Protection
Office of
Public Affairs :
Washington DC 20460
Toxics in Water:
\ A Hidden Threat
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-7
I /
Afloat on a homemade mil.
Toxics in Water:
A Hidden Threat
A l()l has been (I()IH; t() deal \vitll
conventional water pollulants such
as suspended solids anil biochemical
oxygen-demanding substances. A crucial
task now is to understand and meet (he
challenge of toxic substances in water.
This issue of the /minm! explores what
is being done on this pollution cleanup
front.
Tin; issue begins with an overview of
the toxics control activities in EPA's
Office of Water provided by Henry I,.
Longest. II. Acting Assistant
Administrator of the Office. The
agency's current steps to secure better
industrial pretreatment of toxic wastes
before they are discharged into public
wastewater systems are described in
another article. EPA's complex effort to
limit toxics in water through effluent
guidelines is also explained.
The agency's steps to protect drinking
water from toxics as well as other
pollutants are discussed. Another article
reports on an EPA-supported toxics
cleanup effort in Massachusetts that
may provide lessons with nationwide
application. EPA research into the use
of fish as sentinels for toxics in the
environment is described, as are the
agency's actions to control a toxics
problem of growing concern, pesticides
in ground water.
In other features, excerpts are taken
from a recent speech by EPA
Administrator Lee \<1. Thomas
examining the problem of one-track
approaches to cross-media pollution
problems. The recent reassignment oi
seven senior executives at EPA is
discussed in another article.
An experiment under way in
Southern California to help accomplish
the tough task of finding sites for
hazardous waste facilities is reported. A
perspective on the national hazardous
waste siting problem is given in a
companion article.
Concerning another facet of the toxics
problem, an article reports on the
progress that is resulting from EPA's
effort to control these substances from
motor vehicles.
Another article features
ERAMS—EPA's nationwide system to
gather and analy/.e data on
environmental radiation.
This issue of the /ounicil concludes
with two regular features—Update and
Appointments. D
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 11
Number 7
September 1985
xvEPA JOURNAL
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
EPA is charged by Congress to
protect the nation's land. air. and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and
implement actions which lead In a
compatible balance between
human activities and the ability of
natural systems to support and
nurture life.
The KI'A /oiirmil is published by
the U.S. Environmental Protection
Agency. The Administrator of KPA
has determined that the
publication ol tiiis periodical is
necessary in the transaction of the;
public business required by law of
this agency. Use of funds fur
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy.
Contributions and inquiries should
be addressed to the Editor (A-107).
Waterside Mall, 401 M St., S.W..
Washington, D.C. 204BO. No
permission necessary to reproduce
contents except copyrighted photos
and other materials.
Controlling Toxic
Water Pollution
by Henry L. Longest. II
Pretreatment of
Industrial Waste
by Jack Lewis 5
Fighting Water Toxics
with Effluent Guidelines
by Margherita Pryor B
Ensuring Safe
Drinking Water
by Joseph A. Cotruvo 11
Learning from
the Ten Mile River
by David Pickman 14
On the Lookout
for Toxic Danger
by Betty Jackson I *i
Protecting Ground Water
from Pesticides
by Carol Panasewich in
A Systems Approach:
Challenge for EPA
by Lee M. Thomas 21
Senior Executive Shifts
at the Agency 24
Taking the Initiative
in Hazardous Waste Siting
by David Morell 2
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Controlling Toxic
Water Pollution
by Henry L. Longest,
The Water Program is often
described as a mature one, and in
many respects this is true. We have
accomplished a great deal in terms of
controlling conventional pollutants. It
seems, however, that the more progress
we achieve, the more we understand
how much more remains to be done. As
we have worked with municipalities
and industries to put permits into place
for pollution control, we have
discovered more about toxics. As we
have moved forward to control point
The more progress we
achieve, the more we
understand how much more
remains to be done.
source pollution, we have learned more
about the effects of nonpoint sources of
pollution, such as storm water and
agricultural runoff. We have discovered
new threats to ground water from
pesticides and synthetic: organic
chemicals. And we are increasingly
involved in programs to protect oceans
and estuaries. We are a mature program
and, like most adults, we have assumed
new responsibilities at this stage.
Drinking Water
The Safe Drinking Water Act protects
our nation's drinking water in three
ways: through the National Primary
Drinking Water Regulations, the
Sole Source Aquifer Program, and the
Underground Injection Control Program.
The drinking water regulations establish
standards for drinking water quality and
the sole source aquifer and underground
injection control (UK]) programs are
dedicated to protecting ground water
used as a source of drinking water.
(Longest is < unvnflv KPA's Acting
Assistant Administrator for U'ufer.)
The latest data show that our public
water supplies continue to maintain
high levels of compliance with the
microbiological Maximum Contaminant
Level. This represents our continued
progress with conventional drinking
water contaminants. We have also
moved forward on toxics. The first
phase of revised drinking water
standards for volatile organic chemicals
(VOCs) has been proposed, while
regulatory proposals for phase two,
covering a large number of
contaminants, including many
pesticides, have been developed and
soon should be proposed in the Federal
Register. In addition, the agency has
drafted a proposed regulation requiring
systems to monitor for unregulated
VOCs as a means of detecting serious
ground-water contamination. In that
way, we will be able to take appropriate
action to protect users long before
proposed standards become effective.
On the subject of pesticides, the
Office of Drinking Water (ODW) is
conducting a survey with the Office of
Pesticide Programs that is currently
well into the design phase. We expect it
will provide a national picture of the
extent of pesticides in drinking water
drawn from ground water, as well as the
geological and use conditions that
contribute to the migration of pesticides
into ground water. This information will
serve as a basis for development of
future pesticides and drinking water
regulations. In addition, ODW is
accelerating development of health
advisories that state and local officials
use in responding to contamination
incidents that affect drinking water.
Our primary concern with the
operation of injection wells is the
potential threat they pose to the quality
of underground sources of drinking
water. With more than 180,000 injection
wells nationwide, they pose a serious
potential threat to public health and the
environment. So far, the full program
has been delegated in 33 states and
territories, EPA runs the program in 19,
and five have divided responsibility.
We have already begun the
re-permitting of existing wells for the
control of hazardous waste disposal and
wells related to mineral extraction. Both
EPA and the states have also begun the
permitting of wells related to oil and gas
production and the establishment of a
UIC compliance and enforcement
presence where EPA must implement
programs. We are also preparing to
implement the new Resource
Conservation and Recovery Act
requirements as they relate to UIC,
including a major data collection effort
to support the Administrator's decisions
on the continuance of wells injecting
designated hazardous wastes.
Surface Water
Overall, the national strategy to
maintain water quality is working. That
strategy has been to reduce point source
pollution through both technology-based
and water quality-based controls. EPA
and the states, largely through these
controls for conventional pollutants,
have reduced the volume of pollutants
discharged into the nation's waters. As a
More than 180,000 injection
wells nationwide pose a
serious potential threat to
public health.
result, many streams, lakes, and rivers
have shown dramatic improvements,
even while the country experienced
population growth.
However, the goals of restoring and
maintaining water quafity for fishing
and swimming are still not met in many
EPA JOURNAL
-------
Sport lishin" is one nsprcf of Amrnrnn
lite that con he nt'CcrU'if by (o.xi'c
s in ivtifer.
bodies of water. Furthermore, the extent
of the impact of toxics on water quality
remains largely unknown. In 1977, the
Clean Water Act was revised and
redirected towards the abatement of
toxic pollutant discharges.
We have made progress in controlling
the direct discharge of many toxic
pollutants, especially where our first
round of permits contained
requirements to control toxic as well as
conventional pollutants. Permits now
being issued contain new technology
requirements. We will complete this
permitting process for the major
dischargers we regulate during the next
few months, the states having delegated
authority will complete theirs during
fiscal year 1986. In addition, many new
permits will contain water quality-based
toxics limits.
Our progress in controlling toxic
discharges from industrial users of
publicly owned treatment works
(POTWs) is not so far along. Most
indirect dischargers did not have to
install controls during the first phase of
technology requirements. Our recently
issued effluent guidelines are a major
challenge to these indirect users, and
many are just getting started. Most of
them will be regulated through their
local POTW. In the last two years, EPA
and the delegated states have approved
1,100 local pretreatment programs. These
are new programs for most cities, and it
In the last two years, EPA and
the delegated states have
approved 1,100 local
pretreatment programs.
will take some time before all
requirements are completely enforced.
The POTWs themselves will have to
meet more stringent toxics control
requirements in their effluents, as many
municipal permits are being rewritten to
increase controls on toxics.
There is much yet to be done in the
area of water quality-based controls, so
we envision a third round of permits in
four or five years to require even more
controls on toxics. This is because states
will be adopting additional water
quality criteria and site-specific studies.
EPA has recommended an integrated
approach to water quality-based control
of toxics. This would combine
biological tests of toxicity of the whole
effluent and specific criteria for
individual chemicals that we know are
of concern.
Our integrated approach to
monitoring uses both chemical and
biological methods to assess and control
toxic substances in surface water. In the
SEPTEMBER 1985
-------
Slrvr De/aney
biological methods recommended,
scientists expose fish and other aquatic
animals to samples of effluent diluted
with varying volumes of receiving
water. The effects on the animals are
then observed over time and the toxicity
of the wastewater is calculated. This
Industries and POTWs will be
required to test effluents using
biomonitoring techniques.
represents a clearer picture of what is
actually going on in the receiving
waters, and provides a tool for setting
limits in discharge permits to regulate
the toxicity of an entire effluent.
Industries and POTWs will be required
to test effluents using biomonitoring
techniques.
Ground Water
Because half of the country's population
drinks ground water, and because we
have discovered increased ground-water
contamination from toxic chemicals, an
Office of Ground-Water Protection was
established last year in the Office of
Water. Its mission is to create a focal
point to coordinate EPA ground-water
policy, deal with other federal agencies,
and support the work of the states. In
the first year, a total of $7 million in
grants was allocated to the states to
develop and implement ground-water
programs.
A primary job of this office is to
implement the EPA's Ground-Water
Protection Strategy, which has four
major elements: to build and enhance
institutions at the state level; to address
Around (lie <;d«e of (i Virginia pond.
fJcspffe appearances, today's pollution
can be hard to detect.
problems associated with inadequately
controlled sources of contamination; to
issue guidelines for EPA decisions
affecting ground-water protection and
cleanup; and to strengthen EPA's own
organization for ground-water
management.
Half of the country's
population drinks ground
water.
The program is new, but the
organization is now in place, both at
headquarters and in the regions. The
Office of Ground-Water Protection is
working with other EPA offices to
develop strategies to deal with
high-priority issues such as pesticides,
toxics, and the problems across the
country with data management. We are
planning to implement classification
guidelines across EPA programs and to
develop a cohesive management
approach for each classification.
