r/EPA JOURNAL
  Toward a Conserving Society


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                            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

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                               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.
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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

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                                       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

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                              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

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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

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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

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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

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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

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 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

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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

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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

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                                                                   — 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

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  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

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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

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 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

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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 
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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

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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
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                                        V
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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

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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

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Pollution
Over  the
Arctic
by Glenn E. Shaw
                                                                           A floating icebcru