r/EPA JOURNAL
Toward a Conserving Society
-------
Apri] 22, 1970: Thousands of people gather on the grounds of (he Washington Monument
in Washington, D.C., to demonstrate their support for Earth Day.
Toward a
Conserving
Society
Earth Day 1970 marked an
environmental awakening in
America. This issue of the
EPA /ounuil explores the
impact of that awakening on
our society.
Leading off the issue, EPA
Administrator Lee M.
Thomas examines the results
of the dramatic increase in
national environmental
concern. Another article
reviews public attitudes on
environmental problems as
revealed in opinion polls
year by year.
An article describes
the revolution that has taken
place in the design of the
automobile as a consequence
of environmental and energy
concerns. Another piece
reports on the striking
changes that one large
electric utility has
implemented as a result of
environmental regulations.
The impact of Earth Day on
consumer packaging is
reviewed. Developments in
industry recycling—another
focus of Earth Day—are
described. Integrated Pest
Management—a goal of early
environmentalists—is also
discussed.
A final article related to
the issue's theme looks
beyond the changes to date
and asks what needs to be
done to ensure environmental
progress in the future.
Feature stories in this issue
of the magazine include an
article describing what was
done to ensure a safe restart
of production of methyl
isocyanate at Union Carbide's
plant in Institute, W. Va.
Production had been halted
after the Bhopal, India,
disaster. This is the last of a
10-part series in the Journal
by EPA regional offices.
Another article reports on
activity by the chemical
industry aimed at making
better preparations to deal
with emergencies.
A feature describes an
unusual Superfund
site—caves under Bowling
Green, Ky. Another article
describes a clean water
success story at Tillamook
Bay, Ore. And an article
reports on the pollution that
has been appearing in the
Arctic skies, pristine no
longer.
This issue of the Journal
concludes with two regular
features—Update and
Appointments. Q
-------
United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 11
Number 6
July/August 1985
oEPA JOURNAL
EPA is charged by Congress to pro-
tect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and im-
plement actions which lead to a
compatible balance between hu-
man activities and the ability of
natural systems to support and
nurture life.
The FPA Journal is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the publica-
tion of this periodical is necessary
in the transaction of the public
business required by law of this
agency. Use of funds for printing
this periodical has been approved
by the Director of the Office of
Management and Budget. Views
expressed l>y authors do not neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107).
Waterside Mall, 401 M St., S.W.,
Washington, D.C. 20460. No per-
mission necessary to reproduce
contents except copyrighted photos
and other materials.
Lee M. Thomas, Administrator
Richard E. Sanderson, Acting Assistant Administrator for External Affairs
Paul A. Schuette, Acting Director, Office of Public Affairs
John Heritage, Editor
Susan Tejada, Associate Editor
Jack Lewis, Assistant Editor
Margherita Pryor, Contributing Editor
A New Sense of
Environmental
Responsibility
by Lee M. Thomas
Revolution
in Auto Design
by Karl Hellman 3
Ohio Utility Takes a
Giant Environmental Step
by Jack Lewis 5
Discarding the
Litter Habit
by Judy Roumpf M
Strong Incentives
for Industrial Recycling
by Steffen W. Plehn
and Donald Huisingh 10
Pest Management:
Pursuing an
Environmental Dream
by William Jordan
Public Opinion:
Behind the Transformation
by Riley E. Dunlap 15
Looking Ahead
by Clifford Russell
and Paul Portney If!
Union Carbide's Plant
at Institute, W. Va.:
Lessons from Bhopal
by Michael J. Chern 2\
Soul Searching in
the Chemical Industry
by Geraldine Cox 24
EPA Goes Underground at
Kentucky Superfund Site
by Susan Tejada -t>
Helping the Oysters Get
Along with the Cows
bv Bob [acobson -H
Pollution Over
the Arctic
by Glenn E. Shaw
Update .id
Appointments
at EPA :<2
Froni cover: Re/lections bv a
wcilerfnlJ. Pholo by Kverelt C.
Johnson. Fo/fo. Inc.
Design Credits:
Robert Flanagan;
Ron Far rah.
The annual rate for subscribers
in the U.S. for tbe EPA Journal is
$20.00. The charge to subscribers
in foreign countries is $25.00 a
year. The price of a single copy of
the EPA /ournd is $2.00 in this
country and $2.50 if sent to a for-
eign country. Prices include mail
costs. Subscriptions to the EPA
JounicJ as well as to other Federal
Government magazines are hand-
led only by the U.S. Government
Printing Office. Anyone wishing to
subscribe to the EPA /ourmil
should fill in the form at right and
enclose a check or money order
payable to the Superintendent of
Documents. The requests should
be mailed to: Superintendent of
Documents, GPO, Washington,
D.C. 20402.
EPA Journal Subscriptions
Name - First, Last
PLEASE PRINT
Company Name or Additional Address Line
Street Address
City
Zip Code
I I Payment enclosed (Make checks payable to Superintendent of Documents)
I I Charge to my Deposit Account No
-------
A New
Sense of
Environmental
Responsibility
by Lee M. Thomas
Tin1 American public's environment is
!>v no means yet restored In ,in
acceptable condition. Reversing the
damage inflicted by a century of
economic growth is not an overnight
proposition. 1 lowever, recent progress in
controlling air pollution and protecting
water resources demonstrates thai we
are on the right track.
Indeed, for anyone with a sense of
history, the recent shift in attitude
toward the natural world dating, let us
say. from Earth Day 1070. is
extraordinary in its breadth, depth and
intensity. A new sense of responsibility
for our environment is evident
everywhere.
Developments in environmental
technology are also encouraging. The
internal combustion engine is becoming
more efficient and that means not only
fewer harmful exhaust emissions but
more miles per gallon as well. Industry'
uses 40 percent less energy to produce a
given dollar of gross national product
than it did 15 years ago and that
lowers extraction-driven damage to
"I think i: cl lluif
nothir: • do in our
environment is ivitJ
thing
truly is connected ;
. tis.
ambient air and water. Recycling of
materials we used to throw away can be
expected to accelerate as business and
municipal governments recognize that
trash is really "urban ore," a storehouse
of cheap raw materials and recoverable
energy. Cogeneration of power and
steam appeals to more and more
managers, and alternative sources of
sustainable energy such as geothermal,
wind, marithermal, and low-head
hydropower are often realistic options
as we gain engineering and market
experience.
In addition, we are more acutely
aware today of the necessity of
continuous management of toxic
substances and hazardous wastes.
Indeed, here stands the greatest
challenge to our ability to ensure a
clean environment, for toxics are
all-pervasive. Fortunately, we at last
have the legislative tools in KCKA and
Superfund to get a grip on these
problems in the months and years
ahead.
On the biological front, we can he
gratified to see the activity in integrated
pest management, the spread of no-till
cultivation, and the emerging conviction
that soil erosion control is essential not
only to limit a major ntmpoint source, of
water pollution, but to ensure
agricultural productivity over the long
term as well.
i think it can safely he said that
nothing we do or fail to do in our
environment is without consequences,
positive or negative, and that everything
truly is connected to everything else.
Pollution control, resource management.
demographic policy, growth rales,
natural systems, geopolitical events, and
national security are bound together like
the strands ot a Gordian knot. We often
deny or overlook the interdependence of
systems phenomena, but they are real
and all too demonstrable. \Ve ignore
them at our peril.
Fortunately, such "invincible
ignorance" is no longer fashionable. \Ye
Americans have recognized our
necessary role as environmental
stewards; we have set other nations a
timely example of leadership over the
last decade and a hall. I have no doubt
that we will consolidate our gains and
achieve still more in the challenging
years ahead. D
(Thomas is Administrator ol ]•,'!>.\.i
EPA JOURNAL
-------
A Revolution
in Auto Design
by Karl Hellman
Many factors influence tin:
composition of the fleet of cars that
Americans buy and use. The state of the
national economy, how much money
people have to spend, how confident
they feel about the future, and the price
of gasoline are all known to affect the
kinds of cars people buy. Regulations
have also influenced the design of cars,
especially emission standards and fuel
economy requirements.
The first nationwide cor emission
standards were effective in 1968 (prior
to the formation of EPA), but it was the
changes to the Clean Air Act made in
1970 that focused attention on cars as
major contributors to pollution.
Congress wanted our cars to be ten
times cleaner in just five years! This
was a monumental technical challenge
to the automobile industry which
claimed that the timetable was too short
and that the reductions couldn't be met.
The early 1970s were, thus a contentious
period, full of wrangling over emission
standards and timetables, and some
timetable extensions wore granted.
Major technological approaches
became evident right away. It was
apparent that radically new propulsion
systems such as batteries or fuel cells
were not going to be implemented in
such a short time-frame; therefore,
conventional engines were going to have
to meet the standards. For the tenfold
reduction in emissions needed, cleanup
of the omissions outside of the engine
looked like the approach with the
highest potential. After massive research
and development efforts hy the
automobile industry, emission control
systems that used catalysts wen:
generally selected as having the; most
promise. These systems were phased in
during model year 1975.
(I lellinun is ! 'ir (,'onlrols
Ti-i:hni>li:>n. untl Applications J->n;in:li ul
1 auto emissions iuborutoiy in Ann
Arbor, Mich.I
Early signals were sent to the energy
industry by the car makers that a new
kind of gasoline was going to he needed
for nearly all of the 15)75 models, a fuel
that did not have any lead in it liei ause
lead would destroy the? catalyst's
cleanup effectiveness. EPA worked with
the automobile and energy industries to
develop requirements for the availability
of this new gasoline, and the
partnership in providing the engine
control systems and the necessary fuel
was formed. This joint
government/industry partnership
continues today, working somewhat
more smoothly now than it did initially.
Just as the automotive industry was
coming to grips with the emission
control requirements, Congress handed
industry another difficult task: achieve
roughly a twofold increase in average
fuel economy within ten years. In
addition, a "gas gu/./.ler tax" would be
applied to individual car models having
poor fuel economy.
Therefore, by the mid- l!)70s. the
automotive industry was faced with the
twin challenges of making tremendous
improvements in emissions and fuel
economy performance. The car
industry's efforts in response cost more
than America's Apollo program.
The best way to track the progress
made in controlling emissions from ears
is to look at the quality ot the air we
breathe. Carbon monoxide is a good
marker pollutant to study, because mosl
of the carbon monoxide in our air
comes from cars.
Air quality monitors are located at
selected sites throughout the country.
Data from one monitor near 451 h Street
in New York City, a site known to be
heavily impacted by traffic, indicate that
since the mid-1970s the number of
times per year the air is unhealthy
because of carbon monoxide has been
reduced by over 90 percent.
Tail pipe hydrocarbon emissions
provide another indication ol how clean
the new cars are. Tail pipe hydrocarbon
JULY/AUGUST 1985
-------
emissions come from what the engine
doesn't burn and what tin: catalyst
doesn't convert into harmless carbon
dioxide mid water. Today's cars omit
only three-tenths of one percent of the
fuel they consume as tail pipe
hydrocarbon emissions, a tremendous
accomplishment,
.\nv curs lined up in n dealer's Jol
display slickers iv/l/i information ><
consumers,
The Average Car - Mid-1970s and Now
Engine
Si/.e (cubic inches]
Number of cylinders
Ignition system
Fuel metering system
Kind of gasoline
Kmission controls
Transmission/Drivetrain
Type automatic
Speeds ;i
Lockup no
Drive wheels rear
Body
Weight 4100
Room (cubic feet) 1 10
Thm>
290
8
points and condenser
carburetor
leaded
Now
180
4
electronic-high energy
fuel injection
unleaded
catalyst system
automat ic
4
ves
Since the mid-1970s, car fuel
economy has also improved
dramatically. On the average, new cars
now get almost double the miles per
gallon that they did then. No other
consumer product has improved in
efficiency as much.
What are the reasons for these great
improvements in car emissions and fuel
economy?
The simple answer is that everything
lias changed. Engines, transmissions,
and bodies have all been redesigned and
improved.
The accompanying table describes the
typical new car then and now.
The table shows great changes in
every category except one: interior
room. Even though cars are lighter by
half a ton now. and may be smaller on
the outside, on the average the interior
room has remained the same.
Other changes have also resulted in
improvements. For example,
maintenance intervals for spark plug
and oil changes have been increased
due to new technology and the use of
unleaded gasoline.
The advances in technology have
allowed os to have cleaner air and
increased mobility at the same time.
Future improvements in car emission
technology can allow this trend to
continue.
Although things are getting better, our
efforts must be maintained because
there are still major parts of our country
that have unhealthy air. In some of
these areas. KFA and the state and local
governments are now asking the public
to make sure that cars are tuned up
correctly and that they aren't tampered
with in a way that increases emissions.