Marine Programs
The Marine and Estuarine programs also
deal with toxic issues. Under the
Marine Protection, Research and
Sanctuaries Act, the agency is charged
with carrying out strictly regulated
incineration-at-sea activities for the
destruction of liquid hazardous wastes.
These activities include selecting
environmentally safe incineration sites
and issuing permits to applicants. The
Office of Water is currently revising its
proposed regulations on
incineration-at-sea in response to public
comment. We are also proceeding to
implement a comprehensive research
strategy that calls for additional test
burns, as well as other research
activities.
We are working with state and local
agencies to develop strategies to manage
in-place toxic pollutants at critical
locations in the Great Lakes and in
selected estuaries. We also plan to
develop a national strategy to deal with
toxic contamination of sediments. We
will continue monitoring studies to
identify additional pollutants of
concern. As land disposal of hazardous
waste is phased out under the new
Resource Conservation and Recovery
Act amendments, we are assuring that
the ocean is only used for hazardous
waste disposal when it is demonstrated
to be safe.
Although much has been done in the
control of water pollution, it is clear
that much remains to be done. In poll
after poll, the people in this country
repeat their interest in protecting our
water resources. We hear their call. We
continue our persistent work toward a
safe, clean environment, a
EPA JOURNAL
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Pretrealment of
Industrial Waste
by Jack Lewis
roused f>y o massive explosion
in the seu-er system of Louisville, ky..
on February !,'!. J Wi 1. .An urridentul
release of hexone from ci Rtilston Purina
plant roused the explosion. I'.PA
imposed (he maximum penully of
S62.500 (iguinst (lie comp
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USDA Photo by Robert C Bjork
implementation and enforcement of
necessary pretreatment controls.
EPA's pretreatment program dates
from the Clean Water Act of 1972 and
its 1977 Amendments. This law gives
EPA responsibility for assuring that
effective local pretreatment programs
are established throughout the United
States.
The goals of the national pretreatment
program are as follows:
• Protection of municipal treatment
plant workers. Workers at POTWs run
the risk of exposure to toxic substances
in wastewater or toxic vapors such as
volatile organic solvents or hydrogen
sulfide gas;
• Protection of POTWs from
interference. Treatment systems
designed to deal with human organic
waste can be impaired through exposure
Ten percent of America's
POTWs handle 90 percent of
the nation's toxic waste stream
from indirect dischargers.
to toxic substances they were not
designed to purify. For example, toxic
pollutants can inhibit the cleansing
capacity of the microorganisms in the
type of treatment system that uses
activated sludge;
• Protection of surface water from
pass-through of toxics. Biological
treatment systems at POTWs do remove
some of the toxics contributed by
indirect industrial dischargers.
Adequate treatment of toxics cannot
come, however, without treatment
systems specifically designed for that
purpose. Industrial wastewater
treatment facilities designed for
high-strength wastes can remove these
toxics far more efficiently than publicly
>•• •'•fji.
• , - •• --r1
VV. "7
• .
'a- '">
*
owned treatment works. Without
pretreatment of toxics at the industrial
source, many substances will simply
pass through POTWs and enter the
waterways;
• Preventing the contamination of
municipal sludge. When recycled as
fertilizer, municipal sludge can serve as
a useful resource. Forty to fifty percent
of sludge is currently being recycled in
this fashion. Much of it, however, bears
labels warning of metals and other toxic
residues. The economic uses of sludge:
cannot be expanded until pretreatment
succeeds in reducing sludge
contamination. Nor can the enormous
costs of proper disposal of toxic; sludge
be avoided until rigorous pretreatment
of industrial wastes becomes a matter of
course.
EPA designed a National Pretreatment
Program to meet these legally mandated
goals. The agency developed a
two-tiered regulatory strategy for
implementing the program: the first tier
consists of general pretreatment
regulations; the second entails
developing national categorical
pretreatment standards that apply to
wastes from specific industries.
ih' rt>iiiuvin
-------
problems. In April 1985, for example,
EPA brought suit against eight POTWs
in six states to prompt pretreatrnent
compliance.
As of June 30, 1985, 1,100 POTWs
had approved local pretreatment
programs in place. EPA expects most of
the 350 delinquent POTWs to come into
compliance by October 1, 1985, the date
set by the agency as its second major
deadline. To prompt compliance, EPA is
planning a second wave of referrals to
the Department of Justice during
September.
Fortunately, not all POTWs
have been slow in responding
to the perils of indirect
industrial pollutants.
EPA's General Pretreatment
Regulations also provide a framework
for implementing and enforcing the
second tier of EPA's regulatory
approach to pretreatment: categorical
pretreatment standards. EPA's
categorical standards place exact limits
on the discharge of toxics and other
pollutants by industrial users of
POTWs. In other words, these standards
specify the level of pollutant reduction
that must occur prior to discharge to the
POTW.
Categorical pretreatment standards for
specific industries are extremely
important to the pretreatment program.
They complement pretreatment limits
set by individual POTWs in their local
programs. Those are limited by local
boundaries. Categorical pretreatment
standards are not: they apply
nationwide, on an industry-by-industry
basis. Regardless of whether an
industrial facility is located in a city or
in the country, it is legally bound to
pretreat its waste to the standard set for
its industrial category.
This regulatory system is now almost
completely operative. Twenty-three
pretreatment standards for existing
sources are scheduled to be in place by
September 30. The industries covered
by these standards use over 120 toxic
metals and chemicals in their
day-to-day operations. Only one
industrial group—organic: chemicals
and plastics—does not yet have final
pretreatment standards, but these are
expected to be published in final form
in March 1986.
Pretreatment standards for the largest
of the industrial groupings—
electroplaters—had compliance
deadlines in April and June
1984. These standards have served as
the basis for most of the enforcement
actions the agency has taken thus far
against indirect dischargers. In October,
1984, EPA filed charges against eight
General Motors facilities. This past
April, the agency took similar action
against three Chrysler facilities. Twenty
other cases against electroplating
violators are now at one stage or
another on EPA's active case docket.
This year and next will be
particularly crucial to the success of
EPA's pretreatment program. With
almost all categorical standards issued
and in place, and almost all large
POTWs soon to be equipped with
approved local pretreatment programs,
we should begin to see marked
improvements in the quality of the
effluent discharged by treatment works
into America's waterways as well as in
the sludge produced by some of these
treatment works for use as fertilizer.
The success of pretreatrnent in East
Providence, R.I., offers a good example
of the progress other communities can
expect. This New England city forged its
pretreatment program through close
cooperation between the local Water
Pollution Control Division and the
many industries clustered in East
Providence and the town of Harrington,
which is also covered by the program. It
became operative in July 1983. As a
result, toxic fumes no longer endanger
sewage system workers conducting
maintenance work at pumping stations.
In addition, the treated wastewater the
system discharges into the waterways of
Rhode Island is much cleaner than it
once was. From late 1983 to the spring
of 1985, there was a 94 percent drop in
jpper loadings and a 68 percent
decrease in nickel loadings from
electroplating dischargers.
Heavily industrialized
communities are likely to
witness the most dramatic
improvements.
As a general rule, heavily
industrialized communities are likely to
witness the most dramatic
improvements. There should he
something in the neighborhood of a 90
percent reduction in discharges of toxic
pollutants. POTWs in less industrialized
communities should also experience
reductions in effluent toxicity, but not
to such a great extent.
Overall, EPA projects a 50 percent
improvement in the quality of America's
sewage effluent and sludge as a result of
the pretreatment program—a program
implemented at the national, .state, and
local levels. Surely this is a goal well
worth striving to attain—and an
achievement both industry and
municipal officials can take pride in. u
SEPTEMBER 1985
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Fighting Water Toxics
with Effluent Guidelines
by Margherita Pryor
Bill Firestone
Washington is a city accustomed to
horrible acronyms, but even its
seasoned veterans must quail before
EPA's Federal Register notices. NSPSs
and PSESs, PSNSs and POTWs, BPTs,
BCTs, and HATs—all provided courtesy
of the CWA via ITD, MDSD, AED, and
OWRS, and OW. It takes a soldier
hardened in the bureaucratic trenches to
withstand such a barrage of alphabetical
ammunition.
These acronyms may sound like
displaced cartoon characters, but they
are really shorthand or EPAspeak for an
extensive regulatory effort that in little
more than 10 years has revived many of
h'dilur tit (lie EPA
the major bodies of water in the United
States, and has begun to reduce their
contamination by toxic substances. A
decade ago, science couldn't detect
some of these compounds. Today,
they're being removed at the rate of over
800 million pounds every year.
Getting to this point has been no
picnic. The journey has been a long and
rocky one, punctuated by lawsuits,
deadlines, the combined travail of some
90 different project officers—and paper,
lots of paper. (When the paperwork for
one rulemaking runs to more than
500,000 pages, we must conclude that
some aspects of environmental
protection rest on a vast graveyard of
fallen timber.)
Part of the reason for the length of the
journey has been the sheer complexity
h'rf'Iut'nf guidelines issued by l-'.l'A
tc industrial ivusIctvutiT
ps into public iviitrnvuvs.
of the task. Since 1973, the agency has
studied over 70 industrial categories for
possible controls, particularly on toxic
discharges, and has issued regulations
for about 60. The development of these
controls (technically called effluent
limitations guidelines) is subject to a
EPA settled the lawsuit by
agreeing to an unprecedented
pace of regulatory
development.
formidable array of overlapping
statutory and technical requirements.
Just getting the information on
which to base them can be a long,
drawn-out process. It took the agency
four years, for example, just to develop
the analytical methods for detecting and
measuring the presence of certain toxic
compounds.
Faced with the choice of expending
its limited resources on the control of
conventional pollutants, which the
agency knew how to do, or taking on
the seemingly overwhelming problem of
toxics, EPA in its beginning years opted
for the former. Fecal coliform,
suspended solids, oil and grease,
extremes of pH, and biological oxygen
demand—these were the nasties that
were making American waterways
unfishable, unswimmable, undrinkable,
and unbearable. Conventional pollutants
were well-known, with well-known
technologies for removing them.
Toxics were another matter altogether.
Outside observers grew impatient with
the agency's slow progress in that area.
In 1976, EPA was sued by the Natural
Resources Defense Council (NRDC) and
several other environmental groups for
failing to discharge its duty to establish
specific limits for toxics based on Best
EPA JOURNAL
-------
Available Technology (BAT),
EPA settled the lawsuit by agreeing to
an unprecedented pace of regulatory
development. Not only was the agency
to promulgate regulations for 21
specified industrial categories within
about three and a half years; it also
had to develop the analytical tools for
measuring 129 toxic pollutants, and
identify the technologies for controlling
them.
