontations. The inability of the Ad-
ministrator to take into consideration the
practical  problems of implementation
when  setting the health  standards poses
potentially grave problems," he said.
  Attainment deadlines for the health
standards are dictated in the Act. Thus,
 once a level is selected, EPA has limited
 flexibility in implementation. This crucial
 limitation on the agency's ability to carry
 out responsible risk management can re-
 sult in undesirable consequences, he
   "Moreover," Ruckelshaus noted, "the
 statute provides for  a single deadline for
 the primary standard, although the data
 suggest that both the health effects and
 the problems  of implementation may
 vary enormously depending upon the
 makeup and the source of the particulate
  An example of this point would be a
 control strategy that might be much
 more readily implemented  if the particu-
 late matter came from  a single source
 such as a factory than  if it were a com-
 plex mix emanating  from many sources.
 Moreover, some areas  of the country,
 such as arid rural counties, may find their
 problems of implementation aggravated
 by windblown dust and dirt.
  Ruckelshaus explained that "these di-
 lemmas are very real and may  under-
 score the  need for some greater factoring
 into the Clean Air Act of realistic con-
 siderations to  supplement what should
 be the paramount consideration of these
 standards — protection of public health
 and welfare."  He called for public com-
 ment on what, if any, considerations EPA
 should take into account in setting the
 primary standards.
  In addition, the agency is proposing to
 defer a decision on  secondary standards
for even finer particles, i.e., those less
than 2.5 micrometers, so that it can con-
 sider such a standard as part of a more
 detailed look at regional air pollution
 problems  such as visibility degradation
and acid rain.  EPA expects to issue an
advance notice of proposed rulemaking
on this matter in the near future.
  The proposal on the  national  ambient
air quality standards for particulate
matter is to appear in the Federal
Register.  Public meetings on this pro-
posal will  also be announced  in the
Federal Register, with a public comment
period of 90 days, D
APRIL 1984

Government   Files  PCB  Cleanup  Suit
 Pole-mounted transformers are involved in a
 recent Justice Department su/t against
 alleged PCB pollution by a Chicago area
 electric utility.
 I he U.S. Department of Justice recently
filed a civil suit at the request of EPA
against the Commonwealth Edison Com-
pany, a Chicago area electric utility. The
suit seeks to compel the cleanup of
numerous Northern Illinois sites con-
taminated by toxic polychlorinated
biphenyl (PCB) fluids discharged from the
company's pole-mounted electrical
  PCBs can cause liver damage, adverse
skin effects and changes in other
biological functions in human beings and
are suspected  human carcinogens,
according to the government complaint.
The suit, a major enforcement action
under the Toxic Substances Control Act,
was filed in U.S. District Court in Chicago.
  The case could have nationwide
significance for utilities' cleanup prac-
tices, government legal officials noted,
since ruptures of electrical equipment
containing PCBs occur throughout the
United States.  Because of their insulating
qualities, PCBs are used in electric capa-
citors and transformers and other equip-
ment in electric utilities' distribution sys-
  The government's complaint states
that Commonwealth Edison has  routinely
failed to take prompt and thorough ac-
tion to remove PCB contamination
caused by failures of the company's elec-
tric equipment. The complaint contends
that PCB levels found on several residen-
tial properties  affected by Com-
monwealth Edison's discharges pose an
unreasonable  risk to health or the en-
  Commonwealth Edison currently op-
erates many PCB capacitors, transfor-
mers and other items of electrical equip-
ment which are in residential  areas and
other locations where human exposure
to PCBs is likely to result from equipment
failures, according to the government
suit. The government said the utility has
more than 40,000 capacitors and perhaps
27,000 transformers mounted on poles.
  As many as  100 of Commonwealth Edi-
son's PCB capacitors are alleged to rup-
                                                                             ture every year, the government com-
                                                                             plaint said. In some instances, especially
                                                                             where transformers are mounted high on
                                                                             utility poles, bursting capacitors have
                                                                             sprayed PCBs onto people and into
                                                                               The complaint cites several examples.
                                                                             in one, Mrs. Anna Schumacher of Tinley
                                                                             Park, III., allegedly was directly hit in
                                                                             1978 by PCBs discharging from a capaci-
                                                                             tor close to her home. The chemicals
                                                                             sprayed into her house through an open
                                                                             window, and onto a truck, car and house
                                                                             trailer on her property, the suit alleged.
                                                                             The suit charges that she developed
                                                                             rashes on her back, neck and scalp and
                                                                             that her dog developed skin  problems
                                                                             and cancer. The complaint alleges that
                                                                             the utility didn't remove contaminated
                                                                             materials from the Schumacher home
                                                                             until  February, 1982, and that it still
                                                                             hasn't compfeted its cleanup of PCBs on
                                                                             the property.
                                                                               Because the  company's cleanup record
                                                                             has been poor, government officials said,
                                                                             the complaint asks the court to compel
                                                                             Commonwealth Edison to go back and
                                                                             do a  much more extensive and thorough
                                                                             job of removing PCB contamination at
                                                                             sites, possibly  numbering in the hun-
                                                                             dreds, where a spill has occurred. It also
                                                                             asks the court to order Commonwealth
                                                                             Edison to accept responsibility for thor-
                                                                             ough cleanups of future spills.
                                                                               The suit said laboratory analyses of
                                                                             samples of post-cleanup debris have
                                                                             sometimes revealed  PCB contamination
                                                                             levels of hundreds or even thousands of
                                                                             parts per million.
                                                                               Commonwealth Edison, the complaint
                                                                             said, must act to protect health or the en-
                                                                             vironment from unreasonable risk associ-
                                                                             ated with disposal of the PCBs. "Unless
                                                                             ordered to do so by this court," the com-
                                                                             plaint said, "Edison will not take further
                                                                             action necessary to protect health or the
                                                                             environment from such risk." I
                                                                                                      EPA JOURNAL

                                       Biological   Tests  Okayed
                                       for  Toxics  Control
                                       lish swimming in aquariums at EPA
                                       laboratories are helping in the scientific
                                       field of toxicity testing. Based in part on
                                       results of field studies involving the fish,
                                       EPA has  announced  a new policy on
                                       assessing and controlling toxics in rivers
                                       and lakes.
                                        The policy encourages use of bioiogicai
                                       as well as chemical testing methods in
                                       controlling  toxics in these  waters. Pre-
                                       vious efforts had relied almost ex-
                                       clusively on chemical analytical methods.
                                        Biological methods include a variety of
                                       field and laboratory techniques. Toxicity
                                       testing involves pumping effluent and
                                       water samples into aquariums containing
                                       fish and other aquatic animals, then
                                       observing the effects on the animals to
                                       calculate the toxicity of the wastewater.
                                       Chemical methods involve measuring the
                                       concentrations of individual pollutants in
                                       water samples.
                                        The new  policy recognizes that chem-
                                       ical methods may be inadequate, and
                                       biological methods more useful, in cer-
                                       tain situations. A policy integrating both
                                       methods should increase the ability of
                                       EPA and  the states to regulate toxic pol-
                                       lutants under  existing laws, agency offi-
                                       cials believe.