The service industry is also encouraged
to learn how to tune up cars for low
(•missions. With EPA's help, state and
local Inspection and Maintenance
programs are tailored for each area to
ensure that the most cost-effective
emission reduction is attained.
All in all. the U.S. program to control
emissions and improve fuel economy of
cars has been one of the most successful
carried out by any governmental agency
anywhere in the world during the past
10 or 1 5 years.
The partnership formed among EPA,
the automakers, the energy industry, the
service industry, and the public has been
successful. While we have not yet
achieved 100 percent success, we have
made tremendous strides.
EPA JOURNAL
-------
Ohio Utility Takes a
Giant Environmental Step
by Jack Lewis
On May 31, 1985, EPA Regional
Administrator Val Adamkus, Ohio
Governor Richard Celeste, Ohio
Congressman Douglas Applegate, and
Ohio Edison President Justin Rogers, Jr.,
gathered at Ohio Edison's \V. H. Sammis
power plant in Stratum, Ohio. These
officials had come together to celebrate
the completion of the most massive and
expensive pollution control "retrofit"
ever undertaken at a North American
power plant.
It was a journey toward
mutual understanding and
respect between the public
and private sectors.
Adamkus, who administers EPA's
Region 5, spoke of the magnitude of this
engineering and construction
undertaking. "Early in the process,"
Adamkus stated. "1 visited this site. I
was impressed with the scope of the
project and the vision that fostered it,
and while 1 had confidence in (he
concept and believed in the plan, I had
reservations also. The enormous scope
of the task was staggering.
"Today the retrofit is a reality. As you
all know, the road toward that reality
was not always a smooth one. Hut it
represents a journey toward more than
the engineering accomplishment which
we note here today. It was a journey
toward mutual understanding and
respect between representatives of the
public and private sectors."
"Retrofitting" i.s the technical lerm for
the process of renovating an existing
facility to meet more modern needs and
standards than its original designers
envisioned. Even though Ohio Edison's
W. H. Sammis plant is one of the largest
(Lewis is Assistant J'.Wilor ol
HP A Journal]
ever built in the State of Ohio, the price
tag of the Sammis retrofit was only $2
million less—in 1985 dollars—than the
original cost of the entire plant: $440
million in 1971 dollars.
The first of Ohio Edison's Sammis
boilers began producing electrical power
in 1959. During the next twelve years,
six more boilers went into service. The
2,233 megawatt capacity of the
completed plant made it by far the
largest unit in Ohio Edison's 12-plant
network of coal-fired electric power
plants.
Today, as much as 40 percent of all
Ohio Edison electricity can come from
that one power plant at any given time.
Since 1971, the Sammis plant has been
serving over 970,000 customers
inhabiting a 9,000 square-mile area in
central and northeast Ohio as well as
western Pennsylvania.
By the mid-1970s. Ohio Edison's
Sammis plant had become one of the
worst industrial polluters in the
Northeast. Every year it was spewing
from 85,000 to 100,000 tons of
particulate matter (fly ash, dust, etc.)
into the air over Ohio, West Virginia,
and Pennsylvania.
Ohio Edison's tardiness in
reaching compliance with the
Clean Air Act put the
company on a collision course
with EPA.
When originally built between 1959
and 1971, the plant was outfitted with
electrostatic precipitators designed to
remove 97 to 99 percent of particulates.
That design potential presupposed the
burning of high-quality coal.
The low- and medium-quality coal
actually used at Sammis in the 1970s
caused the plant's participate removal
rate to hit abysmally low levels ranging
from 25 to 90 percent. These poor rates
of particulate removal fell far short of
-------
Ohio's standard of 99.4 percent, which
became federally enforceable in 1974.
Ohio Edison's tardiness in reaching
compliance with the Clean Air Act put
the company on a collision course with
EPA. Rather than undertake a massively
expensive retrofit in the 1970s, Ohio
Edison continued to operate its outdated
pollution control devices.
After repeated warnings from EPA,
the company switched to higher grades
of coal in 1979. This move was only a
.stopgap measure, however. It ended
Ohio Edison's violation of federal
emission limitations for sulfur dioxide
and nitrogen oxides. But it left the
problem of particulates unsolved.
Better quality coal did mean fewer
particulates, but the reduction in
The unusual nature of this
engineering design made the
logistics of construction a
great problem.
particulate emissions still left Sammis
far short of Ohio's standard of 99.4
percent particulate removal. Nothing
short of a drastic renovation—or
retrofit—of the Sammis plant could
raise its actual particulate removal rate
to the state standard.
As early as 1979, officials at Ohio
Edison commissioned engineering
designs for improving particulate
removal rates at the Sammis plant. But a
variety of factors, including a coal
miners' strike, caused the company to
delay implementation of this
phenomenally expensive retrofit
package.
In 1981, KPA obtained a consent
decree that compelled Ohio Edison to
take action. Under the negotiated
settlement, Ohio Edison was ordered to
pay fines totaling $1.7 million for its
violations of the Clean Air Act. The
consent decree also set rigid deadlines
Ohio Edison's U. II. Summis POIMT plnnl stands In (he
righl in this pirlun,', ivhirli is -fu
-------
for cleanup of paniculate emissions
coining from the Sammis plant.
Justin Rogers, Jr.—who became Ohio
Edison's President early in 1980—saw
the wisdom of salvaging the huge
Sammis plant through a massive
environmental retrofit. Not even the
pricetag of $438 million could shake his
resolve.
Several factors influenced Rogers'
decision. First, the Sammis power plant
was still "young" by industry standards.
The life expectancy of the plant had
been 30 to 40 years when it was built
between 1959 and 1971. Thus, by 1981,
the oldest boiler unit at Sammis was 22
years old and the newest only 10. To
build a comparable facility from scratch
would have cost much, much more than
its 1971 pricetag of $440 million.
Attaining lawful levels of
particulate removal was the
central objective of the
Sammis retrofit, and Ohio
Edison has met that goal.
Sound planning and solid execution
were particularly vital to the success of
this project, which entailed erecting six
colossal particulate removal devices on
a 915-foot-long concrete platform above
Ohio Highway #7. The unusual nature
of this engineering design made the
logistics of construction a great problem,
almost as great as the problem of
devising an emissions limitation system
capable of removing more than 99.4
percent of particulates.
Ohio Edison made its task easier by
cooperating fully with EPA at every
stage in the design and construction of
the Sammis retrofit project. According
to EPA engineer Michael Valentino,
who monitored the project from the
agency's Region 5 office in Chicago,
Ohio Edison has been "most
cooperative, willing to volunteer any
needed information." In Valentino's
opinion. Ohio Edison has made the
Sammis retrofit "a model of efficient
planning and solid engineering."
When all seven Sammis boiler units
are in operation, compliance with
Ohio's particulate emission limitations
is achieved on a boiler-by-boiler basis at
all the boilers. Each of the boilers is
connected to a new electrostatic
precipitator or baghouse, which removes
particulates from boiler unit exhaust.
Baghouses were selected for
installation on boiler units 1 to 4
because—unlike electrostatic:
precipitators (ESPs)—their performance
is largely unaffected by the amount of
sulfur in the coal burned. This enables
units 1 through 4 to run on low-sulfur
coal. Boiler units 5 to 7. which are
connected to electrostatic: precipitators.
burn medium-sulfur coals from Ohio
and western Pennsylvania.
Thus, some units at Sammis burn
dirtier coal than others. Each unit.
however, is now well within federally
enforceable emission limitations for
particulates. Attaining lawful levels of
particulate removal was the central
objective of the Sammis retrofit, and
Ohio Edison has met that goal.
The plant also remains in compliance
with federal standards for sulfur dioxide
and nitrogen oxides. Ohio Edison
brought Sammis into compliance with
these standards in 1979, when the
company started to burn higher-quality
coal.
Today the Sammis plant continues to
emit legally permissible but significant
quantities of sulfur dioxide and nitrogen
oxides. These pollutants are of concern
because they are thought by many experts
to be key components of acid rain.
A possible means of further curbing
these gases is slated to be tested at
another Ohio Edison facility that
appears destined to make environmental
history. Many miles north of the
Sammis plant, Ohio Edison has a much
smaller coal-fueled power plant. This is
the Edgewater plant—located near
Lorain, Ohio, on the shores of Lake Erie.
Edgewater has been selected for a major
environmental experiment funded by
EPA, the State of Ohio. Ohio Edison.
and the engineering firm of Babcock &
Wilcox.
Ohio Edison has offered one of the
boilers at its Edgewater facility for the
testing of Limestone Injection
Multi-staged Burners (LIMB) technology.
The boiler in question is the
105-megawatt #4 boiler at Edgewater.
This boiler will be used to determine
whether LIMB can control the sulfur
dioxide and nitrogen oxide emissions.
The LIMB method consists of a
combination of two different
technologies: an advanced burner design
to reduce nitrogen oxides; and the
injection of an alkaline sorbanl (such as
lime or limestone) directly into boilers
to reduce sulfur dioxide emissions.
Testing on the LIMB technology is
scheduled to begin in mid-1987. The
total cost of the LIMB demonstration
will be $10 million. EPA has agreed to
pay $6 million—more than a third of
the total cost of the LIMB testing. It is
hoped that the LIMB project will
generate a retrofit technology capable of
dealing with sulfur dioxide and nitrogen
oxides as effectively as the Sammis
retrofit has dealt with particulate matter.
Because of the success of its Sammis
retrofit, Ohio Edison is able to continue
providing the vital resource of
electricity to the communities il serves
while at the same time reducing damage
to the environment from particulate
pollution. EPA is pleased with the
progress Ohio Edison has made at
Sammis, and is even more pleased with
the commitment to future progress Ohio
Edison has made at Edgewater. D
JULY/AUGUST 198b
-------
Discarding the
Litter Habit
by Judy Roumpf
«T~~\rink right from the can. No
1—/empties to return." This was the
compelling message of advertisements
that announced the first steel beverage
cans. Hut the ad's picture also showed a
trolling fisherman conveniently
throwing his can in a lake.
Manufacturers may still boast "no
deposit, no return" to potential
customers, but they now discourage
littering and solid waste pollution.
This is but one change in the
packaging industry. Just what has
happened to packaging in the U.S. since
Earth Day 1970? Has environmental
awareness and interest in recycling had
any effect on packaging?
Many American communities have
nowhere to put their trash. Citi/ens
oppose new landfill sites, and the
promise of waste-to-energy incineration
plants has not been reali/.ed,
Ground-water contamination from
leaking disposal sites is a major
environmental problem.
A significant portion of this nation's
discards is packaging, estimated by the
EPA at about one-third of all municipal
waste. This packaging takes many
forms, from empty cereal boxes to soft
drink cans, catsup bottles, and fast food
hamburger wrappers.
In 1971, the domestic packaging
industry shipped $21.5 billion of goods,
an increase; of BO percent from just eight
years earlier. By I'lHIl, shipments
jumped another 11)7 percent to $51
billion. This growth has often
outstripped the rise in use of the
products enclosed by the package. For
example, from 19IJ3 to 1071 food
packaging tonnage increased :);i.3
percent per capita while food
consumption only grew 2.3 percent.
Americans are buying products in
smaller si/.es and this increases the
volume of packaging wastes.
Competition within the booming
packaging sector is intense. Packaging
materials such as metals, glass, paper,
and plastics vie for market share. While
l is tile pilMisliri id Resource
. I'ortluni!. ()rr. |
consumers may not be aware of the
behind-the-scenes battles, they certainly
are aware of the results. Let's look at
soft drink and juice packaging.
Predominantly sold in glass, these
beverages then became available in steel
cans, which were then supplanted by
aluminum containers. Since 1978, more
and more soft drinks are packaged in
plastics while juices now come in
multi-layered (plastic:, metal, and paper)
boxes.
Similar developments have occurred
in food, health care, and household
goods packaging. It appears that the
paper and metal one-quart oil can is a
thing of the past. Barbecue sauce is in
plastic containers, frozen foods are in
new multi-layer pouches, and the glass
milk bottle is now considered a relic.
The whim and fancy of the American
consumer can drive a product seller
toward a new package in just a few
short months.
The consumer acceptance of
can recycling startled
packaging producers.
The result is that we no longer seem
to have steel can producers and glass
bottle makers. To hedge their bets, most
firms are joining the enemy. Continental
Can was one of the first into plastic
bottles, National Can also owns glass
plants, and Sonoco Products—the
leading paper grocery bag producer—is
also one of the biggest manufacturers of
plastic sacks.
These and other firms are spending
huge amounts of research, development
and marketing monies to find new
forms of packaging, Coca-Cola is testing
a plastic soft drink can, and
considerable research is under way to
develop an aluminum food can.