In the jargon of regulators, EPA's
effluent guidelines are said to be
technology-based limitations. That is,
the limits on substances that can be
discharged into public waterways or
public sewer systems are derived from
the technologies that are available for
treating or removing the substances. The
limits are applied uniformly to every
facility in an industrial category,
It takes years of effort and
thousands of pages of analysis
to get to these numbers.
regardless of the condition of the
receiving water to which the effluent is
discharged. This is in contrast to wafer
quality-based limitations, which are
based on the quality of the water to
which the effluent is discharged.
Identifying the treatment technologies
that will be the basis of the limitations
is easier said than done. EPA engineers
can't just pick up a handbook of the best
available technologies and crunch out
the requisite equations.
The heart of an effluent guideline is a
couple of pages of numbers—
micrograms per liter, kilograms per
thousand kilograms of production
unit, parts per billion, etc.—that
will be used by permit writers
in every state to regulate the discharges
of each industrial facility or publicly
owned treatment works. It takes years of
effort and thousands of pages of
technical, legal, and economic analysis
to get to these numbers.
For the organic chemicals guideline,
for example, EPA sent out questionnaires
to almost 3,000 facilities. The
questionnaire asked for information
on individual plant characteristics,
production processes, and wastewater
treatment technologies in use. A
supplemental questionnaire was also
sent to 84 facilities known to have
installed selected wastewater treatment
operations. Sampling was carried out at
a dozen plants, at some for as long as 15
to 20 days each. The assumptions and
data that support the guideline numbers
were subjected to several rounds of
critical review by all parties expressing
an interest in the guidelines.
Much of the critical review comes
during the public comment period
required for each proposed regulation.
EPA takes seriously the requirement for
public participation in the rulemaking
process. The agency responds to every
substantive comment it receives
concerning a proposed standard.
According to Devereaux Barnes, Deputy
Director of EPA's Industrial Technology
Division, the preliminary information
requests often spark a given industry to
begin reviewing its processes. "They'll
come back to us with data they didn't
have before we asked for it," says
Barnes. "And a lot of times, the
information will be substantial enough
to change our minds and we'll end up
asking for an extension (from the NRDC
agreement timetable)."
It is to the industry's advantage to
provide EPA with solid data. If a group
wants to sue to have a promulgated
standard set aside, the standard is not
stayed during litigation. "Industry can
sue," says Barnes, "but it sues on its
own time." Even so, lawsuits have been
plentiful. Out of 27 guidelines
promulgated under the NRDC
Behind the
Effluent Guidelines
1972
Federal Water Pollution
Control Act Amendments
Major Provisions
• EPA to develop uniform national
standards (effluent limitations
guidelines) based on differing levels of
treatment provided by available
technologies
• Standards to apply to all point
sources, whether they are industries that
discharge to publicly owned treatment
works (POTVVs) and through them
indirectly to bodies of water, or
industries that discharge directly to
bodies of water
• Each point source to obtain permit
based on appropriate effluent guidelines
that specify allowable discharges
• EPA to identify toxic pollutants and
develop specific limitations for them
1976
EPA/NRDC Consent
Agreement
Major Provisions
• EPA to develop effluent guidelines
based on BAT (best available
technology) for a group of 21 industrial
categories
• EPA to develop effluent guidelines
according to court-enforceable
deadline, with all guidelines complete
by January, 1980
to
• EPA to give regulatory priority t
developing BAT limitations for 12
pollutants and classes of pollutants
which agreement defined as "toxic
1977
Clean Water Act
Major Provisions
• EPA to continue provisions of 1972
Act
• 1977 amendments incorporate
provisions of NRDC consent agreement
• EPA to use effluent limitations
guidelines to regulate three classes of
pollutants: toxics, nonconventional, and
conventional.
SEPTEMBER 1985
-------
agreement, EPA has been sued on 21.
Project officers may spend up to 30
percent of their time providing technical
support for all this seemingly inevitable
litigation as well as helping states and
permit writers to implement the
guidelines and helping industry comply
with them.
EPA also takes care to monitor the
economic effects of its regulations,
particularly on small businesses. The
electroplating industry, by way of
illustration, is dominated by many small
"mom and pop" operations. When the
electroplating guidelines were
completed, the agency hired a nonprofit
association to write loan applications
and hold seminars for the thousands of
small facilities expected to be seriously
affected by the costs of installing control
equipment.
The completion of the NRDC
agreement schedule doesn't imply the
demise of regulatory development
either. The Clean Water Act directs the
agency to review guidelines every five
years to ensure their adequacy and to
study other industries for possible
regulation. According to Barnes, the
agency has been finding that some
industries are generating more toxic
wastes than previously expected. New
industries, such as transportation
sources, oil and gas extraction facilities,
and hazardous waste facilities, have yet
to be regulated under the requirements
of the Clean Water Act.
The development of techniques to
detect and control new toxic
compounds is also an ongoing
process—and one that has kept EPA on
the cutting edge of progress in this area.
According to ITD Director Jeffery Denit,
the Industrial Technology Division has
become the center of technical expertise
for the characterization and control of
industrial wastewater pollution and
associated problems. "I continue to
believe our strongest asset is our
industrial pollution control expertise. In
addition to category-specific talents,
several of the ITD staff have completed
regulations on eight to 12 industries."
Finally, every effluent guideline has
to be considered in light of its impact
on other environmental problems.
Stripping chemicals out of a waste
stream, for example, and putting them
into the air is no longer an acceptable
control treatment for certain toxic
compounds. When EPA estimates costs
for treating hazardous wastes, those
costs must reflect treatment that meets
new RCRA requirements.
EPA's ten-year relationship with
NRDC and the timetable may be coming
to an end, but new work is piling up. As
long as we need to use toxic substances,
we will also need to control them. Q
Approaching
a Milestone
In March 1986, EPA's Industrial
Technology Division (ITD) will publish
a regulation in the Federal Register.
This is news? EPA issues scores of
regulations every year.
But this is no ordinary regulation.
Call it a significant milestone or a
monkey on the agency's back, it marks
the end of 10 long years of deadline
schedules.
This is the final regulation for the
final industrial category requiring
control under the terms of the
EPA/NRDC consent agreement. It will
remove 107 million pounds of toxic
pollutants from wastewater generated by
the organic chemicals and plastics
manufacturing industry, will affect
about 1,000 manufacturing plants, and
may cost $720 million a year to
implement. Most strikingly, it may even
put ITD in the business of controlling
toxic air emissions as well as
wastewater discharges. This is no
ordinary notice.
Elwood Forsht doesn't think so,
either. For the last three years, Forsht
has been the senior project officer for
the organic chemicals regulation, and
that translates into many months of
weeks stretching 60 hours or more. So
far, the rulemaking record has reached
over 500,000 pages, and that doesn't
include the final notice scheduled for
March.
"We found that the proposal issued
back in 1983 was based on partial
industry data," says Forsht. "Since then,
we've surveyed the entire industry.
Essentially, we conducted a new project
from 1983 to 1985."
In this case, Forsht was helped by the
fact that industry representatives had
endorsed the idea of gathering more
data. "There are many corporate
philosophies," says Forsht. "Most
companies were very cooperative.
However, a small minority were very
miserly in providing information."
The information is put to good use.
According to Forsht, ITD engineers are
not ivory tower theorists. "We have a
good mixture of backgrounds here," he
says. "I worked for Continental Oil
before coming to EPA, and 1 think most
of our project officers have worked in
industry. While some people came
straight from college, overall the bias in
our Division is towards industrial
experience."
Beyond the individual expertise of
project officers, Forsht feels that ITD's
15 years of institutional experience have
made it a center of technical expertise
that's unique. "Most industry employees
are familiar with their own facilities and
product areas. Since our studies include
all the facilities in a given industrial
category, we gain an overall perspective
on the entire industry. And of course,
the more information we have, the less
likely we are to lose our cases in
litigation."
Forsht also feels that the review
process within EPA is extremely helpful
in developing guidelines. "The whole
process improves the quality of a
regulation," he says. "For example, from
my experience with the organic
chemicals industry, I think that
available technology can achieve any
quality of effluent a company selects.
It's just a question of what's achievable
versus what's affordable. The agency's
analysis of the economic impacts
provides another important basis for
collegial decision-making within EPA."
Will Forsht be sorry to see "his"
regulation finished?
"Well," he sighs, "it's all still on the
horizon. Even if we're not sued once the
guideline is promulgated, we'll spend
time putting on workshops and public
meetings explaining the regulation and
how it will work."
And then?
"And then," he says, "I'd like to go on
a six-month vacation." o
10
EPA JOURNAL
-------
Ensuring Safe
Drinking Water
by Joseph A. Cotruvo
(Dr. Cotruvo is Director of the Criteria
and Standards Division in EPA's Office
and Standard
of Drinking Water.)
SEPTEMBER 1985
Protection of our drinking water and
restoration of water supplies that
have become contaminated is a high
priority for EPA. In fact, 1985 will be a
banner year for the agency's efforts to
revise and strengthen national standards
and guidelines that underlie the Safe
Drinking Water Act of 1974 and are
designed to protect the safety and
quality of drinking water at the
household faucet.
There are more than 59,000
community water supply systems which
serve 25 or more people in the United
States, and about 150,000
non-community systems serving
non-resident populations. While
regulating them is generally a state or
local responsibility, EPA determines the
national regulations and standards used
to assure safety and quality (water
coming from the tap should not only be
safe to drink, but also should be of
esthetic-ally high quality, e.g. having
good odor and taste) and works with
states to enforce laws so that suppliers
will properly monitor, treat, and deliver
safe drinking water to consumers.
Although the Safe Drinking Water Act
is EPA's main legislative weapon
against contaminated drinking water,
most of EPA's operating laws are, to a
substantial degree, designed to help
prevent water pollution. The Clean
Water Act; the Resource Conservation
and Recovery Act; the Comprehensive
Environmental Response, Compensation
and Liability Act; the Federal
Insecticide, Fungicide, and Rodenticide
Act; and the Toxic Substances Control
Act all have elements designed to limit
the likelihood that consumers will be
exposed to health risks from
contaminated drinking water.
One unusual feature of the Safe
Drinking Water Act itself is the
requirement that suppliers notify the
public when their water supply
becomes contaminated or otherwise fails
to meet regulatory requirements, thus
11
-------
giving consumers an opportunity to take
an active role in assuring the safety of
the drinking water that is provided by
their puhlic water system.
What is the Drinking Water Safety
Problem?
Although fatal water-borne diseases are
no longer a major public health problem
in the United States, there are still
thousands of water-related
microbiologically induced illnesses
reported annually. Fortunately,
disinfection and filtration processes can
eliminate the cause of such illnesses.
On the other hand, there is increasing
concern over the risks posed by
chemical contaminants reaching some
drinking water supplies from toxic
waste dumps, agricultural use of
chemical pesticides, leaking
underground storage tanks, untreated or
ineffectively treated industrial effluents,
and from the disinfection processes and
the corrosion of pipes and equipment
within the water supply system itself.