                                       The Clean Water Act  calls for technology-
                                       based controls (best available technology
                                       economically achievable and secondary
                                       treatment),  as well as water quality-based
                                       controls as  needed to achieve water qual-
                                       ity standards.  Historically, permits issued
                                       under the National Pollutant Discharge
                                       Elimination  System (NPDES) program
                                       have been based  on technology require-
                                       ments and on correcting the more tradi-
                                       tional water quality problems such as
                                       violations of water quality standards for
                                       biochemical oxygen demand, total sus-
                                       pended solids, and some heavy metals.
                                        Technology-based permit limits help
                                       insure that appropriate treatment sys-
                                       tems are  installed and operated properly.
But they do not provide adequate pro-
tection of water quality in every case.
That is because technology-based con-
trols are developed nationally, whereas
water quality protection depends on local
circumstances. Thus far, water quality
based controls for toxics have been cen-
tered on individual chemicals.
  Where toxics are concerned, there are
several problems associated with a strict-
ly themical approach to controlling water
pollution. One is sheer  numbers: it is dif-
ficult to analyze all the many toxic chem-
icals that may be discharged into
receiving waters. In addition, effects of
toxic chemicals, which are reactive, often
vary, depending on the constituents of
the effluent and receiving water. Finally,
aquatic organisms are usually exposed to
many toxic pollutants rather than a single
one, and scientists cannot predict the
effects of combined exposures.
  Recognizing the limitations of chemical
analysis in controlling by itself the toxic
pollutant problem, EPA in 1978  and 1979
began holding workshops with repre-
sentatives  of industry and federal and
state agencies to discuss use of toxicolog-
ical techniques. Over the next three
years, the agency circulated issue papers
and draft policy guidance and held  brief-
ings and workshops to examine methods
for toxics control. These efforts  culmin-
ated in September 1983, with issuance of
a draft policy on development of water
quality based permit limitations for toxic
pollutants.  The new policy, issued on
February 3, 1984, is a final version of that
  The policy states that, "in addition to
enforcing specific numerical criteria, EPA
and the states will use biological tech-
niques and available data on chemical
effects to assess toxicity impacts and
human health hazards, based on the
general standard of 'no toxic materials in
toxic amounts.'"
APRIL 1984

              In this t(i*:a',y fe.si, a toxicoki'.iist M l-P
              [fivin,:         Research Lab in Duluth,
              Mini.          minnov*.        itxnts
  Toxicity tests measure, not amounts,
but effects of toxic chemicals. According
to Jack Ravan, EPA Assistant Administra-
tor for Water, the new emphasis on a
biology-based approach represents "a
significant redirection for all involved in
water quality control. These methods will
enable the states and EPA to address
problems that previously were not de-
tectable,  and they provide a means to
tailor controls to the actual effects on the
receiving water."
  Rebecca Hanmer, Director of the Office
of Water Enforcement and  Permits,
spearheaded the effort to develop the
new policy. According to Hanmer, the
policy's most significant aspect is its re-
liance on general narrative criteria in
state standards.  "We used  to believe,"
Hanmer explains, "that specific numerical
criteria were needed in state water quali-
ty standards in order to have an effective
enforcement tool. Although specific
criteria will be adopted for some  toxic
pollutants, the states obviously cannot
adopt criteria for all  toxic pollutants. This
policy, therefore, encourages regulation
based on the existing general standards
protecting the designated water use and
the public  health, and carried out using
available data on chemical effects and
biological testing."
  EPA and some states have been using
aquatic organisms to test the purity of
water on a limited basis. In recent years,
says Bruce Newton of EPA's Permits Divi-
sion, several states have begun using the
tests to define discharge requirements in
NPDES permits. Their experiences, plus
requests for a national policy from other
states, prompted EPA to take a firmer
stand on the use of these methods.
  EPA's policy is also based  on results of
studies conducted at agency research
and development facilities, primarily the
Environmental Research  Laboratory in
Duluth, Minn. There Dr. Don Mount
pioneered methods for investigating
effluent toxicity, and continues work on
refining the methods and their applica-
  In a joint project with the Permits Divi-
sion, the Duluth lab runs the  Complex
Effluent Toxicity Testing Program. Under
this program, scientists have carried out
toxicity evaluations of 10 municipal and
50 industrial  discharge points at six sites
in four states—Connecticut, Ohio, Okla-
homa, and Alabama. The next site slated
for  testing, according to Permits Division
project manager Rick Brandes, is Balti-
more  Harbor.
  The basic thrust of this program is to
determine, through use of ecological sur-
veys and lexicological testing, if toxicity
measured in  an effluent translates inlo
toxic impact  in the receiving waters. Re-
sults,  according to Brandes, show a
strong correlation between measured
toxicity and ecological effects.
  "Office of Research and Development
labs often develop the scientific  basis for
our regulatory programs," Newton ex-
plains. In this case, the findings  of the
scientists in Duluth helped form  the basis
for  EPA's new policy. The Office of Re-
search and Development will continue to
play a significant role, developing better
toxicity tests  and methods to solve pollu-
tion problems.
  The policy  states cases in which dif-
ferent techniques should be used:
"Pollutant-specific chemical analysis
should be used where discharges contain
a few, well-quantified pollutants and the
interactions and effects of the pollutants
are known...Biological techniques should
be used where effluents are complex or
where the combined effects of multiple
discharges are of concern.  EPA recog-
nizes that in many cases both types  of
analysis must be used."
  The nation has made substantial prog-
ress towards achieving the goals of the
Clean Water Act, but much remains to be
done. "There is a tendency to think,"
says Ravan, ' that water pollution control
is largely in place. This is not true. Re-
search shows that there still are signifi-
cant water pollution problems. But the
nature of water pollution has changed."
  As treatment of "traditional" pollutants
becomes sufficient to protect water quali-
ty, attention is shifting to pollutants that
affect water quality through toxic effects.
Compared to the traditional pollutants,
less is known about the effects of pollu-
tants that are toxic to aquatic life. EPA's
new policy on biological testing  should
help change that situation.  Q
                                                                                                               EPA JOURNAL

                                     Report  Surveys
                            Water  Quality  for   Fish
rVn estimated 73 percent of the Nation's
waters are clean enough to support pop-
ulations of sport fish such as iargemouth
bass and rainbow trout.
  At the same time, fish are being widely
affected to some extent by pollution and
by problems with  the quantity of water,
primarily low flow levels. These effects
range from outright fish kills to  stunted
  These are key findings from the
National Fisheries Survey, which EPA
conducted in 1982-1983 in cooperation
with the U.S. Fish and Wildlife Service.
The survey is an assessment of  the biolo-
gical condition of the Nation's waters as
indicated by the ability to support fish
  The survey found that nonpoint
sources of pollution are the cause of
harmful effects to the fish  community in
38 percent of the Nation's waters and are
ranked as a major concern  in 19 percent
of waters. Agricultural sources alone
affect 30 percent of all waters.
  Point sources of pollution are  also a
problem. Although municipal and in-
dustrial dischargers are on or have the
potential to affect  only an estimated 20
percent of the waterbodies in the coun-
try, the survey found that fish com-
munities in more than 10 percent of all
stream miles are  being adversely affected
by these point sources. In  half of these
waters, point sources are considered to
be a major concern.
  According to the survey, the ability  of
the Nation's waters to support sport fish
or other fish of special concern,  such  as
endangered species, has not changed
appreciably during the past five  years,
even though human population  and de-
velopment pressures with  a potential  to
worsen water quality conditions have in-
creased. EPA officials explain that wastes
are generally being treated more effi-
  Other highlights of the survey findings
include the following:

• In about 80 percent of the Nation's  wa-
ters, the survival, productivity or use of
fish populations is being harmed to some
A painting of Lake Trout, a fish found in
and Cat

degree by at least one type of man-
caused or natural condition involving the
quality or quantity of water, the habitat
or other factors such as overfishing or
• Water quality factors such as pollution
in general are causing harmful effects to
fish communities in 56 percent of the Na-
tion's waters. The predominant water
quality factors are turbidity, adversely
affecting fish communities in 34 percent
of all waters; high water temperature,
affecting fish communities in 26 percent
of all waters; surpluses of nutrients,
affecting fish populations in 12 percent of
all waters; toxic substances, affecting fish
in 10 percent of all waters;  and low con-
centrations of dissolved oxygen, also in
10 percent of all waters.

