United States ,
Environmental P
'Agency
Office of
Public Affairs {A-107)
Washington DC 20460
Volume 10
Number 4
May 1984
&EPA JOURNAL
Secrets of the Forest
Another challenge for
EP.A's research program
«•..• ., .5, .'•
>.- >-.<• . '
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Research
Challenges
at EPA
Solving today's complex
environmental problems
requires a lot of facts as well
as action. In this issue of EPA
Journal, the research that
underpins environmental
decisions is explored.
An overview of research at
EPA is provided in an interview
with Dr. Bernard Goldstein, a
physician and research
scientist who is now Assistant
Administrator for Research and
Development. As an example
of advancing EPA research, an
article describes a project to
monitor the actual daily
exposure of people to toxic
substances in their normal
environment.
Reports from the agency's 14
laboratories describe a wide
range of research targets, from
ground-water contamination to
the risk of pollution-related
heart disease.
The major effort being
launched to understand
pollution's role in a forest
die-back in the eastern United
States is explained by EPA
Administrator William
Ruckelshaus in testimony to
Congress.
A renowned scientist and
specialist in the dangers of
asbestos, Dr. Irving J. Selikoff
of the Mount Sinai School of
Medicine in New York,
discusses the lessons to be
learned from the asbestos
tragedy.
A photo essay portrays
activities by EPA specialists
to cope with a mock nuclear
power plant accident in
Florida.
EPA's research to help the
agency deal with the highly
toxic chemical, dioxin, is
explained in an interview with
Erich Bretthauer, who
represents the Office of
Research and Development on
EPA's Dioxin Management
Task Force. Seven other
highlights of science at EPA
are described in an article by
Richard Laska, a writer for the
agency. The role of research
behind the Administrator's
recent proposals for a new
standard for particles in air is
detailed in another article.
A look at another EPA
science resource—the Science
Advisory Board—is provided
•-
err.: » •
Scientists at EPA's Environmental Research Laboratory in Corvallis, Ore,, check for
ozone damage on pine seed/ings in the laboratory's greenhouse facility.
by Dr. Norton Nelson,
Chairman of the Board's
Executive Committee and a
professor of environmental
medicine at the Institute of
Environmental Medicine, New
York University Medical Center.
The results of EPA's program
to test the potential of cleanup
technology and help industry
adopt more efficient control
methods are explained in an
article by Susan Tejada,
Contributing Editor of EPA
Journal. The two-fold benefits
of cost savings and cleaner air
from research sponsored by
EPA and being adopted by
industry to control volatile
organic compounds are
described in a piece by Carl
Gagliardi, an EPA press officer.
Activities to support a chief
EPA goal—good risk
assessment—are explained by
Dr. Elizabeth L. Anderson,
Director of the Office of Health
and Environmental
Assessment.
In a recent speech to the
National Wildlife Federation,
Administrator Ruckelshaus
reviewed progress made in the
first year of his second term as
Administrator. Excerpts from
his comments are included.
Eight new appointments at
the agency are reported, along
with news summaries in
Update, a feature on new
agency developments.
The link between the
horseshoe crab and
shore birds on the
beaches of Cape May, N.J., is
reported in Environmental
Almanac. [.
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 10
Number 4
May 1984
vvEPA 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
proteci the Nation's land, air and
water systems. Under a mandate of
national environmental laws, ihe
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
transection 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
materials.
Research at EPA: An
Interview with Dr.
Bernard Goldstein 2
Measuring Human
Exposure to Toxics 7
Reports from EPA's
Laboratories 10
EPA Probing Forest
Damage 18
20 Lessons from
Asbestos-By Dr. Irving J.
Selikoff 21
EPA Helps in Mock
Nuclear Exercise 25
Learning to Control
Dioxin 26
The Research Behind a
Clean Air Proposal 29
EPA Science
Highlights 32
Science and the
EPA Science Advisory
Board 35
Testing the Potential of
Cleanup Technology 37
Cutting Costs While
Cleaning Air 40
Assessing Health and
Environmental Risks 42
Update: New Agency
Developments 45
Ruckelshaus Reviews
Year at EPA 48
Appointments at EPA 50
Destiny on a Beach 52
Front Cover: Spring brings pale
green leaves to a west Virginia
forest near Harpers Ferry. Photo by
Linda Bartlett of Folio. (See story on
page 18)
Photo Credits: Linda Bartlett of
Folio: Steve Delaney; Vermont
Travel Division, State of Vermont;
Schecter Me Sun Lee; Washington
Suburban Sanitary Commission;
Chemical Week; and Charles
O'Hear, EPA-Documerica.
Design Credits: Robert Flanagan;
Ron Farrah.
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Research at EPA:
An Interview with Dr.
Bernard Goldstein
Q
This is a special EPA Journal interview
with Dr. Bernard Goldstein, Assistant
Administrator for Research and
Development at EPA. A physician and
research scientist by profession. Dr.
Goldstein has been in his post at EPA
since November 1983.
Dr. Craig McFarlane, right, an environmental
scientist at EPA's Corvailis facility, describes
to Dr. Bernard Goldstein the use of an
exposure chamber for measuring the uptake
of toxic substances by plants.
What are some of the major
problems that environmental research
needs to address over the next ten
years?
A
If we look at broader context type of
issues, certain things pop out. For
example, we are going to have to know
better how people are exposed to
environmental contaminants. We do a
good job of interpreting the intrinsic
hazard, the possibility that an adverse
effect may occur due to a compound. We
don't do as good a job of finding out the
extent to which this compound is actually
affecting the public.
Exposure is a broad over-arching area
that we have to look at, and it will
require research in a number of different
media. In terms of air and water a
number of different approaches will be
required. We need better models as to
how people get exposed, and how
environmental targets get exposed. We
need better ways of measuring pollutants
in air and in water and in the soil. We
have to start taking advantage of some of
the newer advances in biological
monitoring.
We need to explore some of the new
wizard-like technology that people read
about in the papers, in terms of making
new genes and things along that line.
These approaches may actually open up
the opportunity to detect very small
changes in normal human constituents,
and, perhaps, even detect the chemica!
that's causing these very small changes
that is now attached to, say, the human
red blood cell.
If we can develop these new
techniques, we can, perhaps in the next
decade, be in the situation of really
knowing how much people are exposed.
We may really be able to know whether
someone living next to a toxic waste
dump has had more of an exposure than
someone living somewhere else. We may
really be able to detect the amount of
diesel exhaust constituents that are
attached to a person's blood cell during
the four months that such a cell usually
survives.
This would give us a much better
handle on exposure than we have right
now and allow us to make a lot more
appropriate decisions as to what really is
affecting people, what really is getting
into the human body and is capable of
causing adverse health.
Q
What else should environmental
research focus on in the next decade?
r\ We have to understand better how
things move through the environment.
The ground-water problem is a classic
example.
EPA JOURNAL
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We don't really understand as well as
we should how a chemical at an
industrial plant eventually gets into a
glass of drinking water somewhere,
perhaps hundreds of miles away. How do
these things move through our society?
It's a little easier to understand in air and
water than it is in the soil.
We are going to have to know a lot
more in the next decade about certain
parts of our ecosystem. For instance,
there is some recent information
suggesting that there may be a
significant die-back in American forests
up and down the whole East Coast.
We just don't yet know enough about
the die-back to be able to ascribe a
specific cause — to say, "Ah, this must
be due to acid rain, or this must be due
to ozone." It could be due to some
natural cycle that occurs in nature for
reasons unrelated to air pollution. We
must know the inter-relationships of all
the various things that go into producing
a forest and how pollution fits into that
relationship.
Q
: What about research into conditions
that make pollution worse than it would
be alone?
A
, We are going to have to start doing
more to understand the stress that a
pollutant causes in relation to the total
stresses that are present in an
environment that are not due to pollution
— the weather, insects, things along that
line which can also have effects, but
which we tend to think of independently
of pollution's impact.
We also have to start spending a lot
more time and effort in the area of
interactions of pollutants. For instance,
we know that even though we do our
research for the most part with one
chemical at a time, in fact in the real
world there are multiple pollutants all
occurring at the same time. Some are in
air and some are in water.
There's now, for instance, a body of
evidence developing that says if you give
a laboratory animal some alcohol in
drinking water, equivalent to a couple of
beers a day, it is going to react
differently to a pollutant. That's telling us
that we have to be very alert to potential
interactions.
Of course, we can't look at every
possible interaction. This brings up the
subject of mechanistic research. If it's
going to be important for us to
generalize from one group of chemicals
to another, then the only way that that
generalization can really work in a
manner that's going to protect the public
is if we understand the mechanism by
which chemicals cause damage. It's not
just counting the bodies, if you will,
measuring the adverse effects, but being
able to state why the adverse effects
occur, because when we understand this,
we can then be much more predictive
about the next chemical that comes
along that might also produce the same
effect.
Q
Q
Is the kind of research you're talking
about longer range, more in depth, and if
it is does EPA have the funding stability
to sustain it?
r\ Funding stability is always a problem,
and I'm not going to try to predict it for
ten years from now. One of our biggest
problems as an agency has been the fact
that we have not had sufficient stability
in our laboratory research program to be
able to do the research that we would
want to do, and, in fact, even research
that we had planned to do.
You just cannot mothball an
experiment. You can't stop an
experiment in the middle without really
losing a lot of what you have invested.
So stability is very important. But by the
same token, when you do science in a
regulatory agency, it means that you will
be responding to the needs of the public;
and if an unexpected problem comes up,
and the public says, "We want a lot of
attention devoted to this particular topic
because we are concerned about it," it is
appropriate for the regulator to ask the
scientists to stop what they are doing
and to address this new area.
In a regulatory agency you do need the
flexibility to respond to what the public
wants, and that's appropriate. But it's
part of the job of management, of the
regulatory agency, of the Office of
Research and Development, to make sure
that when we do change what we are
going to do that that cost is factored in,
that we realize what the costs are. We
should only pull scientists away from
what they're doing to do something else
if there's a real need for it, that will
overcome the cost of what we're losing
by not having the scientist continue the
original research.
Q
Could a better job have been done
on acid rain if the crucial questions had
been asked early enough so that the
research could have been done?
r\ Yes. For example, I've been informed
that from the mid to late 1970s our
research people continually requested
funding to develop the monitoring
techniques to measure the deposition of
acid rain, and they were turned down
because it was simply not a high enough
priority.
I would suggest that in retrospect that
was the wrong decision, and it
demonstrates that we must be looking
far enough ahead.
How can EPA be sure it is looking far
enough ahead in its research?
r\ Right now we're going through a
strategy exercise where each of the
program office assistant administrators
and myself are sitting down with our
senior staff and writing a priority, a
strategy document. We're beginning the
Fiscal Year 1986 planning cycle, and
we're not only asking for an agreement
between the research and development
senior staff and the program office senior
staff on what the priorities should be for
1986, we're asking at the same time
about 1990.
So we're doing both simultaneously.
We intend that when the research
committees set up their research
priorities for 1986, that they also look
ahead to 1990 and say, yes, it's true this
is important for 1986, but here is
something that really deserves a little bit
of a higher priority because even though
it isn't that important in 1986, look how it
becomes more important in 1990, and if
we don't start in 1986 we're not going to
know by 1990.
The concept is that we have to not only
be asking ourselves what are the issues
for the very next year, but what are the
issues for a couple years down the road
so we're not going to get blindsided as
we have to some extent by the acid rain
issue and by other issues in not being
able to provide answers to the questions
that the Administrator and the public are
asking.
Q
When are we going to know enough
to actually step in and control acid rain?
r\ That's a two part question in a sense,
and people have to keep that in mind.
You're really asking a question that has
risk assessment and risk management
aspects.
Knowing enough depends on what
context. For instance, I'm a physician. If I
dealt with a situation where someone
may or may not have a disease for which
I have a medicine which has no side
effects to cure that disease, I don't need
much information to show that the
person has a disease before I give the
medicine.
On the other hand, if I'm dealing with a
situation where the medicine has severe
side effects, or the potential for severe
side effects, I'm not going to give the
medicine for that disease until I'm much
more certain about the fact that the
disease is really present.
We're dealing with that kind of
situation in acid rain. If, for instance, it
costs a dollar and a quarter to clean up
all the sulfur oxides and oxides of
nitrogen that are present in the air, and
MAY 1984
-------
maybe causing acid rain, we would have
spent this as a society. We have enough
information now to say, sure we'd spend
a dollar and a quarter.
If it would cost the entire gross
national product, we would also get
complete agreement from everyone, no,
we're not going to spend the entire gross
national product on this issue, because,
you know, we simply don't have enough
information.
You obviously have to put these
considerations into the equation. And
you have to know what the people are
feeling about these things before you say
that there is enough research. That's
really the risk manager's decision.
Q
, What is the job of research in these
tough environmental issues?
r\ It's our job in research and
development to keep on doing the crucial
experiments, to resolve the uncertainties,
to continually be interpreting the results
as we get them, to be letting the
Administrator and the public know what
the boundaries of our uncertainty are, to
be able to say what it is that the research
seems to be telling us, what the data
seem to say, and with what degree of
uncertainty.
So, again, to get back to the analogy of
the person who's got the disease. I want
to know not only whether the testing
indicates the disease, but how sure I am
about that before I do the management
approach of giving a dangerous
medicine.
Now, I don't know at what point the
manager will decide that this risk is
something that ought to be handled with
this particular type of management tool.
It will all depend on what kind of
management tools are available. My
suggestion is that if the management
tool consisted of spending a dollar and a
quarter, it would have been done by
now. It's not our job to tell the manager
that. That's not an R & D job, it's really, if
you will, a regulatory policy decision to
say we know enough.
The job of R & D is to determine what
the crucial experiment is, so as to answer
the questions that are related to the
mission of EPA.
Q
How does EPA research stack up with
academic research in facing such
questions?
A
I've been very pleased by the fact
that the research that I've seen in our
laboratories has, if anything, less of the
kind of intellectual stagnation that one
frequently sees at universities, where
people just plan next year's research
based on what they are doing this year,
without any real attention to the
questions that they are asking and the
crucial information they may need.
Q
Do public fears about environmental
dangers usually tally with science's
conclusions or is one or the other way
off?
A
It's not unusual that there will be
differences among scientists and the
public. Coming out of a medical
background I think it's certainly no
different than one sees in a medical
situation: sometimes the degree of public
alarm is beyond what seems to be
appropriate from a medical point of view
and sometimes less. We certainly ought
to have much more concern about
cigarette smoking and seat belt use in
our society than we have.
Q
Is it possible to be honest and factual
in assessing the risk of pollutants without
being biased toward industry or public
opinion?
A
It's definitely possible, and should be
done at all times. That's what the
Administrator means when he talks
about separating risk assessment and
risk management. He's asked that the risk
assessors, and in this case we're talking
about the Office of Research and
Development, should be assessing risks
and providing the information so that the
managers can manage the risk. And by
the managers I mean the program offices
and obviously the Administrator and the
Deputy Administrator.
There's a clear-cut distinction between
assessment of risk and management of
risk. There are times when it gets a little
fuzzy. There are small points where it's
difficult to sort out the differences. But I'd
say for 99.99 percent of what we do it's
clear that we're assessing the risk, we're
not managing the risk, and it's clear that
that assessment of the risk must be done
independently of our own personal
biases, independently of what the
program offices might want us to say,
and independently of what somebody
might have voted us to say.
The science must be done in such a
way that the manager can really rely on
getting an unbiased point of view, an
unbiased assessment of what we know
and what we don't know and how sure
we are of what we do know. Then they
can use that information in managing.
Q
Are researchers inevitably part
manager when they assess risks?
r\ It's important not only that we do not
distort the science, but that we don't try
to play the role of policy makers. We are
not policy makers. We should not, for
instance, write a paper for a scientific
journal having to do with, say, the levels
of a pollutant in a given area, and
conclude our journal article by saying
therefore that we ought to take the
following management approach.
(JL In addressing current problems like
EDB and dioxin, is there a gap right now
between what we know and what we
need to know?
r\ It's what we need to know that
counts. You can argue that in terms, for
instance, of EDB we really know what we
need to know on that substance and that
you've seen the Administrator work: get
the information, put it together, and go
forward with that information. In
retrospect, we should have been doing a
lot more research on EDB about ten
years ago.
On dioxin there's a lot of things we do
know; there's a lot more that we need to
know. I can give you a whole lot of
research needs for dioxin that would fill
up a document in and of itself. As we
discussed when we talked about acid
rain, the decision as to when we have
enough information is a management
decision, not a scientific one.
What do we need to know about
dioxin?
A
, A major research concern with dioxin
is how to get rid of it. We know it's there.
But simply banning it doesn't do any
good. It's not like EDB where it's made
for use in commerce and you just can
simply prevent it from being made for
that purpose. Here we've got the stuff
lying around in unwanted places. How do
we get rid of it, and how do we get rid of
it in a way that doesn't cause other
potential damage to the public? That's a
very legitimate area for research.
Obviously, we could decide that to get
rid of dioxin would require digging it up,
putting it in a truck and carrying it cross
country. However there are certain risks
associated with each of those actions. So
we've got to think of ways to remove
dioxin which will cut down on the overall
risk.
Then of course we've got to know
more about how dioxin gets formed. It's
formed in burning processes. So we
i must know more about that so we can
prevent its formation.
We have to know more about the real
risk of dioxin to man—how much of a
likelihood is it that dioxin will cause
cancer in man or cause other effects?
We have some data from which we're
extrapolating, but we could do a lot
EPA JOURNAL
-------
better than we are doing right now if we
had some more research on the subject.
It might lead us to a lot more certainty
about what the limits of the effects were.
Such research would make our decisions
about how to get rid of dioxin, how to
prevent it, and how much money to
spend on it, a lot more firmly grounded.
We have to know more about how
long dioxin persists in the environment.
What difference does it make where it is
in the environment as to how long it will
persist? Will it get into ground water;
how does it move through our
environment?
Q
You seem to be suggesting that we
can find the answer to these modern day
environmental dilemmas.
/A Philosophically there are some
answers which you can never ever get,
but in terms of the kinds of questions we
are asking here at EPA, for the most part
we can reasonably expect that there will
be answers if we want to devote the
resources to the questions.
Sometimes the answers won't get
there quickly enough for us to do
something about them in the near term,
and there will be problems like dioxin
where we can't and we should not wait
until we know every single thing there is
to know before we proceed further.
We don't want to say that the fact
there's one more experiment we
can do means that there's a reason for
the manager not to act. But again, this is
a management decision.
In the six months or so that I've been
in this agency, I have been impressed by
how often I have seen the program
offices wrestle with a decision for which
there could have been an answer, had
the question been asked in time.
Dr. William Hogsett, a plant physiologist at
the EPA Environmental Research Laboratory
in Corvallis, Ore., discusses the use of open
top chambers to study long-term effects of
ozone on hay crops with Dr. Goldstein.
For so many of the questions that I've
seen the program offices wrestle with,
further information could have helped
them with their selection of options. If
the question had been asked a few years
ago, we'd have had the answers for them
now.
So clearly, the important role of the
Office of Research and Development is to
be able to work with the program offices
in anticipating what their questions are
going to be a few years from now.
MAY 1984
-------
Q
Based on what we've learned so far,
are we going to be able to deal with
ground-water contamination?
A
We can deal with it to some extent
right now. Again, it's a question of how
are we going to go about doing it. And
dealing with it is a concern for the most
part of the Office of Water and they've
certainly put a lot of effort into this area.
At the Office of Research and
Development, we've had an integrated,
almost a matrix type of approach to
ground water for a number of years now.
Obviously the research needed cuts
across a number of different disciplines.
For instance, how do compounds move
through the environment to get into
ground water? To answer this, we have
to know a fair amount about just the
normal hydrology of ground water. We
have to know about soils, because we're
usually talking about putting something
down on the soil and then it ends up in
the ground water.
We have to know about how
compounds change as they move
through the soil. We have to know what
their residence time is. Obviously a
compound that will decompose almost
instantaneously when it hits the ground
is not a compound we worry about in
terms of ground-water problems, but
other compounds which stay around for
a long time are of concern.
We have a trade-off in that compounds
that tend to be water insoluble such as
PCBs and DDT tend to stay in our
environment for quite some period of
time. What that means is that the
compounds that are not water soluble
are less likely to get into our water, but if
they do, they'll tend to do different things
than will the usual water soluble
compounds.
There's a whole range in degree of
water solubility or non-solubility, and
soils attract different types of compounds
depending upon their chemical
characteristics. So you have to know
about the chemistry of the compounds
that you're dealing with to be able to
predict what's going to happen, to really
be able to link up the chemistry of
compounds with their action in soil and
water so you can get some predictive
ideas as to the potential ground-water
problems.
\Ji Do you see a role for EPA in
stimulating new cleanup technology on
the part of industry through research and
development work?
r\ Definitely. A very major role. We've
worked closely with, industry. There are a
number of approaches being used right
now that came out of basic findings in
our control technology laboratories,
where the labs have developed the
concept and then in cooperation with
industry have eventually turned it over to
them to make the salable item that is
now being used commercially to keep
the environment clean.
Q
Q
ORD has quite an extensive research
apparatus. Is there overlap or is
everybody working on separate things?
A
, There is some overlap, and it's the
kind of thing which we have to be very
careful about. If you go to business
school and you learn a management type
of approach, overlap is always
considered to be very negative.
From a scientific point of view, though,
overlap is something that's relatively
positive as long as it doesn't go too far.
You want some overlap.
The area I'm most familiar with is
health research. You can look at the most
dynamic types of health research and
you will find that there's tremendous
overlap and it's through this overlap, this
continual feeding back and forth of ideas
from different people occurring at
national meetings and international
meetings and through the mechanism of
publications that the dynamic areas have
really gotten where they are. The same
thing is necessary if you are going to
develop a program for the EPA. No, we
don't want overlap that's unnecessary,
but I'm not afraid of overlap in science in
the same sense that I would be if we had
overlap in our managerial functions.
Q
You come from the scientific
community. How do you like being an
administrator in a government agency?
A
must say when I visit the
laboratories and I sit through the one or
two day briefings that they prepare for
me on the research that's going on, that
to me is the most fun I have.
Listening to good research, and there's
just some outstanding research going on
in the EPA laboratories, is exciting. I find
if I spend too much time in Washington,
and I don't hear about research I start
getting a little unhappy with the job.
Is there anything concluding this
interview that you would like to add?
r\ A bottom line is that I have been so
impressed with the dedication of the
scientists at EPA to the mission of the
agency. The fact that they are really and
truly working beyond the usual hours
shows greater concern than you find in
most research groups. They really are
concerned about the environmental
problems that they're trying to find the
answers for. One comes back from a visit
to the laboratory with a renewed sense
of dedication.
It's again a reminder of the fact that
the most important work in research and
development is not being done here in
Washington, but in the
field, in the laboratories. Our job in
Washington is to facilitate what is
happening out in the field and to make
sure the communication occurs with the
program offices and with the scientific
community so that we can let people
know what's happening. D
EPA JOURNAL
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Measuring Human
Exposure to Toxics
Dear Californian:
The United States Environmental Protection Agency is
currently conducting a study of exposure to toxic
substances in your area. This study, known as the Total
Exposure Assessment Methodology (TEAM Study), is
being carried out by Research Triangle Institute (RTI),
from North Carolina. As part of this study, a
representative of RTI recently interviewed a member of
your household. Based on the information collected
during this interview and several hundred others in your
area, a sample of persons was selected to participate in
this most important study.
A letter further explaining the study was left at your
household earlier, and another copy is enclosed. Within
the next few weeks, an RTI Field Interviewer, who will
display an RTI identification badge, will contact you to
explain more about the study and your participation in
it. With your permission, the interviewer will conduct a
short interview, and set up an appointment for the
collection of the samples listed in the explanatory letter.
Your random selection makes you the representative of
many of your neighbors and other persons like you. Your
cooperation in this important study is therefore vital and
I urge you most strongly to agree to participate when the
interviewer contacts you. Any further questions that you
have will be answered by the interviewer.
Thank you very much for your concern and cooperation.
Sincerely yours,
William D. Ruckelshaus
Administrator
Approximately 75 citizen volunteers in
the California communities of Antioch
and Pittsburg, near San Francisco, will
wear personal air sampling equipment
for a day to help monitor their normal
exposure to toxic substances in their
environment. A companion study is being
conducted with 175 Los Angeles residents.
These two locales, Antioch/Pittsburg and
Los'Angeles, were selected both for what
they have in common — community
interest and cooperation and oil refining
and chemical manufacturing operations
— and, what they don't — meteorological
conditions and vehicle traffic patterns.
These activities are being conducted as
part of an EPA study to test a
methodology for estimating the
distribution of exposures on an entire
community to a number of pollutants.
The project is known as the Total
Exposure Assessment Methodology
(TEAM) study.
"We will be analyzing people in normal
activities, rather than controlled
laboratory situations," explained Dr.
Lance Wallace, an EPA environmental
scientist. "This will allow us to improve
on our previous estimates, which were
based on mathematical models. We are
also introducing new sensitive
instruments and methods for this
on-the-spot research."
Supporting the research study are the
California Department of Health Services
and the California Air Resources Board.
EPA officials have been interviewing
individuals in about 600 households
in the San Francisco area to
create a sample from which 75 people
will be selected to use the monitors.
Persons interviewed are provided with
a letter from EPA Administrator William
D. Ruckelshaus asking their cooperation in
carrying out the study.
The study is innovative in that it calls
for extensive use of personal air quality
monitors to measure the extent to which
these residents are exposed to
concentrations of volatile organic
compounds, such as chloroform,
benzene, and twenty other organics,
during their normal routine. In addition
MAY 1984
-------
to these portable monitors, fixed-site
monitors will be stationed at various
locations throughout the study area.
Samples of drinking water will be
analyzed, along with breath samples. All
of the data will be compared to results of
similar studies conducted last year in
Greensboro, North Carolina, and
Bayonne and Elizabeth, New Jersey, to
compare communities of differing
populations and industrial activity.
The overall study, which is being
carried out by the Research Triangle
Institute in North Carolina, measures
people's exposure to chemicals, but does
not assess health effects.
Early findings are that many of the 20
chemicals studied are present in the air
and water of a majority of residents of
Greensboro, Bayonne and Elizabeth. In
particular, personal exposures to 11 of
the most prevalent chemicals are greater
— sometimes much greater — than the
corresponding outdoor concentrations in
the participants' back yards. All 11 of
these prevalent chemicals were found in
the exhaled breath of the participants,
even while breathing pure air, indicating
that the chemicals were in their
bloodstream. Concentrations in exhaled
breath were also often higher than
outdoor levels. If confirmed by the
California results, these findings would
have an impact on EPA's policy toward
managing toxic organics in air.
TEAM represents the first use of a
statistically sampled population to
unravel the relationship between
exposure and body burden, according to
an article in RTI's publication, The
Hypotenuse. The term "body burden"
refers to the amount of a specific
chemical in a person's body fluids and
tissues.