While microbiological contamination
primarily produces infectious diseases,
the chemical pollutants can contribute
to risks from chronic toxicity or cancer.
Nitrates in drinking water in
agricultural areas, for example, can
cause a rare disorder in infants that
affects the ability of the bloodstream to
carry oxygen and results in a condition
popularly described as "blue babies."
These health concerns are generally
associated with failure to protect the
original water sources.
Source Contamination
Drinking water sources can be selected
that are free of significant biological
contaminants or protected from
potentially harmful contaminants of
human origin, but these same waters are
vulnerable to a variety of chemicals
usually related to pollution discharge.
Ground water in the vicinity of
improperly designed waste disposal
sites has often been found to be heavily
contaminated by migrating chemicals,
such as trichloroethylene, vinyl
chloride, or pesticides.
Many potential drinking water
contaminants are of natural origin.
There may be inorganic contaminants
such as common salts or trace toxic
substances like mercury. Nitrates are
common in agricultural areas. Among
Most of the verified outbreaks
of water-borne diseases were
caused by lack of proper
facilities or a breakdown in
equipment.
the inorganic contaminants are localized
deposits of arsenic or selenium and
sources of radionuclides such as radium
and radon gas from the ground. The
presence or absence of inorganic ions
such as calcium may be related to the
risks of cardiovascular diseases
associated with the degree of hardness
of drinking water.
The principal immediate risk from
drinking water contamination is still
biological in origin; most of the 392
verified outbreaks of water-borne
diseases between 1971 and 1982 were
caused by lack of proper treatment
facilities or a breakdown in such
equipment. There were 86,000 illnesses
associated with these reported
outbreaks, among them giardiasis and
hepatitis. It is believed that many more
outbreaks went undetected or
unreported.
Identifying and controlling the risks
of water-borne infectious diseases is
much simpler than detecting possible
carcinogenic risks. Many acute disease
effects can be identified by proper
population surveillance, then tracked to
their probable origin. Water production
systems can be sited, built, and operated
to reduce the risk of consumer exposure
to infection to an extremely low level.
Simply stated, everyone knows what
needs to be done to assure biologically
safe drinking water; the problem is
mainly a matter of getting it done in all
public drinking water supply systems.
In the case of biological water
contamination, the cause and effect
relationship became obvious through
experience. Epidemiologies] studies of
the spread of water-related diseases
provided straightforward risk
assessments. The wisdom of risk
management decisions such as source
protection and treatment was
immediately demonstrable without
recourse to elegant quantitative risk
extrapolation models and cost
projections. Chemical contamination is
another story. In all but a few
exceptional cases those three
elements—risk identification, risk
assessment by epidemiological data, and
demonstrable risk management
results—may never be available with
any degree of certainty.
Treatment Processes
Technology and operating procedures
are available to prevent the introduction
of many contaminants, and technology
is available to control virtually all of
them in drinking water. However,
consumer costs can be substantial,
especially for small public water supply
systems, because they cannot benefit
from economies of scale. A wide variety
of chemicals are added to drinking
water to remove various contaminants.
Among them are alum, iron salts,
EPA JOURNAL
-------
Everyone knows what needs to
be done to assure biologically
safe drinking water; the
problem is mainly a matter of
getting it done.
polymeric coagulant aids, chlorine and
other oxidizing agents, all of which may
leave Residues or byproducts in trje
finished water. In fact, the most
common source of synthetic chemicals
in treated drinking water is the
interaction of chlorine or other
oxidizing agents with the natural
products already there.
Distribution Systems
Also, a substantial amount of drinking
water contamination occurs while the
water is being transported to consumers
after treatment. Pipes are made of
copper, galvanized iron,
asbestos/cement, lead, or plastic, and
polymeric or coal tar coatings are often
used. All of these can contaminate
water, especially if the water is
corrosive to begin with. Lead, copper,
cadmium and polynuclear aromatic
hydrocarbons in finished water usually
come from the distribution of that
water, not from its original source.
Physical deterioration of the system can
also permit biological contamination.
What is EPA Doing About Safe
Drinking Water?
The Safe Drinking Water Act provides
the mechanism for developing national
standards and guidelines that define
safe drinking water. The Act's goals are
to identify substances that may have
any adverse effect on health and
determine the level that would result in
no anticipated harmful effects, with a
margin of safety. Determining a
permissible level of exposure to a
potentially toxic substance requires
evaluating qualitative and quantitative
factors such as the identity and health
significance of the effects, who among
those exposed to the substance is
sensitive to it, human biological factors
which may be involved in determining
the level of risk, and how the substance
will act in relation to other substances
in the same water.
EPA wrote interim primary and
secondary regulations in the mid to late
1970s for 36 inorganic and organic
chemicals, radionuclides, and biological
contaminants. Since then, drinking
water quality concerns have shifted to
ground-water contamination problems
and the unexpected finding that
numerous substances can migrate to
ground water because soil wasn't always
the protective barrier to aquifers that it
appeared to be.
Revised regulations are being
developed to update the original interim
standards and to expand them in
number and scope. Among the
emphases are ground water, water-borne
biological disease risk, and corrosion.
About 100 substances are being
examined for possible regulation.
Regulatory goals for the first group of
nine volatile synthetic organic
chemicals (e.g., trichloroethylene and
vinyl chloride) were proposed in June of
1984. In 1985, EPA has scheduled
proposals for promulgation of standards
for nine volatile organic chemicals,
fluoride, about 40 pesticides, inorganic
chemicals, and biological contaminants
including giardia and viruses, plus
radionuclides and monitoring
requirements for unregulated organic
chemicals. Disinfection
treatment-related contaminants are
scheduled for proposed standards in
late 1986.
A 1,000-community survey of
inorganics and radionuclides in
drinking water is nearing completion. A
joint Office of Drinking Water and
Office of Pesticide Programs national
monitoring program for pesticides in
ground water is also being developed.
New legislation amending the Safe
Drinking Water Act is moving through
Congress. This would increase the
number of regulated substances and
simplify the regulatory process.
In addition to developing legally
enforceable drinking water standards.
EPA's Office of Drinking Water also
provides guidance on numerous
substances detected in drinking water.
These documents are called Health
Advisories. They include useful
information in digest form on the
chemistry, toxicology, and treatment
technology of many potential drinking
water contaminants. One such advisory
dealt with permissible drinking water
levels of chlordane, an anti-termite
product used in many areas. The
advisories assist state officials and local
water suppliers in responding to
emergencies and interpreting the
significance of contamination by
unregulated chemicals.
The goal of EPA's drinking water
program continues to be the safest and
best possible water for all of our
citizens. Our primary means of attaining
this goal is expansion and revision ot
standards and monitoring so that
drinking water suppliers will provide
proper water treatment, while we all
work to avoid pollution of drinking
water sources. EPA and the states an;
active partners in this ongoing task that
is so critical to our nation's health, u
SEPTEMBER 1985
13
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Learning from
the Ten Mile River
by Dave Pickman
The Ten Mile River is 22 miles long.
While the name is geographically
inaccurate, it actually describes the river
well. Much less than half is river in the
ordinary sense; the rest is
wastewater -at times up to 90 percent.
Rising in the rural, wooded uplands
of Plainville in southeastern
Massachusetts, it passes over 15 dams,
through five ponds, past two municipal
sewage plants, a score of metal refining
and finishing plants and empties into
the Seekonk River in Rhode Island at
the head of Narragansett Bay.
The Ten Mile is one of the urban
industrial rivers chosen by EPA for
intensive study as a basis for reissuing
permits that will bring such streams up
to fishable and swimmable water
quality. The policy finally adopted for
the Ten Mile and other "effluent
dominated" streams may help to set the
pattern for controlling toxic pollutants
in water bodies everywhere.
Small, heavily contaminated rivers are
found in the Northwest, the Great Lakes
region, the Atlantic Coast, and the Gulf
of Mexico, some of them only
Industrialized in the mid-twentieth
century. Like the Ten Mile River, many
are contaminated by metal finishing
plants in the expanding "high tech"
category.
The Ten Mile has been a factory river
for almost two centuries. Its rapid drop
from 230 feet to sea level provides water
power to drive the wheels of industry,
and it has attracted entrepreneurs from
the earliest days of America's industrial
revolution.
Today, 20 factories and the two
municipal sewage treatment plants
discharge toxic metal waste to the Ten
Mile River. Hoth municipal plants
receive treated metal waste from
numerous other metal plating and
jewelry firms. Because of this
concentration of discharges in a small
stream rendered sluggish by numerous
dams, conventional treatment is
woefully insufficient to protect aquatic
life.
Conventional discharge permits, all of
which have expired and must be
renewed by October 1, 1985, are
technology based. The discharger of
heavy metals treats wastewater with
alum or a similar compound. This takes
metal ions out of solution in the form of
a whitish "floe" that is removed by
settling or filtration. To achieve greater
reductions, dischargers must alter their
i's on |/K; sluff ol l/n- Office ul
J'uhlic Alluirs hi l'.l'.\ Hcgion l.J
Action on
a Polluted River
The Ten Mile River in
Massachusetts is far too small to
dilute the heavy metals in the
effluent from jewelry,
electroplating, and metal refining
shops that crowd its shores. After
extensive study of the "effluent
dominated" river, EPA Region 1
Administrator Michael R. Deland
and Massachusetts Water Pollution
Gontrol Director Thomas C.
McMahon have decided to issue
renewal permits to polluting
industries and two municipal
sewage treatment plants based on
water quality rather than
conventional technology. That
decision will mean much more
stringent treatment requirements.
After this article was written, the
proposed new permits were
announced and the public
comment period began. The whole
nation will be watching the final
outcome as EPA and
Massachusetts press for fishable
and swimmable waters—even in a
stream that is up to 90 percent
effluent.
process to a "closed system" in which
there is no discharge, or install
treatment for all metals similar to that
which is used to recover precious silver,
gold, and platinum from plating baths.
Throughout the studies, in which one
Massachusetts and three EPA
laboratories participated along with the
University of Massachusetts and the
state Division of Fisheries and Wildlife,
the key variable was toxicity. Tests for
toxicity are like legal trials in which the
jurors are fathead minnows and tiny
invertebrates called daphnia pulex, or
similarly sensitive organisms. They vote
by dying or surviving, by reproducing
normally, abnormally, or proving sterile.
The measurement of toxicity is
painstaking. While the studies were in
progress, a total of 78 persons were
working, many of them college students
on summer vacation. Much of the labor
is in scientific sampling. That entails
bringing samples to the laboratory with
proper documentation as to when and
how they were gathered.
In a series of tanks, the test organisms
are exposed to known concentrations of
effluent or in-stream water samples
diluted with uncontaminated water
from far upstream. They are tested for
survival over given periods ranging from
one day to one week. They are tested for
the number of young they produce and
how many of them survive. The NOAEL
(no observable acute effects level) is
expressed in terms of dilution in
uncontaminated water. Except for the
waste from two industrial plants, the
NOAELs ranged from .035 per cent to
10 per cent, indicating that survival of
test organisms required dilutions
ranging from 150 to one to 10 to one.