Most packaging ends up in a
community's landfill. It's a waste of
natural resources and energy, although
packaging also assures us of a healthful
diet, fresh and undamaged products,
and a convenient, carefree lifestyle. The
American way of life cannot do away
with packaging, but can we be assured
that environmentally sensible forms of
packaging are used? In the last 15 years,
three forces have been at work to
pressure packaging makers and users to
consider environmental issues. Let's
look at each.
The public's interest in waste
recycling has been a major part of the
high level of environmental interest in
this country. With over half of all
Americans involved in some type of
recycling, the packaging industry has
certainly taken heed.
It basically started in the late 1960s
when Reynolds Metals, the big
aluminum producer, began to purchase
old aluminum cans. Because of its
relatively high value as a metal, the
aluminum can became the recycling
success story of the 1970s and 1980s.
Now more than one-half of all the
aluminum cans used in the U.S. are
returned for recycling. About 5.000
recycling centers purchase cans, with
the elderly, poor, and young being
major suppliers. Numerous charitable
groups raise funds by collecting cans for
recycling.
The consumer acceptance of can
recycling startled the aluminum
companies and other packaging
producers. The vast success had several
major effects. First, it proved that
people weren't hesitant to separate their
containers and to store them tor
recycling. It also provided a consistent
source of cheap metal to the aluminum
companies, allowing them to more
effectively compete against other
packaging materials.
Most important, marketing experts
recognized that some consumers
preferred to buy soft drinks and beer in
aluminum containers because the cans
were recyclable. Recycling became
another determinant of consumer
preference.
Other producers of beverage
packaging then jumped on the
8
EPA JOURNAL
-------
In flic days before Jiffcr/n.u was a major
public concern, this ud purtnired d
rem.'tree fisherman tossing cm empty am
into d lukc.
bandwagon. Nearly 100 glass plants
launched bottle-buying campaigns, and
the steel can industry developed a price
support program to underwrite the
efforts of recycling collectors.
With a solid waste disposal crisis
confronting more and more
communities in recent years, the public:
has been made aware of the problems of
trash. Garbage is no longer out of sight,
out of mind.
Waste production, not waste
disposal, is the major problem.
As city councils and town boards
studied the options, they soon realized
that we just have too much garbage.
Waste production, not waste disposal, is
the major problem.
And in some communities, citi/ens
have taken action to educate other
consumers about over-packaging and
about environmentally senseless
packaging. For example, a handful of
New Jersey and California communities
have launched campaigns that involve
placing tags on grocery store shelves
that rate packaging. For example, a
green tag might be used for a refillable
soft drink bottle, a yellow tag for a
recyclable soft drink can, and a red
label tor a non-recyclable plastic: bottle.
Shoppers are then informed of the
tagging system and encouraged to select
the environmentally proven container.
Though consumer recycling has
grown by leaps and bounds and then;
are efforts to educate citi/.ens about
excess packaging, packaging waste
grows. A number of states, fed up with
overflowing landfills and a littered
landscape, have adopted legislation
aimed at reducing packaging wastes.
The most famous piece of legislation
is the container deposit law enacted by
nine states. About 20 percent of the
American population lives in
communities where deposits are
required on beer and soft drink
packages. Typically, consumers in those
states return some 90 percent of the
deposit containers to retailers or
redemption centers. The bottles and
cans are then sold for recycling,
although current plastic: recycling
markets are so weak that some plastic:
soft drink bottles are placed in landfills.
Other states have gone in another
direction by taxing consumers to fund
packaging cleanup efforts. Called
litter-tax programs, these projects also
attempt to educate citi'/.ens about litter
problems. Generally, packaging
producers and retailers favor litter-tax
campaigns over deposit legislation. Less
than 10 percent of the population lives
in states using this alternative.
Now several states arc: trying to force
the packaging industry into constructive
action by passing legislation restricting
the use of certain types of packaging.
This strategy was first used by
Minnesota several years ago when it
passed legislation that would restrict the
sales of new forms of packaging if such
items were found to bo more
environmentally harmful than existing
packaging. The Minnesota system was
never put into place due to a number ot
legal hurdles.
This hasn't stopped other states from
trying to retard the growth of non-
recyclable packaging. At least six states
are considering restrictive legislation
this year. For instance, the Oregon
legislature may adopt a measure that
gives the plastics industry a few years to
implement a plastic: milk jug recycling
program. If industry fails to do so,
plastic milk jugs would be banned.
New Jersey has gone a bit further. A
mandatory recycling measure supported
by Governor Thomas Kean calls tor
recycling goals to be set tor troublesome
items such as plastic: and hi-metal
packaging. Like Oregon, it allows
industry a window of opportunity to
establish a viable recycling program. If
that effort doesn't attain a 55 percent
recovery goal, a deposit on such
packaging would be initiated, with the
funds going for recycling program
development. If that second effort falls
flat, the items would be banned.
While to date no state legislature lias
adopted such a measure!, there's growing
interest from a number ol states. The
consideration ot drastic: measures
symbolizes the increasing frustration of
many decision makers over burgeoning
solid waste volumes, Industry is getting
a clear message: solid waste reduction
and recyclability should become
packaging design tactors.
In addition, the1 packaging industry is
hearing the; concern that it's not doing
enough to aid the recycling ol
packaging. Some industry sectors ,irc
beginning to respond. For instance!, tin;
plastics industry and others have
established the Plastics Recycling
Foundation. With a planned S5 million
budget, the foundation will develop and
promote plastics recycling technologies.
Similar efforts are needed if we are to
reduce the volume of packaging wastes.
D
JULY/AUGUST 1985
-------
Strong Incentives
for Industrial Recycling
In o quality control check, feclmiciuns
tit an Allied Corporation pl
-------
• Daly-Herring Company manufactures
pesticides and insecticides. The
company altered its dust collection
equipment so that waste streams coming
from various production areas are now
collected separately rather than mixed
in a single baghouse. The collected
materials are no longer contaminated by
alternate waste streams, and each is
recycled back to the process where it
was generated. The firm has eliminated
over $9,000 in annual disposal costs
and estimates the recovered material is
worth more than $2,000 per year.
Allied Corp
• Deere and Company reduced its
hazardous waste 80 percent by
"volume" and over 99 percent by "level
of risk" through two key actions: first by
implementation of a comprehensive
corporate hazardous waste management
initiative at each manufacturing unit:
and second, by construction of an
on-site liquid hazardous waste treatment
facility capable of reclaiming waste
organic oil compounds and metals from
process water, producing a
non-hazardous sludge. The recovered oil
is sold to an oil recycling firm or reused
for machining processes.
• Duke Power Company is one of the
major electric power generating firms in
the State of North Carolina. A team of
staff members was assembled to develop
comprehensive low-level radioactive
waste reduction strategies. One of the
elements of the resulting program was
an effort to improve housekeeping
activities. Compactible materials
suspected of radioactive contamination
were segregated by area within the plant
into "potentially contaminated" and
"not contaminated." Since a significant
portion of the material was free of
radioactivity, this procedure
significantly reduced the amount of
hazardous waste requiring disposal.
While basic forces are pushing waste
reduction in the right directions, the
NAS committee was clear that more'
needs to be done. Direct government
regulation of manufacturing processes
was not recommended. Instead, the
committee favored an emphasis on
access to information about waste
reduction. Through a variety of HUMUS
—education programs, conferences,
workshops, and technical
assistance—and a variety of
institutions—universities, state agencies,
trade associations—the emphasis must
be on wider dissemination of
information on the opportunities that
are available and the techniques that
have worked. Such assistance is
particularly important for small
business, which is the .segment of
American industry most in need o!
help. D
JULY/AUGUST 1985
-------
Pest Management:
Pursuing an
Environmental Dream
by William Jordan
The pioneers of modern integrated
pest management (IPX!) had a dream.
They saw a time when pests would be
controlled by manipulating their
ecology. They reasoned that if pesticides
must be used—as the founders knew
they must—then they would be used
like medicine, prescribed by specialists
in limited doses for a diagnosed ill, and
integrated into the overall ecosystem.
Robert van den Bosch, a fiery
environmentalist who helped develop
the basic concepts of IPM, used to say,
"We can work out integrated control for
any crop in the world, and if we can
just get 'em to use it, it'll save their
' fanny.'"
What is practical is what
brings in this year's crop and
saves the agro-ecosystem for
future crops as well.
(fordcm i.s a sciciicr n'rilcr in /.on;:;
Jicdch. (.'d/il.. tvitli ii doctorate in inset:
Even though these pioneers were
university men, theirs was a practical
dream. To a farmer it may have seemed
idealistic, because to a farmer what is
practical is what brings in this year's
crop. But to an ecologist. what is
practical is what brings in this year's
crop and saves the agro-ecosystem for
future crops as well.
It was a long-term, panoramic: dream,
and it came alive under the overcast
gloom of SiJenf Spring. The goal was to
create an agricultural ecosystem that
could be sustained perpetually. One of
the first steps was to reduce the amount
of pesticide used; as a very attractive
side-effect, the costs would also be cut.
Has the dream come to pass? Looking
back over the past 15 years or so, the
answer appears to a very equivocal "yes
and no."
On the positive side, there is no doubt
that IPM can be made to work. Cotton in
California's Sari Joaquin Valley is a key
example. Cotton is the biggest cash crop
in the state, and it used to be the largest
consumer of pesticides. Fifteen years
ago it was common for tanners to spray
10 to 12 times per season for a
conglomeration of bugs and worms
straight out of a nightmare. Old-timers
talk of schedules where they sprayed on
the same morning each week whether
the fields appeared to need it or not.
Today a typical ranch sprays 1 to I1 .'••.
times a season for mites, and it sprays
only if an application seems warranted.
IPM specialists keep a careful watch on
pest species throughout the season.
recommending a pesticide strike only
when the infestation reaches a proven
danger point. As a result, pesticide costs
are tremendously reduced and the
yields are as high or higher then they've;
ever been.
Other examples exist around the
country. Alfalfa, apples, .soybeans, and
California citrus are considered classic
successes. If you accept the view troin
the U.S. Department of Agriculture
(USDA), the list goes on from here.
Cranberries, hay. rice, raspberries,
potatoes, and peanuts, to name a few.
have all needed less pesticides or
EPA JOURNAL
-------
suffered less injury and economic loss.
The statistics look impressive indued
and the list is growing.
Most impressive of all, the concept ol
IPM is said to he spreading to the grass
roots. According to David McN'eal. head
of (he USHA's cooperative extension
IPM program, farmers are using various
Agriculture is nothing more
than the manipulation of the
Big Ecology.
methods without even knowing what
the term "integrated pest management"
means! At the same time, they're being
educated about IPM by a vast network
of farm advisers administered jointly by
the USDA Extension Service and the
state and county departments ot
agriculture. II you listen to the
government establishment, you get the
impression that IPM has conquered the
world, that the dream has been reali/ed.
JULY/AUGUST 1985
But if you listen to the original
pioneers, things are not what they seem.
In fact, something is rotten in the state
of pest management. According to early
leaders like Vernon Stern of the
University of California at Riverside and
Andrew Gutierrez of the University ot
California at Berkeley, IPM has become
a buzzword, something you say in order
to sound respectable. As insect
ecologists, they feel that the concept ot
pest management has shitted subtly but
massively away from its original center
within the pest's ecology. The USDA's
McNeal verified this, claiming that
"crop ecology is now (lie focus anil hug
ecology has got to tit into this." In other
words, integrated pest management no
longer means what it used to. What it
now means is that you "look at all the
tools available and use the most
appropriate." The pest's ecology is no
longer seen as a unified component, but
something you can chip off in little bits
to fit the overall scheme of crop
economics.
The primary goal of the new IPM is
once again to bring this year's crop in
with the lowest production costs and
Cotton fields in South Carolina.
.According lo the author, cotton and
soybeans arc (he onlv (uo major mips
in the country which have couic
under red) ecological
the highest yields. A stable.
good-yielding agro-ecosystem 20 years
down the line to say nothing of a
healthy environment is a secondary
goal at best.
On the surface this seems logical:
after all. the yield is what you do
agriculture for. If you can't pay the bills
you're not going to be in the business ol
farming very long. But in lact, it's a tals
logic. It comes from a poor
understanding of how nature works.
The basic reality is that agriculture is
nothing more than the manipulation ot
the Big Ecology all around us, and
pest ecology and crop ecology ,in-
integral parts of it. To see the crop as
the basic reason for being is like seeing
the earth as the center of the universe.
-------
with the sun and the stars revolving
around it. You may be able to explain
heavenly motions this way, but
navigation would be a real adventure.