Another unique aspect of the TEAM
study is that techniques developed at RTI
using miniature personal air monitors
I
played an important role in the field
studies. The monitors are capable of
collecting and concentrating organic
substances in the air continuously for 12
hours. The environmental concentrations
of a number of compounds, including
chloroform, toluene and benzene, can be
determined later in the laboratory by
analyzing the contents of the monitor's
removable cartridge.Organic volatiles can
be determined in the parts per billion
range.
"An ultimate goal of TEAM is to
develop a model that can predict the
frequency of exposure in a popluation
and the body burden that results from a
given exposure to a certain organic
compound," said Dr. Edo Pellizzari, who
heads the multidisciplinary team of RTI
analytical chemists, survey specialists
and. statisticians who are carrying out the
EPA study.
Workers in many occupations are
routinely exposed to a variety of
potentially hazardous chemicals, but little
is known about how much their bodies
actually retain.
For each of the chemicals under study,
the RTI researchers also want to find out
how the route of exposure affects body
burden. For example, it may be that a
certain chemical is not absorbed by the
body when present in drinking water, but
is absorbed when present in air. In
addition, some chemicals may be taken
up by the body more readily than others.
"Exposure measurements indicate only
the potential dosage an individual might
receive," Dr. Pellizzari said, "but
EPA JOURNAL
-------
Demonstration by Douglas Keeler. a former
Research Triangle Institute employee, of
special carrying vest and personal air
monitoring equipment used in project to
measure human exposure to toxics.
exposure is not synonymous with
dosage."
Using a properly designed approach,
body burden can be a good measure of
dosage.So by defining the link between
exposure and body burden, the TEAM
study will help scientists determine
which chemicals pose the greatest risk to
the public. Once researchers know the
levels of substances absorbed by body
fluids and tissue, they will be able to
concentrate on the more significant ones.
TEAM, however, will not evaluate the
health effects of exposure to various
chemicals.
"The next step would be to determine
the relationship between body burden, or
dosage, of a specific chemical and its
effect on one's heahh," Dr. Pellizzari said.
"But determining that relationship is not
within the realm of the TEAM."
Health effects laboratories at EPA are
investigating the effects of some of these
chemicals on animals and conducting
bioassay tests which will help estimate
the health effect on humans. D
Analytical Tools and Techniques
The personal air monitor,
which is used to sample air
within the breathing zone of
study participants, was
specially designed for the
TEAM study. Weighing only
about a pound, the monitor
has a battery powered pump.
It is preset and requires no
adjustment by the wearer.
During the 24-hour monitoring
period, the cartridge needs to
be changed only once.
Identical cartridges are used
in the personal air and fixed
site monitors.
Before they could conduct a
large-scale study of human
exposures and body burden,
RTI researchers had to
develop an accurate and
reproducible methodology for
measuring low levels of
volatile organic pollutants in
air, breath and water.
To collect the first two types
of samples, air and breath are
pumped across a cartridge
containing a polymeric
sorbent called TENAX, which
traps certain organic
chemicals present in the
sampled air. After they are
returned to RTI for analysis,
the cartridges are heated in a
special chamber. The organic
compounds are then
thermally purged from the
cartridge with helium gas and
collected in a liquid
nitrogen-cooled trap. Next the
collected vapors are separated
by gas chromatography and
analyzed by electron impact
mass spectrometry.
Dr. Edo Pellizzari, TEAM
principal investigator, began
developing the procedure for
using TENAX to measure the
concentrations of organic
chemicals in ambient air
several years ago. However,
the TEAM study marks the
first time this technique has
been adapted to a miniature
personal monitor and field
tested on a very large number
of people.
A special spirometer was
also developed by RTI
researchers for the TEAM
study. Used in the field to
collect breath samples, it
consists of two bags. One
contains pure, humidified air,
which a study participant
breathes while wearing nose
plugs. Exhaled breath is
collected in the other bag.
"It takes from three to five
minutes of breathing for a
person to fill the empty bag,"
explained RTI chemist Jeff
Keever. "It contains about 40
liters of air when full." After
the bag is filled, the air in it is
pumped through a TENAX
cartridge to trap exhaled
volatile organic compounds.
These cartridges are returned
to RTI, where they are
analyzed in the same way as
those from the personal air
and fixed site monitors.
Unlike the air and breath
samples, the pollutants in
drinking water samples are
not extracted in the field. Vials
of collected drinking water are
kept tightly sealed and
refrigerated until they arrive at
RTI. In the laboratory, organic
compounds are purged from
the water samples with
helium and pumped across a
TENAX cartridge. The flow of
gas is then reversed, and the
trapped pollutants are
removed from the cartridge
and introduced into a gas
chromatograph/mass
spectrometer for analysis.
Extensive quality control
and quality assurance
activities have been employed
in this experimental study.
EPA's Environmental
Monitoring Systems
Laboratory at Research
Triangle Park has conducted
continuing audits on all
phases of the study. All types
of samples are analyzed in
duplicate by a separate
laboratory. Q
MAY 1984
-------
Environmental
Research Laboratory
Athens, Ga.
Environmental
Research Laboratory
Gulf Breeze, Fla.
Reports
from EPA's
Laboratories
's Office of Research and
Development administers 14
laboratories around the country, from Las
Vegas, Nev., to Narragansett, R. I. To
learn about the research activities and
priorities at these laboratories, EPA
Journal asked for reports highlighting
their work. Here are summaries by these
facilities.
Research at the Environmental Research
Laboratory in Athens, Ga., predicts
what happens to chemicals that are
discharged or introduced into lakes and
rivers from point and nonpoint sources.
In cooperation with EPA's Office of
Water, the Athens laboratory is
examining samples of wastewater from
industries across the United States to
identify organic compounds
that are being introduced into the
environment in potentially toxic
amounts. Identification, at
concentrations as low as 10 parts per
billion, is achieved through the use of
sophisticated computer programs mass
spectrometer systems developed at the
laboratory. This cooperative survey will
help provide a profile of chemical
compounds for each industry.
A mathematical model of pesticide
behavior is being used to estimate the
amount of TEMIK, an insecticide that has
been found in wells in Florida, in
leachate from agricultural areas, to
predict the insecticide's movement and
fate in ground water, and to estimate
concentrations in wells or withdrawal
points. The Pesticide Root Zone Model
also is being applied in a long-term field
study in South Georgia to determine the
movement of aldicarb, the active
ingredient of TEMIK, and other
soil-applied agricultural chemicals into
ground water.
Assistance to water quality managers
in EPA and in state and local
governments in the use of mathematical
models in analyzing problems and
evaluating the effects of controls on
different sources of pollutants in
watersheds is provided through the
laboratory's Center for Water Quality
Modeling. The Center distributes and
maintains computer programs and
documentation and sponsors workshops
that provide generalized training in the
use of models and specific instruction in
the application of individual simulation
techniques.
EPA's Gulf Coast research laboratory,
located in Gulf Breeze, Fla., investigates
the effects of toxic chemicals on coastal,
estuarine, and marine environments and
evaluates the response of species of the
habitats to environmental stress.
Priorities for 1984 research are:
• Biological control agent safety testing:
to develop methods and standards to
assess hazards to aquatic species from
biological pest control agents that affect
insect survival, growth, development,
reproduction, and behavior.
• Drilling fluids: to determine chemical
characterizations and effects of fluids
used in oil exploration and drilling to
assess possible sublethal, long- term
impacts on marine life.
• Field validation: to evaluate existing
laboratory procedures for hazard
assessments of pollutants by comparing
laboratory test results with observations
following field applications of pesticides
in ongoing mosquito control programs
and other applications of toxic materials
to the environment.
• Chemical biodegradation: to develop
laboratory systems that can predict the
rate at which complex pollutants wilt
detoxify naturally in the environment.
Major research work completed in FY
1983 included a report on toxicity tests,
chemical characterizations, and modeling
with drilling fluids conducted primarily
under grants or contracts with
universities and private laboratories, and
a study of the use of aquatic systems and
organisms in monitoring pollutants for
cancer risks.
Research toxicologist Lee Courtney (/eft)
and research biologist Steve Foss of the
Environmental Research Laboratory in Gulf
Breeze, Fla,, examine a fish for tumors.
in
EPA JOURNAL
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Health Effects
Research Laboratory
Research Triangle
Park, N.C.
The Health Effects Research Laboratory
at Research Triangle Park has five
priorities for the coming year. They are:
• Clinical research: The laboratory's
clinical research program is conducting a
research project to measure the effects of
carbon monoxide exposure on the hearts
of volunteers with coronary artery
disease. This research, using a gamma
camera, is designed to determine if
individuals who have coronary vascular
disease are at greater risk than the
general public when they inhale low
concentrations of carbon monoxide.
• Genetic bioassay research: Bioassay
testing of photochemical reaction
products of diesel, wood and peat
emissions is used to determine
mutagenic activity. This research involves
outdoor reaction chambers coupled with
biological testing chambers.
• Animal toxicology studies of ozone
and nitrogen dioxide: The laboratory's
toxicology branch is conducting a major
study to investigate the chronic effects
on animals of exposure to ozone and
nitrogen dioxide. Inhalation studies with
rats exposed to these pollutants for up to
18 months are performed to characterize
pulmonary effects and effects on the
immune system.
• Developmental biology research: The
developmental biology division of the
laboratory is performing research to
determine age-related effects of
environmental pollutants. New research
is underway involving the use of in-vitro
cultured rat and hamster embryos to
determine species differences in
teratogenic response.
• Radiofrequency radiation health effects
research: The experimental biology
division is carrying out research to
determine the effects of radiofrequency
radiation on brain structure, function and
processes.
The Toxicology and Microbiology
Division of the Health Effects Research
Laboratory, located in Cincinnati, has
primary responsibility for health research
in the EPA water programs. The division
has a staff of toxicologists, biochemists,
physiologists, analytical chemists,
microbiologists, and epidemiologists with
broad capabilities for investigating both
chemical and microbiological hazards
that may be associated with drinking
water, wastewater and sludge.
Contamination of drinking water can
arise in three basic ways—pollution of
the source, pollution from by-products of
treatment, and leaching from the pipes in
the distribution system. The most
consistent contamination occurring in
drinking water arises from the
treatment and distribution of water for
public consumption. For example,
disinfection of drinking water gives rise
to a variety of by-products whose toxic
properties have yet to be defined, in
addition to the now regulated
trihalomethanes.
Additionally, there is reason to suspect
that similar by-products are formed in
the gastrointestinal tract when drinking
water containing residual
disinfectant is consumed. There is
evidence that chemicals capable of
producing toxic responses in the
reproductive and cardiovascular systems
result from reactions of chlorine to
produce carcinogenic and mutagenic
chemicals.
Unfortunately, similar problems have
been encountered with other
disinfectants and more research is
needed to identify and quantify the
potential hazards.
Physical scientist Pat Clark using electron
microscope to perform analysis at
EPA's Health Effects Research Laboratory
in Cincinnati.
The implications for changes in water
treatment practices that these
observations raise also point to the need
to reevaluate the potential impact of
established and newly-recognized
waterborne, pathogenic organisms.
Consequently, research focused on
developing appropriate methodologies
for detecting the causative agents
associated with waterborne outbreaks is
also an integral part of the Toxicology
and Microbiology Division's research
program.
Health research in the municipal
wastewater area focuses primarily on
questions related to the utilization and
disposal of municipal wastewater sludge.
Two critical areas exist that have not
been addressed by previous research.
The first is the indication that certain
sludges contain high levels of mutagenic
chemicals that cannot be accounted for
by analysis for known constituents of
sludge (e.g., the priority pollutants).
The second area is developing the data
necessary for assessing health risks for
each use or disposal method for sludge.
Data relative to distribution, marketing
and composting operations are particular
problems with regard to chemical and
microbiological contamination
respectively. However, the most critical
issue is to demonstrate how such
information can be used to make overall
estimates of the risks associated with the
particular use of a specific sludge without
having to take a contaminant-by-
contaminant approach to the problem.
In the chemical area, the laboratory
intends to demonstrate how bioassay
information may be used in the decision
process, whereas developing an indicator
system and or adopting most critical
pathogen approaches are being explored
in the microbiological area.
The water quality research program
responds in large part to the NPDES
Permitting Program. This process is the
one mechanism by which the agency is
able to protect water quality on a local
basis.
For the future, emphasis is being
placed upon developing the decision
logic for, and application of, biological
testing methods to improve the ability of
the permitting process to prevent hazards
arising from poorly characterized
effluents. Research in the microbiological
area focuses on developing disease-
related water quality indicators for
shellfish-growing waters.
MAY 1984
1 1
-------
Environmental
Research Laboratory
Corvallis, Ore.
Municipal
Environmental
Research Laboratory
Cincinnati, Ohio
The highest priority research at Corvallis
is focused on determining the effects of
acid rain on aquatic and terrestrial
resources. This laboratory chairs the
federal interagency work group on
aquatic effects and is a major participant
in the group documenting terrestrial
effects. The main objectives of the
aquatic research are to determine:
• Susceptibility of the nation's waters to
acid rain
• Current extent of effects
• How acidified waters affect biological
processes
• Methods to predict changes
• Human health implications
• Effective mitigative measures
The objectives of the terrestrial
research are to determine the effects of
acid deposition on:
• Agricultural crops
• Watersheds and outputs to aquatic
systems
• Soils and soil processes
• Forest productivity
Other programs at Corvallis include the
National Crop Loss Assessment Network
(NCLAN) which seeks to establish a
dollar cost to consumers from loss in
agricultural productivity as a result of air
pollution, primarily from the impacts of
ozone. Scientists in the plant toxicology
program are developing methods to
measure and evaluate the effects of toxic
materials on plants and the potential for
penetrating the human food chain.
Animal toxicology is a comparatively
new research area for this laboratory and
for EPA. Current projects are evaluating
test methods used by EPA to determine
the lethality of chemicals to wildlife. Test
animals are bob white quail and mallard
duck. As the program grows, the
physiological impact of toxics to these
and other mammals will be studied to
help the agency assess chemical hazards.
In the hazardous waste area, cost
effective techniques are being developed
to assess the degree of hazard at
locations receiving hazardous wastes.
Soils from land sites and sediments from
Research concerns at the Municipal
Environmental Research Laboratory
range from wastewater sewage to oil
releases. Here are some examples of the
work now underway:
Securing Drums
Corroding 208-liter (55-gallon) steel
drums holding hazardous wastes present
a threat to man and the environment, a
threat that is intensified in uncontrolled
disposal sites. To prepare such drums for
secure and safe transportation and
disposal, a process was developed to
encapsulate them in polyethylene
overpacks. Process features are custom
designed polyethylene overpacks and a
friction welding apparatus to produce
seamless overpack seals.
Crop Uptake
Beginning in the 1970s, EPA researchers
started determining the types and
concentrations of organic compounds in
sewage sludge. This effort has been
expanded to include the fate of organic
compounds in sludge treatment systems.
The results of these studies have posed
questions about the environmental fate
of the organic compounds when sludge
is applied to soil.
A workshop was held on the "Use of
Municipal Wastewater and Sludge on
Land" in February 1983, summarizing 10
years of research on the subject. The
proceedings of the workshop have been
published.
receiving waters are being studied to
determine what criteria are needed to
protect human and aquatic life.
Other aquatic research is focused on
two priorities: (1) methods to identify
aquatic eco-regions based on mapped
land features, correlating those regions
with aquatic characteristics to simplify
determination of attainable uses, and
(2) development of improved criteria
for dissolved oxygen.
12
Fuel Savings
The Municipal Environmental Research
Laboratory entered into a demonstration
agreement with Indianapolis, Ind., to
determine if the fuel requirements'for
sewage sludge incineration could be
reduced.
About $1,000,000 a year in fuel costs
are saved by the city as a result of the
demonstration. Another $3,000,000 one
time savings were realized when
Indianapolis was able to cancel plans for
construction of new air pollution control
equipment because the demonstration
brought the incinerators into compliance
with air pollution regulations. All this was
accomplished by installing $250,000
worth of instrumentation and equipment
and greatly improving the incinerators'
operating methods by what is now
known as the "fuel-efficient mode of
operation." The fuel-efficient mode is
essentially a partnership of sound
engineering and good operation. Other
cities, among them Nashville, Hartford
and Buffalo, have saved fuel because of
improved instrumentation and fuel
efficient operation.
Drinking Water Treatment
The principal goal of this research area is
to establish practical, cost-effective but
theoretically sound technologies capable
of removing known and potentially toxic
constituents found in drinking water. A
current high priority area of investigation
is the problem of contamination of
ground water by synthetic organic
chemicals. Techniques being examined
for their efficiency and cost effectiveness
in removing organic contaminants are air
stripping, granular activated carbon,
special resins, and home treatment
devices.
Aiternative Technology
The Clean Water Act encourages the
development and implementation of
"Innovative and Alternative" (I/A)
technologies and improved management
and operation of wastewater and sludge
collection, treatment and disposal
systems. Technical reviews by the
laboratory of more than 200 proposed I/A
technology projects have served as the
basis for state/regional funding decisions,
and have avoided the construction of
technology which probably would have
failed. The payback for this activity has
been estimated at 27 to 1, for a total cost
savings of about $12.5 million.
EPA JOURNAL
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Environmental Sciences
Research Laboratory
Research Triangle Park, N.C.
The Environmental Sciences Research
Laboratory at Research Triangle Park
conducts a research program in the
physical sciences to detect, define, and
quantify air pollution and its effects over
various space and time scales. This
laboratory is composed of divisions
dealing with emissions, chemistry, and
meteorology; major projects involve
expertise in all three areas.
The highest priority program at the
laboratory during the next year involves
investigations into the causes of acid
deposition, the transfer of airborne acidic
pollutants to the earth's surface by dry or
wet acid rain processes. The program
blends laboratory, theoretical, and field
research in a unified, multidiscipiinary
approach. Major components deal with
numerical modeling, chemical
composition of precipitation, flow
patterns in the atmosphere, chemical
transformations of pollutants, dry
deposition rates, and damage to
man-made materials. Analysis and
modeling of acid deposition for
mesoscale (300 kilometer) distances will
be a prime consideration, and active
The Eddy Accumulator, an instrument
developed by the Environmental Sciences
Research Laboratory in Research Triangle
Park, N.C., to measure the dry deposition
rates of acidic pollutants. With the
instrument is a laboratory scientist. Ronald
E. Speer.
planning will be proceeding for a
comprehensive regional scale (2,000
kilometer) field study in conjunction with
other federal and industry research
groups.
Research will continue on ozone
formation caused by sunlight-induced
reactions involving hydrocarbons and
nitrogen oxides derived from automotive,
industrial, and natural sources. Reaction
rates will be investigated using controlled
pollutant mixtures in laboratory smog
chambers. In anticipation of alternate fuel
usage, combustion products of methanol
will be included this year. Sets of
equations describing the scores of
reactions thought to take place in the
atmosphere will be further developed
and tested. Finally, the chemical
information will be integrated into
models that simulate all atmospheric
processes on urban to regional scales.
Work on hazardous and toxic air
pollutants will describe chemical
reactions, lifetimes, and transformation
products using laboratory techniques.
Methods of predicting reaction
mechanisms for untested compounds
will be based on similarity of molecular
structures. Measurements of aerosol and
gas phase transformation products will
describe urban atmospheres, and the
data base will be expanded on hazardous
organic chemicals and their ambient
concentrations.
A field study at the Tracy Power Plant
in Nevada will supply validation data for
numerical models of dispersion of
plumes from large pollutant sources in
the mountainous western U.S. Allied to
such field efforts are investigations of
terrain effects on pollutant dispersion
using the laboratory's wind tunnels and
water channel. These laboratory methods
provide carefully controlled experiments
with rapid turnaround, and research
officials expect to use the facility to
provide data for a court-ordered
reconsideration of stack height
regulations.
Synthetic liner being installed at hazardous
waste dump site to protect against
leaching. Liner was developed by the
Municipal Environmental Research
Laboratory in Cincinnati.
MAY 1984
13
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Environmental
Monitoring Systems
Laboratory
Research Triangle Park,N.C.
Industrial Environmental
Research Laboratory
Research Triangle Park, N.C.
The Environmental Monitoring Systems
Laboratory at Research Triangle Park has
the lead responsibility for the agency in
methods development related to air
sampling and is the agency program
manager for air quality assurance
activities. Major emphasis is now being
given to newer and more accurate
methods for sampling (e.g., new
sorbents, cryogenic trapping) and
analyzing toxic air pollutants (e.g.,
luminescence, supercritical fluid).
Development of new active and passive
monitors to measure indoor and/or total
exposure to pollution is also being
pursued.
The laboratory is addressing all aspects
of air quality assurance. The air national
audit program supplies audit materials
for many ambient air pollutants, source
pollutants, and acid rain. Special on-site
audits are conducted for major EPA
monitoring programs. All EPA air
monitoring projects are required to have
approved quality assurance programs.
The Quality Assurance Division of the
laboratory operates the equivalency
program for ambient air monitors. This
group also is providing major input into
the regulation establishing a new
particulate standard.
Congress funded EPA to address the
problem of indoor air quality in 1984. The
Environmental Monitoring Systems
Laboratory at RTP has been named the
Sead laboratory for this effort. In addition,
EPA chairs an Interagency Committee on
Indoor Air Quality. For the first time the
federal government will have a
coordinated program for investigation of
indoor air quality. Current efforts focus
on development and validation of a
protocol to conduct large field studies to
characterize the extent and severity of
indoor air pollution. This information
along with results from source
characterization studies, radon mitigation
studies, and health indicator studies will
be combined to form the EPA input into
the national health and nutritional study
(NHANES III) scheduled for 1987.
Because of its experience in air
monitoring, the laboratory has been
given the lead in researching,
developing, and deploying an acid rain
dry deposition network. A pilot study will
begin in FY-84 and continue into FY-85. A
major network of 100 stations is
EPA's particulate program in the Office of
Research and Development performs
research responsive to the needs of the
program offices, regions, states, and user
community and helps ensure that
technology necessary to achieve ambient
particulate levels consistent with the
health-based ambient air quality
standards is available. It is active in a
broad range of activities aimed at
providing cost-effective technology for
control of paniculate emissions from
smokestacks as well as for fugitive
particulate emissions. The program
which is centered around the in-house
facilities at the EPA Industrial
Environmental Research Laboratory in
Research Triangle Park has one of the
better equipped particulate control
laboratories in the world. The laboratory
contains a number of electrostatic
precipitator and fabric filtration pilot
units. Extramural research supports and
augments the in-house work.
Acid rain and the proposed inhalable
particulate standard will impact upon the
program and its direction. Most acid rain
mitigation options and the control of
finer particles will make more stringent
demands upon particulate control which
may consequently require costly
upgrading.
The Industrial Environmental Research
Laboratory for the past 15 years has
carried forward a combustion research
program aimed at developing and
evaluating cost-effective combustion
process modifications for controlling
nitrogen oxide emissions from stationary
sources. The information gained is used
(1) to support EPA's Office of Air Quality
Planning and Standards in its
development of standards and (2\ for
technical assistance to EPA regional
offices and states.
scheduled for FY-86. A methods
development/evaluation of dry deposition
monitors has also begun in support of
the dry network. The laboratory is also
actively participating in NADP/NTN - the
wet deposition network. The laboratory
has taken the lead in developing a quality
assurance program for the network.
Over these years the combustion
research staff has gained a high level of
expertise in understanding the complex
fundamental phenomena associated with
combustion processes as well as wide
experience in the practical application
and performance testing of the control
technologies on a variety of field
operating combustion systems. More
recently, this combustion expertise has
been directed at providing fundamental
hazardous waste incineration input in
support of the hazardous waste program
at the Industrial Environmental Research
Laboratory in Cincinnati in addition to the
primary emphasis on the nitrogen oxide
control program.
The major efforts of the nitrogen oxide
(NOx) control program during the next
year are focused on the application and
assessment of several advanced control
technologies. One is the evaluation of an
advanced low NOx heavy oil burner for
industrial boilers and for the incineration
of highly nitrated wastes. A second
advanced technology, based on the
in-furnace reduction of NOx through the
injection of secondary fuel beyond the
primary combustion zone, is capable of
lowering NOx emissions by at least 50
percent from the levels entering this
secondary combustion zone.
In support of the hazardous waste
incineration programs, studies are
directed at fundamental research to
develop a better understanding of solid
or sludge incineration processes so that
failure modes of various incinerator
designs (e.g., fluidized bed, rotary kiln or
fixed hearth) can be identified and
eliminated.
The LIMB program is an effort of the
Industrial Environmental Research
Laboratory to develop effective and
inexpensive emission control technology
for coal-fired boilers that will reduce
sulphur and nitrogen oxides. (LIMB
stands for Limestone Injection Multistage
Burner.) LIMB technology represents a
low-cost alternative to currently available
SOx control approaches; e.g., flue gas
desulfurization, coal cleaning, and coal
switching. LIMB technology is attractive if
coal combustion must be controlled to
minimize emissions of acid rain
precursors because LIMB is easily
retrofitted to large and small coal-fired
boilers, is lower in cost than any
available alternative, and can control
both S0xand NOX— the two major acid
rain precursors.
EPA JOURNAL
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Environmental
Research Laboratory
Narragansett, R. I.
Environmental
Research Laboratory
Duluth, Minn.
Over half of the U.S. population lives in a
50-mile wide strip of land along the
nation's coasts. Unregulated ocean-waste
disposal has led in the past, and will lead
in the future, to adverse impacts on
human health and the environment. EPA
has the legislative responsibility to
regulate the safe disposal of wastes in
the ocean. The Environmental Research
Laboratory at Narragansett, R. I. and its
field station at Newport, Ore., is the
agency's center for research related to
the development and evaluation of
procedures to assess environmental
impacts due to ocean disposal of wastes.
The laboratory has adapted a hazard
assessment strategy to evaluate the
environmental risk posed by ocean
disposal of wastes. Research is being
conducted on five components (i.e., site
characterization, waste characterization,
exposure assessment, effects assessment
and monitoring) of a dredge material
disposal operation in Long Island Sound.
Disposal site characterization was
conducted by the Corps of Engineers.
The waste was characterized using
physical, chemical and biological tests
including short- term screening tests with
the solid phase and/or the suspended
particulate phase of the waste.
Exposure studies in the field are
quantifying the relationship between
source inputs of waste contaminants and
concentration distributions of these
contaminants in space and time. Effects
studies both in the laboratory and the
field are being conducted to verify a
hierarchy of biological tests which predict
the environmental consequences of
ocean disposal. Dumpsite monitoring is
providing data for field validation of
hazard assessment predictions as well as
developing methods for monitoring
disposal operations in the future.
The Environmental Research Laboratory at
Duluth, Minn., has set up eight outdoor
channels (lower center and right) as an
experimental approach to measure the fate
and effects of toxic substances in water.
The channels are at the laboratory's
Monticello station on the Mississippi River
next to a Northern States Power Company
electric power plant.