• Poor water quality conditions caused
by natural factors are adversely affecting
fish communities in 22 percent of all wa-
ters. These include sediment stirred up
by flood waters and high concentrations
of certain minerals.
• Water quantity factors such as low
water levels are adversely affecting the
fish communities in 68 percent of the Na-
tion's waters. Natural conditions are a
major source of these effects.

• The two most prevalent sport fish spe-
cies are Iargemouth bass and rainbow
trout which occur in about half of the Na-
tion's waters. Anadromous fish species—
fish that migrate from the ocean  to fresh
water to spawn—are found in an es-
timated 11 percent  of the Nation's wa-
ters. These include  salmon and steelhead

• Twenty-one percent of the Nation's
waters contain no fish. Most of these
reaches, however, are dry during part or
all of the year.

  The survey was based  on existing in-
formation gathered from knowledgeable
biologists in state fish and wildlife agen-
cies for a statistically selected sample of
the Nation's waters. These persons were
asked to provide information on four
basic concerns: the fish species occurring
in a stream segment or impoundment
(reach); the time of year during which
the reach is usable  as fish habitat: water
quality,  quantity, habitat and fish com-
munity conditions which  are adversely
affecting the fish in the reach; and trends
in water body conditions with regard to
the fish  community.
  Fish species used as indicators in the
survey included sport fish, federally-
designated threatened and endangered
fish, and state-designated fish of special
concern. The survey assessed flowing
waters in the lower 48 states, including
impoundments but  excluding the Great
Lakes, estuaries, coastal waters and wet-
  Copies of the National  Fisheries Survey
will be available from  EPA's Monitoring
and Data Support Division (WH-553),
Office of Water, 401 M St., S.W., Wash-
ington, D.C. 20460, or  the U.S. Fish and
Wildlife  Service's Western Energy and
Land Use Team, 2627  Redwing Road,
Fort Collins, Colo. 80526.  ( ',
APRIL 1984

EPA  Battles  Bid  Riggers
"Price fixing, bid rigging and other
typical antitrust violations have a more
devastating  effect on  the American
public than any other  type of economic
crime. Such illegal activity contributes
to inflation,  destroys public confidence
in the country's economy, and under-
mines our system of  free enterprise. In
the case of federal procurement,  such
crimes increase the costs of gov-
ernment, increase taxes, and under-
mine the public's confidence in its gov-
ernment. "

  So begins a U.S. Department of Justice
guideline on antitrust enforcement in
federal procurement. According to this
document, federal procurement in  fiscal
year 1981 amounted to over $134 billion.
"Without doubt," the guideline  states,
"some contracts are the subjects of collu-
sion like bid rigging."
  The EPA wastewater construction
grants program represents one  of the
largest expenditures of public funds.
According to EPA  Deputy Administrator
Al Aim, more than $22 billion has been
obligated in this program on  almost
10,000 active projects.  On any given con-
struction project, 85 to 90 percent of the
total cost goes to private construction
contractors. They are supposed to  bid
"freely and openly" in a "competitive
marketplace," with the award going to
the "lowest, responsive, responsible bid-
der" under the formal  advertisement
method of procurement.
  But when  bids are rigged, the method
doesn't work as it is supposed to.
  Bid rigging is a conspiracy  of two or
more contractors to determine,  before
bidding on  a public contract,  which one
will receive the contract. An EPA guide
calls bid rigging "a blatant corruption of
the competitive bidding process." it is
also illegal, a violation of the Sherman
Act punishable by a fine of up to $1 mil-
lion for corporations, and up  to $100,000
or three years imprisonment, or both, for
  According to EPA Inspector General
John C. Martin, the agency is going after
bid riggers on a national basis. In a
November 1983 memo to senior man-
agement, Deputy Administrator Aim an-
nounced briefings on the Sherman Act
and on detection of bid rigging in the
construction grants program. The brief-
ings are to be conducted by Justice De-
partment attorneys in all regions. "The
limited antitrust projects already initiated
have resulted in indictments and con-
victions, and demonstrate the need for
greater attention  to protect the integrity
of EPA's largest program,"  Aim said.
"The Office of the Inspector General has
commited substantial resources in fiscal
year 1984  to audits and investigations of
possible bid rigging activities."
  Between 1977 and 1979, numerous cor-
porations had been indicted for bid
rigging on highway and airport construc-
tion contracts that had been funded by
the U.S. Department of Transportation
(DOT). But the business of many of these
corporations was not limited to  DOT con-
tracts. At the direction of the Inspector
General, the Office of Investigation's
Southern Division meticulously matched
the list of indicted contractors against
lists of current EPA construction con-
tractors and unsuccessful bidders. The
records showed that a large number of
the indicted contractors had either been
awarded contracts by EPA grantees or
were on the EPA bidders list.
  Investigators from the Office of the In-
spector General then analyzed
wastewater treatment facility contracts
for North and South Carolina and found
a pattern indicating bid rigging. They
worked with the Justice Department's
Antitrust Division on a grand jury probe
in the two states.
  Their work began paying off in May
1982, when the first firm and officers of
two corporations were indicted for bid
rigging under an EPA grant. In August
1982, these individuals were convicted
and sentenced to prison terms and fines
totaling $300,000. To date, results in this
bid rigging probe add up to  14 indict-
ments and 12 convictions, each involving
a jail sentence and most atso involving a
substantial fine and numerous sus-
pensions and  debarments from further
government contract bidding. Several
more cases are still under grand jury in-
  In the  course of its probe,  the Inspector
General's Office identified certain bid
rigging patterns. Low bids on many EPA
projects  were  elevated by $1 million or
more over engineering cost estimates
through  bid rigging.  Each convicted cor-
porate official  stated that bid rigging on
                          SHOULD we
                                                                                                          EPA JOURNAL