In the original concept of 1PM, if you
want to manage pests realistically,
you've got to steer by a fundamental
knowledge of the organisms' habits,
needs, cycles, enemies, and so on. Most
important, you've got to accept the
creature as something impossible to
eradicate. You've got to adjust the crop
to reduce the pest, not reduce the pest
to fit the crop. Doing it this way has the
tremendous advantage of counteracting
the pesticide/herbicide approach, which
clearly does not work over the long
term.
Just as clearly, the approach now
touted as IPM is not working in many
parts of the country. One of the worst
and most ironic examples of this occurs
on cotton in California's Imperial
Valley, a region less than 200 miles
from the San Joaquin Valley with the
finest cotton IPM in the world. Cotton
growers in the Imperial Valley now
spray 10 to 15 times per season to
control the pink bollworm. But it's still
called IPM.
A failed crop can bring
extinction and the temptation
to spray—"just for
insurance"—is often
impossible to resist
Pesticide/herbicide dependency seems
to rule most of the nation's major crops.
Of soybeans, cotton, corn, and wheat,
only cotton and soybeans are coming
under real, ecological management, and
only in certain regions at that. Robert
Metcalf, a world-renowned pesticide
expert at the University of Illinois,
claims that a crop like corn, which
carries a billion-dollar pesticide tag
(primarily for soil insecticides and
herbicides), would do fine with just 10
to 20 percent of the total usage if wisely
applied.
There is, of course, the obvious
question of why things are as they are. If
the original IPM was such a powerful
method, why hasn't it won the day?
In answering this, you could start
pointing fingers. You could blame the
pesticide manufacturers. The USDA
estimates that the total cost of pesticides
used will run to $4.5 billion for 1985;
the manufacturers are not complaining
about business. They advertise
relentlessly through the media and
through a system of pesticide salesmen.
Robert Metcalf calculates that radio
commercials accounted for a total
of about 40 hours of. air time in rural
Illinois this spring. Coming in 30 or
60-second spots, you get some idea of
how all-pervasive this campaign is.
The entire practice of treating
the soil before planting may
be on the verge of useiessness.
But advertising is central to a free
enterprise society, and to blame the
pesticide companies for trying to make a
profit shifts the blame from the real
culprit—just plain old human nature.
Without getting into detailed analysis,
suffice it to say politics follows
closely in arrears of big money. And
farming is scary, a sort of yearly crap
shoot for your farm if you're a smaller
operator. A failed crop can bring
extinction, and the temptation to
spray—"just for insurance" —is often
impossible to resist. The manufacture of
pesticides remains a vigorous, healthy
industry for the same reason as the
manufacture of vitamin pills remains
strong.
And so—no, the whole dream of
ecological pest management has not
come to pass, not if you take the
original concept to heart. The basic
philosophy of agriculture has changed
very little since the early Seventies,
because the basic system of
agriculture—the methods, materials,
and attitudes—has not changed.
So now is probably not the right time
to tally up the IPM score sheet. The
time may be arriving very soon,
however, and like all changes in nature
and evolution, it will be forced upon us.
It will come through the rise of pest
resistance, and now, something even
more ominous than that. According to
Metcalf, the entire practice of treating
the soil before planting may be on the
verge of useiessness. It turns out that
certain bacteria seem to have evolved
new strains that actually thrive on
herbicides and insecticides as food.
Today, a soil treatment lasts only 1/1 Oth
as long as it used to, which makes it a
needless expense. The implications are
revolutionary. It's a comfort to know
that IPM is already proven. D
14
EPA JOURNAL
-------
Public Opinion:
Behind the Transformation
by Riley E. Dunlap
Public concern with environmental
problems escalated rapidly in tin;
late Sixties, and reached a climax with
the celebration of the first Earth Day
(April 22. 1970). !n ,1 1965 Gallup poll.
the public ranked "reducing pollution ol
air and water" ninth among a list ot ten
national problems deserving government
attention. But only five years later, a
1970 poll concluded right after Earth
Day using the same question found
pollution control near the top of the list,
running a close second to crime
reduction. The actual percentages
selecting pollution as a problem
deserving government attention more
than tripled from 1965 to 1970.
Given the exceptionally high level of
public concern with environmental
problems in 1970, it should not be
surprising that several studies found a
decline in such concern over the next
few years. The most dramatic results
were reported by Louis Harris, who
found the percentage of the public:
volunteering environmental problems as
one of the "two or three biggest
problems" facing Americans declining
from 41 percent in 1970 to only 6
percent in 1975.
It would be incorrect, however, to
conclude that public concern for
environmental quality largely
disappeared by the mid-Seventies.
On the one hand, questions such as
those used by Harris (where respondents
volunteer what they see as the most
pressing problems confronting themselves
and/or the nation) measure the salience or
prominence of problems more than they
do commitment to solving them. On
the other hand, social problems in our
society have traditionally enjoyed only
temporary salience, quickly passing
(Dunlap is Professor of Sociology mid
Hiu'fj/ Sociology at Washington State
University, and /'cist (,'buir of (lie
American Sociological Association's
Section on Environmental Sociology. He
IHI.S published severe,' articles on public
attitudes Joiron! environmental
through what Anthony Downs calls the
"issue-attention cycle." A combination
of governmental ameliorative efforts, the
expenditure of large sums of money,
and eventual media boredom leads to
the rapid replacement of old problems
with new ones on the public agenda.
There is a good deal of evidence
indicating that while the salience of
environmental problems declined
significantly after 1970, public;
commitment to solving them has
remained surprisingly strong. Although
the available trend data do not begin
until 1973. two particularly good
measures of public: commitment to
environmental protection show the
unexpected persistence of high levels of
such commitment. First, since 1973 the
National Opinion Research Corporation
has been asking national samples
whether we're spending "too little,"
"about right" or "too much" on
"improving and protecting the
environment." In 1973. 61 percent said
"too little," 26 percent "about right,"
and only 7 percent "too much" (the rest
said "don't know"). The percent
indicating "too little" was being spent
on the environment slowly declined
during the Seventies, reaching a low of
48 percent in 1977 and again in 1980. In
recent years, however, il has increased,
and in 1984. 58 percent said "too little.
31 percent "about right" and only 7
percent "too much" was being spent on
environmental protection (with 4
percent saying "don't know").
A similar pattern emerges on a Roper
Organization question which asks
respondents, "Do you think
environmental protection laws and
regulation have gone too far, or not far
enough, or have struck about the right
balance?" In 1973, only 13 percent ot a
national .sample said that environmental
laws and regulations had "gone too far,"
while 32 percent said they "struck about
the right balance" and 34 percent said
they had gone "not far enough" (with 21
percent saying "don't know"). The
percentage indicating "gone too far"
slowly increased up to 25 percent in
1980, although the percentage indicating
Lore Canal, '1982: Abandoned homes are hoarded up and fenced of) prior to
demolition. The author stoics that environmental disustrrs such as Love L'unul
have increased puh/ic commitment to environmental projection.
JULY/AUGUST 1985
15
-------
"not far enough" was still 33 percent
that year. This .slight trend has been
reversed in recent years, as in 1983 (the
last ve.ir tor \vhi(.h data an; available)
only 14 percent said environmental
protection laws had "gone too tar,"
while 30 percent said they "struck about
tile right balance," and an
unprecedented 48 percent said they
had gone "not far enough" (while only 9
percent said "don't know").
Two aspects ol thest; trends since
1973 deserve emphasis. First, unlike the
salience of environmental problems,
Surprisingly, the Eighties have
seen an upswing in public
support for environmental
protection.
which admittedly declined considerably
by the mid-Seventies, public;
commitment to protecting
environmental quality remained
surprisingly strong throughout the
decade. Second, and even more
surprisingly, the Eighties have seen an
upswing in public support lor
environmental protection.
Before Irving to explain the
persistence and recent upward swing in
public commitment to environmental
protection, 1 would like to provide a
better sense ol the state of public
opinion on environmental issues in the
Kighties. I will do this by focusing on
important environmental policy issues,
beginning with the revisions of the
Clean Air and Clean Water Acts. During
19H1 Louis Harris asked whether
"Congress should make the Clean Air
Act stricter than it is now. keep it about
the same or make it less strict" in three
national surveys. In each survey roughly
half of the public (4(> to 51 percent) said
that Congress should keep the Act about
the same, while the percentages in favor
of making it stricter (29 to 38) clearly
outweighed those in favor of making it
less strict (12 to 17 percent). A similar
he
Harris question on the Clean Water Act
in 1982 revealed even stronger support
for continued environmental protection.
Sixty percent of a national sample
wanted the Clean Water Act made
stricter, 34 percent favored keeping it
about the same, and only 3 percent
wanted it made less strict (while
another 3 percent were not sure).
These high levels of support for
strong environmental regulations are
consistent with the results of questions
designed to gauge the public's
willingness to accept tradeoffs between
environmental protection and economic
growth. For example, a 1982 national
survey by Research and Forecasts found
twice as many people agreeing that "we
must accept a slower rate of economic
growth in order to protect the
environment " (49 percent) as agreeing
that "we must relax environmental
standards in order to achieve economic:
growth" (24 percent). Another 24 percent
agreed that "we can achieve our current
goals of environmental protection and
economic growth at the same time"
(while 3 percent didn't know). (liven
the emphasis on improving the state of
Attitudes on Spending, Laws
_60 percent
_50
Spending—Too Little
_40
Laws—Don't Go Far Enough
1973 1977 1980 1983 1984
our nation's economy in recent years.
results such as these are surprising and
reveal a strong commitment to
environmental protection by the
American public.
After describing the issue-attention
cycle that led him to be pessimistic
about the future of our nation's
commitment to environmental
protection, Anthony Downs suggested a
number of reasons why the
environmental issue might buck the
odds and remain high on the public:
agenda. Two seem particularly pertinent
in hindsight. First, environmental
pollution is more visible and clearly
threatening than many social problems;
and second, pollution affects virtually
everyone, rather than just a small
segment of society. These two factors
may have become even more significant
than Downs imagined in 1972.
The past 15 years have been marked
by the continual discovery of new. and
often quite serious, environmental
problems, a trend which likely reflects
both growing damage to ecosystems as
well as increased scientific scrutiny of
such damage. The result has boon that
the notable progress in cleaning up
many waterways and in improving
urban air quality is generally
overshadowed by all the attention given
to acid rain, soil erosion, toxic wastes,
and other problems. These problems are
not only seen as affecting virtually
everyone but, particularly in the case of
toxic: waste contamination of ground
water, as representing a very serious
threat to public health. The fact that the
public is continually bombarded with
news of newly discovered and
potentially disastrous environmental
problems (e.g., Love Canal and Times
Beach) has surely played a major role: in
keeping public commitment to
environmental protection at a high
level. Such news suggests that
governmental ameliorative efforts have
not been adequate to keep up with the
emerging problems.
The idea that the continual emergence
EPA JOURNAL
-------
100 percent
.75
.bO
25
Hazardous
Waste
Disposal
A Serious
Problem
~
Toxics
Pollution
of Lakes
and Rivers
A Serious
Problem
Balance of
Nature is
Easily
Upset by
Humans
Spaceship
Earth has
Limited
Room and
Resources
Attitudes on Environmental Concerns
Early 1980s
of new and often dangerous
environmental problems has been a
major factor in keeping public
commitment to environmental
protection unexpectedly high during the
past 15 years is bolstered by a variety of
data. For example, a 1082 Louis Harris
survey revealed the exceptionally high
levels of public concern over the health
hazards of environmental problems.
Ninety-five percent of a national sample
viewed "disposal of hazardous wastes"
as a "serious problem" and 93 percent
viewed "pollution of lakes and rivers by
toxic substances from factories" as a
"serious problem."
The endless discovery oi such
problems, despite all of the efforts and
money spent on environmental
protection in recent years, also seems to
he contributing to the public's gradual
acceptance of a somewhat more
"ecological" orientation. Thus, the 1982
Research und Fon;c: trusted to
do the job.
The combination of the increasing
emergence of serious environmental
problems and a decline in confidence
that such problems will be handled by
the appropriate government agencies
accounts, I suspect, for the recent
upswing in public concern about
environmental protection. Whether this
upward trend continues will depend, in
part, on public perception of the Reagan
Administration's commitment to
environmental protection. The decline
in controversy at HP A and the
Department of Interior has likely led to
a more favorable perception in this
regard.
If the dramatic rise in public concern
with environmental problems in the late
Sixties was a "miracle of public
opinion," as one analyst put it. then the
endurance of public commitment to
environmental protection since 1971)
must be regarded as somewhat
miraculous as well. That this
commitment has survived for in years,
after the expenditure of si/able amounts
of money and effort and in the lace ol
energy crises, economic hard times and
an anti-regulatory climate, is a strong
indication that the American people
have come to place a high value on
environmental quality. Twenty years
ago industry could justify its pollution
by pointing to jobs and economic
growth. Since Earth Day this has
become unacceptable to a large portion
of the public, as most people seem to
want economic growth balanced with
environmental protection. This has been
a profound change in our society. D
JULY/AUGUST 1985
-------
Looking Ahead
by Clifford Russell
and Paul Portney
A fielicopler dppiies pesticides to a
Florida orange grove. AppJicatJons like
(his, ivhich can lead to ground-water
contamination, illustrate (lie
inferrelafedness of environmental
problems.