The Environmental Research
Laboratory in Duluth, in cooperation with
the Criteria and Standards Division of the
EPA Office of Water, has recently
developed national and site-specific
guidelines for deriving water quality
criteria using laboratory procedures.
Relatively few studies have been
undertaken to determine whether water
quality criteria derived from laboratory
data provide protection to natural
ecosystems. Field studies have been
conducted at the Monticello, Minn.,
Ecological Research Station to determine
the appropriateness of proposed water
quality criteria in protecting ecosystems
and in formulating guidance on defining
the meaning of ecosystem protection.
The Monticello station is a field facility
of the Environmental Research
Laboratory-Duluth. The station is located
45 miles northwest of Minneapolis,
Minn., adjacent to the Northern States
Power Co. nuclear power plant and the
Mississippi River. The station has eight
outdoor experimental channels. Each one
is 1,700 feet long and 0.3 acres in water
surface area, and contains nine mud-
bottom pools alternating with eight
100-foot-long gravel riffles. Experimental
test water is pumped directly from the
Mississippi River and.or wells to the
outdoor channels. Invertebrate and plant
populations are naturally colonized; fish
are stocked each year.
The experimental approach has
focused on measuring fate and effects of
toxicants under both continuous and
intermittent exposures. Selection of the
exposure concentrations is based on
proposed or published water quality
criteria and onsite laboratory bioassay
results. Ecosystem protection is
determined by evaluating both structural
and functional biological responses.
Structural responses include diversity
and biomass changes, and also
incorporate survival, growth, and
reproductive measures. Functional
responses address energy flow
(production/respiration ratios, litter
decomposition, carbon cycling) through
the outdoor test system. Toxicant fate is
evaluated with available models to
elucidate pollutant behavior in aquatic
systems.
Field studies have been conducted with
six chemicals (acidification- sulfuric acid,
para-cresol, Diazinon, Dursban,
pentachlorophenol, and ammonia) and
one physical pollutant (temperature).
Site-specific evaluation studies thus far
have shown that reasonably good
ecosystem protection has been provided
from exposures near the derived criteria
limits. Tests in 1983-1984 with
pentachlorophenol and ammonia indicate
that these criteria were reasonably
satisfactory for ecosystem protection.
Additional criteria evaluations are
required if EPA and the states are to gain
confidence in water quality criteria
derivation protocols.
S-.*Y:--O-;V*£^ - I-.
MAY 1984
15
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Environmental
Monitoring and
Support Laboratory
Cincinnati, Ohio
Robert S. Kerr
Environmental
Research Laboratory
Ada, Okla.
Dan Dahling of the Environmental
Monitoring Systems Laboratory in Cincinnati
working with tissue culture stocks that will
be used to prepare assay bottles for
detection of waterborne viruses. Dahling is
with the virology staff.
The Environmental Monitoring and
Support Laboratory in Cincinnati
evaluates and standardizes methods to
analyze the presence and concentration
of physical, chemical, and radiological
pollutants in water, wastewater,
sediments and solid waste; investigates
methods for concentrating, recovering,
and identifying viruses and
microbiological organisms in water; and
conducts an agency-wJde quality
assurance program for standardizing and
assuring quality control in water and
wastewater monitoring systems.
Methods research and quality assurance
activities are major programs which
involve all laboratory personnel in one
aspect or another in a continuing effort
to provide state and local laboratories
with the necessary tools to implement
the agency's monitoring program.
Methods Research: Current high priority
research in the Physical and Chemical
Methods Branch is dedicated to
developing cost-effective methods for a
large variety of potentially hazardous and
toxic chemicals which cannot be
measured by existing gas
chromatography techniques. A major
breakthrough appears close at hand with
the development of thermospray mass
spectrometry.
Monitoring technology for waterborne
viruses has been in the making for
several years. A manual of virology
methods, soon to be published, will
provide the scientific community with
methods for recovering, detecting,
identifying, and confirming viruses from
most environmental samples except air.
The manual will constitute the agency's
official methods for environmental virus
monitoring.
Quality Assurance: The Quality
Assurance Branch will be conducting
major performance evaluation studies for
approving and/or certifying over 8,000
drinking water, water pollution, water
quality, and major discharger
laboratories under the National Pollutant
Discharge Elimination System. The
Quality Control Sample Program and the
EPA Repository for Toxic and Hazardous
Materials will be expanded to cover the
hazardous and toxic waste programs and
the revised drinking water regulations as
well as all parameters covered under the
present water laws.
The Kerr Environmental Research
Laboratory is directly involved in
research on two of the highest
priority agency activities: ground-water
protection and land treatment of
hazardous wastes.
Since most of the present
ground-water contamination incidents
are directly related to improper storage
or disposal of hazardous wastes, the
inclusion of both of these programs
under the same laboratory management
is a beneficial symbiotic relationship
unequalled elsewhere in the organization.
The laboratory's mission to investigate
the subsurface environment includes
research to:
• Determine the fate, transport, and
transformation of pollutants in the soil,
the unsaturated zone, and the saturated
zone;
• Define the processes used to
characterize the soil and subsurface
environment as a receptor of pollutants;
• Develop techniques for predicting the
effects of pollutants in soil, ground water,
and on indigenous organisms; and
• Define and demonstrate the
applicability of using natural processes
for protection of the resource.
Utilization of the natural processes of
soil medium in a scientifically controlled
manner to detoxify and degrade
hazardous wastes is based on
phenomena as old as nature itself. The
research necessary to define the
limitations of waste application,
incorporation, and management of the
soil system is inextricably interlaced with
the research necessary to protect ground
water because the soil, the unsaturated
zone, and saturated zone are sequentially
contiguous.
The laboratory staff includes personnel
experienced not only in agricultural,
municipal and industrial waste treatment,
and ground-water protection, but also
those who constitute the nucleus of
EPA's expertise in those areas—a truly
multidisciplinary group including people
with engineering, biology, geology,
hydrology, chemistry, microbiology, and
soil science specialties.
EPA JOURNAL
-------
Industrial
Environmental
Research Laboratory
Cincinnati, Ohio
Environmental Monitoring
Systems Laboratory
Las Vegas, Nev.
One of the highest priority objectives of
this laboratory's research is to determine
ways to reduce and control
environmental waste problems. The
goals of these programs are to establish
a basis for public acceptance of disposal
options. To do this, research efforts will
provide the technical information
necessary to assure reliability of control
technologies or methods.
The waste disposal research is focused
on two areas. The thermal destruction
program is directed toward supporting
the EPA Office of Solid Waste in the
development of regulations and the
regional offices' permitting and
compliance programs. An example of
current research activities is defining
operating conditions for incinerators to
insure complete destruction of hazardous
wastes.
The second area is the chemical
detoxification program. This program
addresses the problems of dioxin-
contaminated soils, i.e., the serious
dioxin problem in Missouri. The
laboratory's efforts are geared to solving
these problems without removing the
soil, an approach which is much less
costly than others which require the
movement of huge amounts of soil.
A recent important development for
the laboratory is the opening of its
Combustion Research Facility in Pine
Bluff, Ark., and the Center Hill Facility in
Cincinnati, Ohio, where the laboratory is
conducting its in-house research. These
are unique, specially designed facilities to
support the agency's hazardous waste
thermal destruction research programs.
Three of the Las Vegas laboratory's
priorities during the next year are as
follows:
• The application of surface and
down-hole geophysical methods such as
electromagnetic induction and resistivity
techniques holds considerable promise
for rapidly assessing subsurface
contamination problems and for
targeting the locations of ground-water
monitoring wells. The laboratory is
evaluating the capabilities of
commercially available equipment and
developing field application and quality
assurance procedures to help in proper
interpretation of data that are obtained. A
number of collaborative projects with the
EPA regional offices will be carried out as
an integral part of the agency's
assessment activities at Superfund sites.
• The laboratory is developing methods
that should improve the agency's
capability to analyze complex samples
faster, at lower costs, and with greater
confidence in the analytical results. A
tandem mass spectrometry system is
being used for analyzing complex dyes,
and a quality assurance program is being
implemented to support high-resolution
analysis of dioxins in environmental
samples. A Fourier Transform Infrared
system is being merged with a Gas
Chromotography Mass Spectrometry
system to enable concurrent
confirmatory analyses for chemicals
which are particularly difficult to
measure. During the next year protocols
for these types of analyses will be
evaluated and made available to
commercial laboratories which support
agency programs.
• Geostatistics is based on spatial
correlations among sampling points
within a contamination plume. The
technique was successfully applied in
designing the soil sampling program for
determining the extent of soil
contamination around lead smelters in
Dallas. The technique is now being
investigated for application to other types
of soil pollution problems such as dioxin
contamination. ;
Dr. Leon D. Betowski, researcher at the
Environmental Monitoring Systems
Laboratory in Las Vegas, operates a Triple
Stage Quadrupole Mass Spectrometry
System with the capability to analyze dyes
and other complex mixtures.
MAY 1984
17
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EPA Probing
Forest Damage
Camel's Hump, a peak in the Green
Mountains of Vermont where research
supported by EPA and others has revealed
a die-back of red spruce trees, a
deterioration similar to that being found in
some other high elevations in the eastern
U.S.
A major research effort is being
launched by EPA and other
Government agencies to help determine
the causes of a significant decline in the
diameter growth of at least five species
of trees in the Eastern United States.
This project was discussed by William
D. Ruckelshaus, EPA Administrator, in
recent testimony on air pollution
problems before a Congressional
subcommittee.
"Based on a limited amount of data, it
appears that over a wide area of the
Eastern United States, there has been a
pronounced decline in tree diameter
growth of several species of trees over
the past two decades," Ruckelshaus said.
"This lack of growth is not correlated
with any specific climatic trend, and
because it involves a number of species
over such a wide geographical range, it
does not appear to be solely attributable
to normal ecological processes.
"In high altitudes, a more severe set of
symptoms called die-back has been
observed. We have seen significant
losses in at least five species of trees.
"In Europe, different and more
extensive types of tree damage have
been observed, involving at least ten
species.
"We do not know the true extent or
meaning of this damage, the speed at
which it is taking place, or what factor or
combination of factors is causing it. We
do not know if the causes are the same
in Europe as in this country. Many
investigators believe that several
interconnected factors are at work, and
that air pollution of some sort may be
important among them. Our current
knowledge, however, does not tell us
whether the offending pollutants are
sulfates, nitrates, oxidants, or heavy
metals. This new information, while
troubling, raises the possibility that if we
act too quickly, we may control the
wrong pollutant.
"This situation illustrates well why
waiting for further research to be
completed before initiating a control
program is a rational decision. If, as
many believe, sulfate deposition is not a
major contributor to forest problems but
oxidants or nitrates are, a significant
reduction in S02 emissions could
inadvertantly result in elevated levels of
oxidants or nitrates. Our current
understanding of atmospheric chemistry
indicates that if we were to reduce S02, it
might result in increased levels of
oxidants. Additionally, excess oxidants
could then combine with the NOX to
produce more nitrates. Thus, in either
case controlling the wrong pollutant
could conceivably make matters worse.
"The interagency research program
expands the work on forests. A long-term
terrestrial survey is being designed and
should be ready to be carried out in
about a year. EPA is sponsoring joint
meetings and field observations by
European and American scientists both
here and in Europe to identify the major
hypotheses which could explain the
mechanisms of forest damage. Once
these hypotheses are identified, research
efforts can be launched to test them
either in the field or in the laboratory in
order to identify the proper cause and
effect mechanisms."
Turning to the subject of recent
testimony that acid rain causes health
damage, Ruckelshaus told the
Subcommittee on Health and the
Environment of the House Committee on
Energy and Commerce: "We agree with
the recent National Institute of
Environmental Health Sciences report on
this subject which, though cautious, did
not find any basis for immediate alarm.
Nevertheless, as thejnstitute suggests,
further assessment is warranted to
expand our understanding of such
potential effects as the leaching of heavy
metals into drinking water by acid rain,
and the impacts of breathing sulfates and
acid fog.
"When I testified on acid rain before
the Senate Public Works Committee last
month I was repeatedly asked when we
will know enough to make a decision
regarding controls. I am sure that many
of you have the same question. The
answer is that I do not know, because I
cannot predict ahead of time what
answers will come out of our research
program or when.
"The Interagency Task Force plans to
produce formal assessments of the
information gained from the acid
deposition research program in 1985,
1987, and 1989. These will be important
milestones in integrating our
understanding of acid rain's causes and
its effects.
"However, our assessement of the
policy impact of what we are learning
from the research program must be a
continuous process. As we continue to
gain knowledge of the deposition
problem, our ability to predict the results
of various control efforts will increase,
and we will reach the point where the
Administration can responsibly make a
decision regarding the need for
additional controls. I cannot tell you
exactly when that point will come, for I
cannot predict what the answers from
the research program will be or when
they will be forthcoming.
"What I can tell you is that I take it as
an affirmative duty on my part as
Administrator of EPA to ensure that we
make this active reassessment an
ongoing process and that I communicate
our newly-found knowledge to the key
decision-makers in the Administration,
including the President, as soon as
appropriate.
"This concludes my summary of acid
rain. I recognize that this issue has been
and remains a most divisive one between
many members of Congress and the
Administration. Unlike any other
pollution problem, acid rain has the
potential for dividing us along regional
and international lines. I believe that if
we all approach this problem with good
will and a recognition of the legitimate
concerns of people in every section of
this country and Canada, we can solve it.
I pledge my best efforts to work with you
to do so."
18
EPA JOURNAL
-------
Speaking on regulation of hazardous
air pollutants under section 112 of the
Clean Air Act, Ruckelshaus said, "it is no
secret that EPA has had problems in
implementing section 112. While some of
these have been the result of
management problems which we are
working hard to correct, others are the
inevitable result of the complex nature of
the problem and the scientific
uncertainties involved. Given the
difficulties we have had in implementing
section 112 — difficulties that have
extended over many years and several
Administrations — it seems reasonable
now to take a hard look at the structure
of the hazardous air pollution program.
"Section 112 requires EPA to impose
numerical emission limits on industrial
sources of a specific chemical that EPA
has 'listed' on health risk grounds.
Cancer is the health risk at issue in
virtually all listing decisions.
"Our knowledge about the
cancer-causing effects of exposure to
various substances at ambient levels is
far from perfect. To best protect public
health, given this uncertainty, EPA has
evaluated the cancer risk of chemicals by
making conservative assumptions that
yield a plausible upper-bound estimate of
the risks at low doses. For example, we
assume that the cancer risk of exposure
to a chemical does not vanish to zero as
the dose declines, but decreases in a
linear fashion with the dose level. We
also assume that a substance acts as a
carcinogen in humans with the same
potency that it shows in the most
sensitive laboratory animal species. We
base our exposure estimates on
dispersion modeling, and in some cases
we assume that people spend their entire
lives out-of-doors breathing ambient
levels of these pollutants. Given these
assumptions, we are confident that our
risk estimates for individual chemicals
are probably overestimates of risk. That
is, the chances are high that the true risk
falls below our estimates. In some cases,
that risk could be as low as zero.
"Using these conservative
assumptions, we have assessed the
cancer risk from emissions of these
pollutants from industrial point sources
such as chemical and manufacturing
plants. In many cases these risk
assessments indicate that the health
benefits of requiring controls on most
industrial source categories are relatively
low. Based on our current experience,
NESHAP standards that eliminate more
than one cancer case per year are more
the exception than the rule.
"Such tentative findings are disturbing
because they suggest that the current
approach to regulating air toxics may not
yield much in the way of public health
protection. Indeed, our current
information suggests that most
hazardous air emissions arise not from
major industrial sources, but from
numerous small sources and from
"non-traditional" sources such as waste
dumps. In those cases where the culprit
is a large industrial source, we often find
that there are only a few others like it
across the country. We are now engaged
in a serious attempt to estimate the
public health risks from such sources and
to compare these risks with those
associated with the major industrial
sources traditionally addressed under
112.
"This is not to say that preventing
these relatively few cancer cases which
may be caused by hazardous air
pollutants from industrial sources is not
important. Obviously, it is. But we all
have a responsibility to use the limited
resources of government and society to
locate and reduce the most significant
risks first. In these cases, it appears that
the limited resources used to set
NESHAPs may be employed elsewhere to
achieve greater public health protection.
"Given what we know about the nature
of cancer and the hazardous air pollutant
problem, we think the Congress should
adjust the Act so as to have its terms
confront reality.
"The current statutory language
requires the Administrator to list any air
pollutant which he intends to regulate
and which he finds may reasonably be
anticipated to result in an increase in
mortality or an increase in serious
MAY 1984
19
-------
irreversible, or incapacitating reversible,
illness. After listing a pollutant, the
Administrator has one year to establish a
national uniform emission standard for
each type of source of the pollutant that
is strict enough to protect the public
health with an ample margin of safety.
Typically, there are at least a half dozen
types of sources of a single
pollutant—meaning that to list 10
pollutants in a year triggers a
requirement to make at least 60
regulatory decisions the next.
Furthermore, in some cases our
assessment of source categories
suggests that the public health risk is so
small as not to warrant controls. The
statute does not mention any factors
other than health and safety that the
Administrator is allowed to consider in
making those regulatory decisons. It is
not possible, without banning a
substance, to establish safe levels for
carcinogens, if by safe we mean entirely
free from risk.
" The current statutory language can
thus be read to require us to eliminate all
risk from chemicals we list regardless of
cost or social impact. Often the only way
to eliminate risks would be to ban
production and use of the chemical.
"In implementing section 112, we have
taken it as a given that Congress did not
intend us to eliminate these chemicals.
We have made judgments about safety,
and have attempted to balance many
factors, including the nature of the risk
and the cost of eliminating or minimizing
it. In my judgment, the varied
circumstances we face in this area make
the authority to engage in such balancing
efforts all the more imperative.
"If we are correct in this assessment,
then Congress should move to make
such balancing explicit in the language of
the Act. If we are meant to act against
chemicals for which we cannot establish
a risk-free level without banning their use
in every case, the statute should clearly
say so and tell us what factors to weigh
in stopping short of a ban.
"Any such test should certainly
recognize the high value the American
people place on public health and should
assign it great weight in any balance that
is struck. But the law should also
recognize that the balance itself is
necessary whatever weight a particular
factor may be given.
"Increased flexibility to treat the varied
nature of toxic air pollutants, exercised
pursuant to Congressionally established
criteria, would render the job of the
Administrator of EPA possible and would
make the goals of section 112
attainable.
"I understand Congress' impatience
with the rate at which EPA has acted
under section 112. As I testified before
Chairman Dingell last fall, we are
committed to working through most of
our present backlog in the next few
years. By doing this we will have
examined and acted upon the health
risks that may be posed by chemicals
now being considered for listing. I
believe that statutory amendments such
as I have described that recognize the
reality of the problems we face would
help us in that task. Any such
amendments must be based on an
appreciation of the complex and varied
nature of the problem of toxic air
pollutants, not simply on a conclusion
that everything must be done faster
because too little has happened in the
past."
Discussing the process of setting
ambient air quality standards and the use
of statutory deadlines for achieving them,
Ruckelshaus commented:
"Since I returned to EPA a year ago, I
have repeatedly stressed the importance
of separating risk assessment from risk
management. The process of setting
ambient air quality standards and then
requiring the use of deadlines to force
their attainment illustrates this point.
Under present law, setting standards is
based solely on my determination of
what is needed to protect public health
or welfare. I have no quarrel with this
approach as it is solely a risk assessment
exercise.
"However, here is where the problem
starts. Once set, the standards must be
attained by fixed deadlines. It is in this
risk management phase that I believe the
Administrator should be given more
flexibility. Nowhere does the statute
explicitly provide for consideration of the
economic or other impacts of attaining a
given standard by a set deadline. Indeed,
the statute can be read as saying that if
the deadlines are missed, sanctions are
automatically imposed. Prudent public
policy demands that those charged with
seeing that a goal is achieved be given
the discretion to evaluate relevant
factors. Historically, the statute has been
read to provide this necessary flexibility.
The law should explicitly provide it.
"Congress has recognized the
problems with these deadlines in the
past by extending them. The problem is
not with the particular dates chosen,
however, but with the inflexible nature of
the approach. We are not repudiating the
concept of deadlines. Indeed, even
though many areas of the country are in
the post-deadline period right now for
some pollutants, our policy continues to
make use of deadlines for most of these
areas. But in some areas deadlines are
simply unattainable.
"The Los Angeles region, for example,
is clearly not going to be able to meet
the 1987 ozone standard. In those areas,
we have required states to adopt specific
measures leading towards attainment of
the standards rather than meet
impossible deadlines. For that type of
situation, we think it is appropriate to
expect very strict but realistic and
enforceable measures as a quid pro quo
for extension of the deadline. The
existence of a deadline that cannot
realistically be met places us in the
posture of being unable to act reasonably
with an area that has done everything it
knows how to do to meet the standards.
This undermines the integrity of the law
and tends to freeze people in place. We
want to ensure real movement towards
the standards, and we would recommend
that a more flexible approach be adopted
in achieving them."D
20
EPA JOURNAL
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Twenty Lessons from Asbestos
A Bitter Harvest of Scientific Information
By Dr. Irving J. Selikoff, M.D.
It seems that we sometimes learn most
from our worst mistakes. This certainly
was the case in one of the greatest public
health disasters in modern times —
cigarette smoking. When the marked
increase in cigarette use began after
World War II, there were few predictions
of what was to occur in the 1960s, 1970s
and 1980s.
More recently, nature has been
similarly unforgiving with regard to
asbestos, perhaps because we were
reluctant to heed the warnings that we
were given. It was found in 1924, for
example, that exposure to asbestos could
result in fatal disease. In that year, the
British Medical Journal published a
report by W. E. Cooke of a young woman
who had worked with asbestos and who
had died with extensively scarred lungs.
In 1927, again in the British Medical
Journal, he gave the disease the name it
still bears, Pulmonary Asbestosis. By
1930, additional British studies
demonstrated that such scarring was
very common among workers exposed to
asbestos and these observations were
soon confirmed in our country by Fulton,
Dreessen, Lanza and their colleagues as
well as by other scientists. By the
mid-1930s it was well established that
asbestos inhalation could frequently
cause disease and that such disease
might be fatal. Scientific research since
then has added much information but, in
a sense, this largely defined the different
ways that asbestos could kill. Thus, in
1935, Lynch and Smith in the United
States and Gloyne in Great Britain, noted
the association of lung cancer and
asbestos work, and during the 1940s and
1950s cases of pleural and peritoneal
mesothelioma were seen in
asbestos-exposed workers. This
association was clarified and firmly
established in the first half of the 1960s by
Wagner, Selikoff, Churg, Newhouse and
others. Additional neoplasms (malignant
growths) — again, further ways of dying
— were subsequently found related.
We are now in the midst of widespread
asbestos disease resulting from
exposures during the past 60 years. So
(Dr. Selikoff is Director, Environmental
Sciences Laboratory, Mount Sinai School
of Medicine of the City University of New
York.)
Dr. Irving J. Selikoff
far, W. J. Nicholson has calculated that
there have been more than 100,000
deaths of asbestos-associated disease
and that we may look forward to more
than 350,000 additional such deaths
before the effects of past exposures run
their course. These projections are
concerned with cancer deaths from
occupational sources. There will be
additional excess cancer deaths from
non-occupational exposures, as well as
deaths from asbestosis, but it has not yet
been possible to make appropriate
quantitative predictions. Further, the
predictions are predicated on the
assumption that, after 1980, asbestos
exposure will have ceased. Initial
experiences suggest that this was a
dubious assumption, and that the tragic
toll of death and disease will extend
longer than we thought. Moreover, the
9,000 or so excess cancer deaths from
occupational sources now seen each year
are accompanied by many times that
number of workers with asbestosis of
greater or lesser severity, with greater or
lesser disability, but insufficient to
directly cause death.
Inevitably, the observation of so much
serious disease has led to increased
understanding of the circumstances in
which it has occurred, (as scientists
sought to evaluate those factors) both for
prevention of disease in the future and to
provide help to those for whom
prevention is now too late. There has
also been the hope that what we have
learned from the asbestos tragedy will
provide principles that may help to
prevent similar disasters in the future.
TWENTY LESSONS
We have been taught much by the
asbestos experience. This could be
analyzed differently by the industrial
hygienist, the regulator, corporate risk
manager, clinician, industry executive,
union official, pathologist, insurance
company executive, lawyer, physiologist,
economist, molecular biologist, and
others. But perhaps the most pertinent
lessons of all have been those gleaned
from a public health point of view, from
the perspective of how to prevent
preventable disease. Twenty have been
selected as being central to EPA
responsibilities and concerns.
1. Latency: Although tissues and cells
begin to react to the presence of inhaled
asbestos fibers on a microscopic level
within hours and days, clinical effects are
not seen for years or decades. Even with
the extensive exposure that was frequently
found in asbestos factories in the past, it
was commonplace to find no X-ray or
pulmonary function change until five,
ten, or more years had passed. These
clinical probes are insensitive for
demonstrating early changes. In one
study of 1,117 asbestos insulation
workers, regularly employed in the
construction industry under
circumstances in which significant
exposure was the rule, more than half of
those with tess than 20 years from onset
of exposure still had normal X-rays. After
that point, most X-rays were abnormal.
We should not expect to see early
evidence of asbestotic change.
The same constraint is the rule for
asbestos-associated cancer and for fatal
asbestosis, as well. In a prospective
study of 17,800 asbestos insulation
workers, 1967-1976, relatively few
asbestos- associated deaths were seen in
less than 20 years from onset of their
work exposure. Indeed, most deaths
MAY 1984
21
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occurred 30, 40 or more years after
exposure had occurred.
The disease and deaths now being
experienced are the results of exposures
in the 1940s and 1950s, with the 1960s
beginning to make their contribution, the
legacy of our mistakes of the past.
Current exposures will not show their
effects until the year 2010 and
subsequently.
2. Irreversible errors: Once exposure has
occurred (with one exception so far, see
below) the die seems cast. We know of
no way to remove or neutralize fibers in
the lung or in other tissues (to which
some migrate). Whether this is because
of the residual fiber tissue burden or
because of cellular and molecular
changes is not known. From the point of
view of prevention of future disease,
control of human exposure, wherever
and whenever it is occurring, is an
emergency. Sometimes this is not
appreciated. Somehow when the disease
effect is 30 years off, there is little sense
of urgency. This is wrong. There might
be less complacency about friable
asbestos in schools and public buildings
if this were better appreciated.
3. Dose-disease response: Less asbestos,
less disease; more asbestos, more
disease. This central fact provides
guidance for what is to be done. We may
not be able to control every last fiber in
the environment, but we can take some
comfort in knowing that as our
engineering and regulatory measures
become more and more effective, there
will be less and less disease. However,
the "dose" of asbestos is cumulative,
with newly inhaled fibers added to the
burden already present. Therefore, each
opportunity for asbestos exposure should
be controlled not only because of its own
hazard, but because it would be adding
to the risk from other sources. This is a
good example of the correctness of the
definition of dose as "intensity x time."