                                          Source  Pollution
                                          in  the   U.S.
EPA projects was very important to his
firm since there were more risk factors in
wastewater plant construction than on
federal highway construction. Bid rigging
had become a way of life in the states
under investigation and the convicted
contractors, prior to the investigation, did
not consider their bid rigging activities as
criminal. When they finally  did accept the
criminality of their behavior, they cooper-
ated with federal investigators.
  The Southern Division's experience in
bid rigging investigations forms the basis
for the nationwide initiative now under
way. The Inspector General's action plan
calls for the four IG Divisions to analyze
all contracts  and subcontracts awarded
under the construction grant program.
They will look for data on potential bid
rigging cases, refer appropriate cases to
the Department of Justice, and work with
Justice on documenting evidence.
  Audit and investigative personnel will
work together on this initiative, using a
new EPA guide on bid rigging analysis in
the construction grants program. In-
cluded in the guide is a 14-item list of
documents required for successful pro-
secutions of Sherman Act violations, and
a 15-item list of indicators of bid  rigging.
The indicators include  previous charges
of bid rigging, a low number of bidders,
joint bids when  one competitor could
have filed its own bid,  identical bids, and
a persistent pattern of  low bidding.
  The goal of the Inspector General's
nationwide attack on bid rigging  is
threefold; to obtain jail sentences for
convicted violators, to  recoup financial
losses through successful civil suits, and
to discourage other contractors from
rigging bids.
  Between April 1 and September 30,
1983, the Office of the  Inspector General
opened 93 new investigations, including
31 cases of fraud against the government
and nine cases of antitrust violations.
Two hundred twenty-three cases were
under investigation, including 120 fraud
cases and 32 antitrust cases. Six  in-
dictments and nine convictions were
obtained during the six month period. D
r\ new EPA report to Congress reviews
the major contributions  made by non-
point sources to water pollution in this
  These sources such as drainage from
farm lands, runoff from  city streets and
parking areas, and waste from aban-
doned mines are considered by many
EPA and state officials to be the principal
remaining cause of water pollution now
that treatment facilities have been pro-
vided for most pollutants discharged
from point sources such  as a  pipeline.
  Excerpts from the EPA report to Con-
gress on nonpoint source pollution fol-
  "The principal sources of nonpoint
pollution vary between EPA regions and
between states, but agricultural sources
are identified as the most pervasive non-
point source in every  region. Pollutant
loadings caused by runoff from urban
lands and by mining activities are the
next most commonly  reported nonpoint
source problems. Urban  runoff con-
tributes to localized water quality prob-
lems and is a source of  concern because
it may contain toxic heavy metals. Where
they occur, water quality problems from
abandoned mines can cause particularly
severe impacts, in some cases resulting
in the devastation of stream life. For
abandoned mines and densely developed
urban areas, cost-effective remedial
measures may be hard to implement.
  "Additional nonpoint sources of local-
ized concern include silvicultural activi-
ties and construction  erosion. The water
quality impacts from both of these
sources are not as pervasive on a  nation-
al level as the other sources described in
this report.
  "For most water quality problems
caused by nonpoint sources, substantial
water quality improvements can be—and
have been —achieved cost effectively
through careful targeting of control ac-
tivities. Targeting high-payoff areas re-
quires identifying both the priority water
bodies for which the adoption of a non-
point source control program will have
significant benefits and the best man-
agement practices that wilt lead to the
greatest improvements for the least cost.
  "While general statements about prob-
lems and potential  solutions are possible
at the national level, the analysis and
decision-making required for effective im-
plementation of targeted controls must
take place on a local levet.
  "The key to careful targeting of control
activities to maximize water quality bene-
fits  is a watershed-based analysis. A thor-
ough watershed analysis will: (1) identify
those use impairment problems that are
caused specifically  by nonpoint sources,
(2) rank priority water bodies  for con-
centrated attention, (3) pinpoint the
specific land management practices
giving rise to the problems, and (4) de-
sign a system of cost-effective man-
agement practices that can reduce the
nonpoint source pollutant load to the
  "The basic approach taken by the
Clean Water Act for managing point
sources—that is, the application of uni-
form technological  controls to classes of
dischargers—is not appropriate for the
management of nonpoint sources. Flex-
ible, site-specific, and source-specific
decision-making is the key to  effective
control of nonpoint sources.
  "Site-specific decisions must consider
the  nature of the watershed, the nature
of the waterbody, the nature of the non-
point source(s), the use impairment
caused by the nonpoint source(s), and
the  range of management practices avail-
able to control nonpoint source pollution.
  "The actual site-specific selection of
particular management practices to con-
trol  nonpoint source pollution (called
Best Management Practices [BMPs]) will
involve locai environmental and eco-
nomic considerations, as well as con-
siderations of effectiveness and
acceptability of the practice.
   APRIL 1984

    rrosion on unprotected corn field after a
    lain storm.
Nonpoint Sources

"As is the case with most types of non-
point source pollution, the nature and ex-
tent of the agricultural nonpoint source
problem is directly related to the way in
which the land is used. The agricultural
sector generally  manages land resources
very intensively.  Row cropping, for ex-
ample, usually involves not only a good
deal of land disruption, but also the
application of chemicals such as fertiliz-
ers and pesticides. About 63 percent of
the non-Federal land in the United States
is used for agricultural purposes, in-
cluding crop and livestock production. It
is not surprising, therefore, that agricul-
tural activities constitute the most per-
vasive  cause of water quality problems
from nonpoint sources. Indeed, it is con-
sidered the most serious cause in most
of the EPA regions. National studies
suggest that agricultural nonpoint source
pollution  adversely affects portions of
over two-thirds of the nation's river
basins. Nonpoint source pollution from
agriculture actually has several different
sources with different associated im-
pacts. These sources are:

• Nonirrigated croplands,  both row (e.g.,
corn and soybeans) and field (e.g.,

• Irrigated croplands,

• Animal production on rangeland and
pasture, and

• Livestock facilities

  "This range of sources indicates that
the agricultural nonpoint source problem
is not only pervasive, but also  multi-
faceted. The primary pollutants from
nonirrigated cropland are sediment, nut-
rients,  and pesticides. While irrigated
farming is a source of these pollutants,
too, it is also the major agricultural
source of polluting salts and other miner-
als. Runoff from  barnyards and feedlots
primarily contributes nutrients, organic
matter, ammonia, fecal bacteria, and
other micro-organisms to receiving water
  "Over-grazing of rangelands and pas-
turelands often contributes sediment and
nutrient pollution  through  runoff. The re-
lated surface disruption and reduction  in
natural cover increases the erodibility of
these lands. Livestock grazing freely
along streambanks compact and damage
them, thus increasing erosion and
sedimentation problems. Livestock
wastes also contribute to stream pollu-

from Cropland

"The most obvious cause of surface
water contamination  from  cropland is
sediment,  which is carried  off eroding
lands via rainfall,  snowmelt, or heavy
wind. Research suggests that  25 percent
to 40 percent of the soil that runs off a
field reaches a water body.
  "Conservation practices such as less
plowing help retain crop  residues on the
land to reduce runoff of sediment. These
practices are considered to be  very effec-
tive and of direct benefit  to farmers, but
may require specialized equipment and
additional costs.
  "Some agriculture water quality prob-
lems can be controlled by best man-
agement techniques beyond the eco-
nomic self-interest or means of many far-
mers. For example, reduction of some se-
vere erosion problems  may require
terracing—a costly technique that breaks
up a long slope into a series of shorter
ones and reduces erosion by interrupting
downhill water flow. Control of animal
waste problems  may require the  fencing
of streambanks to  keep out animals.

Reduction of
Agricultural Sources

"Although agriculture presents the  most
pervasive nonpoint source pollution
                                                                                                             EPA JOURNAL

  Hauling logs in Colorado forest Construc-
  tion of logging roads is a significant source
  of soil runoff in timber cutting.

problems, the best management tech-
niques available for addressing agricul-
tural nonpoint sources are generally well
  "In addition, many—but not all—of the
problems in this nonpoint source cate-
gory can be ameliorated by adoption of
techniques within the economic setf-
interest of the landowner or farmer.  In
fact, management practices designed to
stop erosion may increase the long-term
productivity of the land.
  "Substantial achievements in water
quality can be made by targeting re-
sources, education, and training pro-
grams to the land areas and activities
that are the source of agriculturally-
generated pollution problems.
  "Effective delivery systems for many of
these programs are already in place  as a
result of the excellent outreach agencies
developed  by the  U.S. Department of
Agriculture. The Experimental Rural
Clean Water Program, for example, has
demonstrated the effectiveness of tar-
geting and training in a number of water-
sheds throughout the country.
  "Barriers to widespread adoption of
agricultural best management tech-
niques, in general, are not technical.
These barriers include: educational ones
(farmers lack knowledge about best man-
agement techniques); economic ones
(adoption of certain techniques is beyond
the farmer's economic interest); and pro-
grammatic ones (programs that specif-
ically address nonpoint sources and  that
provide technical and financial assistance
and/or an appropriate  regulatory
framework are often lacking at the state
and local levels).