"It's clear that we have a long way to go
to meet our own water quality
standards," said Steve Silva, who heads
up the industrial permitting section of
EPA's Region 1 office in Boston.
EPA JOURNAL
-------
Massachusetts and EPA scientists and
engineers have been struggling with the
Ten Mile River problems since
February, 1984, when EPA announced a
"National Policy for the Development of
Water Quality-Based Permit Limitations
for Toxic Pollutants."
At one point in the informal
discussions, the group considered
forcing all the industrial plants and both
municipal plants to cease all discharges.
Then someone pointed out that the dry
season flow at the Rhode Island line is
90 percent effluent. If the effluent were
eliminated, the river would become a
trickle in late summer. In technical
language, the river is "effluent
dominated." But it has other uses, most
of which depend on achieving
water-quality criteria.
Five good-sized ponds lie between the
narrow, often channelized segments.
One has beaches and swimmers. Fishers
try their luck in all the unchanneled
reaches, though the former trout stream
harbors only the hardiest species.
Although the fish flesh does not appear
to be heavily contaminated, the
sediments are. A spring flood could stir
up these sediments and poison the
stream all the way to Narragansett Bay
where valuable fishing and shell fishing
would be in the path of biological
destruction.
"We have to consider these sediments
as a real threat to water quality, even
though they are not affecting it right
now," said Silva. He and his associates
believe that a sharp reduction in metals
contamination would permit nature to
bury these heavy metals over the years
and; let them eventually combine with
other soil chemicals to become
stabilized. But effluents must be largely
demetallized before this natural healing
can begin.
Buildings of the Bal/our Company, a
jewelry manufacturer and metal plat'T.
line both sides of (he Ten Mile Hirer
during pur! of its passage through
Atfleboro, Mass.
"I think we're going to have to issue
tough permits," said Silva. "But this
won't be the end of the world for these
companies and these jobs. Most of the
larger companies will tie in with the
treatment plants as dozens of
neighboring plants already have done.
The municipal plants already discharge
nine times as much as all the direct
discharging companies combined, and
they have good reserve capacity. Some
companies might have to improve their
pretreatment. You can't have too much
metal coming in and upsetting the
biological treatment of organic waste.
And the municipal plants may have to
add more treatment for metals—and
charge the companies for the capital
costs and cost of operation and
replacement." Water quality-based
metals limitations would be added to
ensure that the plants meet standards
even with the additional industrial
tie-ins.
Three industrial plants already plan
to eliminate discharges either by process
changes or by tying in to one of the
plants. Perhaps others will be able to
shut off their discharge pipes during the
period allowed for the acquisition of
new equipment, process changes, or
discharge elimination after new permits
are issued.
There is no river too small or too
polluted not to be worth saving. That
belief was expressed by Congress when
it wrote the Clean Water Act in 1972,
and it was often repeated in subsequent
amendments. "Fishable and
swimmable" is the law of the land, and
you can't find anyone at EPA or the
Massachusetts Division of Water
Pollution Control who's willing to say
that they should back off. a
SEPTEMBER 198b
15
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On the Lookout
for Toxic Danger
by Betty Jackson
The expansion of America's economy
since World War II has been made
possible, in large measure, by the
development of thousands of synthetic
organic chemicals. These synthetics
have produced a range of wonder
fabrics, adhesives, and liquid chemicals,
but the byproducts of their production
have the potential to contaminate water
sources. EPA has been involved in
extensive research and testing to
measure the effects of these chemicals
on all parts of the marine ecology and
on human health as well.
Biologists point out that fish have a
unique sensitivity to toxicants added to
marine and estuarine waters by humans
either by design or accident. Although
humans may drink, bathe or cook with
water, fish live in water and thus are
natural sentinels for determining the
full impact of various synthetic
chemicals on their environment.
In the late 1960s, scientists began to
look at fish and shellfish for clues to the
origin and prevalence of cancer-related
diseases, including leukemia. The
National Cancer Institute (NCI) was the
prime mover in 1968 for a landmark
meeting at the Smithsonian Institution
to examine how fish pathology could
contribute to cancer research and to
stimulate the interest of scientists.
The Registry of Tumors in Lower
Animals was established at the
Smithsonian Institution to provide a
central repository and diagnostic center
for fish cancer and to aid in fish
pathology research.
[jurkson is (i Irrhm'nii ivnlcr ul EPA's
Environmental Hoscurcii l.ubomtory u(
Cull Breeze, Flu.J
In 1978, NCI and EPA launched a
collaborative research effort on the
relation of toxic chemicals and cancer
in the environment. Under the guidance
of NCI, a team of government and
university scientists organized by EPA's
research laboratory in Gulf Breeze, Fla.,
set out to determine if fish could be
used to monitor cancer in the
environment and develop a laboratory
test system to screen chemicals for their
potential to cause tumors in fish
populations.
Interest in the research was high. In
the mid-1970s, fishermen and scientists
noted unusual frequencies of tumors in
fish from the Puget Sound in
Washington State, the Hudson River in
New York, the Black River in Ohio, and
the Fox River in Illinois. The most
seriously affected fish fed on the
bottom, where chemicals concentrate
and can enter the animals' food chain.
The cancer rates varied with the fish
and their exposure to pollutant
effluents. The bottom-feeding flatfish in
Puget Sound appeared more vulnerable
than the migratory salmon that
inhabited the Sound only during certain
seasons. In other instances, some fish
appeared less vulnerable to tumors than
others.
Researchers in the NCI/EPA project
have identified both freshwater and
estuarine species that can be used in the
laboratory for experimental exposures in
cancer research. These species also can
be used for on-site testing of suspect
polluted waters.
Tests at Gulf Breeze concentrated on
an estuarine species, the sheepshead
minnow, because many coastal
problems with water quality originated
in estuarine or confined waters subject
to runoff from rains or located near
industrial outfalls. Wild populations of
the sheepshead minnow can be found in
the Gulf and Atlantic coasts as far north
as Massachusetts.
Scientists involved in the NCI/EPA
project have positive evidence that the
sheepshead minnow can be used to
identify cancer-causing toxicants, as
can other species, such as the
rainbow trout and the bullhead catfish.
Further work by the Gulf Breeze
laboratory also sheds light on how fish
metabolize and transport cancer agents.
The work on the fate of cancer-causing
pollutants could be the basis for a fish
biochemical screening technique for
cancer research within wild fish
populations.
The fast generation time of fish is one
of their distinct advantages in cancer
research. For example, it takes only
about six weeks for certain kinds of
minnows to mature following hatching,
so it is possible to detect the early stages
of liver cancer in 14 weeks and to see
the development of full-blown tumors
in less than 30 weeks. Researchers hope
to reduce this early detection time to
eight weeks for precancerous signs.
Fish species have other attributes as
environmental monitors, not the least of
which is cost. Fish are relatively small,
readily available, and can be
manipulated experimentally. Their
home in a laboratory can be as simple as
a desk-top tank or, at most, a somewhat
larger container with flow-through water
for saltwater species. Custom-built
laboratory trailers can be moved to
specific pollution sites for short- or
long-term exposure tests.
Unlike birds and other terrestrial
animals, fish are stationary and have
less chance of escaping an irritant. They
continually consume water, thus
insuring some internal exposure to test
chemicals dissolved in or carried by
their natural environment. As in
mammals, the liver of fish is the organ
16
EPA JOURNAL
-------
Pathobiologist John Couch ol KPA's
Environmental Research Lab in duff
Breeze. Flo., examines an .\-ruv of a
bluefish from (he /mites Hiver fo
diagnose possible cancer.
John Couch and Research Assistant
David Barfee prepon? fish (issues for
analysis of tumors.
that primarily attempts to detoxify any
contaminants ingested.
The most significant contribution of
aquatic animals in cancer studies,
however, may lie in their capacity to
bridge the gap between environmental
and laboratory evaluation of cancer risks
related to toxic chemicals.
From knowledge gained in laboratory
and fish studies, scientists should be
able to predict and verify responses of
representative fish species that are
exposed to toxics in the environment.
The value of fish species as indicators
or sentinels is ultimately that they may
eventually help to link cause and effect
in the larger environment, and warn of
unacceptable risks to humans from
specific chemical pollutants.
As a spinoff of the NCI/EPA project,
the Gulf Breeze research team
conducted a three-year field study
beginning in 1981 to examine wild fish
populations for diseases in the coastal
regions near Pensacola, Fla.; iMobile,
Ala.; and Pascagoula, Miss. No serious
outbreak of cancer was found, but the
team believes that the survey can be
used for comparisons in future years if
fish tumors become more prevalent.
The survey is regarded by the EPA
researchers as further evidence that fish
can help health officials uncover
pollution problems. If fishermen report
a high incidence of tumors in their
catch, regulators will suspect that
cancer-causing materials are present and
could prove harmful to those who use
the water or eat the fish. Generally, if
the fish are healthy, then the water
quality is good. If certain kinds of
disease or tumors are at a high
frequency, there is reason to suspect
that the water quality is not good.
Researchers from the Gulf Breeze
laboratory and universities who
participated in the NCI/EPA project
have published approximately 120
scientific papers and reports on such
topics as tumor induction studies, field
surveys in fish and shellfish, genetic
and mutagenic effects of cancer, and
analytical chemistry and biochemistry
of carcinogens in fish.
In addition, procedures developed for
fish bioassays of waterborne toxics have
been adapted in other laboratories
throughout the country. The research
team plans to continue development of
supplemental toxicity tests with fish as
well as novel cancer screening methods
that may be found serendipitously. It is
almost certain that several useful
methods will evolve from the project
which were simply not anticipated in
advance.
Fish species are making a vital
contribution to our understanding of the
impacts of chemical pollution on our
aquatic environment as well as on our
personal health. Fish combine so many
useful attributes for research and testing
that their future involvement in this
work seems assured, u
SEPTEMBER 1985
17
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Protecting Ground Water
from Pesticides
by Carol Panasewich
Ground water—a vast, invisible
natural resource, moving through
channels hidden (loop beneath the
earth's surface. Silent and mysterious,
connecting countries and peoples,
ground water is the lifeblood of our
mother, the earth.
Scientists define ground water as
"that water which occurs in the
subsurface in a zone of saturation,
when; ail interconnected voids in the
rock are filled with water." In lay terms,
ground water is water that lies below
the surface of the ground and can be
drawn into a well. It can be found
anywhere from just below the surface of
the ground (for example, in swamps) to
thousands of feet down.
The volume of ground water within
the earth is not known precisely, but it
is estimated that 33 to 59 quadrillion
Contamination of ground
water may often be regarded
as virtually permanent.
gallons of ground water (more than four
times the volume of the Great Lakes) lie
within a half mile of the earth's surface.