With many agents, it is very difficult to
ascertain "dose" associated with disease
being seen, since the exposures
responsible for such disease occurred
decades before, when measurements
were not made. Seidman and his
colleagues have recently reviewed a
unique set of circumstances
demonstrating the dose-disease response
nature of asbestos disease. They traced
the long-term mortality experience of a
large group of asbestos factory workers
employed during World War II. They
were all exposed to the same fiber,
making the same products, using the
same machinery, in the same plant. They
differed, however, in one respect.
Because of wartime conditions, some
worked for a day, a week, a month,
several months. Others worked from the
•••^
Two workers removing asbestos from a ceiling.
time the plant opened in 1941 to when it
closed in 1954. Since the intensity, for
the groups involved, was the same, dose
was proportional to duration of exposure.
Lung cancer incidence for the various
groups increased with increasing dose.
4. Disease with brief exposure: There
have been numerous reports of relatively
brief exposure and the subsequent
occurrence of disease. However, many
reflected individual experiences and for
diseases such as lung cancer, they did
not "prove" an association with short
exposure.
The risk of brief exposure became
better established with the study of
mesothelioma, a neoplasm which has
few known causes in humans other than
asbestos. When mesothelioma is found,
prior asbestos exposure is looked for and
usually found. When asbestos exposure
occurs, there is significant risk of
subsequent mesothelioma. The
extraordinary relationship between
asbestos exposure and mesothelioma
was perhaps best considered by
Cochrane and Webster. They interviewed
107 patients in whom the diagnosis of
mesothelioma had recently been
established by biopsy. In 106, potential
prior exposure to asbestos was elicited.
The experiences of Seidman et al (see
above) have provided the necessary
population-based data to confirm the
keen clinical observations previously
made.
The mechanism by which brief
exposure subsequently results in disease
is not known. It may be related to the
retention of fibers in tissues but it may
not. The same phenomenon is seen in
bladder cancer following exposure to
beta-naphthylamine or benzidine or in
angiosarcoma of the liver after vinyl
chloride exposure where there is no
evidence for retention of the chemical
carcinogens.
5. Disease with low-level exposure: The
dose-response relationship for asbestos
appears to be linear. This predicts
disease with low exposures. The model
has been shown to be correct. In 1965,
Newhouse reported mesothelioma
among individuals whose only known
exposure had occurred as a result of
residence in households of asbestos
workers, or by virtue of living within a
half-mile of an asbestos plant in London.
Such family contact and neighborhood
exposure mesothelioma has been widely
confirmed and its importance
documented. Of course, it can be argued
that such exposure is not "low,"
particularly since it results in a significant
amount of disease (in one current study,
lung cancer risk appears to be about
doubled and mesothelioma to be
responsible for approximately 1% of
deaths occurring 20 or more years
following the initiation of household
contact exposure).
What will happen at the lowest levels
of exposure is still not known. There are
other uncertainties. Brief exposure, if
fairly intense, produces disease.
Long-term exposure, at relatively low
levels (household) produces disease. It is
not known whether brief exposure to low
levels will produce detectable disease.
Complicating such analyses is the
cumulative nature of even low-level
exposure. The problem is not unique to
asbestos; it is also the case with PCBs,
dioxins, etc. This again points to the
necessity for control of all sources.
6. Multiple factor interaction: It has long
been suspected that much human
disease from exogenous sources is
multifactorial in nature. Asbestos taught
us that this is indeed so. When the
experiences of the 17,800 asbestos
insulation workers, with smoking habits
known and observed prospectively, were
compared with those of 73,736 like men
EPA JOURNAL
-------
in the American Cancer Society's
prospective study of cigarette smoking, a
remarkable multiplicative effect was
seen. Men who did not smoke and did
not work with asbestos suffered 11
deaths per 100,000 man-years. For
asbestos workers who did not smoke, it
was five times as much, 58. On the other
hand, individuals who smoked but did
'not work with asbestos had a death rate
of 122 per 100,000 man-years, and men
who had both exposures, asbestos and
cigarette smoking, had 601. There is
evidence that the same cigarette
smoking-asbestos interaction may
explain the increased risk of cancer of the
esophagus, oropharynx and buccal
cavity, and larynx. There is no such
interaction, however, for mesothelioma,
cancer of the stomach, colon-rectum or
kidney — both smokers and non-smokers
suffer equally.
Conclusions important for prevention
may be drawn. First, all individuals
known to have been exposed to asbestos
should never start smoking or, if they are
smoking, should stop immediately. This
is particularly important since data
indicate that there can be reversal of risk
once smoking ceases. Asbestos
insulation workers who stop smoking,
after 5-10 years, have about one-third to
one-half the risk of lung cancer of their
mates who continue to smoke. While
cancer, once it occurs, is not reversible,
cancer risk may be. A corollary
conclusion, however is inherent in the
above observations. Since smoking
cessation will not affect risk of
mesothelioma or the other neoplasms
not associated with smoking, it will be
equally necessary to control asbestos
exposures. Both measures are needed.
7. Product use: For every worker
employed in the manufacture of asbestos
products, there may be 500 who would
use them or be exposed indirectly during
such use. It is therefore unfortunate that
at the outset of our asbestos experience,
we thought of "asbestos workers" —
men and women employed in mining,
milling or factory work. The first phase of
asbestos exposure and accompanying
disease was associated with product
manufacture. Later, during the last 40
years or so, there was increasing
attention to disease associated with
product use in the construction industry,
shipyards, powerhouses, chemical plants
and refineries, brake maintenance and
brake repair, etc. We are now entering a
third phase — in which asbestos
exposure will be associated with
environmental exposures, during repair,
renovation, removal, and maintenance of
the asbestos put in place during Phase
Two. We have learned the difficult lesson
of not thinking of asbestos workers, but
asbestos-exposed workers.
8. Industrial origin of environmental
disease: The factory gate and the factory
fence are porous. Almost all asbestos
exposure is industrial in origin, although
some fibers derive from erosion of
natural outcroppings, and water may be
contaminated as it filters through
asbestos rock formations. Such
environmental contamination is very
limited, however, particularly in terms of
disease.
9. Multiple effects/multiple agents:
Asbestos can produce a variety of
illnesses, ranging from pulmonary and
pleural fibrosis to lung cancer, pleural
and peritoneal mesothelioma,
gastrointestinal cancer, cancer of the
oropharynx and buccal cavity, laryngeal
cancer,,and, kidney cancer. Other effects,
too, are now being seen, including
immunomodification and serological
changes. The other side of the coin,
important from a diagnostic point of
view, is that virtually all of these diseases
and modifications can be caused by
other agents, as well. Even
mesothelioma, so highly attributable to
asbestos, can be found to have other
causes. Already, erionite has been seen
to produce pleural and peritoneal
mesothelioma among residents of
Cappadocia, Turkey, and there is
considerable concern that other
materials, particularly man-made fibers,
may eventually be associated with
mesothelioma risk.
10. Environmental persistence: It has
been said that asbestos has "a half-life of
infinity." This is remembered ruefully as
one considers the 30,000,000 tons of
asbestos put in place from 1900 to 1980,
in our ships, buildings, schools, chemical
plants, refineries, powerhouses, factories,
etc. Approximately 700,000 tons of
insulation materials were installed in the
same period; much remains.
11. Complexity of initiation and
promotion: There has been much
scientific interest in recent years
concerning the concept that carcinogenic
agents may either initiate the cancer
process or, once initiated by other
agents, promote its development.
Asbestos seems to do both, according to
circumstances. Thus, for lung cancer, the
data suggest that it acts as a promoter,
multiplying the background risk at each
attained age. A 50-year- old individual
has a much greater background risk of
lung cancer than, let us say, one who is
20. Asbestos, in each, multiplies that risk.
It therefore does not achieve very much
to restrict hiring to older workers, in the
hope that latency would give them a very
long life before lung cancer might strike.
Two latencies have to be considered —
background exposure and asbestos. This
would apply, for example, to teachers in
asbestos-laden schools. Their risk
depends upon their age as well as their
prior asbestos exposure. A 55-year-old
teacher with only 10 years in such a
school nevertheless has important risk.
On the other hand, since there is little
background risk of mesothelioma,
asbestos acts as an initiator with risk
increasing with age by approximately a
power of four. Again in school
circumstances, this points to the
importance of prevention of exposure of
children, with long lives ahead of them.
12. Complexity of societal consequences:
It has long been a truism that, from an
ecological and environmental point of
view, everything is related to everything
else. With asbestos, this dictum applies
to other circumstances, as well. Current
litigation has been marked by bankruptcy
of major industrial firms, thousands of
lawyers face each other in courts clogged
by suits seeking help and redress,
insurance companies are concerned with
potentially monumental costs. It has
been variously estimated that asbestos
disease payments to victims will range
between 40 and 150 billion dollars. In
addition, Professor William G. Johnson
of Syracuse has calculated that social
costs of asbestos disease due to previous
exposure will total more than three
hundred billion dollars. Industrial
practices are changing, with the advent
of substitute materials, many of untested
toxicity. Doubt has even been cast on the
effectiveness and applicability of the
workers compensation system.
We are also beginning to see another
legal tangle, perhaps of equal or greater
complexity, with legal battles shaping up
over who is to pay for the expense
associated with abatement of asbestos in
schools and public buildings.
13. Early utilization of industrial hygiene
engineering: Failure to respond early to
information concerning the disease
potential of asbestos carried with it the
omission of measures needed to control
exposure. Asbestos became entwined in
industrial procedures with hazards intact.
When, decades later, there was
increasing concern with disease
potential, it was doubly difficult to
change uses and procedures integral
with the entire fabric of industrial
production. Moreover, since the
industrial engineering measures that
were needed were being telescoped into
a relatively short period of time rather
than having been accomplished over
many years, attendant costs were
correspondingly high. To further
complicate matters, these costs had to be
borne at a time when the product itself
was being questioned and sales were
decreasing.
MAY 1984
23
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14. Disadvantages of fragmentary
regulatory approaches: There has been
less than complete interaction and
interdigitation of knowledge, experience,
research, regulatory actions. Dreessen of
the U.S. Public Health Service undertook
a rather elegant study of asbestos
disease potential in the early 30s
(published in 1938). I expect that it was
hardly known to the National Cancer
Institute's Advisory Council when, in
1951, it rejected a proposal by Leroy
U.Gardner, then dean of experimental
dust disease pathologists, to study
cancer potential of asbestos in animals
(he had early hints of such findings in his
pneumoconiosis experiments).
There has been less than complete
integration of the interests and studies of
the EPA, NIOSH, NIEHS, CPSC, NCI.
Fortunately, mechanisms exist for such
interdigitation.
15. Science is necessary but not
sufficient: When, in the latter half of the
19th Century, it began to be found that
serious human disease could be caused
by exogenous agents (infectious) a
revolution in scientific thinking began;
there was now not only description, but
causation. (It is instructive to appreciate
how recent this has been; 1982 was only
the one hundredth anniversary of the
discovery of the tubercle bacillus by
Koch.) It was soon found that the
identification of causes could be followed
by their control. Pasteurization of milk,
sewer systems, and clean water supplies
were put in place. In the first half of the
20th Century, we again applauded those
who discovered still other causes of
disease, often metabolic, endocrine, or
nutritional.
The same approbation has not
inevitably met those studies which have
identified some of the newer exogenous
causes of disease. The tobacco industry
has given no testimonial dinners to the
researchers who have shown that this
year we might expect more than 100,000
deaths of lung cancer due to cigarette
smoking (plus additional excess deaths
of pancreas, bladder, oropharyngeal,
esophageal and larynx cancers, plus
deaths of cardiovascular disease and
emphysema). As we consider
8-naphthalymine and benzidine,
4-aminobiphenyl, nickel smelting,
arsenic, vinyl chloride, lead, cadmium,
chromium, etc., we are reminded that, in
the 1890s, there were no trade
associations for the protection of the
cholera vibrio or the tubercle bacillus, no
firms producing salmonella, no public
relations groups operating on behalf of
the pneumococcus, the diphtheria or the
staphylococcus.
It has become clear that, just as in the
1890s, scientific research is necessary for
the identification of causes of disease.
But the simple gathering of data is only
one part of the process. Utilization of the
information is also required. Regulatory
measures are needed, often of
considerable complexity.
16. Indoor air pollution: It took some
little time before it became clear which
agency was going to consider itself
responsible for indoor air pollution with
asbestos. The complexity of the
problems being found make such
bureaucratic reluctance understandable.
Nevertheless, in view of the very large
number of people involved, this has
become increasingly important. Perhaps
the late acceptance of responsibility, as
well as the late identification by scientists
of the potential importance, help to
explain the paucity of exposure data now
at hand.
17. Recruitment of constituencies: An
important asbestos lesson, perhaps
related to what has been said before
about science being necessary but not
sufficient, has been the increasing
understanding that application of
knowledge can be speeded when those
who are directly affected have the
information that intimately concerns
them. OSHA operates best, perhaps,
when both labor and industry are aware
of the facts that form the background for
OSHA regulations. EPA's requirements
that parents and teachers be told of
asbestos findings in schools, is of this
genre. Control of asbestos exposure
depends at least as much upon
understanding at the shop floor, as upon
intricate regulations ensconced in the
Federal Register. If we don't have
understanding of what has to be done on
the part of supervisory personnel and
workers, there will never be enough
inspectors to insure safety. With
understanding, we will need few.
All this translates into an important
educational function for EPA!
HOW MANY ANGELS ON
THE HEAD OF A THRESHOLD?
18. Disease: There are learned and often
esoteric discussions of how much
disease might be expected at very low
levels of exposure. Calculations are made
and projections offered. It will be very
difficult to verify or contradict these.
Epidemiologically, very large populations
will be required, carefully defined as to
biases and variables. Since few cases of
disease are expected at such levels, it is
unlikely that the vast resources necessary
for these studies will ever be made
available. Animal experiments at very
low levels will always have the
disadvantage of insecurity with regard to
extrapolation to humans.
The discussions, while interesting and
important from a regulatory point of
view, nevertheless have an air of
unreality at this moment, with workers
still being exposed to permissible levels
of more than 20 million fibers per day;
these estimates refer to longer fibers and
do not take into account the very much
larger number of shorter ones which
accompany them but are not counted.
Concern about very low levels seems
somewhat out of touch with reality while
some schools have levels of 100 to 1,000
nanograms and while maintenance and
repair work on asbestos materials is
often undertaken without precautions or
supervision.
19. Limitations of epidemiology: These
are widely acknowledged — evidence is
based upon human disease that has
already occurred, available methods are
insensitive in detecting other than very
gross and marked effects, studies are not
suitable for smaller populations, there is
frequent lack of concomitant exposure
data, etc. Further, with the inevitable
biases and variability inherent in human
population studies, residual uncertainties
persist and sometimes the best that can
be achieved is the acknowledgment of
"associations" rather than definitive
causation.
Yet for asbestos disease, epidemiology
has served us well and we have had only
limited assistance so far from animal
studies. It is to be hoped that in coming
years, with other agents, we will no
longer have to depend so heavily on
epidemiological studies of human
experience.
20. The concept of "industry" identity.
There is probably no such thing as a
monolithic industry, each sector being
identical with all others. Some industry
units are knowledgeable, others not.
Some are concerned and truly
responsible, others couldn't care less.
Who, then, speaks for "industry"? My
own experience with asbestos problems
indicates that trade associations do not
always speak for the most
knowledgeable and the most involved
industry units. This can be an important
disadvantage. D
24
EPA JOURNAL
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EPA Helps in Mock Nuclear Exercise
... -._., nuclear power plant of
.. .„ Florida Power and Light Company
played a key role in the full-scale field
exercise.
To test the new Federal Radiological
Emergency Response Plan, officials
from EPA, the Federal Emergency
Management Agency, and other federal,
state, and local agencies conducted a
mock exercise recently. The objective
was to test the effectiveness of plans to
help cope with a simulated nuclear
power plant accident on the eastern
coast of Florida near Ft. Pierce. EPA
radiological specialists from agency
laboratories in Montgomery, Ala., and
Las Vegas, Nev., as well as
representatives from the Office of Air and
Radiation and the Office of External
Affairs from EPA's headquarters in
Washington played roles in the exercise.
Mark 0. Semler, Montgomery, Ala., reviews
output from the gamma spectrum analyzer
in EPA's mobile radiation counting
laboratory.
Edwin L. Sensintaffar, Montgomery, Ala., places the filter on a
high-volume air sampler for one of EPA's environmental
monitoring stations. Radioiodine sampler and gamma exposure
rate equipment are also shown.
Michael F. O'Connell of the Las Vegas laboratory measures the gamma
radiation exposure as Edwin L. Sensintaffer of the Montgomery laboratory
collects a vegetation sample to document radioactive deposition.
MAY 1984
25
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Learning to Control
Dioxin
An Interview with Erich Bretthauer
Erich Bretthauer represents the Office of
Research and Development on EPA's Dioxin
Management Task Force and coordinates
the Office's dioxin research Bretthauer,
who has been with EPA since its inception,
is a/so Director of ORD's Office of
Environmental Processes and Effects
Research. He is a chemist.
Q
Why is the chemical dioxin of such
great concern?
A There are eight classes of chlorinated
dibenzo-p-dioxins. The classes depend on
the number of chlorine atoms in the
molecule. One form in particular, 2,3,7,8
tetrachlorodibenzo-p-dioxin
(2,3,7,8-TCDD), has been shown to be
extremely toxic in animals at very low
levels and to persist in the environment.
Q
What are the toxic problems with
2,3,7,8-TCDD?
A In laboratory animals, 2,3,7,8-TCDD
has been demonstrated to be toxic to
fetuses, to have the ability to cause birth
defects and to cause cancer.
Q
How did the dioxin problem first
develop?
A The toxic 2,3,7,8-TCDD was first
identified in 1969 as an unavoidable
contaminant of 2,4,5
trichlorophenoxyacetic acid (2,4,5-T), a
popular herbicide at that time. It was also
found in Agent Orange which contained
2,4,5-T. In 1974, 2,3,7,8-TCDD was
recognized as a component of the wastes
from the manufacture of 2,4,5-TCP, a
fungicide and disinfectant. In 1979, Dow
Chemical Company announced that
dioxin was associated with certain
combustion processes.
Erich Brenhauer
Q
Is it possible that the danger from
dioxin has been exaggerated in the
public mind?
r\ , The toxic potential of dioxin in its
pure form in all laboratory animal studies
to date is very clear and it certainly is a
very toxic compound. However, the fate
of this material, how it moves in the
environment, how biologically available it
is to humans, animals and plants and its
food chain magnification potential are
poorly understood at this date. Because
Ol llllT.P Hill I'ltMMltll!-. lint M-.t III lllOXJn tO
liuniiiii:. in.-iy ,-n lu;illy ho •.mallei limn wi:
currently now
\JL
Wh.i! is I I'A ttyini) to li'iiin .iliout
(tioxin in it:, if, (-.IK h pnxjinm?
r\ fcPA's dioxm ii'se.iK h pni(|t,iin is
multi-faceted. There are several
important components. The first is to
understand better the sources of dioxin
in our environment. We know of some
but not all potential sources of dioxin.
Work is continuing in an effort to defim:
the relative contribution of each of these
sources to the total dioxin problem. For
example, we would like to determine
better the magnitude of the dioxin
problem from incineration. We wouid
also like to know how much comes from
the production and use of pesticides.
Q
What about bio-accumulation
studies?
A Bio-accumulation studies are a very
important component of our work. We
hope to understand to what extent dioxin
is accumulated in the human body,
animal tissue, and in various types of
plants in order to assess the likely risks
of dioxin to humans.
We don't know at this time how
biologically available the various forms
of dioxin are that we find in our
environment. For example, there are
reports from laboratory studies that
dioxin attached to, or found in, soil in
one particular area has a negligible
bio-availability. But similar studies
recently conducted with dioxin on other
soils from other areas show a
significantly greater bio-availability. Thus
most dioxin measurement methods,
which rely on extraction with strong
chemicals, may not accurately represent
the hazard to man.
Q
Is it possible that plants may be used
to clean up dioxin pollution through
bio-accumulation?
EPA JOURNAL
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Mike demons, EPA Region 7, holds a hand auger while Keith Schardein, Missouri Department of Naiural Resources, removes
a so;7 sample to test for dioxin in Times Beach, Mo., in December, 7982.
r\ We know that certain types of plants
do accumulate metals from the soil in
which they are grown. We are evaluating
as a part of our overall dioxin research
program whether there are plants which
preferentially take up dioxin from
contaminated soil. However, given the
concentrations involved and the chemical
structure of dioxin, it seems unlikely that
this method will provide an effective
control strategy.
levels in water below a part per trillion in
contrast to analysis of metals in water
where we are usually interested in
concentrations in the parts per million
range.
Q
What about research on the effects of
dioxin in humans?
A
Q
What are the units of the Office of
Research and Development that are
involved in dioxin research?
A
Q
What about other areas of ORD's
dioxin research program?
A
Another important part of our
research program relates to what we can
do about the areas that are currently
contaminated with dioxin. We have
several important research projects
underway to determine how to reduce
the hazard of contaminated soils to man.
We also have some research underway
to develop methodologies to measure
the extremely low levels of dioxin found
in the environment. We are interested in
measuring levels of dioxin significantly
lower than we're usually interested in for
other pollutants in our environment. For
example, in our dioxin water surveillance
studies we are interested in measuring
Many of our research laboratories are
involved. Our Municipal Environmental
Research Laboratory in Cincinnati is
conducting research to determine where
and under what conditions dioxin is
formed in our environment. The
laboratory is also conducting research
with several chemical compounds to
actually detoxify dioxin in soil.
Our Environmental Research
Laboratory in Ada, Okla., is conducting
work to determine the persistence of
dioxin in soil and how long it exists
under which conditions in our
environment and how it moves in soil
systems.
We also have work going on in our
Municipal Environmental Research
Laboratory in Edison, N.J. which is
evaluating thermal destruction
techniques for dioxin-contaminated soil.
Our Office of Health Research
and our Office of Health and
Environmental Assessment in
collaboration with the National Institute
of Environmental Health Sciences have
several programs underway. One such
program will determine how dioxin is
metabolized in the body, using a species
closely related to man, the rhesus
monkey.
These studies utilize female rhesus
monkeys which have a metabolism
similar to humans. These monkeys were
fed a very small amount of dioxin over a
four-year period. Current studies will
determine the rate in which dioxin is
excreted from the fat in their bodies. In
addition, when some of these monkeys
are bred, and have offspring,
concentrations of dioxin will be
measured in their breast milk.
In animal studies, dioxin is
embryotoxic; that is offspring with
reduced birth weight result after maternal
exposure. We are conducting some
epidemiological studies in conjunction
with the State of Missouri to determine if
unexpected increases in childhood cancer
as well as low birth weights of children
in local areas of Missouri exist, and if so,
MAY 1984
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whether these increases correlate with
the time of dioxin exposure.
Also in the area of health research we
are working to develop a monoclonal
antibody, one specific and sensitive for
2,3,7,8-TCDD. The purpose here is the
eventual production of an antibody
suitable for detection of dioxin in human
blood or even environmental samples at
the parts per trillion level. It may even
serve as a tool to give us more
information about the dioxin molecule
itself.
Q
Are there other aspects of the dioxin
problem that the Office of Research and
Development is researching?
r\ We're conducting work in our
environmental research laboratories in
Duluth, Minnesota, and Corvallis,
Oregon, to determine the bioavailability
of dioxin from contaminated soils to fish,
plants, and grazing animals. These
studies will provide information on food
chain magnification of dioxins. In
addition, our environmental monitoring
laboratories in Las Vegas, Cincinnati and
Research Triangle Park are working on
quality assurance procedures, methods
and measurement techniques to detect
dioxin at very low levels in soil, air,
water, and fish tissue samples.
Q
What are the main techniques being
studied to dispose of dioxin? Are any
currently usable or operational?
r\ We're studying several techniques. A
promising one is to treat soil with a
chemical compound and sunlight. The
compound that we're studying at the
present time is an alkali metal in a
polyethylene glycol base solution. This
chemical seems to hold good promise for
actually breaking the chlorine bond, and
thus detoxifying the dioxin molecule.
This process may be enhanced by
ultraviolet radiation in sunlight.
In addition, we have a soil-washing
technique under study. We'll actually
wash the soil with certain chemical
solvents to try to solubilize the dioxin in
order to remove it from the soil.
Subsequently, we may incinerate the
solubilized dioxin. We also have a
program underway to evaluate the
feasibility of actually burning soil in an
incinerator as well as efforts to evaluate
stabilizing dioxin on soil using chemical
techniques.
All of these types of studies are
underway at the present time. Some of
them are proceeding from the laboratory
scale to the field scale for evaluation.
And this summer we'll be performing
field work with the chemical stabilization
techniques. We also hope to test our soil
washer and incinerator to see how
practical it is for detoxifying
dioxin-contaminated soil.
A
Q
Is it possible to lick the dioxin
problem?
r\ I'm very optimistic that the research
which is currently underway, both in this
agency and in other agencies, will allow
us to better understand the true risk of
dioxin-contaminated soils to humans. I
also believe that the control technology
research being done here at EPA will
provide more and better options for
effectively dealing with dioxin
contaminated soil. So yes, I believe that
we can adequately address the dioxin
problem.
\J. Isn't the cost of dealing with the
dioxin problem going to be enormous?
r\ Cost certainly is an important factor.
Our control options research will provide
cost information for each option.
Li How does the Office of Research and
Development fit into the overall EPA
dioxin control plan?
Our research is designed to support
the agency's overall strategy. It is
designed to get a better estimate of the
risks of dioxin to humans and to develop
remedial techniques we might use to
improve, control, or minimize risk. Also
we are providing technical guidance for
the various field investigations that are
currently underway and various types of
technical support in terms of quality
assurance samples and measurement
methods for the various EPA regional
programs.
Q
Can you estimate the budget of the
Office's dioxin research program?
A
. We have about $2.5 million dollars
devoted to dioxin research in Fiscal Year
'84 and expect a similar amount in Fiscal
Year '85. Two million dollars of that work
is extramural and supports work in
universities and other institutions.
Q
Will what we are learning about
dioxin help in dealing with other
dangerous chemicals?
r\ We're very optimistic that some of
the dioxin research will be beneficial in
solving other environmental problems.
For example, if we are able to develop
monoclonal antibodies to estimate very
low levels of dioxin in exposed humans,
this will indeed provide a valuable
research tool which we might use to
estimate the amount of other hazardous
materials to humans such as the toxic
by-products of PCB's and dibenzofurans.
One might even envision a battery of
antibodies capable of measuring a
number of toxic substances in blood
without using more invasive procedures
such as surgical removal of tissues and
elaborate expensive laboratory
procedures such as mass spectroscopy.
D
28
EPA JOURNAL
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The Research Behind
a Clean Air Proposal
An inlet measuring paniculate matter on a
rooftop in downtown Durham, N.C. New
paniculate samplers, and new inlets on old
samplers, are also being tested in Los
Angeles, St. Louis, and Phoenix. The
samplers will be used in EPA's nationwide
Inhalable Paniculate Network.