Nonpoint Sources

"The smaller area and extent of forest
management activities, less intensive site
preparation, infrequent harvest, and  low-
er frequency of  pesticide and nutrient ap-
plications in a given year all result in sil-
viculture generating a smaller volume of
total nonpoint source pollutants than
agriculture nationwide. However,  38
» • •*
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states cited forestry impacts in their
water quality management plans, and sil-
vicultural management activities can
generate major localized nonpoint source
pollution problems.
  "One factor in understanding the na-
ture of the Silvicultural nonpoint problem
is the frequency with which land dis-
turbance takes place and the nature of
that disturbance. The time intervals at
which forests are cut is an important fac-
tor  in the potential  for nonpoint source
pollution. Rotation  periods vary from 20
to more than 100 years for different spe-
cies of trees. Thus, harvest sites in the
pulp and paper producing areas with
shorter (20-year) cutting cycles have
more frequent opportunties for con-
tributing to nonpoint source pollution.
  "Silvicultural activities are actually
comprised of a number of different op-
erations, each of which has a different
potential for nonpoint source pollution.
              These activities include road building,
              pesticide and herbicide application,
              harvesting and logging operations, re-
              moval of trees from the harvesting site,
              and preparation of the site for revegeta
                "Poorly planned road building and
              poorly managed site preparation activi-
              ties offer the greatest potential for pollu-
              tion impacts. The likelihood of such im-
              pacts is dependent upon such factors as
              road design, extent of soil disturbance,
              and time required until cover is reestab-
              lished (generally 2 to 5 years, and, in cer-
              tain terrains substantially longer).
                "A mature forest may experience ex-
              tremely low soil erosion rates when un-
              disturbed  by the activities of people (0.5
              tons per acre per year or less). While
              average erosion rates from carefully
              managed  logging activities may be fairly
              low (less than  an additional ton per acre)
              erosion rates from 10 to 15 tons per acre
APRIL 1984

per year are not uncommon. Losses due
to intensive site preparation (preparing
soil for replanting) can exceed 100 tons
per acre per year.
  "Nonpoint source impacts on water
quality from silviculture depend on the
characteristics of the forest land (e.g., soil
type and slope), on climatic conditions,
and on the type of forest  practices and
the care with which they  are undertaken.
  "As is the case with agriculture, sedi-
ment is the major pollutant by volume,
and the soil type,  slope, and climate
markedly alter the  rates of erosion and
sediment delivery to water courses.
Although fertilizers and pesticides have
been increasingly used in silviculture,
they are typically applied only once or
twice during a 20- to 35-year period, as
compared to  annual agricultural applica-

Control of
Nonpoint Pollution

  "Although silvicultural  activities do not
appear to cause nonpoint source pollu-
tion problems as pervasive as those
caused by agriculture, or  as severe as
those related to mining, they  can still
lead to localized water quality problems
in places where they are  not well man-
aged. The main nonpoint source pollu-
tants from silvicultural activities are sedi-
ment, chemicals (from pesticides and
herbicides), and organic debris. Principal
sources are roads, logging activities,
preparation of sites for revegetation, and
aerial spraying of pesticides. Man-
agement practices to control these pollu-
tants are well known and well under-
stood. Major  implementation  concerns
are institutional in  nature.
  "As in agriculture,  adoption of some
best management plan will be within
both the means and self-interest of the
owner or operator. For example, proper
construction of logging roads intended
for tong-term use may lower operation
and maintenance  costs. Needs for spe-
cialized equipment may put some best
management practices beyond the
means of the small landowner or oper-
ator. Finally, certain management prac-
tices may be unattractive because they
result in lost timber sales (e.g., stream-
bank management zones that leave a
buffer strip in both sides of the stream).
  "In cases where the self-interest of the
landowner or operator has not been
enough to cause adoption of best man-
agement practices, many states have
effectively encouraged compliance with
regulatory or quasi-regulatory  programs.
In other states, educational and training
programs are used.

Nonpoint Sources

"Mining cannot be viewed as a
homogeneous source of nonpoint pollu-
tion. Many different minerals are mined,
each with its own set of nonpoint source
problems. Coal and  metal mining are the
sources discussed here, because both are
associated with serious water quality
problems in large geographic regions.
  "Although mining  is not as widespread
as agriculture, its water quality effects
are normally much more harmful.
Sedimentation rates  from mining can be
extraordinarily high.  Furthermore, whole
streams may be biologically dead as a re-
sult of  acid mine drainage. Other pollu-
tants with potentially serious effects in-
clude heavy metals and radioactive mate-
  "The  main nonpoint source problems
at mining sites are:

• Runoff of sediment from haul roads at
both active and inactive mine sites;

• Drainage of pollutants including acid,
sediment, salts and  metals from  inactive
mines; and

• Drainage and leachate containing acid,
metals, and sediment from the spoil and
tailings piles generated both by active
and inactive mines.
Mine Problems

"Mining-related nonpoint source water
quality problems are found in many parts
of the country. Because mining  activities
are typically concentrated in a limited
area, water quality impacts are also local-
ized in nature. Where they occur, how-
ever, the resulting impact can be quite
  "Techniques for controlling pollution
from operating mines are widely avail-
able. Proper site planning of a new
mining operation is the key to preventing
pollution, and is  required by law for all
new mines. In many parts of the country,
however, it is the inactive and aban-
doned mines, the design and operation
of which were completed a number of
years  ago, that pose serious water quali-
ty problems.
  "Techniques are available for solving
many of the water quality problems
associated with surface mining. In some
instances, significant costs may be
associated with regrading land areas and
adding topsoil for revegetation in aban-
doned mines where improper planning
for reclamation makes  after-the- fact
problem solving  difficult. Correction of
drainage problems from deep mines is
both more technically difficult and more
costly. In addition, correction of these
drainage problems may not last, and will
usually require long-term monitoring and
  "Although techniques are available to
arrest many abandoned surface mine
problems, institutional  issues and costs
continue to present barriers to effective
control. Mine owners are sometimes reluc-
tant to cap or bury tailings piles, and to
take other steps that might make future
recovery of mineral values more difficult.
Furthermore, ownership and responsibil-
ity for abandoned mines is often difficult
or impossible to  establish.
                                                                                                             EPA JOURNAL


Nonpoint  Sources

"On a national  basis, the water quality
degradation caused by nonpoint  source
pollution from construction activities is
not nearly as great as the amount caused
by other major  nonpoint sources. Sedi-
ment is the main construction  site pollut-
ant, but it represents only about 4 to 5
percent of nationwide sediment loads in
receiving waters. Other pollutants from
these sites can  include chemical fertiliz-
ers, pesticides,  paint and debris.
  "Where construction activities are in-
tensive, however, the  localized impacts
on water quality may  be severe because
of the high unit loads  involved. Erosion
rates from construction sites typically are
10 to 20 times that of agricultural  lands,
and runoff rates can be as high as 100
times that of agricultural  lands. Thus,
even a  small amount of construction may
have a  significant negative impact on
water quality in localized areas.
  "Construction site erosion rates are
highly variable  because site characteris-
tics are  many and varied. Climate, soil
type, slope,  and the type of construction
activity conducted are all involved. Se-
vere erosion problems can occur locally
anywhere in the country.
  "Usually, a combination of structural
and nonstructural controls produces the
most cost-effective answers to  construc-
tion nonpoint source problems. For ex-
ample,  highway construction nonpoint
source  pollution can be decreased signifi-
cantly by utilizing diversion and filter
structures, mulches, and well planned ex-
cavation work. Total costs are estimated
at more than $1,000 per acre, but  these
costs are more than recaptured by the re-
duced expenditures for cleaning up sedi-
ment damage.

Nonpoint Source
Pollution Controls
  "The major nonpoint source  pollutant
from construction sites is sediment.
Although pollutant loads  are small
nationally, the volume of runoff from a
particular construction activity—and  its
impact on a  local water body—can be
significant. Best management practices
are well understood technically. They are
also recognized to be beyond the eco-
nomic interest of the builder. Practices
are typically instituted as a result of reg-
ulatory action on the part of the state
and or local government, and costs are
passed on to the consumer.
  "The failures in existing implementa-
tion programs need to be better  under-
stood so that appropriate steps can be
taken to reduce this source of nonpoint
pollution. Although precise data are not
available, one of the  apparent problems
in many construction erosion control pro-
grams is the difficulty of inspecting and
enforcing control measures at numerous
sites scattered throughout a local
jurisdiction. Weak inspection and en-
forcement point to the need for more
emphasis on training and education to
complement regulatory  programs.