This ocean of ground water moves
much more slowly than a river,
traveling in the range of only a fraction
of an inch to a dozen feet per day.
Ultimately, ground water does discharge
itself into oceans, streams, or lakes. Hut
since it may take many years for this
natural recycling process to be
completed, contamination ot ground
water may often be regarded as virtually
permanent.
Until recently, the layers of soil and
rock between man and ground water
(Pcma.wmrh is a writer in the K/'.A
Of/ire of Pesticide /'rognnns.J
were thought to protect that resource
from contamination. Pesticides, used
intensively in some agricultural and
other areas, were thought to be absorbed
by and bound to the soil until they
degraded. Some pesticides were found
to run off from the site of application
into bordering ponds, lakes, or streams,
but ground-water contamination by
pesticides was unknown until the late
1970s. In 1979, DBCP was found in a
number of wells in several states and
aldicarb was discoveretl in New York
ground water, confirming what some
agency scientists and others had
suspected for several years. Certain
pesticides can and do travel from the
site of application, through soil and
rock layers, and leach to ground wrater.
As EPA's knowledge and
understanding of the characteristics and
movement of ground water have
increased, so has our curiosity and
concern about the presence of pesticides
in ground water. Unfortunately, the
more we look, the more we
find—detections of pesticide residues in
ground water are increasing. To date, 16
pesticides have been detected in ground
water in 23 states as a result of normal
agricultural use, as opposed to improper
disposal, spills, or other accidents
involving those pesticides.
The agency is concerned because
people may be unknowingly exposed to
unduly high levels of pesticide residues
by drinking water from contaminated
wells. Almost half of the U.S.
population obtains its drinking water
from ground water rather than surface
water. Further, the use of ground water
is increasing faster than is the use of
surface water.
Response
In response, EPA is taking aggressive
action, exercising all the pertinent
authorities under its jurisdiction to
protect public drinking water. To
control pesticides in ground water, the
agency is using the far-reaching
provisions of the amended Federal
insecticide. Fungicide, and Rodenticide
Act (FIFRA). Under that law, EPA is
empowered to act on society's behalf to
prevent any "unreasonable adverse
effects" on people or the environment
resulting from pesticide use. The agency
must consider and weigh both the risks
and the benefits of each pesticide use in
order to determine whether it passes the
unreasonable adverse effects standard of
FIFRA.
In assessing the degree of risk
presented by a pesticide, EPA considers
its toxicity as well as all possible routes
of exposure. Without human or
environmental exposure, even the most
toxic chemical poses no risk. Pesticides
that leach to ground water that is used
for drinking provide increased
opportunities for human exposure. They
may, therefore, present unacceptable
risks.
When a pesticide is found to pose an
imminent hazard or undue risks to
people or the environment. EPA may act
to temporarily suspend or permanently
cancel its uses. The compound DBCP,
for example, was the subject of a series
of such regulatory actions by EPA
between 1977 and early 1985. A
chemical capable of causing cancer,
gene mutations, and male sterility,
DBCP was canceled for most
agricultural use during the late 1970s.
When DBCP was found in wells in
California as well as other states,
apparently as a result of normal
agricultural use of the pesticide, other
remaining uses also were canceled after
an exhaustive court battle. Recently, the
last use of DBCP, in Hawaii's pineapple
culture, was finally canceled after
IH
EPA JOURNAL
-------
Pesticides /codling info the ground
ivufer from a vim-racd such as (his
could be a threat to drinking ivutor
supplies.
residues of the pesticide were found
contaminating wells near pineapple
fields in Oahu and Mani.
A number of other less drastic but
nonetheless effective regulatory
remedies under FIFRA are being used to
address problems from pesticides in
ground water. If a situation raises
serious questions, but an imminent
hazard is not thought to exist. EPA nun-
conduct a special review of the
pesticide. This review may or may not
lead to initiation of cancellation action.
For example, EPA currently is
evaluating aldicarb under a special
review because that pesticide is acutely
toxic to the nervous system and leaches
to ground water.
The agency may also decide that the
problem could be addressed through the
restricted use provisions of FIFRA. That
is, EPA may restrict the use of the
pesticide to certified applicators
(limiting who may use it), or may
impose geographical limitations
(controlling where it may be used). As
an example of the first type of
restriction, the agency has decided to
restrict the use of simazine and
cyanazine to certified applicators, and
to require an advisory statement on the
labels alerting users to the potential for
leaching to ground water. While the
producer of c.yanaxine has agreed to
restrict the use of that herbicide
voluntarily, the simazine registrant has
objected to the restriction. EPA is
therefore in the process of initiating a
notice of intent to cancel sima/ine
registrations so that the matter may be
addressed in administrative hearings.
should the registrant so desire. A good
example of the geographical type of
restriction is aldicarb, which may not be
used at all in Suffolk County, N.Y., and
Del Norte County, Calif., and is subject
to various restrictions in other states
because of ground-water concerns.
Jhom McDermorr Photography
SEPTEMBER 1985
19
-------
Assessment and Prevention
While some pesticides in some
agricultural nreas have leached to
ground water, not all do or will. (Hased
on our current knowledge, we estimate
that less than ten percent of all pesticide
active ingredients are leachers.) To gain
control over the pesticides in ground
water problem, KPA must determine
which pesticides are sufficiently mobile
and persistent to leach; which
geographic conditions are conducive to
lc,idling; which agricultural practices
enhance leaching potential; and where
leaching has occurred or is likely to
occur.
By vigorously implementing some
additional authorities under FIKRA.
EPA can assess the extent of the
problem of pesticides in ground water
and can prevent future unreasonable
risks.
In order to register a pesticide product
for use outdoors, the manufacturer must
submit data demonstrating what will
happen lo the chemical under
conditions of use in the environment.
These laboratory and field data on
environmental fate are used to predict
which chemicals are sufficiently
persistent and mobile to leach to ground
water, and in which soil types. KPA is
currently obtaining such data, both for
new pesticides first coming on the
market and for a group of over 100
existing pesticides which may possibly
have some leaching potential. New
pesticides that can leach may be denied
registration or may be registered with
The only way to detect actual
levels of pesticides in ground
water is to conduct monitoring
studies.
use restrictions on their labels.
Registered pesticides which are leachers
may be restricted, suspended, or
canceled.
The results of environmental fate
studies can be entered into computer
models to predict the movement of
pesticides through soil under various
environmental conditions. These models
organize all the available data on
meteorology, geology, and
environmental fate into a consistent and
reproducible prediction of chemical
behavior in soil. EPA uses one such
model to predict how likely pesticides
are to leach and is developing more
sophisticated models for the future.
Using environmental fate data and
leaching models, EPA can assess the
contamination potential of pesticides.
However, the only way to detect actual
levels of pesticides in ground water is to
conduct monitoring studies.
Well-planned, systematic monitoring for
pesticides in ground water has not yet
taken place on a large scale, though the
states, EPA and other federal agencies,
and pesticide registrants have all
contributed a considerable number of
small-scale monitoring studies.
To fill this need for comprehensive
monitoring, EPA's Office of Pesticide
Programs and Office of Drinking Water
are designing a national survey of
pesticides in drinking water from
ground-water sources. The survey,
which should be underway next year,
will be statistically designed so that
national inferences can be drawn from
the results. Future monitoring and
regulatory efforts may be more
accurately targeted based on the results
of this EPA survey.
By responding to existing
contamination problems, determining
the full extent of the pesticides in
ground water problem, and preventing
future unreasonable risks from
pesticides in ground water, EPA is
gaining control over the situation. To
organize and coordinate these efforts,
the agency is drafting a comprehensive
strategy which will be available for
public review in several months.
Dealing with ground-water questions
is highly complex, and given these
complexities, there are many issues to
be dealt with in EPA's development of
its pesticides in ground water strategy.
We expect a broad debate on many of
these issues as the strategy is developed.
There is much to be done, but a good
start has been made, a
,'u
EPA JOURNAL
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.__
A Systems Approach
Challenge for EPA
by Lee M. Thomas
In a recent speech, EPA
Administrator Lee M. Thomas discussed
a major challenge at EPA—moving
toward a whole systems approach to
environmental decisions. Thomas spoke
at a meeting of the Natural Resources
Council of America. Here are excerpts
from his speech:
Nations! Oceanic and Atmospheric Administration
A pmver plunt in the mid-Atlantic eimstal /one. Pollution in our medium
such as dir con (ravel lu another medium such us ivuter.
For the past 20 years our
environmental movement has been
teaching a series of great lessons to the
American people. It has taught that the
environment is a seamless web, that
everything is connected to everything
else. If you try to kill bugs in a
thoughtless way, you may well end up
killing fish, birds or animals.
Right now the major source of several
toxic metal pollutants in the Great Lakes
is air deposition. In the upper Great
Lakes, air deposition is also the
principal source of PCBs. We are also
starting to see a rise in the
concentration of banned pesticides in
Great Lakes fish. We are not sure where
it comes from yet, but there is a good
possibility that it blows in on the air
from hundreds of miles away. It's
obvious that no amount of cranking
down on water permits is going to stop
this sort of water pollution.
In several of our largest cities, a
significant source of toxic air pollution
may be industrial volatile organic
compounds, which evaporate at
municipal sewage treatment plants.
Tightening pretreatment standards may
not solve all of the problems because
the volatile organic compounds may
still end up in the air if the industrial
source plants do not dispose of the
waste properly.
Water pollution control also produces
an enormous amount of solid \v,istr.
Municipal wastewater treatment plants
will he generating 10 million tons of
sludge annually by 1990. Some of these
sludges are contaminated by toxic
metals, and finding a safe place to put
them has become an increasingly
difficult problem for some of our
industrial states.
Finally, in our efforts'to control air
pollution from industrial point sources,
we have caused a substantial water
pollution problem. It is entirely possible
that somewhere in the country, toxic
metals are being removed from the air,
transferred to a wastewater stream.
SEPTEMBER 198fc
21
-------
removed again via water pollution
controls, converted to sludge, shipped
to an incinerator, and returned to the
air.
Now it should be clear from these
descriptions that cross-media transfer is
a real problem. And it bears the
potential for compromising the
hard-won achievements of our major
There is no mandate for
environmental regulation that
produces only a fast shuffle.
environmental programs. For while the
American people have made clear their
willingness to sacrifice and spend in
order to obtain tangible environmental
improvements, there is no mandate for
environmental regulation that produces
only a fast shuffle. People get very
disturbed when they are given
assurances that a pollution problem is
"solved" and then find that it has only
been brushed under the rug. We cannot
afford to risk the loss of public
confidence that this kind of discovery
engenders.