Where do environmental standards
come from? It is part of the job of
the Environmental Protection Agency, as
a regulatory body, to set new
environmenta! standards and reevaluate
old ones for possible revision.Standards
issued under the Clean Water Act, for
example, govern oxygen supply and
microbiological content of surface water.
Resource Conservation and Recovery Act
standards govern hazardous wastes. And
Clean Air Act standards regulate amounts
of certain pollutants in the air and
emissions from power plants and other
sources.
Any one of these standards may affect
the health of millions of people.
Compliance may cost industry millions of
dollars. So when EPA sets out to change
a standard, it bases revisions on the best
available science.
This article describes how the
procedure worked in one case, when EPA
undertook to revise the National Ambient
Air Quality Standard (NAAQS) for total
suspended particulate matter. In the
process, the agency faced many
complicated questions — for example,
where to set the numerical limit of the
24-hour and annual standards. This
article focuses primarily on the reasoning
behind the decision to regulate only
particles of a certain size.
Change
in focus
On March 9, 1984, EPA Administrator
William D. Ruckelshaus proposed major
revisions of national ambient air quality
standards for particulate matter,
changing the pollutant regulated from
total particles in the air irrespective of
size to inhalable particles that are widely
acknowledged to be more damaging to
human health (see EPA Journal, April
1984). Under the Clean Air Act, the
agency had established the first standard
for particulate matter in 1971. The
revisions now being proposed are the
result, not of any instant decision, but of
a complex and lengthy process that
began eight years ago, in 1976.
At that time, the National Air Quality
Criteria Advisory Committee advised
review of the standards for six principal
air pollutants. The following year,
Congress amended the Clean Air Act.
The new legislation required EPA to
review air quality criteria and ambient
standards every five years and, where
appropriate, to revise them. New
standards were to be based on the best
scientific information.
The process for revising a national
ambient air quality standard includes five
major steps: 1) compilation of relevant
scientific information into a criteria
document, 2) evaluation of criteria
document information in a staff paper, 3)
recommendation by the Clean Air
Scientific Advisory Committee (CASAC),
4) publication of the proposed standard
in the Federal Register, and 5)
promulgation of the final standard. The
whole process is enormously complex,
"an ambitious undertaking," according to
Ruckelshaus, "spanning many years and
requiring input from many scientists,
health experts, environmental officials,
and the interested public." Revision of
the particulate matter standard involved
dozens of EPA offices and laboratories,
hundreds of scientists, and thousands of
studies - nearly 3,000 in all.
What is
particulate matter?
Particulate matter (PM) in the
atmosphere comes from both natural and
manmade sources. Natural sources
include wind blown soil, sea spray,
volcanos, and forest fires. Manmade
particulate emissions originate from
automobile exhausts, power plants, and
activities like construction that stir up
dust and dirt.
Inhaling particulate matter can affect
breathing and the respiratory system,
aggravate existing respiratory and
cardiovascular disease, alter the body's
defense systems against foreign
materials, damage lung tissue, and
contribute to premature mortality. People
likely to be most sensitive to effects of
MAY 1984
-------
participate matter are those with lung or
heart disease, influenza, or asthma, plus
the elderly, preschoolers, and people
who breathe through their mouth.
At elevated concentrations, particulate
matter can also affect visibility, climate,
and vegetation. It can soil materials and
become a nuisance.
The first standard for particulate matter
that EPA had established back in 1971
covered total suspended particulate
matter (TSP). TSP measurements
included "anything that could enter the
sampler," according to Dr. Fred Miller of
EPA's Health Effects Research Lab in
North Carolina. Large particles 30-50
micrometers in size were being
measured. But, says Miller, particles that
big "don't get into the lungs, and we
wondered, 'What do these particles have
to do with pulmonary effects?'"
Human studies relating to the
particulate standard were conducted at
the Clinical Studies Branch of the Health
Effects Research Lab (HERD, located on
the campus of the University of North
Carolina Medical School at Chapel Hill. At
this lab, volunteer subjects were exposed
to ambient levels of water soluble
particulate matter, alone and in
combination with ozone, nitrogen
dioxide, and sulfur dioxide. The studies
showed the effects of the different
pollutants on lung function. According to
Branch Chief Dr. John O'Neil, the
research project on inhaled particulates
studied the responses of over 325
volunteers, and took over three years to
complete.
Animal studies for the particulate
standard took place in HERL's Toxicology
Branch.Unlike human studies, animal
studies used exposures over long periods
of time and provided for more detailed
examinations of the lungs.
Miller headed a task force of EPA
scientists and technical experts who
addressed the question of health effects
of particulates in 1978. Drawing upon
their own research and several other
published studies, the authors examined
the distribution of various kinds of
particles in the atmosphere and the
manner in which such particles were
deposited in the human respiratory tract.
In a 1979 article, "Size Considerations for
Establishing a Standard for Inhalable
Particles," published in the Journal of the
Air Pollution Control Association, the
group recommended that research to
develop a size-specific standard focus on
inhalable particles (less than 15
micrometers in size) that can penetrate to
the lower respiratory tract. The group
also recommended a focus on fine
particles (less than 2.5 micrometers in
size) because of the composition of such
particles in the atmosphere. That same
year, EPA set up an Inhalable Particulate
Network of about 100 monitoring stations
to measure the distribution of inhalable
and fine particles in various U.S. cities.
Since particulate matter is likely to be a
health concern chiefly when it reaches
the lower respiratory tract, and since
large particles do not reach the lower
respiratory tract, the need to control
them is questionable, according to Dr.
Miller. This reasoning eventually led to
the shift in the standards from larger
particles to smaller ones now being
proposed.
Criteria
document
The first step in revising the particulate
standard was preparation of a criteria
document. Mike Berry of EPA's
Environmental Criteria and Assessment
Office in North Carolina was heavily
involved in that effort. By 1978, according
to Berry, work on the criteria document
had begun in earnest.
A criteria document is an extensive
review of the relevant scientific
information on a pollutant. Some of that
information comes from studies carried
out at laboratories that are part of EPA's
Office of Research and Development
(ORD). Much of it comes from other
sources such as universities, utility and
chemical companies, the National
Institute of Occupational Safety and
Health, and the National Institutes of
Health.
In addition to carrying out
standards-related research, EPA lab staff
performs the equally important tasks of
reviewing and interpreting outside
research.
EPA lab scientists, consultants, and
staff of ORD's Environmental Criteria and
Assessment Office where Berry works all
contributed to the writing of the criteria
document on particulates. "We tried to
be objective scientists," says Berry."We
EPA JOURNAL
-------
At EPA's Health Effects Research
Laboratory in North Carolina, a scientist
checks data on volunteer undergoing a
multi-gas rebreathing test. The volunteer,
seen through the window in the
background, is in an exposure chamber,
breathing ambient levels of test pollutants
while exercising on a treadmill. Through a
device called a pneumotach, he is
connected to a machine that measures
cardiovascular output and changes in
functional capacity of the lungs. The
measurements are displayed on the
terminal seen here.
weren't looking for evidence to
support a particular regulatory
decision.We simply tried to describe the
effects of a pollutant objectively."
Different specialists managed different
parts of the document, reviewing
thousands of citations as part of the
literature search. The document then
underwent an extensive and rigorous
peer review process.
By April 1980, a first draft of the criteria
docuftient on particulate matter was
ready. Two years and three drafts later,
the final document was released. It
contained more than 1,400 pages in three
volumes.
Staff
paper
After the Office of Research and
Development prepared the criteria
document on particulates, the Office of
Air and Radiation (OAR) took the next
step when its Office of Air Quality,
Planning, and Standards, located in
North Carolina, prepared the staff paper.
This document, its authors write, "is
intended to help bridge the gap between
the scientific review contained in the
criteria document and the judgments
required of the Administrator in setting
ambient standards for particulate matter.
As such, particular emphasis is placed on
identifying those conclusions and
uncertainties in the available scientific
literature that the staff believes should be
considered..."
The final staff paper strongly
recommended that EPA move from
regulating all particles regardless of size
to regulating small particles only, and
examined the possibility of alternative
size-specific indicators as well as chemical
classes (such as sulfates). With the
concurrence of the Clean Air Scientific
Advisory Committee, the authors
recommended a size-specific standard,
stating:
"The current TSP standard directs
control efforts towards particles of lower
risk to health because of its inclusion of
larger particles which can dominate the
measured mass concentration, but which
are deposited only in the extrathoracic
region. A new particle indicator
representing those particles capable of
penetrating the thoracic regions...is
recommended. The size range should
include those particles less than a
nominal JO micrometers..."
John Bachmann was a principal author
of this staff paper. He describes how the
decision was made to switch from total
suspended particulates to PM10
(particulate matter 10 micrometers or
smaller). "Research showed that the least
obnoxious particles were being deposited
in the least sensitive area," Bachmann
explains. "But the smaller particles were
being deposited in the lower regions of
the respiratory tract, where they could do
the most harm. We felt we should
concentrate on the particles that could
have the worst health effects." According
to Bachmann, the 10 micrometer size that
had been recommended by the
International Standards Organization and
supported by the Clean Air Scientific
Advisory Committee represents a logical
refinement of the original 15 micrometer
definition of inhalable particles. The
Inhalable Particulate Network is now
being retrofitted for the 10 micrometer
measurements.
By June 1981, a first draft of the staff
paper had been completed. Six months
and two drafts later, the final, 252-page
document was released.
CASAC
review
The Clean Air Scientific Advisory
Committee (CASAC) is one of four
permanent standing committees of EPA's
Science Advisory Board. The Clean Air
Act specifies that at least one physician,
one member of the National Academy of
Sciences, and one representative of a
state air pollution control agency should
serve on the seven-member committee.
Members are appointed by the
Administrator.
The Committee was heavily involved
right from the start in revision of the
particulate standard. At a public meeting
in November 1978 the Committee made
the recommendation, subsequently
adopted, that information on particulate
matter and sulfur oxides be combined in
one criteria document. (Proposed
revisions in the sulfur oxides standard
are still under development.) The
Committee also reviewed each of many
drafts of both the criteria document and
staff paper, and submitted reports on
both documents to the Administrator.
"EPA's practice," says Ruckelshaus, "is
to make the criteria document final only
after the Clean Air Scientific Advisory
Committee, a Congressionally mandated
group of independent scientific and
technical experts, is satisfied that the
document contains an adequate
assessment of the latest scientific
knowledge."
Where
we are now
The particulate standard work of the
Office of Research and Development, the
Office of Air and Radiation, and the Clean
Air Scientific Advisory Committee
culminated on March 9, when
Ruckelshaus announced the proposed
revisions. As explained above, the
proposal calls for replacing the current
primary (health-related) standards for
total suspended particulate matter with a
new indicator that includes only particles
10 micrometers or smaller. The agency is
also proposing that: 1) the new 24-hour
primary standard be a number selected
from a range of 150-250 micrograms per
cubic meter of air, 2) the annual primary
standard be a number selected from a
range of 50-65 micrograms per cubic
meter of air, and 3} the new secondary
(welfare-related) standard replace the
current 24-hour TSP secondary standard
with an annual TSP standard selected
from a range of 70-90 micrograms per
cubic meter of air.
A 90-day comment period on the
proposed revisions began March 20, the
date they were published in the Federal
Register. According to Ruckelshaus, it
will take about one year for EPA to
review all comments received, assess
any new information, and develop and
promulgate a final standard.
* * * * *
This article has focused on the scientific
groundwork for the proposed particulate
standard revisions. It has not discussed
some of the non-scientific issues that
were involved, such as litigation to
accelerate review of the criteria
document. And it has not discussed
some of the issues that will come into
play now that the revisions have been
proposed — issues like risk management
and state implementation. The law
requires that public health should be the
sole criterion for setting primary
standards, and that economic and
technological feasibility may not be
considered. Despite the fact that, as
Ruckelshaus said, "even a seemingly
minor revision in these standards can
trigger major regulatory consequences,"
the Administrator is not allowed to
consider practical problems of
implementation in selecting a specific
number from the range recommended
for the new 24-hour primary standard. D
MAY 1984
31
-------
Science Highlights:
The targets of EPA's research and
development range from ground-water
contaminants deep in the earth to air
pollution movements high overhead. In
this article, EPA science writer Richard
Laska highlights some recent advances.
How to
catch a virus
There are more than 100 different types
of human viruses which can be
transmitted by drinking water. Most of
these viruses are extremely small — it
would take 1,000,000,000,000,000,000 to
fill a ping pong ball — and yet exposure
to a very few virus particles can cause
illnesses ranging from intestinal cramps
to heart, liver or central nervous system
disorders. In some cases, these viruses
are not adequately removed by
chlorination or other wastewater
treatment processes. Coming from
sewage effluent or sludge, these viruses
can enter drinking water supplies where
they are, understandably, extremely
difficult to detect.
"You're looking for 10 or 20 particles in
100 gallons of water," notes researcher
Robert Safferman, "but these few
particles can cause a whole lot of
mischief." Safferman and other
researchers at EPA's Environmental
Monitoring and Support Laboratory in
Cincinnati, Ohio, have just presented a
procedure whereby viruses can be
concentrated to make further testing
possible. Using advanced filters and
straightforward techniques, this method
can concentrate the viruses present in a
100-gallon sample into less than one-half
cup. The half cup of concentrate can then
be placed into cell cultures designed to
detect the presence of human intestinal
viruses.
The advantage of this method is that it
can be used under field conditions or in
minimally equipped bacteriology
laboratories to concentrate viruses from
large volumes of water. The concentrates
can then be shipped to an appropriately
equipped virological testing facility for
cell culturing. "This is the first time that
state and local laboratories have had
standardized, step-by-step procedures to
detect viruses in drinking water," states
Safferman. The procedures have been
published as the U.S. EPA Manual of
Methods for V/ro/ogy, which is available
from EPA's Center for Environmental
Research Information in Cincinnati.
In the bag...
A major problem in both spills and
clean-up operations involving hazardous
liquids is the lack of a quick and
inexpensive way to keep spills from
spreading. As noted by Mike Royer of
EPA's Municipal Environmental Research
Laboratory in Cincinnati, Ohio, "if you
can contain a spill where it's spilling, you
avoid a much bigger — and more
expensive — cleanup operation."
Investigators working for the
laboratory's Edison, New Jersey facility
examined a variety of methods to
capture and contain spilling hazardous
liquids. Although novel methods such as
coating the ground with an impervious
polymer layer were explored, the most
promising approach was also the
simplest. This involved creating a large,
chemically resistant bag to contain the
liquid at the point of the spill. This
lightweight (20 pounds) disposable bag
includes a drip apron to catch spills and
a built-in drainage hose for removing
captured liquids.
In response to a very positive reaction
from the spill control community, EPA
researchers are having six prototype
1,000-gallon bags created. The bags,
which should cost less than $200 each if
mass produced, will be given to
organizations such as fire departments
and emergency response units for
evaluation. There are already more
organizations interested than there are
bags to test. "If the response of the folks
on the front lines is positive," noted
Royer, "we would expect private
manufacturers to pick up the ball."
Preliminary results from the evaluation
should be available by late summer.
Sketch of a large bag designed to contain a
pollution spill. The bag is being developed
as a cleanup device by the Edison, New
Jersey facility of EPA's Municipal
Environmental Research Laboratory.
Like a
sludge brickhouse
Many cities are having increasing
difficulty disposing of the sludge left over
from sewage treatment. Recently a
researcher from Purdue, supported by
the National Science Foundation,
discovered a potential new use for the
sludge. He worked with a Maryland brick
maker to manufacture 500,000 bricks with
sewage sludge in place of the water and
sawdust normally used. The sludge made
Bricks made of about 50 percent sewage
sludge were used to build this covered
picnic shelter in Brighton Dam Park near
Washington, D.C.
up approximately half of the brick. The
bricks were used to build a covered
picnic shelter in a park near Washington,
D.C.
Although the kiln firing temperatures
(2,000°F) destroy any organic matter,
there is some concern with regard to the
fate of the heavy metals present in the
original sludge. To assure that the
sludgebrick process does not release
harmful amounts of these heavy metals,
EPA's Municipal Environmental Research
Laboratory in Cincinnati, Ohio is testing
some of the bricks. In addition,
researchers there intend to make some of
the bricks under laboratory conditions to
determine what happens to sludge
components. Eventually, a significant
portion of sludge may find a new identity
as "biobrick."
EPA JOURNAL
-------
LA. hare
Using sophisticated airborne monitoring
equipment, investigators from EPA's
Environmental Monitoring Systems
Laboratory in Las Vegas have provided a
far more complete and detailed
visualization of air pollution movement in
southern California than was previously
possible. The study was done using a
laser-based remote sensing system,
known as lidar, mounted in an airplane.
EPA pioneered the use of lidar to
measure pollutants.
In the study, a laser beam from the
airplane is directed down at the air
masses below and a very sensitive
detector picks up the laser light scattered
by pollutants in the air. The result is a
"picture" of the relative concentrations of
pollutants at different altitudes. "These
studies have given us tremendous insight
into the complexity of the situation,"
notes researcher Dr. James McElroy.
The studies have clearly shown how
pollutant masses can form into several
distinct layers before moving on. "On
occasion, we've watched an air mass
form over L.A., be drawn out to sea by
night breezes and return inland the next
morning far to the north toward Santa
Barbara or south toward San Diego,"
says McElroy. Such layering and
pollutant air mass movement had been
hypothesized based upon knowledge of
meteorology and piecemeal monitoring
data. The recent lidar measurements
have finally put the pieces together and
provided researchers with important
insights into the physical mechanisms
which govern air mass movements.
It'll knock
your SOx off
Sulfur oxides (SOX) emitted to the
atmosphere are a potential health hazard.
They also account for more than half of
the man-made compounds which
contribute to acid rain. The main source
of SOX emissions east of the Mississippi
is coal combustion. Over the past five
years, approximately 120 coal-burning
power plants have installed flue gas
desulfurization (FGD) systems called
"scrubbers" to reduce SOX emissions. In
these scrubbers, combustion exhaust gas
comes into contact with a slurry of
crushed limestone (or a similar
substance) and water. The slurry reacts
with the sulfur oxides in the flue gas and
captures them as a sludge.
City Utilities' Southwest Power Station in
Springfield, Mo., with flue gas scrubber
whose effectiveness is increased by the
addition of organic acids. Scrubber structure
is at base of smokestack.
That scrubbers work is no longer in
question. Neither is the fact that they are
expensive and could be improved both in
terms of sulfur dioxide capture rate and
reliability. Several years ago, researchers
from EPA's Industrial Environmental
Research Laboratory at Research Triangle
Park in North Carolina discovered that
the addition of organic acids such as
adipic acid (used as a food additive and
in nylon manufacture) improved both the
performance and efficiency of FGD
scrubber systems.
To prove their point, the researchers
are testing the addition of organic acids
to commercial scrubber systems.
Preliminary results from testing at the
San Miguel Electric Cooperative in
Jourdanton, Texas, have been
encouraging. Significant improvements
were noted in S02 removal, limestone
use, generating capacity, waste handling
and system operability. Further studies
indicate that the utility could reduce FGD
operating costs by more than $100,000
per year by converting to organic
acid-enhanced operation. In another
evaluation at City Utilities' Southwest
Power Station in Springfield, Missouri,
S02 removal was improved from 70
percent without to 90 percent with the
addition of organic acids. Based upon
these tests. City Utilities has decided to
convert their FGD system to organic
acid-enhanced operations as a method of
allowing them to achieve regulatory
compliance.
...and reduce
gross sulfur loads
Ever since flue gas scrubbers were first
introduced in this country, our
researchers have been maintaining
accurate records of their numbers, status
and construction plans. Right now there
are nearly 120 units in operation controll-
ing 50,000 megawatts of generating
capacity. Using this information, our re-
searchers were able to estimate how
sulfur dioxide emissions could be
reduced through the widespread use of
organic acid additives (see story above).
Their findings are impressive. They
estimate that the use of organic acid
additives in those scrubbers which are
either in operation or under construction
would reduce S02 emissions by
approximately 930,000 tons per year.
Such a shift could reduce total U.S. sulfur
dioxide emissions (approximately 24
million tons per year) by approximately
four percent.
Continued to next page
MAY 1984
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Science Highlights:
Oh say
can you see?
Regardless of what the song says, on a
clear day you can't see forever. In fact,
the theoretical limit to visibility through
"pure" air is just over 200 miles (320 km)
at sea level. This fact is apparent in
western states where magnificent vistas
which sometimes approach this
theoretical maximum are a natural
heritage. Recent research by EPA's
Environmental Monitoring Systems
Laboratory in Las Vegas has shed new
light on the causes of visibility
impairment in the area which includes
many of our most spectacular national
parks.
The EPA, along with the National Park
Service and several other Federal and
state agencies, has conducted extensive
visibility monitoring and analysis studies
in the region for more than four years.
These studies are beginning to yield
definitive results. "We have
demonstrated very clear seasonal
trends," says program manager Robert
Snelling, "and a definite decrease in
visibility with time over the four years of
the study."
In addition to overall trends, the study
has shown that pollution from sources
hundreds of miles away often impairs
visibility. Analysis of air mass trajectories
and trace element.s implicates three
major regional sources — industrial and
urban areas in southern California and
along the coast of the Gulf of Mexico,
and copper smelters in southern Arizona.
"It doesn't take much pollution to
dramatically reduce visibility," notes
Snelling."The cleaner the air, the greater
the impact of a little pollution." Analysis
of the composition of the fine particles in
the study region showed that 38 percent
are sulfates. The only major source of the
sulfates is regional transport from the
sources mentioned above. An additional
37 percent of the particles are light
elements including nitrates and
carbonaceous particles which may also
hail from far away. The remaining 23
percent of the particles are suspended
soils. The bottom line of these studies is
that between 60 percent and 75 percent
total visibility impact in the west is due
to regional transport of pollutants.
Eavesdropping
on the underground
Underground injection wells are common
in many areas. Texas alone has almost
50,000 injection wells for secondary oil
recovery and brine disposal and 30,000
more for solution mining. During oilfield
secondary recovery operations, wells
often inject brine at depths of 3,000 to
5,000 feet — presumably safely below
aquifers which might be used as sources
of drinking water. Unfortunately, the
casings of many older wells have
corroded or the grout which seals
casings has cracked. This allows the
upward leakage of injected brine and
other fluids.
Until now, contamination from leaking
injection wells at depths of 100 feet or
more has been impossible to detect
without drilling expensive monitoring
wells. In cooperation with the U.S.
Geological Survey, researchers from
EPA's Environmental Monitoring Systems
Laboratory in Las Vegas have
investigated advanced techniques for
detecting and mapping leaking brine
injection wells in Osage County, Okla.
"Preliminary results are very
encouraging," according to EPA
researcher Ron Evans, "It would seem
that saltwater contaminant plumes may
be detected at depths of from 100 feet to
as much as 1,000 feet below the
surface." The technique used is adapted
from mineral exploration technology.
Called "time domain electromagnetic
induction," it involves inducing transient
electrical currents deep within the earth
and measuring the rates at which these
currents decay. As the currents re-radiate
energy, major conductive masses such as
salt water plumes reveal themselves by
influencing the rates of decay. "Now that
we know that it can work," notes Evans,
"we will focus on developing techniques
to allow investigators to correctly
interpret the data that these instruments
produce." I
A 1,500-foot-deep chasm winds for more
than five miles, carved by the San Juan
River in southeastern Utah. The
long-distance visibility in the scene is typical
in a region that has been renowned for its
clean air.
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EPA JOURNAL
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Science and the
EPA Science Advisory Board
Dr. Norton Nelson, center, chairman of the Executive Committee of EPA's Science Advisory Board, meets with Administrator
William Ruckelshaus and Jerry F. Yosie, staff director of the Board.
By Dr. Norton Nelson
Chairman, Executive Committee
Science Advisory Board
To say that sound regulation depends
on good science may come through
as a statement of the obvious; it also
happens to be correct. It is widely agreed
that where there is a basis for concern,
the public supports appropriate
regulation insuring good health and
protection of the environment. In turn,
Dr. Nelson was appointed in January by the
Administrator as Chairman of the Science
Advisory Board's Executive Committee, He
is a professor of environmental medicine at
the Institute of Environmental Medicine,
New York University Medical Center. Dr.
Nelson, who has a broad background in
environmental health and risk assessment,
has previously served on committees of the
Science Advisory Board as well as other
federal scientific advisory committees.
those who are regulated, for example
industry, have repeatedly taken the
position that their concern is chiefly the
soundness of the technological and
scientific basis on which regulation is
undertaken rather than a difference in
objectives. Industry is staffed by
managers, by technicians and scientists
with roughly the same objectives as the
rest of their fellow citizens; one should
credit them with motives shared by the
general public, namely, to control
adverse exposures to prevent health
damage and to maintain the quality of
our environment.
The science that can and should go into
regulation comes from many sources,
from within the regulatory agency, from
other federal institutions such as the
National Institutes of Health, from
universities and independent research
enterprises, and from industry itself.
There has been a legitimate debate as
to the ability of a regulatory agency to
conduct research for its own regulatory
needs. There is a predictable limitation
on research in a regulatory agency
arising from inevitable conflict between
short term needs and longer term goals.
In the operation of the regulatory agency,
today's crisis is likely to overwhelm a
prudent concern for long term research
programs. On that basis, resources tend
to be shifted to immediate firefighting
requirements, always with the possiblility
that the longer term research will be
sacrificed.
This conflict is not insurmountable but
the conflict is real; failure to recognize it
is to run the danger of slipping into
erosion of longer term research. The
solution depends entirely on the success
of management in protecting the longer
range objectives of the agency.
On the other hand, there are very good
reasons why research responsive to
regulation should be conducted within
the regulatory agency; the agency is in
MAY 1984
35
-------
the best position to determine its own
needs. Constant oversight, however, is
required to insure continuity of long
range objectives as well as to insure that
the science remains independent of
perceived regulatory pressures.
As noted above, it is not supposed that
all of the research supportive of health
and environmental control comes from
the regulatory agencies.Indeed, only a
modest fraction is produced in-house.
Much of the needed information, new as
well as old, has been and is being
developed in universities, research
institutes and in some degree within
industry. It is most unfortunate that at
the very time the research budget of EPA
was being severely reduced, federal
support of extramural research resources
was also, in many instances, reduced. At
best, it has barely stayed abreast of
inflation.Time and talent have been lost
in the last few years in failing to maintain
the needed research base supportive of
EPA's objectives.
TL
I he new EPA management is clearly
making a determined effort to improve
the budget for research support both
in-house and extramurally. A balanced
science program supportive of EPA's
objectives cannot possibly be
accomplished with its own resources
alone. It will be dependent very much on
the building of linkages to the academic
community and to independent research
agencies and, indeed, to industry.