Nonpoint  Sources
  "Rainwater running off roofs, lawns,
streets, industrial sites, and other per-
vious and impervious areas washes a
number of pollutants into urban lakes
and streams. A large volume of the con-
stituents in urban runoff is comprised of
sediment and debris from  decaying pave-
ments and buildings that can clog sewers
and waterways, reducing flow (and thus
increasing the chance of flooding) and
degrading aquatic habitat. Heavy metals
and inorganic chemicals (including  cop-
per, lead, zinc, and cyanides) from trans-
portation activities, building materials,
and other sources are also significant
  "Nutrients are added to urban  runoff
from fertilizers applied around homes
and in parks. Petroleum  products from
spills  and leaks, particularly from service
station storage tanks, and fecal bacteria
from animal wastes and ineffective septic
tanks  are other important contaminants
and may affect ground water as well as
surface water. In short, many of the
wastes from urban living make their way
into urban runoff.
   "Of equal importance is the volume of
 stormwater runoff leaving urban areas.
 When natural ground cover is present
 over an entire site, approximately 10 per-
 cent of the stormwater runs off the land
 into nearby creeks, rivers, and lakes.
 When paved surfaces account for 10  to
 20 percent of the area of the site, 20  per-
 cent of all stormwater becomes surface
 runoff. As the percentage of paved sur-
 faces increase, the volume and  rate of
 runoff and the corresponding pollutant
 loads also increase.
   "Metals and inorganics are  the urban
 runoff contaminants  having the greatest
 potential for long-term impacts  on aqua-
 tic life, although they appear not to cause
 the immediately observable acute im-
 pacts of pesticides (e.g., fish kills). Some
 of these pollutants accumulate in the tis-
 sues of fish and other aquatic organisms.
 They  also accumulate in the environment
 through continuing sedimentation and or
 are resuspended in the water  column
 during high flows associated with storm
   "These constituents may also have im-
 portant effects on ground water, the ex-
 tent of which ib dependent on hydroiogic
 and geologic conditions that determine
 the amount of runoff which percolates
 through to underground aquifers. Aquif-
 ers in limestone areas are particularly
 vulnerable because runoff flowing into
 sink holes and surface water is thus
 transmitted to ground water rapidly.

 Control of
 Urban Runoff
   "Water quality problems caused by
 urban nonpoint sources will be most
 acute in heavily populated, built-up areas
 such as the Northeast. The most effective
 control measures are structural, however,
 and opportunities for implementation of
 these measures will be very limited in
 such situations. Developing urban areas
 offer the greatest potential for utilizing
the full range of structural and non-
structural controls. Adoption of  these
measures is an important means of
 reducing future urban nonpoint  source
pollutant loads. D
APRIL 1984

New  Appointments,
New   Missions  at  EPA

Recent appointments at EPA include the
filling of high ranking posts in the Office
of Water and the Office of Inspector
General. Meanwhile, it was announced
that an EPA scientist will be one of the
astronauts in a space flight scheduled for
lift-off in December, 1985.
  The EPA appointments are:
Rebecca Hanmer, Director of the Office of
Water Enforcement and Permits.

Marian Mlay, Director of the new Office
of Ground Water Protection.

Kenneth Alfred Konz, Deputy Assistant
Inspector General for Audits.
  Hanmer, who has been with EPA since
its inception, served as Acting Assistant
Administrator for Water from May to
November 1983. In this position she was
responsible for administering the Clean
Water Act, as well as the Safe Drinking
Water Act and the Marine Protection Re-
search and Sanctuaries (Ocean
Dumping) Act. She served as Deputy
Assistant Administrator for Water during
the previous year.
  Hanmer was EPA's Region 4 Adminis-
trator in  Atlanta, Ga., from  January 1980
to July 1981 and was Deputy Regional
Administrator for EPA's Region 1 in Bos-
ton from  1977 to 1980. Prior to that she
served as assistant director of the agen-
cy's Office of Federal Activities from 1972
to 1976 and as director from then until
October  1977. She joined the office when
EPA was created in  1970 as Federal Ac-
tivities coordinator for public land man-
  She began her government career in
the Department of Health, Education and
Welfare in 1964,  and was a staff assistant
in the Interior Department's Federal
Water Quality Administration at the time
it was transferred to EPA in 1970.
  Hanmer was honored as  a Presidential
Meritorious Executive in 1980 after
receiving EPA's gold medal for ex-
ceptional service in  1977 and the silver
medal for superior service in  1975.
  She received a Bachelor of Arts from
the College of William and  Mary in  1963
and a Master's degree in political science
from American University in 1965.
  Mlay has been Deputy Director of the
Office of Drinking Water since 1979. The
new Office of Ground Water Protection,
which she will head, is part of EPA's
Office of Water. The ground-water office
will coordinate all EPA ground-water ac-
tivities, develop policies and guidelines
and provide guidance  to regional ground-
water programs. It also will provide staff
support to a ground-water oversight
committee chaired by  Jack Ravan, EPA
Assistant Administrator for Water, and
will manage a ground-water steering
committee which will  review policy and
make recommendations on budget re-
quests for this program.
  Mlay brings more than two decades of
experience in federal government service
to her new post. For the past five years
as Deputy Director of the Office of
Drinking Water she supervised de-
velopment of the ground-water protec-
tion strategy. From  1978-79 she was Di-
rector of the program  evaluation division
in the EPA Office of Planning and Man-
agement. She served as Deputy Director,
Office of Policy Development and Plan-
ning, Assistant Secretary for Health, in
the Department of  Health, Education and
Welfare from 1973  to 1977 where she
managed a multi-million-dollar program
involving several Public Health Service
  She was Director of  the Division of
Consolidated Funding, Office of the
Comptroller at HEW from  1972 to 1973,
and developed a recruitment program  for
executive level women at  that agency in
1972. Earlier she held  a variety of posi-
tions including Acting  Regional Director
of HEW in Chicago.
  Mlay received  a B.A. degree  in political
science from the University of  Pittsburgh
and a law degree from American Univer-
sity. She has received numerous honors
in government service including the
National Institute of Public Affairs Career
Education Award in 1969, Public Health
Service Superior Performance Award,
and the HEW Executive Management
Award in 1977. She was a Princeton Fel-
low in Public Affairs at the Woodrow Wil-
son School of Public and International
Affairs from 1969 to 1970.
  Konz was Special Assistant to the
Assistant Inspector General for  Audits at
EPA beginning in 1981 where he was in-
volved in all aspects of Office of In-
spector General audit operations.  From
1976 to 1980, he was Director of the East-
ern Audit Division of the Office  of In-
spector General.
  Previously, Konz  was on special assign-
ment from EPA as Special Assistant to
the Commissioner of the New Jersey De-
partment of Environmental Protection
from 1975 to 1976.  He was Supervisory
Auditor of EPA's Mid-Atlantic Audit Divi-
sion from 1973 to 1975 and began his ex-
perience of 13 years at EPA as an  auditor
in the Office of Audit about one month
after it was organized in 1971.
  In other jobs, Konz was Auditor-!n-
Charge and  Supervisory Auditor for
HEW in Colorado and Virgina, 1968 to
1971, and was with the Army Audit
Agency from 1965 to 1968.
  Konz graduated from the University of
Denver with a Bachelor of Science-Bachelor
of Arts degree in 1965 and did graduate
work in public administration at the  Uni-
versity of Oklahoma.
                                                                                                      EPA JOURNAL