What does that mean for EPA? First of
all, it means that we have to find a way
to analyze whole systems as we create
regulations. Since pollutants are going
to move among the media, we need
some standard for judging whether to
encourage the move or to try to stop it. I
should say here that cross-media
transfer is not of itself a bad thing. The
fact is, pollution control is often nothing
/Jiil cross-media transfer. If the choice is
between, say, letting chromium dust
float around in the air and putting it
into a can. it may make sense to put it
into a can. As long as you remember to
watch the can.
For most pollution control situations,
where human health protection is the
highest priority, our standard for
judgment is a quantified estimate of
risk. Despite well-known uncertainties
associated with such estimates, they
remain the only feasible way of
assessing the probable effects of
cross-media transfer.
This is one of the reasons we have
advanced the idea of risk assessment
and management so strongly at EPA in
recent years. The risk management
approach includes the idea that risk
from pollutants is rarely eliminated
through controls. We expect controls to
reduce risk, of course. But we can't
know how much reduction we have
really obtained unless we carefully track
the controlled material through all of its
man-made and natural transformations.
Then we can assess and compare the
risks associated with each of them and
devise a control solution for the whole
system.
Current EPA policy is beginning to
support this approach by requiring
appropriate regulatory packages to
include a statement of what the
outcome of the regulation will be in
terms of risk reduction. It must
specifically consider the risk effects of
any cross-media transfers associated
with the control practice.
A number of other significant
cross-media initiatives are under way.
For the past 18 months we have been
engaged in a major review of our
statutory base. Part of this review was
directed at how our statutes dealt with
the undesirable cross-media transfer. We
found that the statutes generally give us
room to consider cross-media effects in
our regulatory decisions as long as there
are adequate data to document them.
One problem we have, however, is that
single-medium programs frequently
don't collect data on cross-media
impacts.
We are therefore trying to include
cross-media considerations in initiatives
that deal with major remaining
single-medium problems. As already
noted, we have found that in some areas
substantial air pollution may be the
result of sources such as hazardous
waste management facilities and
wastewater treatment plants. An
important part of our forthcoming
strategy to control toxics in the air
therefore deals with these sources.
Such considerations require a new
kind of information. We must continue
to direct resources into integrated risk
analysis. For example, we must track
the flow of particular kinds of
pollutants through complex natural or
pollution control systems. We can do
this for particular chemicals of concern,
like dioxin, or for a series of wastes
flowing through a particular part of the
country. Under our integrated
environmental management programs,
we are currently studying the "cradle to
grave" system of hazardous waste
control in the New England region. This
analysis will examine how well current
or proposed controls reduce risk in the
environment as a whole.
For the past few years we have been
looking at several industrial regions
from the standpoint of integrated risk
management. Such regions are likely to
have more serious toxics problems than
the rest of the country. The purpose of
such geographic projects is to help state
and local authorities figure out the most
efficient way to minimize toxic risk,
taking all media into account.
From the national perspective this
approach enables us to concentrate our
attention and resources in those
particular places where the threat to
human health is likely to be highest. We
intend to expand our use of this form of
analysis. A number of states have
expressed interest in operating
geographic projects on their own. We
are making our experience available to
them through six state pilot
projects—cooperative, jointly funded
efforts that we have launched this vear.
This agency is bound up in
more timetables than the
Union Pacific.
Finally, we intend to build a
cross-media priority into our annual
planning process. This process produces
the annual guidance on which the
operating programs base their year's
work. By combining the planning efforts
of all the media offices into a single
coordinated process, we may help to
avoid the inadvertent cross-media
transfers that have characterized many
of our previous control policies.
These and similar initiatives will help
to change the agency's perspective on
cross-media pollution, in that we have
the time to figure out the best way to
minimize risk across all media and the
flexibility to change the way we do
things now. But as everyone knows,
time and flexibility are the two things
we have the least of. This agency is
bound up in more timetables than the
Union Pacific. The majority of EPA staff
is driving as hard as it can to get
single-purpose regulations out the door
in response to court orders and
Congressional mandates. Their main
EPA JOURNAL
-------
priority, often their sole one, is to make
their slice of the pie as effective and
defendable as it can be.
As for flexibiliy, the single-medium
approach is set up like concrete in the
practical, day-to-day administrative
operations of EPA. As Administrator, I
must protect each individual medium as
the law directs. While I may consider
other media in so doing, no statutory
phrase tells me to look at the
environment as a whole and control
pollution so as to allow the minimum
negative effect on public health and
other environmental values.
But surely that is what is needed.
Surely that is what environmentalists
want.
If EPA is ever going to live up to its
name in the fullest sense, if it is ever
going to become more than a holding
company for single-medium programs,
we are going to have to re-examine the
roots of environmental policy.
The current statutory structure arises
from a general environmental strategy
that has been accepted—consciously or
not—by nearly everyone who has
worked for environmental protection in
this country. Let's call it the strategy of
the cork.
It consists of putting a regulatory cork
in every pollution source you can find
as quickly as you can. At first the corks
may be somewhat loose and some
pollution escapes. But with advances in
technology they can be pushed in
It has become clear that each
push of the cork is more
expensive than the one before
it.
tighter. Of course, as we have seen, the
pollution will tend to squirt out in new
and unexpected places. The solution is
a new set of corks, and the process of
jamming them in begins all over again.
The idea is that if you get enough corks,
and put enough pressure behind them,
pollution will eventually be eliminated.
Let me repeat here that I do not
question the success, up until now, of
this medium-by-medium strategy. The
single-medium approach has worked.
We breathe it and drink it every day. No
one would quibble over the progress we
have made since 1970 in cleaning up
our air and water.
But we know things now that we did
not know 15 years ago. We are trying to
control many more pollutants. We have
to accept the fact that this general
environmental strategy may be flawed.
We have to recognize that the
cross-media problem is a symptom of
that flaw. We must come to understand
that the present approach was
necessary, but is no longer sufficient for
continued environmental progress.
Here are some observations to support
that statement. First, it has become clear
that each push of the cork, each
increment of pollution control, is more
expensive than the one before it. Yet it
accomplishes less in the way of risk
reduction. Cross-media transfer of risk
makes this ugly fact even less attractive.
Second, as we look around the world,
we see that the nations that are doing
the best job on environmental protection
are those that are both prosperous and
free. The environmental movement has
a stake in the prosperity of the country.
The American economy has been able to
absorb environmental expenses up to
now with little strain. That doesn't
mean it's invulnerable. Remember that
absolute purity is infinitely expensive.
It follows that all reasonable
environmental policy discussions must
deal with the question of where to stop.
How clean is clean? How safe is safe
enough? Since we now understand from
our analyses of cross-media transfer thai
every real resting place for pollution
entails some residual risk, it appears
that some corks are going to have to stay
loose for the indefinite future.
How do we move toward an improved
environmental strategy? I think we have
to keep the whole system in mind
whenever we make policy. The kind of
integrated analysis I have been
describing will help us to do that. At
the same time, we have to remember
that every pollutant winds up
someplace, and it's best for us to decide
in advance where we want it to go. We
have to learn to accept the risk
associated with its best final resting
place.
Finally, we have to get serious about
source reduction. Do we want industry
to spend its money mopping up ever
smaller increments of risk, or do we
want those resources spent developing
processes and products that pollute
less? There is already a trend towards
source reduction in this country. I'm not
sure that we encourage this trend by
continually mandating new and more
stringent controls. We need fewer fire
drills and more fire-proofing.
In closing, I want to reiterate very
briefly a few ideas I have on how an
agency like EPA should address
cross-media issues. Some of these
approaches are already policy. Others
are still in the thinking stage. A few
may require development of new
legislative authorities before we can
actually carry them out. I'll be looking
at these and other ideas in the months
ahead, and I need input and advice:
Remember that absolute purity
is infinitely expensive.
• We need to review ail of our
legislative authorities to determine
whether language written to afford
protection to a single environmental
medium in fact encourages unwanted
effects in other media. Where we find it.
we must be prepared to seek statutory
changes. Congress never intended to
mandate a game of environmental
musical chairs.
• We must have a cross-media focus in
our planning, budgeting, program
evaluation, and implementation
processes so that the work we do
reflects a multi-media perspective,
• We need consistency in our risk
assessment and risk management
activities across all media. In this way.
the risk assessments we reach will be
comparable with one another. Our
decisions and our policies will be
uniform and compatible.
• Systems impact statements should be
prepared for all single-medium
regulations so that we do not overlook
cross-media implications of our
decisions.
• Finally, the statutes we implement
should allow more time for cross-media
analysis before promulgation of new
rules. It is time for Congress to
recognize that each of our decisions will
be felt throughout our environmental
system, regardless of which statutory
authority we use to reach it. W«; need
the time and the flexibility to put
together consistent and workable
policies. And we need to be held
accountable for them, a
SEPTEMBER 1985
23
-------
Senior Executive Shifts
at the Agency
HonrjJd Hnmd
Marcia E. Williams
Dr. John H. Skinner
EPA Administrator Lee M. Thomas
recently announced the reassignment
of seven senior agency executives as
part of an ongoing management program
designed to increase the diversity of
experiences for top and mid-level
managers throughout EPA.
The executives chosen for this round
of reassignments were all selected
because of their sustained high
performance, recognized technical
competence, and strong leadership
skills. Each is being assigned a major
leadership post in a top priority
program.
"In coming months, I intend to
announce additional reassignments,"
Thomas said. "I am confident that this
approach to management will become a
part of EPA's institutional framework."
The reassignments were to be
effective on different dates.
Effective August 1, 1985:
Ronald Brand, who has been Director of
the Office of Management Systems and
Evaluation, in the Office of Policy,
Planning and Evaluation, was named
Director of EPA's new Underground
Storage Tanks Program in the Office of
Solid Waste and Emergency Response.
Aided by his extensive management
experience, he will be responsible for
carrying out those provisions of the
Resource Conservation and Recovery
Act dealing with the identification,
regulation, and maintenance of
underground storage tanks containing
hazardous materials.
Dr. Thomas Ingersoll has been named
Acting Director of the Office of
Management Systems and Evaluation.
Effective September 1, 1985:
Marcia E. Williams, Deputy Assistant
Administrator for Pesticides and Toxic
Substances, will become Director of the
Office of Solid Waste. A 1985 recipient
of the Presidential Rank Award as a
Meritorious Senior Executive, she will
be responsible for implementing EPA's
hazardous waste management regulatory
program under the Resource
Conservation and Recovery Act.
Susan Vogt, currently Director of the
Asbestos in Schools Program, will serve
as Acting Deputy Assistant
Administrator for Pesticides and Toxic
Substances.
24
EPA JOURNAL
-------
Henry L. Longest, If
William .V. Hedeman, Jr.
Victor J. Kinini
Michcu'l 15. (,'ook
Dr. John H. Skinner, Director of the
Office of Solid Waste, assumes duties as
Director of the Office of Environmental
Engineering and Technology in the
Office of Research and Development. He
brings to the program a strong
understanding of research needs,
particularly in the hazardous waste and
ground-water management area, and
experience in technical assistance and
technology transfer.