When people an: queried about
environmental regulation and
asked to contemplate its good and bad
effects, the images recalled are generally
(be obvious ones. Tbey may relate
stories of particular rivers that have
boon cleaned up and air pollution
problems that are no more. They might
cite estimates of the cost of pollution
control over the past year or decade or
perhaps for some future period, as well
as the growth of KPA and the numbers
of regulations it has issued. All these
images are helpful to some extent, lor
such evidence does suggest that the
quality of the nation's air and water has
improved, albeit at considerable
expense.
The majority of citizens do
not regret the basic decision to
push toward a cleaner
environment.
It also appears that the shift in public
attitude that made environmental
regulation possible has survived these
successes. Polling results suggest that
environmental awareness remains alive
and well and that the majority of
citi/ens do not regret the basic decision
to push toward a cleaner environment
despite the costs and despite the extra
burdens imposed on individual and
corporate actions. Further, though then:
have been exceptions, environmental
••ell tun/ J'nrliiev urf Senior Fellou's
kit Hesonree.s lor (lie Future, tin
'independent reseurch und edueoh'onul
on;! (lie group's Quality of
(lie Knvimnmeiil Division und I'nrlnev
on( I (iieclor. J
issues have so far not divided region
from region or rich from poor in the
ways that early analyses predicted.
But if a retrospective look is to help
in the future, it is not sufficient to stop
with a chronicle of successes. We must
look to see what groundwork has been
laid for the long run. A decade ami a
half, after all, is not a very long time.
and tht! residuals from human
consumption and production will he
with us always.
From this perspective! it seems fair to
say that tin; record is mixed or that the
effects have been modest. Consider four
long-run concerns and how we stand
with them:
• How are we dealing with the
interrelatedness ot environmental
problems?
• How are we dealing with the
interregional character of major
emerging problems?
• What kind ot long-run incentives are
we providing to private; decision
makers?
• Ami perhaps more; fundamentally,
how are we reconciling opposing views
of what environmental regulation is all
about- -ethics or engineering or
economics?
There is no doubt that the
environment must be managed with a
broad view toward all potential
problem areas including the;
troposphere ami atmosphere, the; land
and water surfaces, and aquifers. Horror
stories abound about the; results of
ignoring this (imposition. Most often
they involve; the transfer or escape of
untreated wastes from one medium to
another, where:, in our ignorance.!, we; do
neit anticipate; the; results. Thus, putting
ha/.ardons chemical wastes into open
landfills once appeared a cheap and
therefore clever strategy. Similarly, laws
mandating air or water pollution control
have left us with mountains of solid
waste we; find hard to ignore; but harder
still to dispose of safely.
It hardly needs saying that neither
our laws and regulations nor our form
of legislative oversight are; set up to deal
with this reality. Rather, for historical
and peilitical reasons our environmental
There simply is no
"elsewhere" on a heavily
populated planet.
statutes ofteui emanate from different
congressional committees and consider
problems one at a time and in isolation.
A question for the future: is whether this
will cemtimu; to be; so or whether we
can advance to coordinated
environmental inanage;me;nt.
Experiments by KPA and research by
outside experts are now addressing this
question. The results may or may not
lead to sweeping e;hanges in the: current
system, but it is at le;ast clear that there
cannot remain unregulated "sinks" that
allow for the; cheap disposal ot
residuals. The "spaceship earth"
metapheir is a powerful OIK; in this
regard—the;re: simply is nei "elsewhere"
on a heavily populated planet.
Above, we: said that surprisingly little
interregional conflict has occurred over
environmental regulation. Add rain.
however, bus set region against region.
Analyses of the phenomenon have;
generally stressed long distance
transport of sulfur and nitrogen e>xiele:s
from areas where emissions are heavy to
areas where acids are; deposited. Ozone
is also thought to "migrate" from region
to region. VVhe;n this is the; structure: of
the problem, solutions must eithi;r
boldly impose costs on one region and
18
EPA JOURNAL
-------
— J-i>-
*
.-• ,»
confer benefits to another, or inn.st
involve transfers of one sort or another
in the opposite direction so that the
gainers pay for their gains. Neither
outcome is easily legislated in our
system.
However, the parts ol the
environmental pu/y.le addressed in the
main by the major statutes have been
local. That is, the statutes are written as
if discharges and effects, costs and
benefits, are located in the same region.
This, coupled with the national
uniformity generally required in
standards, has tended to short circuit
interregional squabbling. But things will
not be so simple in tin: future. Indeed.
the past five years have already seen
half a do/.en or so attempts to force EPA
to judge interstate frays over
cross-boundary pollution. These
attempts have been sidestepped in one
way or another, often because of the
technical difficulty of resolving the
disputes.
As our technical understanding of
long-range pollutant transport improves.
however, it will probably be
increasingly difficult for EPA (or the
Congress) to avoid judgments and
solutions. There is no reason to expect
Crafting individual solutions
for problems with well
identified winners and losers
is not easy.
this necessity to be confined to sulfur or
nitrogen oxides or hydrocarbons
discharged to the atmosphere.
Nonpoint sources of water pollution,
for example, may well be concentrated
in upstream, heavily agricultural states.
so that a major effort to reduce this form
of "discharge" may impose costs largely
on the agricultural sector and confer
benefits largely on those downstream
who withdraw water or use it for
instream recreational uses. Even more
threatening could he the interregional
movement of contaminated ground
water. If a major regional aquifer
becomes contaminated in one state,
those jurisdictions "downstream" will
want action, probably dramatic and
expensive action, to protect their uses.
Existing legislation is not \\cli
designed to deal with such problems
and, as has been said, crafting
individual solutions for problems with
well identified winners and losers is not
easy. The litigative alternative is slow
and uncertain. This inability to handle
interregional problems, then, is one
potentially major flaw in our foundation
for the future. It almost certainly
requires a generic; solution before
particular interests are committed in a
particular battle. Such a solution might
involve some taxing and transfer
scheme aimed at spreading costs beyond
the identifiable region or group
"causing" the problem. Whether this
could be so precise as to attempt to tax
away the benefits from the "victim"
group is another matter, one related to
the moral or ethical views of pollution.
JULY/AUGUST 1985
19
-------
The U.S. pollution control laws
crafted in the 1970s have at their heart
an ethical view that was translated into
a pollution control imperative that
stressed "doing your best" at all times.
That is, the idea was to put dischargers
under constant pressure to adopt the
best existing technology. The problem
with this approach is that by ''ratcheting
down" the discharge standards each
time technology improves, any incentive
for dischargers to seek technology
improvements themselves is removed.
The burden of supporting research, of
convincing reluctant sources that new
developments really work, and of
gathering evidence sufficient to justify
characterizing them as "best"
(practicable, conventional, available, or
whatever) falls entirely to the EPA or to
the struggling manufacturers of
pollution control devices. In other
words, we lose the input of the
regulatees themselves.
A related long-run matter is the
monitoring for, and enforcement of,
continuing compliance. Studies of
monitoring activity and continuing
compliance, whether by government
itself or by private organizations, have
agreed that while self-monitoring by
sources is generally required, very little
is being done to check up on, or even to
stay current with, the self-reported data.
Such fragmentary evidence as exists
further suggests that rates of
noncompiiance are substantial. This
problem is related to the technology
incentives issue because the strong
focus on technology and its installation
embodied in (he existing laws is
reflected in an emphasis on monitoring
for initial compliance—that is, for the
installation of the desired technology.
While it would be an overstatement to
say that the current practice is to check
on the installation and initial operation
of pollution control equipment, and
then to ignore what happens day to day,
it is certain I)' true that the monitoring
efforts being made do not even begin to
approach those that would be necessary
to produce a long-run incentive for
continuing compliance.
For the long run, pollution sources
should face a reasonable probability of
detection and u realistic penalty when
contemplating violation of existing
requirements for day-to-day or
week-to-week discharge limits. And
they must be able to capture some
substantial part of any reduction in the
cost of meeting those limits brought
about by the development and
introduction of new technology.
As indicated above, the
environmental legislation of the past
decade reflects in some of its key
features an ethical view of pollution:
that pollution is a wrong in itself. This
contrasts with the view that pollution
is, at its heart, a problem of supplying
the proper signals to private or public
decision makers. In this latter view,
some pollution is inevitable because of
the laws of conservation of mass and
energy that prohibit us from truly
getting rid of anything. Pollution control
simply means changing the form,
substance, or timing of discharges. Too
much pollution is likely to be the result
of the operation of an unregulated free
market. The job of government is to
balance the benefits of pollution control
(however defined and measured) against
its costs and to choose discharge limits
for particular places or substances, or
other policy instruments so as to
achieve what the market by itself
cannot. In this view, what is wrong is
for a source to exceed its discharge limit
or to practice fraud in its
self-monitoring report. Discharges
within the defined limits are not seen as
wrong.
Pollution is a ubiquitous
problem and not simply a
short-term ethical aberration
created by modern market
societies.
The ethical view of pollution as
intrinsically wrong leads to a long-run
goal of zero pollution and to the
continuing interim requirement to do
the best that existing technology will
allow. The cost in incentive terms of
this approach has already been noted.
The ethical view is also reflected in the
position that, like freedom of speech or
the right to keep ami bear arms, citizens
have an inalienable rig/il to be free of all
environmental risks. In the view of
some, this right extends even to the
most sensitive individuals and covers
even relatively minor health effects. If
pollution is "wrong" but temporarily
necessary, the logic runs, perhaps we
can at least eliminate essentially all its
deleterious effects.
This contrast in views between
pollution as a wrong and pollution as a
necessary inconvenience is reflected in
continuing tension within EPA. It is
manifested primarily between those
who would increase the role of
cost-benefit or risk-benefit analysis in
decision making and those for whom
such exercises are at best useless and at
worst immoral. Notice that this debate
is not over the capabilities of
cost-benefit analysis—what can and
cannot be measured—but over whether
any measuring should be done.
This is not a healthy tension, it seems
to us, because the absolute character of
the ethical view rules out analysis
generally. It discourages the seeking of
information about what can be or is
being achieved and at what prospective
or actual cost. Much more importantly,
it would put environmental regulation
on a different plane from other
government activities, even medical
research and the support of the
medically indigent, that might offhand
be seen as having at least as great a
claim to this ethical standing. Moreover,
the laws of physics, within which we
have no choice but to operate, do tell us
that leftovers (residuals) are inevitable.
Thus, we must decide what to do with
them rather than whether to allow them.
Our choices can range over the form the
leftovers can assume and the timing and
place of their discharge to the natural
environment. (We can reduce the total
amount through recycling. But we can
never push it to zero.) Recognizing that
pushes us toward weighing options.
Thus, in our view, one important
piece of foundation building for the
long-run success of environmental
policy is to recognize the uncomfortable
fact that pollution is a ubiquitous
problem and not simply a short-term
ethical aberration created by modern
market societies. With this lesson in
mind, we can prepare to pass from the
substantial successes of the past decade
to dealing with the less exciting but no
less important business of managing
society's residuals into the indefinite
future. D
20
EPA JOURNAL
-------
Union Carbide's Plant
at Institute, W.Va.:
Lessons from
Bhopal
by Michael J. Chern
(This is the last in a series of articles in
the Journal b}' EPA's regional offices on
major environmenta/ concerns (hev are
addressing.j
Union Carbide Agricultural Products Co, 'nc
In (his manu/acturing unit in Institute,
YV. I'd., ('nii)ii Carbide produces rnelh\
isnr vanute by react int; phosgene ami
monomethylamine.
On December 3, 1984. ;in event
occurred that \vill never he forgotten
by the chemical industry or those
involved with it. An estimated 2,001)
people were killed and tens of
thousands injured when a massive leak
of highly toxic methyl Lsnrvanate (MKl)
occurred at a Union Cm-hide
Corporation plant in Hhopal, India. |usl
JULY/AUGUST 1985
21
-------
Tlio control room (or ['iiion
production of methyl isocvunciti; in
Institute. IV. Vu.
as Three Mile Island forever changed
tlni life of the nuclear po\v<;r industry,
Bhopal has become a watershed for the
(;henii<,al industry.