  Dr.Bill Williams, head of EPA's Wildlife
and Toxicology Research Group in Cor-
vailis. Ore., was nominated for the seven-
day Spacelab-4 flight. The experiments he
will be conducting aloft involve
monitoring changes in the bones and
blood vessels of rats and squirrel monk-
eys during periods of weightlessness and
the possibility of an egg developing in
zero gravity. These experiments are de-
signed to  help advance the treatment of
cancer and diabetes in humans.
  Williams is a  specialist in thermal regu-
lation, the control of the body's tempera-
ture by the brain and  other systems.
After 14 years as a scientist at NASA he
came to EPA on a sabbatical in  May  1982
to work on wildlife toxicology, especially
the effects of pesticides on wildlife.
  While still with the space agency, in
1977, Williams participated in a simulated
flight of the  Spacelab during which he
and the other participating astronauts
were totally  isolated and otherwise
treated exactly as if they were in orbit.
Now that  he has been selected for the
Spacelab-4 flight his training will in-
tensify. He has recently begun alternating
one week  working with EPA and the  next
with NASA.  Sometime early this summer
he will take a sabbatical from EPA  to
train full time.
  Once the flight (or flights—he may fly
two missions) is completed, Williams
plans to return to EPA's Corvallis lab. LJ
                                                                                   EPA /
                                                                                   speaks to group ot :
                                          EPA astronaut Bill WiUumt; in simulation
APRIL 1984


Clean Air Week, May 7-13
The annual Clean Air Week will
be held May 7-13 this year and
will focus on transportation
problems which adversely
affect air quality.
  The event is being  spon-
sored by the American Lung
Association in  conjunction with
the State and Territorial Air
Pollution Program Administra-
tors and the Association of Lo-
cal Air Pollution Control Offi-
  EPA will be cooperating in
the activity which will help
reinforce the campaign EPA is
conducting to stop  tampering
with auto emissions control
equipment and use of leaded
fuel in cars designed  for un-
leaded gas.

Fuel Blending Violations
EPA recently issued notices of
violation against seven gaso-
line blenders and two fuel
additive manufacturers selling
alcohol gasoline blends in the
State of Ohio in violation  of
federal limits. The agency has
proposed that  civil  penalties
totalling $140,000 be  levied
against the alleged offenders.
  This action closely  follows
the agency's recent actions
against the use of illegal
amounts of alcohol in un-
leaded gasoline in the State of
Michigan and signifies the
EPA's increased investigation
of alcohol blending practices
  EPA said samples of un-
leaded gasoline obtained from
retail service stations pre-
dominately in the Columbus,
Ohio, area contained high
levels of methanol  without
other required fuel  additives.
Laboratory analysis showed as
much as 11.4 percent methanol
and 15.3 percent ethanol in the
samples taken. EPA has
granted waivers of a  Clean Air
Act statutory ban for certain
fuels and fuel additives of 10
percent by volume of an-
hydrous ethanol in unleaded
gasoline and several  other
blends of methanol with co-
solvent alcohols in  unleaded
Air Proposal
EPA  recently proposed not to
regulate polycyclic organic
matter (POM) compounds as a
general class under the Clean
Air Act. POM is a generic term
which covers a large class of
chemical substances usually
emitted as particulate  matter
from various stationary and
mobile sources.
  POM emissions to the
atmosphere are generally pro-
duced by combustion  proc-
esses, especially where com-
bustion is incomplete. Because
POM encompasses a large
class of compounds from di-
verse sources and because
these pollutants are not gener-
ally quantified, national es-
timates of POM emissions are
very  unreliable. However, one
study in 1980 estimated nation-
al POM emissions to be nearly
18,000 tons. The major source
categories of POM  include resi-
dential use  of wood and coal
in stoves (44 percent) and fire-
places (three percent); mobile
sources such as automobiles,
trucks and aircraft (40  percent);
forest fires (five percent); com-
mercial and industrial  incinera-
tion (three percent); and coke
oven emissions (two percent).
  The major human health
concern over airborne expo-
sure  to POM stems from its
carcinogenic (cancer-causing)
potential, tt  is well established
that extracts of particular air
pollutants which contain POM
are carcinogenic when painted
on the skin  of rodents or in-
jected into newborn mice. A
variety of POM and POM mix-
tures are mutagenic (causing
changes in genes) in various
tests. However, not all POMs
have been tested.
  The extent to which people
are exposed to these pollutants
in the ambient air, and hence
the need to regulate them as a
class under the Clean Air Act are
very unclear. Many of these
compounds are currently con-
trolled under other environ-
mental programs, especially
the national ambient air quality
standards for  particulate
matter. EPA intends  to contin-
ue investigating various POM
compounds and sources to de-
termine the magnitude of their
emissions, the public health
risks they pose, and  applicable
control techniques. Results of
this work will  be  made avail-
able to the public as they are
completed, and EPA will take
what action is needed to pro-
tect the  public health.
                                                                                  ENFORCE MENT

                                                                                 Suit on PCBs
                                                                                 The Department of Justice, on
                                                                                 behalf of EPA, has filed an
                                                                                 amended civil  suit against six
                                                                                 companies for contaminating
                                                                                 New Bedford Harbor, Mass.,
                                                                                 with polychlorinated biphenyls
                                                                                   The  original  suit on behalf of
                                                                                 the U.S. Departments of Com-
                                                                                 merce and Transportation, filed
                                                                                 December  1983 in U.S.  District
                                                                                 Court in Boston, seeks to hold
                                                                                 the defendant  companies liable
                                                                                 for damages to natural  re-
                                                                                 sources from release of PCBs
                                                                                 in the  harbor and the Acushnet
                                                                                 River estuary.  In addition, it
                                                                                 asks for recovery of past and
                                                                                 future  costs incurred by the
                                                                                 government in identifying and
                                                                                 assessing those damages. EPA
                                                                                 now seeks injunctive relief and
                                                                                 asks the defendants to  plan
                                                                                 and undertake removal and re-
                                                                                 medial actions in the harbor.
                                                                                   The  current  action charges
                                                                                 that the defendants  created the
                                                                                 threat  of imminent and sub-
                                                                                 stantial endangerment to pub-
                                                                                 lic health or the environment,
                                                                                 alleges each is jointly and
                                                                                 severally liable for environ-
                                                                                 mental and natural resources
                                                                                 damages caused  by release of
                                                                                 PCBs,  and  seeks recovery of
                                                                                 the government's costs in con-
                                                                                 nection with the site.
                                                                                                  EPA JOURNAL

   "The overall action is partic-
 ularly significant because it ad-
 dresses damages to natural  re-
 sources. New Bedford Harbor
 is a vital habitat and feeding
 area for lobster, shellfish and
 other organisms, and histor-
 ically has been a  major com-
 mercial and sport fishing
 area," said Assistant Attorney
 General F. Henry Habicht II,
 head of the  Justice De-
 partment's Land and Natural
 Resource  Division.