It is my perception that the bringing
together a number of years ago of the
predecessor units of EPA had the effect
in some instances of interrupting a well
working pattern of scientific rapport
within the academic community for a
number of the constituent programs of
EPA. The lost ground has never been
totally regained and EPA needs now to
redouble its efforts to rebuild those
bridges through a series of moves:
conferences, scientist exchanges,
increased extramural support and an
enhanced program of long-term
university research centers.
The Health Effects Institute which
brings industrial and EPA money
together to support research relevant to
EPA is a useful model for expansion in
other directions going beyond air
pollution and its health effects.
There are, in addition, opportunities for
EPA to achieve fuller cooperation with
other federal research resources such as
the National Institutes of Health, the
Centers for Disease Control, the Food and
Drug Administration, the National Center
for Toxicological Research, and still
others. Some advances in developing
such cooperation had been made in an
earlier time; such linkages should be
resumed and intensely expanded.
It is my view that the Science Advisory
Board in the past has allowed itself too
frequently to become involved in what
may be overly detailed editorial review of
staff papers. Meticulous scientific review
of such EPA products as the Criteria
Documents which support the national
ambient air quality standards is, of
course, extremely important and
indispensable. It is important that these
be scientifically sound and represent the
best scientific judgment.
I would hope, however, that ways can
be found to expedite such reviews and
minimize the purely editorial examination
of such documents. Less attention may
have been given to final documents
prepared for regulatory action. More
attention to these papers would bring the
very high talents of the Science Advisory
Board closer to the ultimate "action" in
terms of regulation. In this way, the SAB
would be giving attention not only to the
initial survey of science, but also to that
winnowing and selection of scientific
judgments and principles which enter
into the final regulatory position. I
believe this change in emphasis is
desirable and possible.
The information required by EPA for
regulatory purposes is very diverse,
covering the entire biosphere, human
and non-human as well as inanimate
systems. In addition to this broad scope
there is a great deal of interaction and
linkage in the needed assembly of
information for wise regulation. It
includes such issues as transport through
water, ground water, soils and air. During
this transport, materials may be altered
and increased or decreased in toxicity
and transportability. These chemical
changes can be complex and decisive for
the qualitative nature of the chemical and
the intensity of exposure of the target.
Once the chemicals reach the target
organisms, be they human or nonhuman,
the nature of the biological interactions
needs to be understood. A next step in
the linkage has to do with the need to
quantitate the responses.
mat this adds up to is that much of
EPA's research needs for regulation may
require the understanding of hydrology,
meteorology, reaction within air, within
water, within soils, biochemical
interactions, statistical analysis, and
mathematical modeling of the
interrelationships of these components.
This suggests that regulatory research
will often require a set of related
inquiries using many different disciplines.
Thus, careful and thoughtful planning of
the interactive components in these steps
from source to adverse outcome will be
required. Examples of such
comprehensive planning are rare: one
that springs first to mind is the extensive
and rewarding effort in the study on
diesel exhaust in order to determine its
probable human impact.
This concept implies that appropriately
broad research planning should be
employed wherever needed in EPA. The
Science Advisory Board could play a role
here through the development of ad hoc
subgroups working with EPA staff in
developing broad strategies which would
bring together these various interrelated
disciplines. This approach is worthy of
exploration; it would expand the
initiatory role of the Board in research
planning. I believe, on the one hand,
broader planning of this sort needs
greater use within the agency and I think
it well worth the effort to explore
whether a useful contribution along these
lines can come from the diverse talents
within the Science Advisory Board.
T.
he present EPA administration has
properly placed a very high priority on
qualitative and quantitative risk
assessment. Currently, the distinction
between risk assessment and risk
management has been rather well
defined by the recent National Academy
report. Risk assessment falls clearly
within the purview of science and
technology; thus, the technology of risk
assessment is clearly in the domain of
the Science Advisory Board. To go
beyond this into risk management or the
balancing of cost and benefits is,
however, to invade the area of the
Administrator who is by Congress
defined as a surrogate for the entire
citizenry representing all constituencies
and all interests, general and special. As
such, he is clearly responsible for making
the decision which balances benefits and
societal costs.
On the other hand, such a separation,
though easily stated, sometimes is
difficult to maintain. There is an area
between assessment and management
which is blurred and in which the
scientists can legitimately participate and
may sometimes inadvertently overstep.
The basic objective here, I believe, is to
recognize that such separation is
desirable and that a full awareness of the
separation should be kept in mind at
each stage of the risk assessment
process.
The Science Advisory Board has over
the years been an important resource to
EPA and a very solid monitor of its
research programs and research policies.
The Administrator and the Deputy
Administrator have both clearly
expressed themselves as wishing to
make fuller use of the Board and to look
to it even more than in the past for its
full participation in science and science
policies relating to EPA's control and
regulatory responsibilities. We are
confident the Board can meet these
expectations. D
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EPA JOURNAL
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Testing the Potential of
Cleanup Technology
By Susan Tejada
EPA engineering laboratories are
evaluating a variety of new technologies.
The labs are part of EPA's Office of
Research and Development (ORD). In
many cases, they introduce technology
with commercial potential, to be
developed and marketed by the private
sector.
In some instances, ORD assesses the
potential of a technology already in use
overseas, for use in the United States.
Such was the case with the swirl
separator and regulator for sewers,
which was developed in England. ORD
modified the original design, and
evaluated its use for combined sewer
overflow control and sewage degritting
in this country.
ORD also conducts research on new
technology in-house. Use of organic acid
Hazardous Waste
additives to improve limestone scrubber
performance was conceived of and tested
by agency lab staff.
ORD funds technology research by
private sector institutions, and assesses
the practical application of technology
that has already been developed by
industry but is not in widespread use.
This was the case with pressure sewers,
discussed in more detail below.
EPA sometimes becomes involved in
development of a specific technology
when industry has little incentive to do
so. For example, waste treatment is not
an especially profitable area for waste
generators. Consulting engineers who
work for generators tend to emphasize
refinement of proven waste treatment
processes for their plants rather than risk
funds on untested ideas. Even
manufacturers of pollution control
equipment tend to improve or expand
their existing lines rather than work on
innovative but initially expensive high
technology with unknown applications.
Many plants are simply too small to
afford research and development efforts.
In situations like these, EPA's Office of
Research and Development has a role to
play in evaluating the feasibility and cost
effectiveness of new technologies.
This article looks at three EPA program
areas — air, water, and hazardous wastes
•— where the Office of Research and
Development has tested new
technologies. The examples chosen are
mainly of time-tested technologies that
have been around long enough to have
been picked up, adapted, and marketed
by private industry.
EPA's Municipal Environmental Research
Laboratory facility in Edison, N.J., tests
and evaluates prototype equipment for
hazardous material spill response and
control. Technologies now being
evaluated include mobile versions of
various kinds of waste treatment
systems: a mobile incineration system, a
mobile reverse osmosis treatment
system, a mobile system for
detoxification and regeneration of spent
activated carbon, and a mobile system
for extracting spilled hazardous materials
from soil.
The two examples cited below, having
withstood the test of time, have been
adapted and marketed by industry.
Acoustic emission
monitoring device
There are as many as 500,000 diked
areas in the United States containing
potentially hazardous wastes. These
range from small waste ponds at
chemical manufacturing plants to
mile-square tailings lagoons at mines,
smelters, and phosphoric acid plants.
Many of these impoundments are
unstable. Under slight stress from a
heavy rain, for example, they can
An acoustic emission monitoring device
used to pick up sounds from soils under
stress, helping to determine the stability of
dams that might collapse and spill toxic
contents.
collapse and spill their contents. Some of
the more notorious such incidents have
resulted in a large fish kill in Norris Lake,
Tennessee and kepone contamination of
the James River in Virginia.
Soils under stress emit sounds. To
study this phenomenon, EPA awarded a
grant to Drexel University. Field testing
carried out by EPA and Drexel scientists
verified that unstable soil produces large
quantities of acoustic emissions and that,
conversely, stable soil produces low or
nonexistent acoustic emissions.
Based on the results of their field
testing, the scientists developed an
acoustic emission monitoring device to
determine the stability of earthen dams.
The device consists of metal waveguides,
an accelerometer, an amplifier, and a
display system counter. The electronic
components are battery operated.
Acoustical emissions are transmitted to
the surface of the soil through
waveguides, or rods, driven into the
walls of the impoundment. These sounds
are converted to electrical analogues,
amplified, and recorded for analysis. A
MAY 1984
37
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Water
counter responds to signals above a
preset threshold level, and records the
rate of sound emissions.
The acoustic emission monitoring
device is portable and inexpensive. It
can be operated either periodically or
continuously, and requires little
maintenance.
Since their development, acoustic
emission devices have been installed
across the country, at dams ranging in
length from 20 feet to 6 miles, and have
proven successful. For example, they
provided early warning of the threatened
collapse of an industrial dike and of an
abandoned lagoon at a chemical waste
disposal facility. In each case danger was
detected in time to shore up the walls
and prevent collapse.
In 1977, Industrial Research magazine
presented its IR-100 award jointly to EPA
and Drexel University for development of
the acoustic emission monitoring device.
Citing use of acoustic emission monitor-
ing by chemical manufacturers and
construction companies, the award called
the "Earth Dam Spill Alert Device" one of
the year's most significant contributions
in industrial research.
In 1979 EPA's Industrial Environmental
Research Laboratory published a capsule
report on acoustic monitoring as part of
its technology transfer program. Today
several manufacturers sell packaged
systems for acoustic emission monitoring
of earth structures.
Mobile
physical-chemical
treatment system
In 1971, EPA contracted with a private
company to build a trailer-mounted
system of wastewater treatment for test
and evaluation. In this system, as
modified by EPA lab staff, contaminated
water is pumped into a settling tank for
flocculation and sedimentation. The
clarified fluid then passes through filters
and enters carbon adsorption columns.
Sludge is removed from the
sedimentation tanks and stored for
disposal. Any step in the process can be
bypassed, and additional storage tanks
can be provided for filter backwashing or
temporary storage of unprocessed
materials.
EPA maintains two mobile treatment
trailers, a larger one with three filters and
carbon columns, and a smaller one with
one filter and carbon column. EPA has
used the trailers at more than 50 clean-
up operations during the past several
years. For example, when pesticides
were washed into a tributary to the
Millstone River, a public water supply for
Allentown, N.J., more than 7.6 million
liters of the contaminated water were
processed through the trailer. In another
incident, PCBs were spilled into the
Duwamish Waterway in Seattle, Wash.
Divers in protective suits first pumped
water and spilled material through
pre-settling tanks. Then the filters and
carbon adsorption columns of the trailer
were used to further decontaminate the
water.
In a 1978 report published in the
Journal of the Water Pollution Control
Federation, EPA scientist Dr. Joseph
Lafornara observed that, in six cases
studied, use of the trailer had achieved
greater than 90 percent removal from
water for 21 toxic materials.
EPA published a report on the
development of the mobile physical-
chemical treatment system as part of the
Environmental Protection Technology
Series. Physical-chemical treatment
systems have since been developed, or
are now being developed, by many
companies, including Calgon
Corporation, OH Materials, ENSCO
Group, and IT Corporation.
A mobile trailer-mounted system developed under contract from EPA to treat water
contaminated by spills and other pollution incidents.
Phosphorus
removal
Eutrophication is the slow aging process
in which a lake evolves into a marsh and
eventually disappears. During
eutrophication a lake is choked by plant
life. Human activities such as wastewater
disposal that add nutrients to a lake can
speed up the process.
The Great Lakes are particularly
susceptible to eutrophication caused by
the high phosphorus content of
wastewater from adjacent treatment
plants. The phosphorus comes from
agricultural runoff, detergents, and
human and industrial wastes.
Under a treaty agreement between the
U.S. and Canada, amended in 1972,
eutrophication of the Great Lakes was to
be brought under control. Yet the
municipalities concerned did not have
the research capability to come up with a
solution, and industry did not have a
profit incentive.
EPA originated a small in-house pilot
scale project to test the feasibility of
adding metallic salts to treatment
systems to control phosphorus. The salts
combine with phosphates in the
wastewater to form an insoluble
compound which can be removed by
gravity sedimentation. A patent on the
process was issued to the U.S.
government for unrestricted use by any
municipality. EPA's Municipal
Environmental Research Lab in Cincinnati
subsequently conducted full scale pilot
testing at 20 treatment plants.
Without the addition of metallic salts,
treatment plants had had about a 10
percent phosphorus removal efficiency.
With metallic salts, the efficiency rate
increased to about 90 percent.
The government-patented technique of
phosphorus removal has been so
successful that it is now being used at
about 1,500 facilities worldwide. This
includes more than 560 facilities in the
U.S. Although the great majority of these
plants — about 400 — are located in the
Great Lakes area, the largest one is the
Blue Plains Wastewater Treatment Plant
in Washington, D.C. A 1982 survey
estimated that, by the year 2,000, more
than 1,200 facilities in the U.S. will be
using this process.
EPA continues to have an active role in
providing technical assistance to
treatment facilities seeking to use this
technique.
Pressure
sewers
Conventional sewers operate by gravity;
wastewater is transported through
sloping pipes underground. In densely
populated areas, conventional sewers are
cost-effective because the amount of
sewer required per person is
38
EPA JOURNAL
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reasonable. But in less populated areas,
where houses are spread out, the
amount of conventional sewer required
per person is greater, and so is the cost.
As a result, on-site systems — usually
septic tank-soil absorption systems —
are the primary form of wastewater
treatment and disposal in rural areas.
Unfortunately these systems sometimes
fail because of unsuitable soil, faulty
design and construction, or owner
negligence.
EPA initiated a study through the
American Society of Civil Engineers
(ASCE) to find an alternative to
conventional sewers. One of the
alternatives studied was a pump-grinder
unit that could be used for pressure
sewers. Because it relies on pump
pressure instead of gravity to move
wastes, and because it uses small
diameter plastic pipe, a pressure sewer
system can follow the contours of the
ground, going uphill or downhill. It does
not require deep trenches, so installation
costs are less than those for a
conventional sewer system. Also,
because they run intermittently on low
horsepower and are easily repaired,
pressure sewer pumps have nominal
operating and maintenance costs.
The ASCE study determined that use of
a pump-grinder unit for pumping ground
sewage through small diameter pipes
was feasible. EPA then funded four
studies of pressure sewer systems in
Albany, N.Y., Phoenixvilfe, Pa.,
Grandview Lake, Ind., and Bend, Ore. The
last of these studies was completed in
1978. The research showed the viability of
pressure sewers in a variety of
situations: one house one pump in
Albany, multiple family dwellings on a
single pump in Phoenixville, and a much
larger, lakeside system in Grandview
Lake. The Bend project also looked at
another type of pump, a septic tank
effluent pump. In Grandview Lake, where
the cost of installing conventional
sewerage had been estimated at $10,000
per home because of unfavorable terrain,
the installed cost of pressure sewerage
was only $1,000-$1,500 per home.
As a result of these studies, EPA
produced a technology transfer
document with engineering design
parameters for pressure sewers that are
used today. This document was the first
centralized compilation of information on
pressure sewers.
Pressure sewer technology is now in
use at more than 200 installations in the
United States. Pressure sewers have
saved small communities from 10 to 90
percent of the cost of conventional
sewers. From late 1978 to mid-1982, EPA
funded 146 small community wastewater
collection systems under the construction
grants program. About two-thirds of
these were pressure sewer systems.
The Blue Plains Wastewater Treatment Plant in Washington, D.C. Jhis is the largest
such facility in the U.S. using phosphorus removal methods originated by LPA.
Air
Low NOxburners
The low NOX (nitrogen oxides) burner
program is an EPA-sponsored effort to
conduct research into combustion
systems that reduce nitrogen oxide
emissions from coal-fired boilers.
Existing combustion technology did
not appear capable of meeting projected
nitrogen oxides emission goals. EPA tried
to upgrade that technology, and to
demonstrate its technical feasibility and
reliability to boiler manufacturer and
utility companies.
In the low NOX burners developed by
EPA's Industrial Environmental Research
Lab in North Carolina, combustion air is
added in stages. This insures, early in the
combustion process, a fuel rich zone
which tends to reduce production of
nitrogen oxides. The goals of the low
NOX burner program are to reduce
nitrogen oxides by 60-70 percent over
uncontrolled levels for retrofit
applications, and by 70-80 percent for
new applications.
A retrofitted wall-fired industrial boiler
at Western Illinois Power Company in
Pearl, III., and a tangentially-fired utility
boiler at Utah Power and Light Company
in Castledale, Utah, were field-evaluated.
In both cases, nitrogen oxide emissions
were successfully controlled with no
adverse impact on other
combustion-related pollutants or on unit
performance. The companies which
participated in these field evaluations will
be in a position to commercialize the
technology.
Work on low NO* burners has led EPA
to sponsor research on another emission
control technology for coal-fired boilers:
limestone injection in multistaged
burners, or LIMB. The agency is
sponsoring research, pilot scale testing,
process analysis, and field evaluations.
Unlike flue gas desulfurization, which
removes only sulfur oxides, and low NOX
burners, which remove only nitrogen
oxides, LIMB will simultaneously remove
both sulfur and nitrogen oxides from
boiler flue gases. The LIMB concept uses
low NOX burners to introduce limestone
or other sorbents in the boiler
combustion zone for the sulfur oxide
removal.
If LIMB meets its technical objectives, it
would be unique among commercial
technologies in achieving high levels of
sulfur oxide removal at relatively low
costs, lower than the costs of flue gas
desulfurization. An extra bonus, of
course, would be its ability to
substantially reduce nitrogen oxide
levels. LIMB technology may also prove
to be particularly important in control of
acid rain.
* * # *
The Office of Research and Development
projects described in this article have
been around long enough so that the
operating problems have been resolved
and commercialization has taken place. In
years to come, work being done in ORD
labs will be time-tested as these
projects have been, and present day
research should result in many more
private industry applications five or six
years from now. I '
MAY 1984
.1!)
-------
Cutting Costs
while Cleaning Air
Painted truck parts moving into a drying
oven at the Mack Trucks plant in Allentown,
Pa. Computer-controlled oven improves the
control of volatile organic air pollution and
cuts energy costs.
by Carl Gagliardi
A;k anyone about the way the federal
government and industry are
supposed to work out their environmental
problems and you will likely hear this
conventional scenario. Congress passes a
law setting pollution standards for an
industry. EPA writes the regulations for
the law, calling for the industry to meet
the standards within a certain time limit.
The industry protests, saying it cannot
meet the standards, or it cannot afford
the necessary technology, or both. EPA
replies that they must meet them
anyway.
Like most conventional wisdom, this
scenario is sometimes wrong, and EPA is
showing that it doesn't have to work this
way. The agency and industry have been
finding ways of helping each other. In
addition to setting standards, the agency
is helping industries find the ways to
meet them.
A perfect example of the agency's
commitment to helping industry meet
standards mandated by Congress is a
program to help the painting and
chemical coating industry develop the
technology to meet provisions of the
Clean Air Act. The agency's Office of
Research and Development, in a joint
effort with the Department of Energy and
the Chemical Coalers Association (CCA),
developed a system for the coating
industry that not only helps them meet
the clean air standards but also saves
them money in the process.
In the process of painting and coating
metal and other surfaces, these
industries release volatile organic
compounds (VOCs) into the air. VOCs are
a class of hydrocarbons that react with
sunlight to produce ozone, a harmful air
pollutant. Some VOCs are toxic in
themselves. Because so many
manufactured products are painted with
solvents that produce VOCs during the
baking process, the coating industries are
Carl Gagliardi is a Press Officer in the EPA
Office of Public Affairs.
one of the leading contributors to
industrial air pollution. Automobiles,
appliances, furniture, plastics, aluminum
siding and hundreds of similar products
are coated in ovens that release VOCs in
dangerous quantities. This industry
generates more than 8.5 million tons of
VOCs a year. According to EPA, these
emissions are considered to be one of
the biggest contributors to the smog
problem in most major U.S. cities.
Under sections of the Clean Air Act,
EPA is responsible for curbing VOCs. But
the agency must also take into account
the financial ability of industry to absorb
the cost of cutting emissions or
developing equipment to reduce them.
Most coating companies are small
operations with modest financial
resources that cannot afford the
enormous cost of complying with the
VOC standards set down under Sections
111 and 112 of the Act. The metal
finishing industry, which typically uses
VOC coatings or cleaning agents in their
processes, is made up of over 80,000
plants. More than 40,000 of them employ
fewer than 20 people.
The cost of controlling VOC emissions,
particularly difficult for small plants, was
the main obstacle to industry acceptance
of the regulations. Some of the existing
emission control processes would have
cost the industry one to two times the
cost of coating the product. A less
expensive method of controlling
emissions was needed.
So, in 1979, EPA and the U.S.
Department of Energy became partners
with the Chemical Coaters Association in a
venture to develop the technology for the
coating industry to reduce VOC
emissions without driving up the cost of
painting manufactured goods. The
project officials contacted over 75
painting equipment users, vendors and
designers to choose the best evaluation
sites and to get a better understanding of
what was involved in the coating
process. They formed a committee of
government and industry officials to give
the project technical direction, and in
1981 they picked the Mack Trucks plant
in Allentown, Pa., as the host site to
evaluate the technology for controlling
VOCs.
Coating and painting plants that
release large amounts of VOCs do so
because they take more air into the oven
during the baking process than is
necessary. Certain solvents used in
paints and coatings are extremely
explosive in vapor form. So the coating
operator must draw a large volume of air
into the oven to keep the density of the
vapor from reaching a point where it
would ignite. The amount of air needed
depends on the lower explosive limit
(LEL) of the solvent. The lower explosive
limit is the least amount of solvent that
makes an atmosphere explosive. Coaters
have been operating the ovens with
greater amounts of excess air than is
needed to keep the oven environment
safe, sometimes as much as 50 to 100
times greater.
The coating industry traditionally has
regarded operating the ovens at 25
percent of the LEL as required for safety,
but it has been found that the oven can
be operated with less air, or 50 percent
of the LEL. It was the job of the EPA
project to demonstrate that industry
could bake the coatings at higher solvent
concentrations approaching the 50
percent LEL.
The project officials developed a
computer system to allow the operation
of the oven at lower air flows and higher
solvent concentrations. With LEL
monitors installed at certain points in the
oven, the microprocessor receives
readings which signal that the solvent
concentrations have reached the safe
level. It then automatically activates
various control surfaces—like dampers,
fans and coating applicators—which set
the oven atmosphere at the most
economical level. The microprocessor
permits instantaneous changes in
concentrations, so the oven atmosphere
remains relatively stable.
Because the computer-guided system
requires less air, VOCs are released at
much lower levels. And because more
40
EPA JOURNAL
-------
energy is required to heat excess air to
the incineration temperature, the
microprocessor-directed system is more
fuel efficient than the conventional
system to control VOC emissions. Using
less energy, of course, means the
industry operates its ovens at less cost.
Before Mack Trucks was chosen as the
demonstration site for the project, the
development and engineering work was
completed by Centec Process Systems.
Although the system was developed
entirely from off-the-shelf equipment,
computers had never been used for this
purpose. Centec programmed the
computer and adapted it to work with the
ovens. EPA's engineers managed the
system and defined its performance
requirements.
The development of the technology to
demonstrate the advantage of reducing
the amount of air needed during the
baking process was considered too costly
by the industry because, among other
reasons, any coating company
enterprising enough to absorb the cost of
developing it would not be able to patent
it because the process, although new, is
considered public information.
The project members put their findings
to the test. They found by using the
microprocessor system, the emissions
rate dropped significantly, while operations
could be carried on at a safe level. In
energy use alone, a typical plant would
save more than $100,000 a year.
Charles Darvin, an EPA physical
scientist at the agency's Industrial
Environmental Research Laboratory in
Cincinnati and the project director, has
shown that if this system were installed
in only 600 of the estimated 13,000 metal
finishing ovens, the savings in energy
costs and VOC emissions nationally
would be enormous. According to his
figures, industry could save an estimated
7 million barrels of oil a year. At $29 a
barrel, this would amount to a savings of
$200 million each year.
Not only does the computer system
reduce VOC emissions but, because it
does so at a lower cost, it gives EPA the
ability to set more stringent standards.
Under Section 111 of the Clean Air Act,
EPA must take the cost to the industry
into account when it establishes New
Source Performance Standards (NSPS)
for a pollutant. In this case, the agency
has the option of setting tougher
standards because it can prove that the
costs to the industry will not be
prohibitive. EPA can show, in fact, that
the microprocessor will even save
industry money.
Once the project team evaluated the
system, their next step was to sell it to
the industry. Darvin picked the "toughest
peer review committee I could find." The
committee consisted of Fred Jensen of
Jensen Oven Co., Rolf Westen of
Price-Westen & Co. and A.C. Walberg of
Arvid C. Walberg & Co. In June 1983,
that committee endorsed the project,
saying the microprocessor system "is a
very viable project."
"It provides excellent air pollution
control with very good economic returns
on a large capital investment," the report
said. "The project would never have
been carried out by the private sector.
The funding by the EPA made the project
possible, and the data obtained from the
project is now public information."
Joe Schrantz, executive editor of
Industrial Finishing, a trade magazine,
observed the Mack Trucks oven
microprocessor system and concluded
that the project "proves for the first time
that an industrial finishing oven's solvent
vapor concentration can be controlled
automatically by a computer. Controlling
vapor concentration means less dilution
air is required, thus dramatically reducing
the amount of oven air that has to be
heated."
Mack Trucks and Prior Coated Metals,
Inc., already have begun using the
equipment in their daily operations, with
seven more companies preparing to
install it. D
MAY 1984
-------
Assessing Health and
Environmental Risks
by Dr. Elizabeth L. Anderson
The Office of Health and Environmental
Assessment, located in the EPA Office
of Research and Development, is
primarily responsible for providing EPA
with a central capability for evaluating
information on the health effects of toxic
pollutants and for ensuring the
consistency and technical competence in
the agency's risk assessment work. This
office prepares a variety of documents
including: air and water criteria
documents; health, risk, and exposure
assessments; and guidance and
methodology documents used in
assessing the risk of exposure to
hazardous pollutants. This office consists
of five units: the Carcinogen Assessment
Group, the Exposure Assessment Group,
and the Reproductive Effects Assessment
Group, located in EPA headquarters, and
two Environmental Criteria and
Assessment Offices located in Cincinnati,
Oh. and Research Triangle Park, N.C.
As one stage of its document
development and scientific review
process, the Office of Health and
Environmental Assessment convenes
workshops with scientific experts to peer
review its health assessment and criteria
documents. Through announcements in
the Federal Register, the public is invited
to comment on the revised, or external
review drafts. Final versions of health
assessment and criteria documents
reflect the advice from the workshops
and the public comments, and from
EPA's Science Advisory Board, which
meets in public sessions to review these
health assessments.
Air quality criteria documents contain
all of the latest scientific knowledge
about an air pollutant and indicate the
kind and extent of all identifiable effects
on health and welfare. These documents
are mandated by the Clean Air Act and,
as directed by the Act, are reviewed at
5-year intervals. The Air Quality Criteria
Documents form the health basis on
which the Administrator relies in setting
ambient air quality standards.