Tlie Bhopal disaster caused American
political leaders, environmentalists, and
citi/ens to ask if the same kind of
accident could happen here. Fnhlic
attention here Inf.used on the only plant
in the United States that manufactures
MIC: Union Carbide's facility in
Institute. W. Va., in the Kanawha River
Valley near the state capital of
Charleston. Federal and state regulatory
agencies, at the urging of area political
leaders, decided to conduct a
multi-media inspection of the entire
Institute plant, even though Union
Carbide had already shut down the MIC
production unit on its own.
The inspection revealed that
exis ting en vironmen tal
regulations were not
principally designed to
prevent catastrophic accidents.
An interagency inspection
team consisting of representatives from
EPA Region 3's Wheeling Field Office,
the federal Occupational Safety and
Health Administration, the West
Virginia Department of Natural
Resources, and the state Air Pollution
Control Commission—arrived at
Institute four (lavs after the Bhopal
accident. The inspection reviewed
compliance with state and federal air
pollution, water pollution, ha/.ardous
waste, toxic substances, and
occupational safety regulations and
permits. KI'A's on-.site inspection was
supplemented by a comprehensive
review of compliance records at the
Region 3 main office in Philadelphia.
Although the inspection revealed that
no major environmental violations had
occurred at the Institute plant, EPA
officials realized that the compliance
review did not really address the issue
of overall plant safety. In fact, the
inspection clearly revealed that existing
environmental laws and regulations
were not principally designed to
prevent catastrophic: accidents but
rather to limit routine and expected
pollutant discharges.
There was no reason to
believe that the MIC unit at
Institute was any more
dangerous than hundreds of
other chemical production
units.
This past February, while EPA was
working on the safety issues left
unresolved by the inspection. Union
Carbide announced tentative plans to
restart the MIC production unit some
time in April. EPA immediately decided
to form an intergovernmental task group
to review the entire MIC unit in order to
ensure public safety would not be
harmed by the restart.
This decision was, in many respects,
a revolutionary one. Although a
number of statutes give EPA broad
authority to take action to prevent
an "imminent and substantial
endangerment" to public health or the
environment, the agency had never
invoked this authority in a similar
situation. Aside from the disaster at
Bhopal. half a world away, there was
no reason to believe that the MIC] unit at
Institute was any more dangerous than
hundreds of other chemical production
units operating in the United States.
Nevertheless, Union Carbide agreed to
cooperate fully with the review team.
The federal/state task group was
chaired by EPA Region 3's
Environmental Services Division
Director, Creene Jones. It was composed
of the same agencies that conducted the
first compliance inspection, with
additional support provided by the
Federal Emergency Management
Agency. The evaluation covered such
areas as the equipment and procedures
used in the production, handling, and
storage of MIC; the emission control and
detection systems: the plant safety
program; and emergency response plans.
While the federal/state task group was
conducting its evaluation. Union
Carbide was independently improving
the safety systems used at the plant.
Many of the improvements that the task
group was prepared to suggest had been
anticipated by the company and
changes already proposed. EPA also
asked the company to make additional
changes to the unit to further enhance
safety.
The most significant equipment
changes included:
• Replacement of brine coolant with
chloroform for MIC storage tanks (the
introduction of water into the storage
tanks at Bhopal may have caused the
accident);
• Installation of additional monitoring
and alarm equipment;
• Alterations to the emission control
systems to increase capacity and
reliability;
• Installation of an air-sampling leak
detector;
• Installation of a computerized system
to help predict the direction and
concentration of a chemical plume in
the air if a leak occurs.
In conjunction with the task group's
review of the plant equipment and
safety procedures, the Regional
Response Team (RRT), an
EPA JOURNAL
-------
intergovernmental organization which
coordinates federal response to
emergency situations, was reviewing
emergency response plans tor the Union
Carbide plant and the Kanawha Valley.
The RRT looked at five different plans
covering the plant: two by the state, one
by the county, one by an area industrial
council, and one by Union Carbide.
Despite the voluminous nature: of tin-
plans, the RRT found that coordination
between them needed to be improved.
lines of communication and authority
needed to he more clearly established,
an inventory of hazardous materials in
the area had to be obtained, and
response personnel needed more
protective equipment and training. A
summary of the RRT findings and
recommendations was made available to
the involved parties, and commitments
were obtained to make the necessary
changes in response plans. Some of the
changes actually were made while the
review process was still under way.
On April 15, following the completion
of the task group and RRT reviews, and
the commitment of Union Carbide to
make equipment improvements before
the startup of the MIC unit. EPA issued
a report on the safety of MIC production
at Institute. Based on the new
production and storage! equipment.
operating procedures, emission control
systems, monitoring and alarm systems.
and emergency response plans in use at
the plant, the report concluded that the
restart of MIC production did not
substantially endanger public health.
No one is prepared to
guarantee that a catastrophic
release can never occur.
MIC production resumed at Institute
on May 4 with EVA ami other federal
and state representatives on-site to
monitor the operation. Although the
start-up went without incident, no one
is prepared to guarantee that a
catastrophic release can never oe:cur.
EPA Regional Administrator James \i.
Seif said. "With any major chemical
plant we can never rule out with 100
percent certainty the possibility ot
human error or equipment malfunction.
However, Union Carbide's early
detection systems help ensure that the
company has ample opportunity to
prevent a major release if a proble:m
develops."
The Bhopal incident has led many
people to question how far federal and
state governments should go in assuring
that all reasonable measures are; taken to
prevent and respond to catastrophic
releases of toxic: chemicals. A number of
options are now being nationally
debated. One option is additional
federal regulation of the chemical
industry including uniform national
safety standards.
Another option would be: to giu1 the
states the primary responsibility to
oversee chemical plant salety. This
option is based e>n the: belief that a
case-by-cast; detailed evaluation of each
plant is probably iwcessary te> reveal
improvements that should be made:, and
that state pollution control agencies are1
in the: best position to provide this kind
of evaluation and to tailor improvement
programs appropriate' for (lie local
conditions.
The amount of further regulation
may also be influenced by the response
ol tin: chemical industry to the
situation.
Whatever happens, it is safe to say the
chemical industry will never be1 the'
same again. D
(Cheni is a writer/editor in I lie Olfice ol'
Public A[lmrs in KPA's Hrgion .'),
JULY/AUGUST 1985
23
-------
Soul
Searching
in the
Chemical
Industry
by Geraldine Cox
The accidental release of methyl
isocyanate gas in Bhopal, India, late
last year prompted deep .soul searching
among U.S. chemical makers for better
ways to deal with hazardous materials.
The result: the public will get more
information about chemical hazards and
extra help in handling them it
emergencies do occur.
Even before the cause of the accident
could be determined, chemical
companies began "white glove"
inspections of operating procedures in
plants worldwide. They made sure that
the elaborate safeguards built into
process units over past decades were
still running smoothly. Then industry
experts gathered at the Washington
headquarters of the Chemical
Manufacturers Association (CMA) to
decide what should be done differently
in the future. CMA's 175 member
companies represent more than
-------
emergency preparedness in Louisiana
and options tor improving il.
New Jersey's chemical industry is also
involved. Two hazardous materials
advisory councils at the county level
have raised $400.000 to help emergency
response crews throughout the state get
specialized training in managing
hazardous materials emergencies.
Another key element of CAKK is the
concept thai the public should have
access to information on hazardous
chemicals. This community
right-to-know policy will provide the
puhlic witli information we now give to
our employees. The material safety data
sheets (MSI)S) developed by companies
under the federal Occupational Safety
and Health Act are an example of the
type of information that will he made
available. MSDS's provide detailed
information on the hazards, properties
and elteets oi chemicals.
The other major initiative, the
National Chemical Response and
Information Center, will supply hazard
data on chemicals during emergencies.
route non-emergencv inquiries to
appropriate information sources, and
manage a network providing direct
assistance lor handling chemicals
involved in accidents. In effect, it will
become an information switchboard for
anyone wanting help from the chemical
industry.
The operation is being built around
the Chemical Transportation Emergency
Center (CHEMTREC). the industry's
14-year-old transportation emergency
hotline service. CHKMTRKC provides
information on chemicals to emergency
service personnel —such as fire, police
and rescue squads- - during
transportation accidents involving
chemicals. It is recognized by tin: I'.S.
Department ot Transportation as tin; key
source of emergency information on
hazardous materials involved in
transport accidents.
Tht! now center is expected to become
fully operational this fall. Four now
programs will be added to this existing
service. An expanded CHKMTRKC will
provide information and assistance for
all major chemical emergencies, not just
those related to transportation. This
arrangement will include a telephone
bridge between emergency room
physicians and company medical
departments to expedite emergency
treatment for toxic exposure.
'.iiirrge.'icy response (ed/n
implemented through CHKM.YKT
(ChemicaJ Xehvork) rushes experts and
eqm'pmen! to the seem ums
chemical accident.
A chemical network (CHEMNET) of
chemical company and for-hire
emergency response teams will be
implemented to put chemical experts at
the scene of serious accidents in
minimum time. A toll-free number
will be available to refer routine public
requests for information to chemical
companies and other qualified sources.
Training materials will be developed for
fire, police, and medical services first
responding to chemical emergencies.
While CMA was hammering out these
programs, toxic air pollutants became a
major environmental issue in the 99th
Congress. Interest centered around the
question: "Could a leak like the one in
Bhopal happen in the United States?"
In April, Rep. John Dingell (D-Micli.),
chairman of a House oversight and
investigations subcommittee, asked
CMA for information about how the
industry handles hazardous air
emissions. To find the answers, plants
in three geographical areas were
surveyed. They are in the Baton
Rouge-New Orleans corridor, the
Philadelphia-Wilmington-South Jersey
area, and the Niagara Falls-Buffalo area.
These centers of chemical industry
activity represent different types of
chemical processes, physical features,
and regulatory controls.
The survey of CMA member company
plants collected two types of data: 1)
information about the systems in place
for monitoring and detecting routine
and accidental releases ot chemicals,
and 2) types of emergency response
programs in use involving plant
personnel or plant and local emergency
response crews. The information has
been compiled by CMA anil forwarded
to Rep. Dingell.
Safety is a number one priority among
chemical makers, and the effort shows.
The National Safety Council judged the
chemical industry to he the safest of 42
basic U.S. industries last year, an
achievement that the chemicals sector
has earned for three of the past four
years.
But an industry that depends on
hazardous materials for many basic
feedstocks can never rest on safety
records. While Bhopal was an
aberration, the industry is taking giant
strides toward reducing the chance that
it will ever happen again. G
JULY AUGUST 1985
-------
EPA Goes Underground at
Kentucky Superfund
by Susan Tejada
Hun i n (i!( r
contn;. iv.hrn
I his ,
\i(
1:1'.\
Superfund.
In the 1930s and 1940s, the Lost River
Cave was the coolest hot spot in
Bowling Green, Ky. Before the days of
air conditioning and climate control,
this was one place in town that was
never too warm. Dancing couples
whirled away .sultry summer nights, fox
trotting on the huge dance floor just
inside (lie cave's entrance. Lost River
(lave was a subterranean nightclub.
In 1985, the nightclub is long gone.
Instead of the strains of big band music,
what comes wafting up from this
underground domain today are toxic
fumes.
Bowling Green is the largest
city in the United States built
entirely over a cave system.
Bowling Green sits atop a sinkhole
plain. According to Dr. Nick Crawford
of Western Kentucky University, it i.s
the largest city in the United States built
entirely over a cave system. The
sinkhole plain resembles "a landscape
of funnels," Crawford says. The
sinkholes direct storm water runoff into
the caves in the underlying limestone.
Toxic wastes have also entered the
caves, and KPA and the Stats: of
Kentucky are now trying to determine
what the wastes are, how they got there,
and how to mitigate the problem.
Several theories, says Crawford,
explain how contaminants move
underneath Bowling Green. Chemicals
that were spilled onto soil over a period
of time may he carried by rainwater into
the aquifer, where they travel rapidly
through limestone. As the chemicals
volatilize, the caves fill with fumes.
. u1 cii Ki'.A
This could account for the fact that
fumes are strongest after a heavy
rainfall. Another possibility i.s that
contaminants collect in natural traps in
the cave system. Chemicals floating on
top of underground streams may stick to
the walls and ceilings of caves when the
water recedes, forming a kind of
stinking, giant bathtub ring under the
city. Leaking underground storage tanks
and deliberate discharge of chemicals
into sinkholes may also be contributing
to the fumes in the caves.
EPA became involved with the
Bowling Green site in mid-1984,
following complaints of toxic fumes in
several residences. Fred Stroud, an
On-Scene Coordinator from EPA's
Region 4 office, had preliminary air
samples taken. "They went way off the
scale," Stroud recalls, "showing the
presence of organics."
Stroud then turned to EPA's
Environmental Response Team (ERT).
Using more sophisticated
instrumentation, ERT collected air
samples from various residences in July
and November of 1984. Further
sampling was conducted at two schools
in February, 1985.