 Delaware Receives Award
 Delaware Governor Pierre Du-
 Pont was presented by Ad-
 ministrator William Ruckel-
 shaus with a "Certificate of
 Achievement" in recognition of
 that state's becoming the first
 to achieve final authorization
 under the federal Resource
 Conservation and Recovery Act
 (RCRA) to manage its own
 hazardous waste program.
   "Delaware's authorization
 signals a new era for this
 country as the states and
 federal  government move
 jointly to assure that the
 hazardous wastes our society
 produces are effectively con-
 trolled," Ruckelshaus stated.
   "I commend Governor Du-
 Pont and  Delaware's De-
 partment  of Natural Resources
 and Environmental Control for
 recognizing the state's role in
 regulating hazardous wastes,"
 said Ruckelshaus.
   Delaware, by achieving final
 authorization, will have pri-
 mary responsibility for
 enforcing regulations to control
 the generation, transportation,
 storage, and  disposal  of
 hazardous wastes.
   Currently, more than 40
 states and territories have  re-
 ceived interim authorization to
 administer the RCRA program,
 which  permits them to manage
 one or more  aspects of
 hazardous waste management
 at the state level. Under RCRA,
 the program  developed  by the
 states must be "substantially
 equivalent" to the federal pro-
 gram to receive final authoriza-
 tion. Delaware is the first
 state to receive final authoriza-
Superfund Contracts
Two contracts totalling more
than SlOO million to provide im-
mediate  emergency response
capabilities at hazardous waste
sites in the Northeast and Mid-
western  states were recently
awarded by EPA.
  The  contracts are with O.H.
Materials Co. of Findlay, Ohio,
and PEDCO Environmental,
Inc., of Cincinnati, Ohio.
  Each firm will provide all
cleanup personnel, equipment,
and materials needed to con-
duct Superfund emergency ac-
tivities. Each contractor is also
responsible for maintaining a
management organization to
support a standby  network of
cleanup resources  and to pro-
vide on-scene deployment of
these resources in  accordance
with the  EPA On-Scene Coordi-
nator's instructions.
  O.H. Materials Co. will stand
by to handle Superfund
emergencies for EPA's Region
1 — Maine, Vermont, New
Hampshire,  Massachusetts,
Connecticut and Rhode Island;
Region 2 — New York, New
Jersey, Puerto Rico, and the
Virgin  Islands, and Region 3
 -- Pennsylvania, Delaware, the
District of Columbia, Maryland,
Virginia,  and West Virginia.
  PEDCO Environmental, Inc.,
will handle Superfund
emergency actions for EPA's
Region 5 covering Illinois, In-
diana,  Michigan, Minnesota,
Ohio and Wisconsin.
  Similar contracts for Super-
fund emergency actions in the
Southern, Western and North-
western states were awarded
in December 1983.
Expediting Waste  Rules
In a precedent-setting action,
EPA is  listing certain hazardous
wastes as a  group, rather than
individually, in order to speed
up the  process of controlling
them. Pollutants to be  listed
are chlorinated hydrocarbon-
contaminated wastes that re-
sult from the manufacture of
such products as drycleaning
liquids, degreasing solvents,
and other chemicals.
   "We're cutting the time and
 effort to deal with these
 hazardous wastes without cut-
 ting corners," said Lee M. Tho-
 mas, EPA's Assistant Adminis-
 trator for Solid Waste and
 Emergency Response.
   "One regulation, rather than
 25 individual regulations, will
 cover the wastes of 25 major
 commercial  products," Thomas
   "As part of EPA's overall
 mission to protect public
 health and the environment,
 we must determine which
 wastes are hazardous and
 therefore legally subject to
 control. Expediting the listing
 process for hazardous wastes
 also expedites their control,"
 he explained.
  This new listing of wastes
 resulting from the manufacture
 of chlorinated aliphatic hydro-
 carbons means they now will
 be subject to controls in stor-
 age, treatment, shipment and
 Remedy at Superfund Site
 EPA Assistant Administrator
 Lee M. Thomas has decided
 that excavation and off-site dis-
 posal of wastes will remedy
 surface  contamination at the
 40-acre  Berlin & Farro Liquid
 Incineration Co., site near
 Swartz Creek,  Mich.
  The estimated $6  million
 needed  for the project will
 come from the trust fund ad-
 ministered by EPA under the
 Comprehensive Environmen-
 tal Response, Compensation,
 and Liability Act (CERCLA),
 known as Superfund.
  The Berlin & Farro site,
which was operated as a
 hazardous waste and disposal
facility from  1972 to 1981, in-
cludes two dumps filled with
drums, metal hydroxide set-
tling ponds, a paint-sludge
trench, agricultural drains, the
foundation of a liquid in-
cinerator, contaminated soil,
and numerous pockets of li-
quids, sludges, and solvents.
  Among contaminants found
at the site are a number of
organic chemicals and various
polychlorinated biphenyls
Japan Meetings
Administrator William D. Ruck-
elshaus attended a series of
meetings in Japan February 7
and 8 dealing with joint en-
vironmental projects of Japan
and the United  States.
   Ruckelshaus said the visit
afforded him the opportunity
to "see first-hand some  of the
innovative technology the
Japanese are applying to the
problems of pollution control."
   The meetings, held in  Tokyo,
were a result of a bilateral
U.S.-Japanese agreement on
environmental cooperation
signed in 1975,  which es-
tablished 14 joint projects in
such areas as sewage treat-
ment technology, solid waste
management and the control
of air  pollution from vehicles
and industrial and commercial
sites. Oversight  for the projects
is  provided by the Joint  U.S.-
Japanese Planning and
Coordinating Committee of
which Ruckelshaus is co-
chairman with Minoru Ueda,
Japan's environmental agency
APRIL 1984

Environmental  Almanac
Exploring  Fern  Valley
In a green sanctuary in Northeast
Washington the notes of a woodthrush
floated down from a towering beech tree
while an ambulance siren wailed in the
distant background, adding poignancy to
the melancholy birdsong.
  These sounds were heard recently in
Fern  Valley, one of the more secluded
nooks in the U. S. National Arboretum.
The arboretum is an oasis of trees,
shrubs and flowers which graces an
urban neighborhood dominated by ware-
houses, motels, fast food restaurants and
the endless car and truck traffic on New
York Avenue, one of the main entrances
to the Nation's Capital.
  Fern  Valley is a natural woodland
where thousands of ferns, shrubs, and
wildflowers have been planted since 1959

as part of a joint educational project of
the National Arboretum and the National
Capital Area Federation of Garden Clubs.
  Most of the ferns native to the Eastern
United States can be seen in this peace-
ful four-acre retreat hidden away from
the hurly-burly of a huge metropolis.
  At this time of year many of the ferns
are beginning to rise from the  ground
with their leaves or fronds in tightly
curled shapes known as fiddleheads,
curved like the scroll  at the head of a
  Among the ferns growing here are
Christmas ferns, which have leaflets
shaped like stockings hung on  the mantle
at Yule time; Cinammon ferns, named for
the brownish wool which grows on their
fiddleheads and which are used as nest
material by many small birds;  and New
York ferns, recognized by the lacy fronds
which taper at both ends. Students are
taught to remember the name  of this
plant by recalling that New Yorkers are
reputed to burn the candle  at both ends.
  Some of the more exotic plants  include
the Royal fern, an imposing species
which often grows in swampy  locations
or shallow waters; Ostrich ferns, named
because of the supposed resemblance of
its fronds to an ostrich feather; and the
remarkable walking fern. When the tips
of this plant's spear-iike fronds touch the
ground, they take root and produce clus-
ters of similar fronds, thus advancing this
species across the ground.
  Tree-like ancestors of modern ferns
formed some of the world's great coal
deposits. Today ferns generally have no
economic value, but they do bring grace
and beauty wherever they are found.
  They carpet the forest floor in parts of
Fern Valley where they live in com-
munities of plants with similar require-
ments for climate, soil, moisture  and sun-
  One of these communities demon-
strates the plant life of a northern forest.
Here in addition to ferns are many
shrubs and small trees which have been
planted including azaleas, laurel, rho-
dodendron, blueberry, hobblebush, nan-
nyberry, witchhazel, bay berry, mountain
holly, shadbush, dogwood, and striped
and mountain maple.
  In the acid soil  under the pine trees are
found pink ladyslippers, orchids,  winter-
green, partridgeberry,  and Canada may-
  In less acid locations under deciduous
trees such as oak and  beech many spring
wildflowers bloom before the new tree
leaves shade the  sunlight. These flowers
include trillium, hepatica, spring  beauty,
dutchman's breeches,  bloodroot, foam
flower and wood violets.
  Near the end of the  marked trail that
winds through Fern Valley is  a wall of
historic limestone rocks, built to  prevent
erosion and to provide a habitat  for such
plants as the walking fern that need  a
"sweet" or neutral soil.
  Standing by this wall and reflecting on
the interrelationships of these plants to
each other and to the  larger world
around them, one can recall the words of
a poem by Tennyson about a flower in a
crannied wall:

"Little flower, but if I could
What you are, root and all,
  and all in all,
I should know what God
  and man is."
—C. D. P.
                                                                                                     EPA JOURNAL


Shore birds feeding on the beach.

United States
Environmental Protection
Washington DC 20460
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Penalty for Private Use
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