There are five air criteria pollutants:
carbon monoxide, oxides of nitrogen,
ozone and other photochemical oxidants,
paniculate matter and sulfur oxides, and
lead. In 1983, an addendum to the carbon
monoxide document was released for
review as was the lead criteria document.
In early 1984, the final criteria documents
for oxides of nitrogen and particulate
matter and sulfur oxides were published.
The ozone criteria document is scheduled
for public review in August 1984. These
documents are prepared under the
direction of the Environmental Criteria
and Assessment Office in Research
Triangle Park, N.C.
The emphasis in the water quality
criteria documents is on the protection of
aquatic life and human health. Thirteen
ambient water quality criteria documents
were updated in 1983 and the final water
quality criteria document on dioxins was
published in February 1984. Drinking
water criteria documents are
comprehensive evaluations which
contain health effects criteria and
recommended maximum contaminant
levels (RMCLs) for chemicals in drinking
water. Approximately 31 drinking water
criteria documents have been completed
or are underway at the present time.
These include 1,1-dichloroethane,
mercury, silver, 2,4-D, endrin, lindane,
methoxychlor, toxaphene, and 2,4,5-TP.
These documents are developed by the
Environmental Criteria and Assessment
Office in Cincinnati with input from EPA's
Duluth laboratory (aquatic effects) and
Carcinogen, Reproductive and Exposure
Assessment Groups.
Health assessment documents provide
evaluations of the known health data
from all exposure routes and risk
assessment information. The documents
are widely used by the agency and, in
particular, form the primary health basis
(Dr. Anderson is Director of the Office of
Health and Environmental Assessment.)
for deciding whether certain substances
should be listed as hazardous air
pollutants. Final health assessment
documents have been published on
acrylonitrile, carbon tetrachloride,
chlorofluorocarbon FC-113, coke oven
emissions, inorganic arsenic, methyl
chloroform, and toluene. Draft
assessments have been made available
for public review and comment on
cadmium, chlorinated benzenes,
chloroform, chromium, dioxins,
epichlorohydrin, ethylene dichloride,
ethylene oxide,
hexachlorocyclopentadiene, manganese,
methylene chloride, nickel, tetra-
chloroethylene, trichloroethylene, and
vinylidene chloride.
Among the other chemical
assessments underway or scheduled for
initiation are mercury, beryllium,
phosgene, chloroprene, acrolein,
acetaldehyde, phenol, propylene oxide,
copper, and 1,3-butadiene. Health
assessment documents are developed in
the Environmental Criteria and
Assessment Offices, with chapters on
carcinogenicity, mutagenicity, and
reproductive effects prepared by the
Carcinogen Assessment and
Reproductive Effects Assessment Groups.
Examples of other assessment support
provided are:
• Health and Environmental Effects
Profiles are assessments of a chemical's
toxicity and environmental fate that
provide preliminary scientific judgments
regarding a chemical's potential harmful
effects to human and aquatic life, and the
environment. These reviews serve as a
basis for listing regulations under the
Resource Conservation and Recovery Act.
Approximately 90 of these profiles have
been completed for the Office of Solid
Waste.
• In support of Superfund,
methodologies for deriving reportable
quantities were developed and 244
reportable quantity documents based on
chronic toxicity were prepared in 1983 by
the Environmental Criteria and
Assessment Offices in Cincinnati. Profiles
for ranking carcinogenicity hazards for
192 chemicals will be provided to the
program by the Carcinogen Assessment
Group in the summer of 1984. These
profiles summarize available
carcinogenicity data and will serve as
scientific input to ruiemaking decisions to
establish levels for reporting on
hazardous substances.
• The evaluation of health risk of
populations near hazardous waste sites
considers the risks posed by the
combined multi-route exposure to the
chemical mixture. Brief preliminary
evaluations of health risks due to waste
EPA JOURNAL
-------
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i DISPOSAL SITE >
WAPERIAL COUNTY
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site releases or chemical spills are
provided to the regional and program
offices on request. These evaluations are
prepared by the Environmental Criteria
and Assessment Office in Cincinnati, In
emergencies, the brief summary is
communicated within two working days
of the request. This quick response is
made possible by the extensive use of
the database known as "studies in toxicity
applicable to risk assessment," which
contains dose-response information by
exposure group for each chemical listed.
These data include species tested, route,
exposure levels and duration, affected
organs, severity of toxicity, and details
on the specific effects observed. This
database currently covers 160 chemicals
and is being expanded to incorporate
epidemiologic and pharmacokinetic
information.
Exposure assessments are evaluations
of human exposure occurring as a result
of an industrial operation or the dumping
of hazardous materials. Several
assessments of dioxin-contaminated sites
have been conducted by the Exposure
Assessment Group during the past year
in support of the agency's regulatory and
enforcement programs. Some of the
specific sites which have been assessed
are the Shenandoah Horse Arena (dioxin)
in Moscow Mills, Mo., and the ASARCO
smelter (arsenic) in Tacoma, Wash. The
Office of Health and Environmental
Assessment also provides technical
reviews of exposure assessments
prepared by other EPA offices, and
technical advice and guidance to these
offices on conducting evaluations.
EPA uses the scientific knowledge
concerning the effects of toxic pollutants
to implement its statutory
responsibilities. The Office of Health and
Environmental Assessment plays an
active role in providing advice and
guidance to the EPA regulatory and
enforcement offices because of the
scientific knowledge accumulated during
the course of its evaluations.
An example is the public hearings EPA
recently held in Tacoma, Wash, on the
proposed regulation of arsenic emissions
from the ASARCO smelter. The purpose
of these hearings was to solicit
Disposal site in the early 1970s in the
imperial Valley, near El Centre, Calif., for
discarded pesticide containers. EPA is
assessing the risks of wastes to people.
comments from concerned citizens and
to explain the information the agency
used to make the proposed regulations.
The Office of Health and Environmental
Assessment played an active role in
these public meetings. The final
regulatory decisions on inorganic arsenic
will rety, for health information, on the
office's assessment of the health effects
associated with arsenic exposure.
The Administrator has adopted a
two-step approach to the management of
public health risk. The first step is risk
assessment, or characterizing the nature
and extent of the risk. The second step is
risk management, or deciding what to do
about the problem. The Office of Health
and Environmental Assessment is
concerned with risk assessment. This
involves critical analysis of all available
toxicological data on the environmental
agent being evaluated, and estimates of
human exposure.
Risk assessment answers two
questions: how likely is an agent to be a
toxic substance (the qualitative
evaluation), and what is the magnitude of
the risk of exposure to the agent (the
quantitative evaluation)? Most of the
experience to date is in the area of
cancer risk assessment. EPA adopted an
approach in 1976 to first determine the
weight-of-evidence that an agent might
be a human carcinogen, and, second, to
determine the magnitude of the public
health impact given current and
projected exposure. Cancer risk
assessments are prepared by the
Carcinogen Assessment Group.
While there is no scientifically proven
method for quantitatively estimating
effects at low doses from human and
animal cancer incidence data at high
doses, the Office of Health and
Environmental Assessment has adopted
the use of a linear, non-threshold model
in its quantitative risk assessments. The
linear non-threshold model is regarded
as having some biological plausibility
and is based on the concept that
cancer can be initiated by a single
molecular event somewhere in a cell.
Although there are major uncertainties in
the extrapolation to low doses, the use
of the linear model gives a plausible
upper limit of risk which generally is a
higher risk estimate than other models.
However, other models would be
considered if available data would
warrant their use.
Because of the uncertainties in
estimating cancer risk, the Carcinogen
Assessment Group has several projects
which are designed to better the risk
MAY 1984
-------
assessment methodology. One project is
being conducted in cooperation with the
Department of Defense to identify and
quantify the uncertainty in quantitative
risk assessment. The objectives are: to
.identify and to express quantitative
uncertainties that are involved in the
process of risk estimation, excluding the
uncertainties due to the low dose; to
examine the impact of the different
assumptions that are made in the risk
estimate; to compare results calculated
from human and animal data, including
the identification of the assumptions that
produce best correlation of risk estimates
between humans and animals; and, to
develop guidelines for presenting a range
of risk estimates based on different but
scientifically acceptable assumptions or
the assumptions that have considerable
backing in the scientific community.
The Deputy Administrator convened a
toxics integration task force to examine
ways for EPA to coordinate its policies
and actions on toxic substances. One of
the task force's principal areas of concern
was assurance of technical quality and
consistency in EPA's risk assessments.
From the task force recommendations,
the Deputy Administrator directed two
activities in risk assessment, both of
which will be chaired by the Office of
Health and Environmental Assessment
with participation by all of the EPA
program offices.
I he first of these will be to revise
or develop guidelines for performing risk
assessments. The guidelines, which
cover six areas, are expected to be
available during the summer of 1984.
These are: carcinogenicity, mutagenicity,
reproductive effects, systemic toxicants
(other chronic effects), complex mixtures,
and exposure assessment.
A risk assessment forum will also be
established under the chairmanship of
the Office of Health and Environmental
Assessment. This forum will consist of
senior scientists from each of the
program offices and will oversee risk
assessment in four ways:
• Review risk assessments upon referral
from the program offices.
• Make recommendations for risk
assessment procedures not covered by
the original guidelines.
• Make recommendations on risk
assessment issues of a procedural
nature.
• Recommend revisions to the 1984
guidelines whenever such revisions
appear to be necessary.
Suggestions for improving the
scientific basis for risk assessment also
are made by the staff as they perform
their assessments. These are often made
to strengthen the ability to make risk
assessments in general, as well as for
chemical-specific limitations. The Office
of Health and Environmental Assessment
has recently sponsored workshops to
convene recognized experts in the field
of mutagenicity and reproductive effects
(teratogenicity and male and female
sterility] and complex mixtures.
The workgroups focus on research
approaches for improving the scientific
foundation for risk assessment in
specific, key problem areas. A forum of
expert scientists is an efficient way to tap
the current knowledge and to help
identify approaches and research to
improve the agency's ability to assess
the potential risk of environmental
agents.
For example, a symposium of
international experts is being planned for
March 25-28, 1985 at the Carnegie
Institute of Washington, D. C. to discuss
the topic of aneuploidy (an end point in
mutagenesis) with regard to information
on mechanisms of action, existing
experimental test results, and the human
aspects of the problem.
A human biomonitoring workshop was
conducted in December 1982 because
certain federal laws require balancing the
consequences of mutagenic risks with
the benefits provided by the use of
chemical substances. This requires that
risk be quantitatively assessed. Estimates
of human genetic risk can be made
indirectly based on data from animal
experimentation and human somatic
cells, but it is not feasible to estimate
genetic risk directly based on data from
human germ cells.
The indirect estimates are highly
debated because of uncertainties about
interspecies and interorgan
extrapolations. Uncertainties in
extrapolating from effects observed in
animals at high experimental doses to
effects likely to occur in humans at much
lower environmental levels further
complicate genetic risk assessment. The
workgroup suggested that comparative
studies be conducted to define the
relationships between somatic cell and
germ cell events and between
experimental animals and humans. The
work group also recommended that at
least one high-risk human population be
selected for study, such as cancer
chemotherapy patients and their children,
to compare them with experimental
animal populations given the same
drugs.
uch a study would show how
predictive the animal model is for
humans for the days tested. To be
effective, such efforts will require a
long-term coordination of activities
among federal agencies, industrial
laboratories, and the academic
community. So far, EPA has held
follow-up meetings with the National
Cancer Institute, the American Red Cross,
and the National Toxicology Program, as
well as with other concerned offices.
Relevant research has been initiated to
address some of the problems and a
follow-up workshop to identify an
appropriate high-risk human population
is being planned. Most workshop
endeavors are published in the scientific
literature and have or will influence the
direction of research in government and
academic laboratories.
Risk assessment activities of the Office
of Health and Environmental Assessment
are not limited to chemical substances,
per se, but include organisms and their
products as well. Within the past year,
EPA has increased its activities in
biotechnology. The Office of Health and
Environmental Assessment working
closely with the Office of Exploratory
Research and the EPA Office of Pesticides
and Toxic Substances has played a
significant role in coordinating EPA
research activities in this area. With
assistance from the EPA Office of
Pesticides and Toxic Substances, the
Office of Health and Environmental
Assessment successfully conducted an
in-house workshop last December.
Activities are now underway to develop
risk assessment approaches and
guidelines for biotechnology. There are
five geneticists and several micro-
biologists and engineers with training in
industrial fermentation on the staff of the
Office of Research and Development and
plans are being made to hire additional
people in these fields. The Office of
Health and Environmental Assessment is
working to help the agency build a
technical base for making regulatory
decisions about biotechnology
applications.
In conclusion, the Office of Health and
Environmental Assessment has many
functions. These functions include taking
the lead responsibility for developing risk
assessment guidelines, ensuring that
agency health risks are conducted in a
consistent and technically sound manner,
performing risk assessments and
providing technical assistance at the
request of the program offices,
developing new risk assessment
methodologies and suggesting new
research efforts that will better support
future risk assessment procedures, and
interacting with all levels of the
environmental health science community.
The functions demand that the technical
staff in the office not only keep abreast of
current scientific techniques but identify
and promote the development of new
techniques to support health risk
assessment. D
44
EPA JOURNAL
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Update
A review of recent major EPA activities and developments in the pollution control program areas.
AIR
Asbestos Emissions Standards
Final rules for amending
portions of the national
asbestos emissions standards
have been announced. The
rules reinstate some work
practice and equipment safety
provisions that were
invalidated by a 1978 U.S.
Supreme Court decision.
The new provisions 1)
reinstate work-practice
alternatives to the standards,
providing additional means of
compliance and greater
flexibility to the owners and
operators; 2) reinstate the
work-practice standards in
prohibiting the surfacing of
roadways with asbestos
tailings or asbestos-containing
waste materials; 3) reinstate
the prohibition of installation of
certain commercial asbestos;
4) reinstate a partial exemption
for demolition operations for
structurally unsound buildings;
and 5) reinstate the
requirements that asbestos
removed during demolition or
renovation be kept wet until it
is collected for disposal, and
that asbestos not be dropped
or thrown to the ground or a
lower floor.
Asbestos removed
more than 50 feet above
ground level must be
transported to the ground in
dust-tight chutes or containers
unless removed in units or
sections. Requirements for
warning signs and fencing
around asbestos waste
disposal sites are also
reinstated. The 1977
amendments to the Clean Air
Act gave EPA the authority to
establish work practice rules in
setting national emission
standards for hazardous air
pollutants, as called for by
the Act.
Methanol Standards
Considered
In response to the growing
interest of auto manufacturers
and others in using methanol
as an alternative fuel for
vehicles, EPA is inviting public
comment on an advance notice
of proposed rulemaking that
would eventually establish
methanol-fueled vehicle
emission standards,
certification test procedures,
and a fuel equivalency factor
for calculating fuel economy.
The Clean Air Act authorizes
EPA to adopt requirements for
all vehicles regardless of the
fuel type. Methanol-fueled
vehicles could become the
third major type of certified
vehicles subject to the same
pre-production and in-use
requirements as gasoline and
diesel vehicles are now.
Engines designed to operate
on methanol are more
fuel-efficient than similar
gasoline engines. Also, engines
using methanol have relatively
low emissions of both nitrogen
oxides and particulates.
Methanol vehicles are
expected to be similar in type,
size, and functional ability to
gasoline and diesel-fueled
autos. Therefore, the
certification and emission test
protocols could be applied to
methanol cars without
undertaking any major change.
Methanol vehicles are being
built in limited numbers by
major automobile companies
and other groups, agency
officials said. In addition, test
fleets are in operation in
California and several other
parts of the world.
Agency officials said these
programs are an indication of
the possibility that
methanol-fueled vehicles could
enter the marketplace in the
near future. However, before
they can be mass produced,
the methanol-fueled vehicles
would have to comply with
emission standards, test
procedures and fuel economy
requirements.
Sanctions in Nashville
EPA has banned new or
modified construction of major
pollution sources in the
Nashville, Tenn., area as a
result of the city's failure to
comply with the automotive
emissions' inspection and
maintenance requirements of
the Clean Air Act.
Under the Act, areas of the
country which could not meet
federal ozone and/or carbon
monoxide standards by 1982
were required to implement
the vehicle tailpipe emission
inspections. Nashville is
currently in violation of the
national ambient air quality
standard for carbon monoxide.
In its 1979 state
implementation plan (SIP),
Nashville originally committed
to the federal government to
have an inspection and
maintenance (I/M) program
operating by Dec. 31, 1981.
However, Nashville has not
moved forward to establish the
program, and just recently
failed to reach agreement on a
proposed contract to set up the
inspection program.
Nashville is one of only three
remaining areas in the country
which is not meeting its I/M
commitment. Michigan and
Illinois have not made
adequate progress in setting
up auto emission inspections.
Twenty-one states now have
inspection programs in
operation, with six expected to
start tailpipe testing this
summer, the agency said.
For any area not meeting its
commitments under its
implementation plan, the Clean
Air Act imposes a ban on
construction of stationary
pollution sources for the
pollutant involved, which in
this case is carbon monoxide.
The ban, which becomes
effective immediately, means
no permits will be allowed for
construction of major new or
modified sources in the
Nashville/ Davidson County
area that could contribute to
carbon monoxide pollution.
Major new and modified
stationary sources of carbon
monoxide could include
municipal incinerators,
foundries, certain major boilers
and other industrial processes.
A major source is one which
emits 100 tons or more of the
specific pollutant per year. The
construction ban will be lifted
when Nashville implements
the auto emissions inspection
program.
Nashville will also face a
cutoff of federal highway funds
for failing to submit an
acceptable revised plan in
1982. The process to institute
that cutoff is underway.
Unleaded Fuel Violation
Between Dec. 17, 1982 and
April 1, 1983, Capital City Oil
Co., a subsidiary of Mid States
Petroleum Co., delivered
leaded gasoline into unleaded
storage tanks at retail stations
owned or operated by Mid
States, an EPA investigation
disclosed. The stations
displayed the Mid States or
Union 76 trade names.
Now, under the terms of a
unique and innovative
settlement with Mid States, all
concerned purchasers may
return their vehicles to test for
defects, and up to 3,000 new
catalytic converters will be
replaced free of charge where
damages are confirmed.
Mid States also has agreed
to pay $100,000 in civil
penalties, adopt stringent
quality controls for the future,
and endow the University of
Michigan and Detroit College
of Law with donations
promoting research and
enforcement of the Clean Air
Act.
Mid States Petroleum Co.
will advertise and test
unleaded cars and trucks at
nine retail stations where the
violations occurred. All
qualified applicants will be
given the opportunity for free
catalyst replacements on a
first-come first-serve basis at
repair facilities in their area.
Mid States has agreed to
spend up to $35p,000 in
replacing catalytic converters
where evidence of lead is
detected within the exhaust
system of unleaded vehicles
which were contaminated
between Dec.16, 1982 and
April 1, 1983.
Use of leaded gasoline in
cars designed for unleaded fuel
can destroy a car's catalytic
converter and result in a 200 to
800 percent increase in tailpipe
emissions of hydrocarbons and
carbon monoxide.
Under the Clean Air Act's
unleaded fuels regulations,
EPA can assess civil penalties
up to $10,000 per violation
against gasoline retailers,
distributors, and refiners who
sell leaded fuel represented as
unleaded fuel.
SIP Revisions Approved
EPA has given final approval to
six states and proposed
approval to six states for
revisions to Clean Air Act State
Implementation Plans that will
allow total actual increases of
sulfur dioxide (S02) emissions.
The increases represent
approximately one-tenth of one
percent of the total annual
Eastern U.S. S02 emissions.
The agency is also issuing
final disapproval for some of
Kentucky's request for
increases because air quality
modeling indicates that the
proposed increases would
violate the Clean Air Act
standards.
The Clean Air Act requires
that the EPA Administrator
approve any request for a
revision of a State
Implementation Plan if the
emission increases meet a
number of criteria, including
attainment and maintenance of
the national ambient air quality
standards.
MAY 1984
45
-------
Update
Continued
Final approval has been
given for S02 increases for the
States of Massachusetts,
Mississippi, Kentucky, Virginia,
Indiana, and New Hampshire.
Proposed approvals are given
for increases in New Jersey,
Illinois, New Hampshire, Rhode
Island, Ohio, and New York. In
total, the revisions to the State
Implementation Plans
represent actual increases in
362 emissions of 16,000 tons
per year while allowable
emissions will increase by
approximately 123,000 tons per
year.
Allowable increases, as
opposed to actual increases,
reflect changes in the State
Implementation Plan emission
limits for specific sources to
match the reality of what the
source is currently emitting
(actual emissions). Many of the
allowable emissions limits
were originally established at
levels that are now determined
to have been more stringent
than necessary to meet the
ambient air quality standards.
None of the actual or allowable
increases approved by EPA will
result in violations of either the
primary (health-related) or
secondary (welfare-related)
standards.
ENFORCEMENT
EPA Wins Dow Access
A consent decree signed by
EPA and Dow Chemical
Company settles a lawsuit
involving EPA's authority to
obtain internal information
from Dow under the Clean
Water Act. The settlement
resolves a three-year dispute
over EPA's efforts to obtain
information on processes and
waste streams inside the Dow
complex.
The decree requires Dow to
provide any internal
information on production
processes, other operations, or
waste streams that EPA seeks
for purposes of drafting water
discharge permits; and to
grant EPA access to its
Midland facility to conduct
sampling and analytical studies
on any waste discharged from
any process or other
operations. In addition, Dow
must perform studies
requested by EPA to support
the drafting of the wastewater
discharge permit and ongoing
EPA investigations.
This settlement guarantees
the EPA broad access to any
information that Dow develops
concerning the presence,
sources, and control of dioxins
and furans at the Dow Midland
facility, including access to
review raw data from studies
that are not complete.
In combination with the
$48,450 settlement of a Toxic
Substances Control Act (TSCA)
penalty action on March 9,
1984, this settlement resolves
EPA's outstanding enforcement
suits against Dow's Midland,
Mich., facility. The TSCA case,
filed May 23, 1983, addresses
the disposal of tetrachloro
dibenzo-p-dioxin (TCDD)
contaminated waste through
the wastewater treatment plant
and in the incinerator at Dow's
Midland facility in 1980 and
1981 without giving EPA the
60-day notice required to
review and possibly
disapprove the proposed
disposal method.
$4 Million Settlement
EPA has agreed to a settlement
of contempt actions against
Jones & Laughlin Steel, Inc.
and its parent company, the
LTV Corporation, for Clean Air
Act violations at five
steelmaking plants in
Pennsylvania, Ohio, and
Indiana. The Pennsylvania
Department of Environmental
Resources and the County of
Allegheny are also parties to
the agreement.
The settlement agreements
establish new schedules for the
installation of pollution
controls and demonstration of
compliance with Clean Air Act
standards. They also require
Jones & Laughlin and LTV to
pay $4 million in penalties for
violating past decree
requirements, and undertake
projects that will yield
environmental benefits beyond
what is currently required by
federal and state law.
One of the most significant
projects obligates Jones &
Laughlin to share with the
American steel industry, free of
charge, the company's
technology for the control of
paniculate emissions from
blast furnaces.
The agreements are in
settlement of three separate
contempt actions initiated by
EPA against Jones & Laughlin
and LTV in January 1983 for
violations of earlier air
pollution abatement
agreements. The violations
involved failure to install
pollution controls and to
demonstrate compliance with
particulate matter and sulfur
oxide emission limitations at
the company's plants in
Pennsylvania, Ohio, and
Indiana.
According to the terms of
the agreement, the $4 million
penalty will be split among the
U.S. Treasury ($3 million) the
Commonwealth of
Pennsylvania ($500,000), and
Allegheny County,
Pennsylvania ($500,000).
Civil Penalty Policy
A new general civil penalty
policy should improve EPA's
ability to take a more
consistent approach in
pursuing civil penalties for
violations of the nation's
various pollution laws. The
new policy calls for EPA to
seek penalties that are at least
as large as the profit a
company may have realized by
violating the law. And the
amount of the penalty should
take into account the
environmental risk posed by
the violation, the violator's
efforts to correct it, the degree
to which the violator tried to
avoid compliance, the
violator's history of
noncompliance and the
company's ability to pay a fine.
The new agency-wide policy
consists of two documents,
both of which provide
guidance to EPA's program
offices on how to develop their
own specific policies. The first,
"Policy on Civil Penalties,"
gives them an overall EPA
enforcement policy, and the
second document provides a
set of guidelines for
developing their own policy,
called "A Framework for
Statute-Specific Approaches to
Penalty Assessments."
EPA's new penalty
guidelines will become
effective once the program
offices finish developing
statute-specific guidelines
based on the general policy.
HAZARDOUS WASTE
Remedial Cleanup Manual
Options are newly available to
states for expediting remedial
cleanups under Superfund at
uncontrolled hazardous waste
sites. Described in an EPA
manual, "State Participation in
the Superfund Remedial
Program," the options include:
• Multi-site EPA/State
cooperative agreements to
fund remedial planning
activities at more than one site
within a state;
• Management assistance
cooperative agreements to
cover costs states may incur
during EPA-managed remedial
activities;
• Extension, from six months
to one year, of the maximum
period during which EPA will
share with a state the
operation and maintenance
costs at a remedial site.
Copies of the manual can be
purchased from the U.S.
Government Printing Office or
the National Technical
Information Service.
Uniform Manifest Rule
A manifest form requiring all
transporters to provide uniform
information on all shipments of
hazardous wastes in the United
States —whether by highway,
rail, air, or water—is being
promulgated as a new rule by
EPA and the U.S. Department
of Transportation.
The new regulation will
require consistent information
on the wastes being shipped,
and will improve the tracking
of shipments from the
originators of wastes to a
designated waste-handling
facility. EPA and DOT worked
with state, industry, and
environmental representatives
to develop the new form.
EPA regulations under the
Resource Conservation and
Recovery Act require
generators to prepare a
manifest to accompany all
regulated shipments from the
producer to the final treatment,
storage, or disposal facility.
When the shipment is
delivered, a signed copy of the
completed form is returned to
the originator. If a waste
generator does not receive a
completed manifest from the
designated hazardous waste
facility within 45 days, the
generator must report the
missing shipment or manifest.
EPA JOURNAL
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PESTICIDES
Dicofoi Review
EPA is initiating a special
review of the pesticide dicofol
after determining that its
continued us.e may cause
unreasonable risks to wildlife
populations, particularly
aquatic birds.
The review was triggered by
data that show dicofol is
contaminated by DDT and
chemically-related compounds
such as DDD, DDE and CI-DDT.
DDT, a once widely used
insecticide, was banned in
1972 by EPA after it was
shown to cause severe
reductions in the reproductive
levels of various fish and fish
eating birds. Dicofol is used on
agricultural crops and
ornamental shrubs.