Benzene levels documented by the
residential sampling were, according to
a later review by the Centers for Disease
Control (CDC), "too high for
non-occupational settings," In addition.
some substances detected at the
schools—benzene, toluene, and
chlorinated hydrocarbons—were highly
toxic, and others—alkane
hydrocarbons—were explosive at high
concentrations.
In March of this year, CDC issued a
public health advisory for Bowling
Green. "Although the relationship
between contamination in caves
[underneath Bowling Green] and fumes
in buildings is hypothetical," the
advisory states, "sufficient evidence has
been collected to indicate that the
presence of cave contamination and
building fumes are probably related . . .
The presence of chemicals in the cave
system under Bowling Green. Ky., may
represent a potential long-term health
concern to persons living in the
community. Long-term exposure or
frequent intermittent exposure to
benzene would represent the greatest
public health concern since benzene has
been associated with leukemia, bone
marrow depression, neurological
depression, and kidney and liver
damage. High levels of volatile
hydrocarbon chemicals also pose an
explosion hazard."
EPA launched a Superfund emergency
response to meet the hazards spelled
out in the public health advisory.
Working with state and local officials,
the agency installed ventilation systems
to mitigate the problem of toxic: fumes.
Now in place in the ground near the
four homes having the worst fumes,
each vent is a roof-level stack topped by
a fan that pulls fumes away from both
the cave passages and the homes. The
local school district installed similar
ventilation systems at two schools.
Dispersed in the atmosphere, the fumes
are believed to be harmless. "We still
have fumes," says Stroud, "but at least
we're keeping them out of the
buildings."
EPA is also trying to locate the
contaminants and their source and to
determine if they have accumulated in
one place where they can be collected
and pumped out. This difficult task is
further complicated by the fact that
there is no ready access to the
subterranean labyrinth where the
contaminants float on sub-surface
streams. An EPA team that includes
Crawford and some of his students from
the university's Center for Caves and
Karst Studies must make that access.
First they drill exploratory wells on
the spot of underground voids. At the
outset they had to drill many small
wells looking for voids. More recently,
they have used microgravity studies to
26
EPA JOURNAL
-------
<
.
V
V
pinpoint the exact location of the voids.
The entry team then goes down
through entrance wells, which are only
30 inches in diameter, often landing
knee-deep in underwater streams.
Obviously, these are not people who
mind tight spaces or wet feet. A smoke
ejector fan brings in fresh air and blows
contaminated air away. When
conditions warrant, team members wear
full-face respirators. They keep wet suits
on hand, should the water get too deep.
They are aided by a cave radio system,
down-hole video cameras, and ERT's
on-site mobile lab that can perform
specialized analyses on the spot.
Despite the high-tech gear, the
explorations are still somewhat hit or
miss, as evidenced by this excerpt from
a daily activity report on the site: "On
May 20th two teams of cavers entered
Robinson Cave. One team mapped 800
feet upstream and explored another 800
feet discovering several new leads to
other passageways. The second team
pushed downstream to explore and map
the downstream section. Downstream
push ended when the stream ran under
a cave wall and disappeared."
At this time, work in Bowling Green
continues on locating the contaminants,
but major questions remain. How did
they get there in the first place? Has
there been continuous, deliberate
discharge? By whom? For how long?
Everyone was putting
something there at some time
or other.
The State of Kentucky is investigating
industries in the Lost River drainage
basin in an attempt to answer these
questions, and EPA is assisting with dye
traces and analytical work. Dye is
injected in places such as the storm
drains of industrial facilities. Cavers
then attempt to map the path of the dye
underground by using dye indicators
placed at selected locations throughout
the cave system. So far a connection
between industrial discharge and the
fumes in the vented homes has not been
proven. But the state has already cited
six factories that it discovered had
either accidentally spilled or
deliberately discharged wastes directly
into the aquifer. "It looks like everyone
was putting something there at some
time or other," Stroud remarks.
"It's pretty critical to this town to do
something about this situation,"
concludes Crawford. In addition to the
danger of explosions anil the potential
health threat posed by chronic exposure
to the fumes, there is the additional
problem of ground-water contamination.
The sinkhole plain in Howling Green,
Crawford explains, "is the type of
landscape most vulnerable to
ground-water contamination."
While the fans atop the vent stacks
continue to blow fumes away from
threatened homes, EPA presses on with
the search for the Lost River
contaminants. "Whatever we do here,"
Crawford told a reporter last spring,
"will end up in the textbooks." D
JULY'AUGUST 1985
27
-------
Helping the
Oysters
Get Along with
the Cows
by Bob Jacobson
Dairy fanners in Oregon's Tillamook
County an; proving that people can
eat Tillamook cheese without having to
give up Tillamook oysters. Cows ami
oysters can coexist.
That's good news lor gourmets, hut
even hotter news for local shellfish
growers whose livelihood depends on
the oysters they raise in Tillamook Bay,
00 miles due west of Portland on
Oregon's Pacific Coast. The bay
produces 80 percent of the oysters
commercially harvested in Oregon.
There are a lot of oysters in Tillamook
Bay.
There are also a lot of Tiilamook
County dairy cattle: 19,000 of them on
1 18 separate dairy operations. Kach
year, these cattle produce 275,000 tons
of manure. And that can cause
problems, especially in a climate where
rainfall ranges from between 90 to 150
inches a year. With all that moisture
and with five major watersheds draining
into the Tillamook Bay basin, runoff can
easily carry fecal coliform bacteria into
the shellfish beds.
One day in 1977, federal Food and
Drug Administration officials told
Tillamook oyster grower Sam Hayes that
they were closing the bay to commercial
shellfish harvesting because of unsafe
levels of fecal coliform bacteria, and
that it was illegal for him to sell his
oysters.
Hayes got together with other
oystermen and called on KPA and local
and state agencies for assistance.
(/(iroli.son is HcgiotmJ Press- ni'liccr in
s Hegion 10 in Srulllr. U'usli.j
Researchers traced the source of the
contamination to animal waste. Hayes
and his group approached the
Tillamook Creamery .Association, which
is made up of dairy fanners, to ask for
their help. For the oyster growers,
things were bad and getting worse.
Now, in 1985, the situation is good
and getting better. Tillamook Bay
shellfish bed closures are much less
frequent. Fecal bacteria levels have been
significantly reduced in the streams
flowing into the hay, according to
Ernesta B. Barnes, EPA's regional
administrator in Seattle.
"While credit belongs to several
government agencies for getting things
started, it has been the Tillamook
Creamery Association and individual
dairymen who have actually been
getting things done," Barnes says.
The fanners built cement tanks for
holding manure, curbs around barnyard
areas to prevent runoff, cattle crossings
over streams, roofs and rain gutters for
holding pens and feeding stations, and
they installed gutters in buildings to
carry fecal material to safe distribution
sites.
EPA helped to yet things started in
1979 with a grant to the Oregon
Department of Environmental Quality.
The purpose of the grant was to develop
a water quality management plan for the
Tillamook Basin. The Department got
the ball rolling by working closely with
the Division of Soil and Water
Conservation within the Oregon
Department of Agriculture, and with the
Tillamook County Soil and Water
Conservation District.
The District turned out to be a key
player. By 1980, it had developed an
agricultural nonpoint source pollution
abatement plan. If nonpoint source
pollution was ever to be controlled, said
the planners, heavy reliance must be
placed upon dairymen using waste
management practices individualized to
each farm. The plan recognized that
what was best for one dairy might not
work at another, and that no uniform set
of management practices would work
across the board. It was the conclusion
of the Tillamook County Soil and Water
Conservation District that, for its plan to
succeed, best management practices
(cleanup plans) should not be imposed
by law or regulation on each farm. Since
management practices had to be tailored
to each individual dairy, compliance
should be on a voluntary basis. The
question then became: How do you get
the dairymen to volunteer? And how
will dairymen know what is really best
suited for each of them?
The U.S. Department of Agriculture
made it easy for dairy operators to
volunteer with the 1981 funding of a
Rural Clean Water Project for the
Tillamook Bay area. A chief feature of
the project was the offer of federal
money to share costs for instituting best
management practices. More than S3.4
million in cost-sharing funds has been
awarded to local dairymen.
In deciding what was best for each of
them, the dairymen had the benefit of
technical assistance from the Soil
Conservation Service. The solutions
varied dairy to dairy, but the most
common best management practices
were found to be the installation of
underground concrete storage tanks for
animal waste, application of manure to
fields during appropriate soil and
climatic conditions, addition of gutters to
barns to control runoff, and construction
of fences to keep cattle out of streams.
Many of the dairies have already
improved their handling of animal
wastes and are using the controls
needed to reduce runoff. The dividends
are becoming apparent. Sampling of
streams flowing into Tillamook Bay has
been limited, but measurements show
that fecal bacteria levels now range from
15 to 50 percent of what they were
before the Rural Clean Water Project.
Improvements should continue as
more dairymen begin implementing best
management practices and as other
non-agricultural sources of nonpoint
pollution come under control. Local and
state governments are correcting failing
on-site septic systems and upgrading the
operation of five small sewage treatment
plants.
Elbert Moore, a nonpoint source
pollution expert with EPA's Northwest
regional office in Seattle, is one observer
who has been encouraged by the
Tillamook Bay experience. "Technically,
we know how to solve nonpoint
pollution problems." says Moore. "On a
small scale, for example, putting up a
fence around a stream to keep animals
away can reduce fecal coliform levels in
that stream almost immediately. On a
large scale, we can also control
nonpoint pollution. All it takes is the
will to do it and individual initiative to
get it clone."
The farmers, the soil conservation
district, and all the others in Tillamook
County not only have had the will, they
have also shown the way. D
EPA JOURNAL
-------
Pollution
Over the
Arctic
by Glenn E. Shaw
A floating icebcru
-------
V^IJ^idlr^J A review of recent major EPA activities and developments in the pollution control program areas
AIR
Toxic Air Pollutants
A national strategy has been
announced by EPA to reduce
the risks from toxic air
pollutants. At thn same time,
EPA announced a decision
on five chemicals for federal
regulation under the
hazardous air pollution
control provisions of the
(Mean Air Act.
EPA's strategy for
controlling the air toxics
problems calls for:
• Expanding the focus of the
national air toxics control
program from solely
regulating individual
pollutants to also regulating
multiple pollutants from
different source categories;
• Expanding the program to
reduce risks in specific
communities with air toxics
problems;
• Increasing federal support
of state air toxic programs so
that states can improve their
capability to deal with air
toxics within their borders;
• Improving emergency
preparedness and response
for sudden, accidental
releases at all levels of
government;
• Beginning new efforts that
will give the public: the
information it needs to
prevent, prepare for and
respond to toxic accidents.
Final Smokestack Height
Rules
New regulations have been
set by EPA which limit the
use of tall smokestacks to
disperse air pollution from
industrial sources.
The regulations limit the
extent to which industries
can disperse pollutants into
the atmosphere! through tall
stacks instead of installing
additional control equipment
to reduce emissions of the air
pollutants.
The new rules will require
states to revise their clean air
plans (State Implementation
Plans) to determine what
additional reductions are
necessary for those
companies whose stacks are
taller than allowed. EPA
expects that the Clean Air
Act regulations will affect
primarily the electric utility
industry, some of whose
coal-fired power plants use
tall stacks to disperse sulfur
pollutants high into the
atmosphere.
EPA estimates the
regulations will result in
potential sulfur dioxide
emissions reductions of up to
1.7 million tons per year by
1995.
Nitrogen Dioxide
EPA has decided to retain the
existing national ambient air
quality standards for nitrogen
dioxide and has deferred a
decision to establish a
short-term standard until it
better understands the health
effects of short-term nitrogen
dioxide exposures.
The Clean Air Act
Amendments of 1977 call for
a review every five years of
all national ambient air
quality standards, which are
designed to protect public
health and welfare. Those
amendments also require that
EPA establish a short-term
(one to three hours) health
standard unless there is no
significant evidence showing
that it is required to protect
public health.
Fuel Economy Credits
EPA announced final rules
granting automakers fuel
economy credits for 1980 and
later model year vehicles to
compensate for changes in
the agency's vehicle test
procedures.
The corporate average fuel
economy (CAFE) standards
established by Congress and
the Department of
Transportation are based on a
1975 EPA test procedure.
EPA has changed the test a
number of times since then
to improve its accuracy. But
because the changes took
some fuel economy points
away from each model
tested—making the CAFE
standards for the automakers'
fleets more stringent—EPA is
required by the Federal
Energy Policy and
Conservation Act to grant
them fuel economy
adjustments to compensate.
Ford Recall
Ford Motor Company is
recalling approximately
119,000 1981 model year
passenger cars to assure that
the vehicles will meet federal
exhaust standards for
hydrocarbons and carbon
monoxide.
The affected 1981 model
year cars are Ford Mustang,
Grenada, Fairmont and
Thunderbird models and
Mercury Capri, Zephyr,
Cougar and XR-7 models
equipped with 4.2 liter or 5.0
liter, eight-cylinder engines.
California vehicles are not
included in the recall.
Ford decided to recall the
cars after EPA testing
revealed they exceeded the
1981 hydrocarbon and carbon
monoxide exhaust standards.
The repair will consist of
replacement of the carburetor
choke pulldown motor.
Fuel Blending Violations
A civil penalty of $650,000 is
being proposed by EPA
against the Imperial
Petroleum Corporation of
Seattle for improperly
blending alcohols with
unleaded gasoline. EPA sent
Imperial, a distributor of
gasoline in the Seattle area, a
notice of violation, which
cites the company for
violations of the Clean Air
Act fuel regulations.
Specifically, Imperial is
charged with manufacturing
an illegal unleaded gasoline
blend from December 1983
through September 1984.
Agency investigators
documented at least 61
occasions during a
three-month period last
spring when the company
allegedly blended too much
alcohol (methane! and
ethanol), with unleaded
gasoline and sold it to eight
service stations in the Seattle
area. On four other occasions,
Imperial illegally blended
lacquer thinner with
unleaded gasoline before
delivering it to several of the
eight retail outlets involved.
Car Importer Indicted
The Department of Justice
and EPA announced that a
grand jury has handed down
a criminal indictment against
the owner of a
California-based automobile
import and emission testing
facility which had submitted
false emission test results on
imported cars to EPA.
Named in the indictment is
Albert Mardikian, owner of
Trend Import Sales and
Albert Mardikian Engineering
of Orange County, Calif. The
U.S. Attorney's office in Los
Angeles has filed 35 felony
charges against Mardikian.
The counts allege that he
submitted false information
to EPA and used the U.S.
mails to defraud the
government.
HAZARDOUS WASTE
Largest Superfund
Settlement
The federal government; the
State of Indiana; the County
of Monroe, Ind.; and the City
of Bloomington, Ind., have
reached a hazardous waste
settlement with
Westinghouse Electric
Corporation to clean up
contamination from
polychlorinated biphenyls
(PCBs) at six sites in the
Bloomington area. EPA
estimates the settlement is
worth between $75 and $100
million.
Resolution of this
enforcement case represents
the largest hazardous waste
settlement in the history of
the agency. It is a
comprehensive agreement
which provides for the
ultimate destruction of the
PCB wastes, rather than
long-term landfilling.
The six sites are known as
Neal's Landfill, Neal's Dump,
Lemon Lane Landfill,
Bennett's Dump,
Winston-Thomas Sewage
Treatment Plant, and
Anderson Road Landfill.
State Actions
Chief Judicial Officer Ronald
L. McCallum of the EPA has
held that the agency cannot
take a hazardous waste law
enforcement action when a
state authorized by EPA to
run its own hazardous waste
program already has taken
reasonable and appropriate
action. This decision will
30
EPA JOURNAL
-------
reassure the states that EPA
will fully support their
actions to enforce compliance
with hazardous waste rules.
McCallum's decision
upheld a decision by
Administrative Law Judge
Spencer T. Nissen. Nissen
dismissed an attempt by
EPA's San Francisco regional
office to take an enforcement
action against the BKK
Sanitary Landfill in West
Covina, Calif., after the State
of Calif, has acted. EPA and
the state had inspected the
hazardous waste facility in
June 1983 and found a
number of violations of the
hazardous waste laws,
including a faulty
containment and ground-
water monitoring system.
Cleanup of Chem-Dyne Site
EPA has reached a $19
million settlement with 158
companies to clean up
subsurface soil and water
contamination at the
Chem-Dyne hazardous waste
site in Hamilton, Ohio.
The companies, primarily
waste generators who sent
their wastes to the site, have
agreed to long-term pumping
and treating of the
contaminated ground water,
the installation and long-term
maintenance of an
impermeable clay and
synthetic cap on top of the
site, excavation of highly
contaminated soils,
demolition of buildings, and
an extensive ground-water
monitoring program.
The companies have agreed
to take all necessary steps to
remove the contamination
threatening public water
supplies, which serve 60,000
residents.
Earthquake Exercise
In late June, EPA
Headquarters and Region 9
participated in the Federal
Emergency Management
Agency's (FEMA) RESPONSE
'85 Earthquake exercise in
Los Angeles, Calif. The
exercise was designed to
provide a "real world" test of
the "National Plan for
Federal Response" to a
catastrophic earthquake,
RESPONSE '85 was a
disaster simulation exercise
which involved state, local,
regional and national
response to a major
earthquake on the San
Andreas Fault in California.
While many of these plans
have been independently
exercised, RESPONSE '85
was the first major exercise
testing such plans in an
interactive environment.
While all significant issues
learned from the exercise
have not yet been identified,
areas that are being closely
examined are intra-agency
communications.
institutionalizing designated
points of contact for program
offices, and ways for EPA to
improve its overall
participation within the
federal family.
TOXICS
PESTICIDES
Captan
EPA is proposing to cancel
all food uses of the pesticide
captan after determining that
dietary exposure to this
product may pose an
unreasonable risk to public
health.
Captan is a fungicide
registered since the early
1950s and is used on a
variety of fruits and
vegetables as well as
non-food products.
EPA's proposed actions are
based on evidence that
captan produces oncogenic
(tumor) effects in mice and
rats and, therefore, may pose
a potential risk of cancer to
consumers through dietary
exposure and to workers
through dermal (skin)
exposure and inhalation.
Because EPA lacks reliable
residue data, the agency
based its estimated dietary
risks for captan on
worst-case assumptions
about health effects. The
worst-case assumptions are
the highest permissible
residues (tolerances) of
captan that would be allowed
in foods.
School Asbestos Abatement
EPA is awarding $45 million
in grants and loans to the
nation's most needy schools
to help abate asbestos
hazards.
EPA has selected 341
schools from 4,800 applicants
to get federal funds under the
Asbestos School Hazard
Abatement Act of 19fi4
(ASHAA).
To help all schools, EPA is
pursuing a variety of federal
assistance measures under a
new group called the
Asbestos Action Program,
including helping states set
up certification programs,
establishing training centers,
and expanding and updating
guidance and technical
assistance.
Under ASHAA, EPA may
award a loan of up to 100
percent of the cost of a
specific abatement project.
These no-interest loans are
repayable over 20 years. If
the agency determines that
an applicant cannot complete
an abatement program with a
loan, the applicant will be
eligible for a grant of up to
50 percent of the cost of an
abatement program. Grants
and loans are also available
in combination.
Chemical Notification
Violations
Six chemical manufacturers
are being fined a total of $6.9
million by EPA for failing to
notify the agency before they
began manufacturing new
chemicals.
The companies are BASF
Wyandotte Corp. of
Wyanciotte, Mich.; Ciba-Geigy
Corp. of Hawthorne, N.Y.;
BASF Systems Corp. of
Bedford, Mass.; Union
Carbide of Danbury, Conn.;
Dow Corning Corp. of
Midland, Mich.; and Tremco,
Inc. of Cleveland, Ohio,
which is part of Akron
Adhesives, a wholly-owned
subsidiary of B.F Goodrich
Co. (BASF Systems and
BASF Wyandotte are
wholly-owned subsidiaries of
the West German company
BASF AC, and ore
independent of each other).
EPA said the companies
specifically violated Section
5 of TSCA which requires all
firms to notify the agency 90
days before they manufacture
or import a new chemical.
4,4'-MDA
EPA is formally referring the
chemical 4,4'-\lDA to the
Occupational Safety and
Health Administration for
possible regulation.
4,4'-MDA is short for a
chemical called
4,4'-methylenedianiline.
About 98 percent of the
400 million pounds of
4,4'-MDA produced in the
U.S. each year are used to
make methylene diphenyl
diisocyanate (Ml)l). which is
used, in turn, to make
polyurethane foams and
elastomers. The chemical is
also used to make products
such as epoxy resins, wire
coatings and dyes.
EPA has decided to refer to
OSHA a report which
concludes that the
manufacture and use of
4,4'-MDA presents an
unreasonable risk of cancer
to workers.
Since all known exposure
to 4,4'-MDA occurs in tin:
workplace. Kl'A is exercising
its referral authority under
Section 9 of the Toxic
Substanc.es Control Act by
giving OSHA the first
opportunity to regulate
exposures to 4,4'-MI3A.
Asbestos Protection Rules
Under an EPA action,
federal asbestos safety rules
would be extended to state
and local employees to
protect them from the
potential ha/ards of asbestos
abatement work.
EPA is making the rule
immediately effective to
make sure that it covers
asbestos abatement activities
planned for this summer.
The rule, issued under
authority of the Toxic
Substances Control Act
(TSCA), will extend
Occupational Safety and
Health Administration
(OSHA) worker protection
requirements to state and
local employees, including
school maintenance workers
such as janitors who perform
asbestos abatement work.
JULY/AUGUST 1985
-------
Appointments
at EPA
Or. }. U'inston Porler
Karen \'. firoivn
HDITOK'S NOTE: The June issue of the
i'.l'A lournul reported that Sanford VV.
Harvey, Jr.'s now title in EFA's Region 4
is Deputv Regional Administrator. Mr.
Harvey's actual title is Associate
Regional Administrator. The Deputy
Regional Administrator of Region 4 is
John A. Little. The editors of the EPA
/ounmJ regret any confusion that this
error has caused.
Dr. J. Winston Porter has heen
nominated for the position of Assistant
Administrator for EPA's Office of Solid
Waste and Emergency Response.
Since 1976, Porter has heen with J.W.
Porter & Associates, a management and
engineering consulting firm. Previous
experience also includes \vork with the
Bechtel Group, where he served as a
vice president for international
operations.
Porter received his doctorate in
chemical engineering in 1966 from the
University of California at Berkeley.
Francis S. Blake has heen confirmed by
the U.S. Senate as General Counsel for
EPA. He will serve as the primary legal
adviser to the Administrator.
Before corning to EPA, Blake
specialized in environmental, utility,
find administrative law. 1'Yom 1983 to
the present, he was a partner in the linn
of Swidler, Berlin and Strelow. Chid..
and from 1978 to HUM, he was an
associate with the firm ol Leva, Hawes.
Symington, Martin, and Oppenheimer.
Between HUM and 1983. Blake served
as Deputy Counsel to Vice President
Bush, as well as Deputy Counsel to the
President's Task Force on Regulatory
Relief.
From 1977 to 1978, Blake served as a
law clerk to Justice John Paul Stevens ol
the U.S. Supreme Court; from 1970 to
1977, lie clerked for Judge Wilfred
Feinberg of the U.S. Court of Appeals
for the Second Circuit.
Between 1971 and 1973, Blake was a
legislative aide for the Joint Committee
on Social Welfare of the Massachusetts
Stale Legislature.
Blake graduated magna cum lancle
from Harvard in 1971 with a degree in
government. He received his law degree
in 1976 from Columbia University Law
School.
Karen V. Brown has been appointed
Small Business Ombudsman in the
Office of Small and Disadvantaged
Business Utilization. In addition to
helping small businesses understand
and comply with environmental
regulations. Brown will be responsible
for increasing agency awareness ol and
consideration for their special problems
and concerns.
Brown has been with EPA since HUM,
where she has held management
positions in the offices of the
Administrator. Deputy Administrator,
and Assistant Administrator lor Solid
Waste and Emergency Response.
Before coming to EPA. Brown had
heen a chemist and environmental
specialist with the District of
Columbia's Environmental Health
Administration and wilh two business
firms.
She received a B.S. in Biology in I97."i
from the University of the District of
Columbia, and has clone graduate work
in environmental science at George
Washington University in Washington,
D.C,
32
EPA JOURNAL
-------
Microorganisms in an aeration lugoon rvmovt- biochemical
oxygen-demanding substances from uff'hirnl. Tlic Jdgoon is ptirt of tin;
wastewater treatment process of (Jonsolif/aJud I^/pcrs, /tic., of
Wisconsin Rapids, Wis. From (lie /o^oon, the ef/Juont upiJJ flou- to u
secondary clarifier, and then to flic Wisconsin Hi\-t;r. /\ sludge
by-product ivi/l be used as fertilizer on nearby/arms. The company's
Water Quality (/'enter, ivhich includes the aeration lagoon, is an
example of tvasteivater treatment improvements industry has made as
a resuJt of environmental laws.
/Jack Cover:
/\qu
-------
United States
Environmental Protection
Agency
Washington DC 20460
Official Business
Penalty for Private Use $300
Third-Class Bulk
Postage and Fees Paid
EPA
Permit No. G-35
4
*
------- |