The nine to 15 percent DDT
levels found in technical
dicofol products are estimated
by EPA to result in
accumulated levels of about
nine garts per million DDT in
the bodies of fish. This level is
greater than that known to
affect reproduction by causing
eggshell thinning in certain
species of fish-eating aquatic
birds. DDT is also known to be
persistent, highly toxic to
aquatic organisms, and to
bioaccumulate through food
chains.
EPA's review will weigh the
benefits of dicofol to industry,
growers, and society against
the risk of continued use as
required by the statute. At the
conclusion of the review, the
agency will decide either (1) to
allow use to continue with
certain restrictions and
possibly ban some uses, or (2)
to ban all uses.
New Pesticides Committee
EPA Administrator William D.
Ruckelshaus has established a
special pesticide advisory
committee to assist the agency
in addressing legislative and
administrative issues critical to
regulating pesticides.
Called the Administrator's
Pesticide Advisory Committee
(APAC), the proposed group
will be made up of 16
members appointed to serve
from one to three years. One
of the first tasks of the
committee will be to examine
recommendations to amend
the Federal Insecticide,
Fungicide and Rodenticide Act.
Dr. John A. Moore,
Assistant Administrator of
Pesticides and Toxic
Substances, has been
designated to oversee the
committee which is expected
to complete its work within
three years. All meetings will
be public.
TOXICS
Asbestos Penalties
The Diocese of Pittsburgh and
Southwestern City Schools,
Grove City, Ohio have been
assessed penalties of $23,200
and $36,000 respectively for
violations of EPA's school
asbestos rule.
EPA's first civil complaint
under the rule, announced
March 12, was against three
schools in Goffstown, New
Hampshire, and totalled
$24,000; the second complaint,
totalling $12,000, was issued
March 15 against two schools
in the Philadelphia system.
EPA has also filed complaints
against school systems in
Cheyenne, Wyo. and Lebanon,
Ohio.
Under EPA's school asbestos
rules, issued May 27, 1982, all
public and private elementary
and secondary school
administrators were required,
by June 28, 1983, to have
inspected their buildings,
sampled and analyzed any
friable materials for asbestos,
notified employees and parents
of any asbestos detected, and
maintained records certifying
compliance with the regulation.
Scientific evidence points to
asbestos as a cause of lung
cancer and of mesothelioma, a
cancer of the membranes that
line the chest and abdomen.
The administrative fines
against these school systems
may be reduced or remitted if
the schools promptly take
action to comply with the rule.
The Pittsburgh and Grove
City schools have 20 days after
receipt of the penalty notice to
request a public hearing.
WATER
Coordinating Permits, Lease
Sales
A Memorandum of
Understanding between EPA
and the Department of the
Interior outlines coordination
of environmental permits with
oil and gas lease activities on
the Outer Continental Shelf.
The agreement provides for
the two agencies to coordinate
studies and related regulatory
responsibilities to ensure that
EPA can issue the permits at
the time Interior publishes a
final notice that it is offering
such leases.
The memorandum provides
for early participation by EPA
in Interior's environmental
studies program and
environmental impact
statements, as well as giving
EPA a mechanism for using
information from Interior in
issuing the National Pollutant
Discharge Elimination System
(NPDES) permits.
It also assures that whenever
possible, these permits will be
issued at the time Interior
issues its final notice of lease
sales, which will help prevent
delays on offshore drilling
operations by providing
industry with early notice of
permit conditions.
NPDES permits are required
under Section 402 (a) of the
Clean Water Act to regulate the
discharge of pollutants from
point sources such as oil and
§as wells drilled offshore.
efore issuing such permits,
EPA in consultation with
Interior seeks to identify any
potentially productive or
unique biological areas in the
ocean that may be sensitive to
discharges of pollutants from
such drilling operations. An
NPDES permit in these areas
may contain effluent
limitations to prevent the
degradation of such waters.
The memorandum spells out
terms under which EPA may
issue general NPDES permits
which may apply to entire
tracts or planning areas in
offshore lease offerings as well
as individual permits. The
timing of public hearings for
draft permits will be '
coordinated with hearings for
draft environmental impact
statements, to assure full
public participation in the
process.
In addition, the
memorandum described
procedures under which EPA
will share information with
Interior on criteria involving the
environmental vulnerability of
lease areas, which may be
used to suggest appropriate
permit conditions. New source
performance standards by EPA
for such drilling will be
coordinated with existing
Interior procedures for
environmental impact
statements.
Office of Ground Water
Protection
An Office of Ground Water
Protection has been created to
administer EPA's overall
strategy in this area.
Marian Mlay was named as
the Director of the new office.
She has been Deputy Director
of the Office of Drinking Water
since 1979.
The Office of Ground Water
Protection, which is part of
EPA's Office of Water, will
coordinate all EPA
ground-water activities,
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
requests for this program.
EPA Administrator William
Ruckelshaus said, "We have
taken this action to deal with
what EPA views as one of the
major environmental problems
confronting the nation in the
1980s—the contamination of
our ground water. We are
fortunate to have a manager of
Marian Mlay's experience and
knowledge to head this new
organization, which will
enhance EPA's institutional
capability to protect this critical
resource."
The new office is the focal
point of efforts that are carried
out by a number of EPA
programs. Ruckelshaus said
that an office to coordinate
policy development activities
was of paramount importance
because regulations and
programs affecting ground
water come under the various
laws EPA administers. They
include the Resource
Conservation and Recovery
Act, Superfund, the Safe
Drinking Water Act, the Clean
Water Act, the Federal
Insecticide, Fungicide and
Rodenticide Act, and the Toxic
Substances Control Act. D
MAY 1984
47
-------
Ruckelshaus Reviews Year at EPA
In a recent speech to the National
Wildlife Federation EPA Administrator
William Ruckelshaus reported on
progress made in the first year of his
second term as Administrator. Here are
excerpts from his remarks:
A stream in the mountains of North Carolina.
48
"r PA has survived a difficult period of
L-uncertainty and I think it's fair to say
is now on the right track again. At the
risk of sounding self serving, I believe that
during the last ten months the agency
has regained its morale — and we are
doing what the law says we should be
doing.
"This recovery of a sense of direction
at EPA may have been inevitable,
considering that the American people
have expressed their commitment to the
protection of public health and the
environment in a broad array of
legislation and citizen action over the
past two decades. They value their
environment deeply. That's why public
support for the values EPA was created
to protect has been so strong and
persistent.
"Shortly after returning to EPA, I was
given a report card by the Izaac Walton
League. It was really more like a list of
required courses with some pointed
suggestions for fast action. The League
was deeply concerned about the size and
general thrust of EPA's budget, water
quality issues, control of toxics, the
clean-up of hazardous waste and our acid
rain policy.
"Those were the very issues we at EPA
were concerned about and I told the
League that they would receive our
immediate attention. They have. We have
followed through and we have done well,
almost certainly better than realists
thought was possible in so brief a time.
"First, the budget. With the President's
support I asked the Congress to provide
additional funding for Fiscal Year 1984,
and as a result, our operating budget has
risen 27 percent overall since last
May—47 percent if you include the
Superfund. Growth of the Superfund
between May 1983 and Fiscal Year 1985
will exceed 100 percent—up from $310
million to $640 million. In an era of huge
deficits and great pressure on domestic
spending this isn't bad in 10 months.
"Many have called for larger increases.
But expanding a government agency
rapidly is not easy and it can't be done in
an instant. Pouring in too much money
may not speed things up and it can be
terribly wasteful. Instead, we have
planned a deliberate, rational expansion
in high-priority areas where the need for
action is greatest.
"To make sure our new funds were
invested wisely I recruited the best
EPA JOURNAL
-------
people I could find to manage EPA
programs. Literally thousands of people
volunteered last spring, including many
from my first tour of duty, who had
proven themselves under fire and who
were willing to sacrifice their personal
interests to help their country.
"Based on my recommendations, the
President appointed 13 new top staff
people with a total of 180 years of
experience in governmental
management, 32 of them at EPA. They
were confirmed by the Senate without a
single dissenting vote and are now
serving with distinction.
"I
In FY 1985 we are requesting 750
additional work years above the 1984
level, 350 of which will be allocated to an
intensified Superfund effort. During the
first five months of FY 1984 we have
hired 900 people, probably the fastest
intake of staff in the agency's history,
and I expect the pace will continue at a
rate of at least 100 people per month
throughout Fiscal 1984.
"Second, water quality. We reversed a
previous EPA decision to downgrade
water quality regulations. We have
issued new rules that will make it easier
for the states and the federal
government, working together, to fulfill
the intent of the Clean Water Act. We
have set an effective process for altering
standards where necessary, and tough
anti-degradation requirements have been
retained. We have task forces hard at
work examining a number of urgent
water related issues, such as nonpoint
source pollution, waste treatment plant
construction grants, ground-water
management, pollution monitoring and
clean-up of toxic waste dumps.
"Third, control of toxics. We have
taken action to phase out EDB, develop a
strategy for control of dioxin, regulate
benzene, address the threat of PCBs, and
initiate rulemaking on asbestos in
schools, to cite only a few.
"EDB perfectly illustrates our more
aggressive attitude these days. Nobody
had done much about EDB for ten years,
despite mounting evidence of hazard,
until the new EPA took action to get this
unacceptably risky compound out of the
food chain.
"Fourth, hazardous waste. We will
continue to stabilize imminent threats at
uncontrolled hazardous waste sites
through Superfund removal actions. In
Fiscal Years 1984 and 85 we shall
complete 300 emergency clean-ups. We
have placed 546 of the most dangerous
locations on our National Priorities List
for early action because they pose the
greatest risk of air, ground-water and
surface water contamination.
"Clean-up is moving much faster now
that we've dropped our requirement that
the states pay 10 percent of the upfront
costs of planning. We've delegated more
authority to the EPA regions and adopted
a philosophy of clean-up first — we can
decide later who pays for it.
"We intend to use the Superfund
remedial program to complete long-term,
complex site cleanups. We have
identified more than 17,000 hazardous
waste sites in this country already and
we estimate the total may go as high as
22,000. We are working virtually around
the clock with the states to complete our
site survey, rank the sites by degree of
hazard and study long-term effects on
public health.
"\A/
V we will move vigorously to reduce
the number of violations by major waste
handlers.
"Fifth, acid rain. This has been my
biggest disappointment. I've been trying
to forge a consensus on this complex
problem but none has emerged as yet
from the whirlwind of conflicting opinion
and diverse interests. I'm determined to
continue to work to find a formula that
will permit us to address this problem
effectively.
"We have boosted our acid rain
research budget from $15.4 million to
$34.4 million in one year. The federal
interagency acid rain effort will double to
$55.5 million for research to support a
national survey of some 2,000-3,000
lakes, plus periodic monitoring of several
hundred lakes to establish baselines,
determine actual damage and lay a
foundation for appropriate action. And
we are planning additional studies to
determine whether acid rain has caused
damage or changes in rate of growth and
species composition in forests.
"We are working with our state agency
counterparts to be ready to put a control
program in place when Congress and the
Administration can agree on the need
and structure for it.
"No one can deny we have a problem.
We're doing the necessary fact-finding
and research to sharpen its outlines and
ensure that if controls are imposed they
can be as effective as possible. I can
assure you that the door has not been
closed on a control program.
"Despite the public demand for action
it is more difficult to pass environmental
legislation today than a decade ago. For
one thing, the opposing sides seem to be
farther apart. And the positions of the
major players are not likely to soften
during this election year. So it won't be
easy to make major breakthroughs on
our legislative agenda in 1984.
"In any event, the current concern
about acid rain should not obscure the
very real progress in cleaning the air that
is being made. At the end of a recent
five-year period pollutants in all six
categories controlled by the Clean Air Act
were trending down. To cite just one
dramatic example, if the clean air
legislation had never become law, sulfur
dioxide emissions would have reached
40 million tons nationwide by 1980
instead of 27 million.
* * * * *
"Ours is probably the on!-y age that has
ever cared about the environment as an
entity or ever had even modest resources
to do something about it. In a little over
two decades we have evolved from blithe
indifference to irrevocable commitment,
and I have no doubt that by the turn of
the century this country will be safer and
less defiled than it is now — even if we
do no more than enforce existing laws.
"My optimism springs from a realistic
assessment of where we were in
comparison with where we are.
"Elsewhere in the world things are not
so good. Indeed, the real challenge
during the 80s and 90s may be to export
environmental consciousness. You
launched your magazine Internationa/
Wildlife in 1971 in recognition that the
earth constitutes but one ecosystem.
Now that perspective is more vital than
ever.
"We are on the move, and I believe
with ever more resolute conviction that
nothing, save deliberate self-destruction,
can stop mankind from creating a higher
form of planetary civilization." D
(Copies of the full text of this speech by
Administrator Ruckelshaus to the National
Wildlife Federation in Atlanta, GA. on March
17, 1984, can be obtained by writing to the
EPA Journal.)
MAY 1984
49
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Appointments at EPA
Eight persons have been named to EPA
posts by Administrator William
Ruckelshaus. The appointments include
Director of the Office of Health Research,
Director of the Environmental Monitoring
and Support Laboratory in Cincinnati,
Director of Program Management and
Operations in the Office of Water,
Director of the Office of Policy Analysis,
and Director of Integrated Environmental
Management. Other positions are Chief
of EPA's Regulatory Reform Staff,
Associate Enforcement Counsel for Air,
and Associate General Counsel for Water.
Filling the position of Director of the
Office of Health Research is Dr. Robert L.
Dixon. For the past 12 years, he has been
with the National Institute of
Environmental Health Sciences, first as
chief of the Laboratory of Environmental
Toxicology and then as chief of the
Laboratory of Reproductive and
Developmental Toxicology.
Along with his duties as laboratory
chief, Dr. Dixon was assistant to the
director of the Institute's international
program from 1978 to 1981. From 1978
to 1979, he served on detail to the Office
of Science and Technology at the White
House as a senior policy analyst.
At the National Cancer Institute from
1969 to 1972, Dr. Dixon was chief of the
Laboratory of Toxicology in the
chemotherapy program. From 1965 to
1969, he was assistant/associate
professor in the Department of
Pharmacology, School of Medicine,
University of Washington. Previously he
was a senior investigator at the
Laboratory of Chemical Pharmacology at
the National Cancer Institute.
Dr. Dixon received a B.S. degree from
Idaho State University in 1958, an M.S. in
pharmacology from the University of
Iowa in 1961, and a Ph.D. in
pharmacology toxicology from the
University of Iowa in 1963.
Among his honors are the Society of
Toxicology Achievement Award in 1962
and the National Institute of Health
Dr. Robert L Dixon
Hobert L Booth
George Marienthal
Director's Award in 1977. He has been a
member of 18 scientific societies,
published more than 60 scientific papers,
participated in more than 25 advisory
committees and study groups and was
President of the Society of Toxicology
from 1981 to 1982. A native of California,
he is married, with three children.
Filling the position of Director of EPA's
Environmental Monitoring and Support
Laboratory in Cincinnati is Robert L.
Booth, who has been acting director of
the laboratory since 1980. In other
positions at the laboratory, Booth was
Deputy Director from 1976 to 1980 and
technical coordinator from 1974 to 1976.
In earlier work at federal water quality
laboratory facilities in Cincinnati, he was
first a chemist, later a research chemist
and then a supervisory research chemist,
from 1966 to 1974.
From 1955 to 1966, Booth was
associated with the U.S. Public Health
Service's Robert A. Taft Sanitary
Engineering Center in Cincinnati, doing
water quality research, undergoing
graduate training from 1959 to 1962, and
helping set up and supervise the
International Joint Commission's field
laboratory. From 1954 to 1955, Booth
was technical director for the Western
Paper Co. in Terre Haute, Ind.
He received an A.B. degree from
Indiana State University in 1954, an M.S.
from the University of Illinois in 1961,
and did doctorate work at the University
of Illinois. His honors include listing in
Who's Who in American Colleges and
cash awards as a federal employee.
Booth has published about 25 papers
related to environmental measurements
and quality assurance, served a
three-year term on the board of the
American Society of Testing and
Materials, and represented EPA on the
Joint Editorial Board of Standard
Methods, the "bible" of the water and
waste management field.
Born in Terre Haute, Ind., Booth is
married and has one child.
Named to the post of Director of
Program Management and Operations in
the Office of Water is George Marienthal,
a former EPA official. His most recent
position, from 1981 until he rejoined EPA,
was Vice President of Survival
Technology, Inc., in Bethesda, Md.,
where he was responsible for the overall
management of the firm's
pharmaceutical business.
From 1975 to 1981, Marienthal was at
the Department of Defense, where he
was Deputy Assistant Secretary for
Energy, Environment, and Safety,
managing total Defense Department
programs in these areas.
Marienthal was previously with the
EPA from 1971 to 1975, serving as
director of the Office of Regional Liaison
and Director of the Office of Federal
Activities.
From 1967 to 1971, he was Senior
Research Associate for Logistics
Management Institute in Washington,
D.C., working as a management
consultant for the Office of the Secretary
of Defense and the National Aeronautics
and Space Administration.From 1966 to
1967, Marienthal was a development
engineer for the Air Force Contract
Management Division in Los Angeles and
from 1963 to 1966, he was chief of the
Policies and Procedures Branch and
Production and Procurement Officer for
the Air Force Plant Representative,
Lockheed Missiles and Space Company,
Sunnyvale, Calif.
Marienthal received the EPA Bronze
Medal in 1974, the Defense Civilian
Distinguished Service Award in 1981, the
National Defense Medal, outstanding
performance ratings from 1978 to 1981 at
the Defense Department, a Senior
Executive Service Bonus Award in 1980,
and is listed in Who's Who in America.
He graduated with a B.S. from the U.S.
Naval Academy in 1962, an M.S. from
Stanford University in 1963 and an
M.B.A. from American University in 1974.
Marienthal's other activities include
50
EPA JOURNAL
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Richard D. Morgenstern
long distance running, membership in
the Institute of Industrial Engineers,
ADPA Chemical Systems Steering
Committee, and Association of Chemical
Officers. He is married and has three
grown children.
Named to the position of Director of
the Office of Policy Analysis is Richard D.
Morgenstern. From mid-1982,
Morgenstern has been Director of the
Office-on a special assignment from the
Urban Institute under the
Intergovernmental Personnel Act.
Morgenstern was Director of the Urban
Institute's Energy Program from 1980 to
1982. He was Senior Legislative Assistant
to U.S. Senator J. Bennett Johnston from
1979 to 1980, and Deputy Assistant
Director for Energy, Natural Resources
and the Environment at the
Congressional Budget Office from 1976
to 1979.
From 1971 to 1976, Morgenstern was a
tenured Associate Professor of
Economics at Queens College of the City
University of New York. Prior to that he
taught for a year at American University
in Washington, D.C.
He received an A.B. degree from
Oberlin College in 1966 and a Ph.D. from
the University of Michigan in 1970. He
graduated with high honors at Oberlin,
received the Starr scholarship prize, and
was awarded graduate fellowships under
programs of the National Science
Foundation and the National Defense
Education Act.
Born in Brooklyn, he is married to Dr.
Devra Davis. They have two children.
Appointed to the position of Director of
Integrated Environmental Management is
Dan Beardsley, who has held several
different posts at EPA since 1980. He was
responsible for overall management of
the Integrated Environmental
Management Division, staff director of
the Intra-Agency Toxics Integration Task
Force, and responsible for management
of the Interagency Risk Management
Council, reporting to the Administrator of
EPA.
Michael Levin
Michael S. Alushin
Colburn Cherney
Previously, Beardsley was Special
Assistant to the Director of the federal
agency ACTION from 1979 to 1980. He
was a project director at the National
League of Cities from 1978 to 1979. He
served as a program manager at the
National Assn. of State Drug Program
Directors from 1977 to 1978, served as a
deputy project director for A.J. Nellum &
Associates in Atlanta from 1976 to 1977,
and served as a project director from
1975 to 1976 for Atlanta Mayor Maynard
Jackson.
In earlier positions, Beardsiey was a
planner for the City of Atlanta in 1975, an
administrator and program director with
the State of Georgia from 1972 to 1975
and a minister and university chaplain in
Gainesville, Fla., from 1968 to 1971.
He received a B.A. from Kalamazoo
College in Kalamazoo, Mich., in 1966 and
an M.Div. from Yale University in 1972.
Born in Detroit, he is married and has
two children.
Named as Chief of EPA's Regulatory
Reform Staff is Michael Levin, who for
the past four years has been serving in
this capacity under several interim
assignments.
From 1977 to 1979, Levin served as
Deputy Director of a Presidential task
force on regulatory reform and as
legislative aide on regulatory matters to
several Congressmen and the Senate
Judiciary Committee.
From 1972 to 1977, Levin was Counsel
for Appellate Litigation, U.S.Department
of Labor, responsible for litigation of all
court cases under the Occupational
Safety and Health Act (OSHA).
Levin graduated from the University of
Pennsylvania with a B.A. in 1964, from
Harvard Law School with a J.D. in 1969,
and from Oxford with a B.Litt. in 1970. He
received EPA's Gold Medal in 1982.
Born in Philadelphia, Levin is married
and has two children.
Named as Associate Enforcement
Counsel for Air was Michael S. Alushin.
Since 1982 he has been acting in the
position, which manages Clean Air Act
enforcement litigation in the Office of
Enforcement and Compliance Monitoring.
During 1981 to 1982, he held various
positions in the former Office of
Enforcement Counsel, including acting
Deputy Enforcement Counsel, Director of
Special Programs staff, and
attorney advisor. In other service at EPA,
Alushin was a Senior Environmental
Fellow in the Office of Planning and
Management from 1980 to 1981.
Alushin was Director of the Bureau of
Regulatory Counsel in the Pennsylvania
Department of Environmental Resources
from 1978 to 1980 and was an assistant
attorney general handling environmental
enforcement cases in the Bureau from
1972 to 1980. His other work included
serving as a law clerk in a New York law
firm and a management intern with the
Defense Contracts Administration Service
in Cleveland.
Alushin received a B.A. degree magna
cum laude from Oberlin College in 1969
and a J.D. degree from Harvard Law
School in 1972. His honors include Phi
Beta Kappa, an EPA Special Achievement
Award and an EPA outstanding
performance rating, both in 1982. He is
married and was born in Cleveland.
Filling the position of Associate
General Counsel for Water in the Office
of Genera! Counsel is Colburn Cherney.
He has been acting in the position since
last year. From 1981 to 1983 he was
Assistant General Counsel in the Office of
General Counsel and from 1974 to 1981
he was a general attorney in the Office.
Cherney received a B.A. degree from
the University of Wisconsin in 1970 and a
J.D. from the University of Wisconsin
Law School in 1974 graduating with
honors. He received an EPA Silver Medal
in 1980 and EPA performance awards in
1980 and 1982. He was born in Green
Bay, Wise., and is married.
MAY 1984
51
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Environmental Almanac
Destiny on a Beach
On a moonlit night soon a female
horseshoe crab will be pulling herself
out of the ocean and onto a sandy beach
to lay her eggs as members of her
species have been doing for millions of
years.
Many of the tiny eggs buried annually
by this crab and thousands of her fellow
creatures on the sands of Cape May,
N.J., will provide vitally needed food for
shore birds, including a remarkable
long distance flyer, the Red Knot.
The Knot, a bird only a little larger than
a robin, will be winging in from
Argentina on its way to nesting grounds
in Canada. These shore birds fly
thousands of feet high and make few
stops on their way north.
Their need for food is critical when
they descend on such migration resting
places as Cape May. Despite the fact that
Knots and other shore birds have long
been feeding on these eggs, the
horsehoe crab continues to be one of the
most successful survivors in the world.
Called living fossils, these so-called
crabs are descendants of creatures who
lived more than 200 million years ago.
Unprepossessing animals, which are
actually marine arthopods and not crabs
at all, they acquired their common name
because their shells resemble the shape
of a horse shoe. They are well adapted to
the soft mud or sand where they live in
shallow seas.
An important key to their survival is
that the females lay so many eggs that
there have always been many left over to
continue the species, no matter how
ravenous the appetites of shore birds and
other predators.
When the female crab arrives on shore
she is accompanied by smaller male
crabs who cluster around or cling to her
and promptly fertilize her eggs.
The success of the egg laying can help
determine not only the size of the future
horseshoe crab population but also how
many Red Knots will be hatched in Arctic
Canada.
The emergence of the crabs from the
sea to lay their eggs is determined by
water temperature and the timing of high
tides pulled by the moon's gravity.
These factors must mesh with the
arrival of these shore birds from South
America, often despite driving rain and
violent wind storms.
Peter Dunne, Director of the famed
Cape May Bird Observatory, reports that
this institution is preparing a major
long-term research project to study the
links between shorebirds and horseshoe
crabs at Cape May. Preliminary aerial
surveys of shorebird concentrations have
indicated that the population, which
sometimes mounts to hundreds of
thousands, can fluctuate widely,
depending presumably, at least in part,
on the timing and quantity of horseshoe
crab eggs.
Last year when horseshoe crabs
delayed laying their eggs at Cape May
until the end of May and early June
because of cool water temperatures, the
population count for Red Knots alone
dropped from more than 100,000 in 1981
to about 33,000, according to the Cape
May Bird Observatory records.
After their feeding stop at Cape May,
the Red Knots resume their long annual
migration. In Northern Canada they fly
over tundra country in the Arctic Circle.
In breeding season they sing a
melodious but plaintive song which
sounds like "Poor Me," according to
Peter Matthiessen, a noted writer about
shore birds.
For many years ornithologists had
searched unsuccessfully for the nests of
the Red Knot. Finally a few nests were
found by Admiral Robert E. Peary on
Canada's Ellesmere Island while he was
journeying homeward after discovering
the North Pole in 1909.
But why do we really care about the
horseshoe crab or the Red Knot? Aren't
there many other more pressing matters
in the world? An answer to questions like
these was once given by J. Henri Fabre,
the noted French entomologist and
writer:
"Is it not childish to inquire so
minutely into an insect's actions? Too
many interests of a graver kind hold us
in their grasp to leave leisure for these
amusements. That is how the harsh
experience of age impels us to speak;
that is how I should conclude...if I did not
perceive, amid the chaos of my
observations, a few gleams of light
touching the loftiest problems which we
are privileged to discuss... What is life?
Will it ever be possible for us to trace its
sources? What is human intelligence?
What is instinct?... These questions are
and always will be the despair of every
cultivated mind, even though the insanity
of our efforts to solve them urges us to
cast them into the limbo of the
unknowable. " —C. D. P.
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EPA JOURNAL
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Karen Ekstron, a geologist,
using a portable electromagnetic
induction device to test for
toxics in the environment.
Ms. Ekstron is with the
Environmental Monitoring Systems
Laboratory in Las Vegas.
Back Cover: Patricia Blau,
a chemist at the Research
Triangle Institute, wears a vest
containing personal air quality
monitoring equipment used in
an EPA research project, as she
works with scientific equipment
in her laboratory at the
Institute. (See story on P. 7)
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Environmental Protection
Agency
Washington DC 20460
Official Business
Penalty for Private Use
$300
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