Dr. Skinner will replace Carl Gerber,
who is taking an assignment with the
National Science Foundation to work on
international scientific issues.
Effective October 1, 1985:
Henry L. Longest, II, Deputy Assistant
Administrator for Water, who currently
serves as Acting Assistant Administrator
for Water, will become Director of the
Office of Emergency and Remedial
Response. An experienced engineer who
has been instrumental in the
development and implementation of
EPA's sewage treatment construction
grants program, he will be responsible
for implementing the Superfund
program for cleaning up abandoned and
uncontrolled hazardous waste sites.
William N. Hedeman, Jr., Director of the
Office of Emergency and Remedial
Response, will take over as Deputy
Assistant Administrator for Water.
Hedeman, an attorney and experienced
manager, has broad knowledge in water-
related matters in part from heading the
Superfund program for four years as
well as from previous positions in
EPA's Office of Federal Activities and
the U.S. Army Corps of Engineers.
Also effective in October:
Victor J. Kimm, Director of the Office of
Drinking Water, will become Deputy
Assistant Administrator for Pesticides
and Toxic Substances. A seasoned
manager with a variety of policy
experiences, Kimm will be able to draw
on his water office experiences when
addressing such issues as the
contamination of ground water by
pesticides.
Michael B. Cook, Deputy Director of the
Office of Solid Waste, will become
Director of the Office of Drinking
Water. Cook has broad experience in
water-related issues from his current
assignment, where he must deal with
ground-water contamination problems,
as well as from previous posts in the
water program, o
SEPTEMBER 198b
25
-------
Taking the Initiative
in Hazardous Waste Siting
by David Morell
Public concerns over toxic wastes
grow with each truck accident
spilling hazardous materials on a
crowded freeway, each underground
tank leaking hazardous solvents into
underground aquifers, and each
chemical leak at a factory or toxic
dump. There are clamorous demands to
officials at all levels of government: "Do
something."
But while concern is mounting, places
to dispose of hazardous waste are
disappearing. In 1980 Southern
California had five operating toxic
landfills; by the end of 1984 it had
none. The BKK Corporation's landfill in
West Covina, the largest hazardous
waste landfill in the country, closed its
gates to any further disposal of
hazardous wastes on November 30,
1984.
The region is now at a critical
juncture: It must take action to treat
these wastes instead of dumping them
on the ground. For the past four years,
the counties and cities of Southern
California, working with state agencies
and the federal Environmental
Protection Agency, have been
addressing the dilemma of building new
hazardous waste facilities despite local
fear and opposition. Pressures to find
new sites for facilities to treat the
region's hazardous waste—some 2.5
million tons of it every year—are now
very powerful.
The nation's shift from land disposal
to treatment began here in California in
1981. That was the year the state
adopted new regulations banning land
disposal of selected categories of
dangerous wastes: strong acids, heavy
metals, cyanides, and polychlorinated
(Until recently. Morell ivus a Senior
Policy Aiidlyst for h'PA's He.uion .'). fie is
scheduled (o lake tin.1 post of Sprciui
Assisfdiil |or Toxics' Management for
Simtu (,'luni (.'iMinh , (.'ulifoniia. where
Si/icon Valley is locafod. A/ore/l's
(irlicle originally appeared in (lie Los
Angeles Times. II does not necessarily
reflect the views of KPA.J
biphenyls (PCBs), among others. These
wastes were to be treated instead.
Unfortunately, due to a loophole, little
change ensued. Millions of tons of
wastes continued to be dumped.
In 1984, however, a new state law
closed this loophole. And last
November a revised version of the
federal statute regulating hazardous
wastes carne into effect. This law
incorporates for nationwide
implementation the entire "California
list" of those hazardous wastes being
phased out for land disposal, and
requires the EPA to determine that
waste is safe before it can be placed in
the ground.
But can the needed sites be found for
treatment facilities? Despite continuing
controversy, the answer is a qualified
yes. Although there was opposition,
Los Angeles in 1984 approved an
application by BKK to build a large
treatment plant in the industrialized
Wilmington area near the harbor. Local
residents objected, however, and
subsequent litigation has stalled
construction.
Last December, Los Angeles County's
Board of Supervisors unanimously
appropriated $500,000 to find 10 to 15
locations for new facilities for the
treatment or transfer of wastes, and for
the ultimate placement on land of the
de-watered residues. These "residuals
repositories" would use covers to keep
the treatment residues dry from the day
of deposit. A draft report has identified
20 possible locations in urban-industrial
areas, and six possible locations for
residuals repositories.
Last month, representatives of five
Southern California counties—Orange,
Riverside, San Diego, Santa Barbara, and
Ventura—and two cities—Los Angeles
and San Diego—formally signed a joint
powers agreement creating the Southern
California Hazardous Waste
Management Authority.
Under the regional authority, each
county and major city commits itself to
find sites for new hazardous waste
facilities in proportion to its own share
of waste generation. Actual decisions on
sites will continue to be made by the
individual jurisdictions, under their
existing land-use authorities, but the
decisions will now be made in a
regional context.
Finding sites, never easy, now at least
seems conceivable as regional economic
necessity and the politics of equity take
precedence over the politics of
parochialism and local resistance.
Yet the very public fears that now are
pressing governments throughout
Southern California to act seem
ironically to be paralyzing corporate
action. In the wake of the Bhopal
disaster in India, insurance companies
are backing away from corporate
liability policies. Unable to obtain
adequate insurance, large corporations
are reconsidering plans to build new
treatment facilities.
Thus we see an odd situation.
Southern California is poised to erect a
dozen or more new hazardous waste
treatment facilities, but private firms
may not be willing to build them.
What choices do we have? A retreat to
the era of leaky landfills and surface
impoundments is out of the question.
Nor can we rely forever on
long-distance trucking of dangerous
wastes over crowded freeways. And the
inequity of moving the region's waste
elsewhere is politically untenable.
While a national dialogue is being
pursued on liability and insurance, it is
of overriding importance to sustain the
powerful political momentum apparent
in Southern California. It may become
necessary for state or local governments
to construct and operate the facilities, or
for the state or federal government to
provide adequate liability coverage as a
supplement to private insurance. For
there is no doubt we must protect the
area's 15 million residents from the
threats posed by a growing mountain of
toxic chemical waste, while allowing
the region to maintain its huge
industrial base, n
EPA JOURNAL
-------
A Perspective on
the Siting Issue
by John H. Skinner
Without a doubt, the siting of new
hazardous waste management
facilities is one of the more
controversial issues in the entire
environmental arena; yet it is clearly
one with which the nation must begin
to grapple effectively and immediately if
we are to succeed in properly managing
hazardous wastes under the new
Resource Conservation and Recovery
Act (RCRA).
Our experiences with many present
waste disposal practices point up the
great need for upgrading waste
management techniques. Inspections of
existing land disposal facilities have
exposed numerous instances of
improper disposal techniques and
insufficient monitoring capabilities.
Many existing treatment, storage, and
disposal facilities either cannot or will
not commit to the upgrading necessary
to achieve final permit approval;
therefore, their operations will
terminate. Ground-water protection
needs, the development of new, more
sophisticated treatment technologies, as
well as the probability that at least some
wastes will be entirely banned from
land disposal pursuant to new
(Dr. Skinner Inis l)t;rn DJrcrfor of I'.l'A's
OHi(.'l
Environ men fal /•Jig/ncrn'ng un
-------
Tackling Toxics
from Motor Vehicles
by Margherita Pryor
Motor vehicles contribute heavily to
iiir pollution problems. In some
areas without major "smokestack"
sources, they are the pollution problem.
Of the seven criteria pollutants which
EPA regulates under National Ambient
Air Quality Standards, vehicles are far
and away the primary source for lead
and carbon monoxide, and are also a
significant source for nitrogen oxides,
ozone-forming hydrocarbons, and
particulates. Mobile sources also emit
known carcinogens such as
benzo(a)pyrene, EUB, ethylene
dichloride, formaldehyde, and various
chlorinated hydrocarbons such as
benzene.
Cars not only emit pollutants
directly; sometimes their emissions
react with other substances in the
atmosphere to form additional
carcinogenic, rnutugenic, or toxic
compounds, Formaldehyde!, for
instance, forms not only in exhaust
gases, but also in the atmosphere
through photochemical reactions among
many kinds of hydrocarbon emissions.
Some constituents of particulate
emissions have been found in
experiments to become more mutagenk:
when mixed with ozone and nitrogen
oxides. And the entire automobile
fueling process is a fertile source of
hydrocarbon emissions from bulk
terminals down to local service stations.
EPA has found that many toxic
emissions from motor vehicles are
controlled surprisingly well by the
standard catalytic converters originally
developed to control carbon monoxide,
hydrocarbons, and nitrogen oxide. The
converters have been found to remove
up to 90 percent of some toxic
compounds.
But EPA is not depending solely on
indirect controls. In January 1986, the
lead content in leaded gas will be
limited to a maximum of 0.10 grams per
gallon. This will have three immediate
effects:
• it will reduce direct emissions of
lead;
• it will reduce emissions of the lead
additives EDB and ethylene dichloride.
EDB emissions alone will drop from
300,000 pounds this year to 27,000
pounds in 1986;and
• it will protect catalytic converters—
which are designed to work with
unleaded fuel—from the disabling
effects of leaded gas, and thus provide
continued control of toxics.
EPA has taken steps to limit
significantly the emission of particulate
matter from diesel motor vehicles. This
action has come in part due to concerns
about the carcinogenicity of diesel
particulates. Beginning in 1987, diesel
cars nationwide will employ new
devices called trap-oxidizers to reduce
particulate emissions. Recently enacted
rules affecting trucks and buses will
also control about 50,000 tons per year
of diesel particulates by the year 2000.
As a result, the health risk from diesel
particulates should be considerably
lower than would otherwise be the case.
EPA is also taking new steps to
control hydrocarbons associated with
gasoline marketing. The agency
currently is considering two alternative
control methods:
• Requiring stage II vapor recovery
systems in gasoline stations. These
systems recycle gasoline vapors through
special fuel nozzles to prevent the
vapors from escaping into the
atmosphere; or
• Requiring factory installation of
on-board control systems, which
include built-in vapor seals in auto fuel
tanks.
Another step to control hydrocarbon
emissions involves the development of a
strategy dealing with fuel volatility.
Evaporative hydrocarbons now account
for one-third of light-duty hydrocarbon
emissions. Evaporative controls on
vehicles are not doing the job they are
designed to do, in part due to the
durability of the controls and in part
due to the highly volatile gasoline now
being sold. Because commercially
available fuel is more volatile
than the fuel currently used to certify
cars for production, EPA is considering
requirements that cars be certified to
meet the standards with commercial
fuel, or that the volatility of commercial
fuel be limited.
The agency is also developing fuel
certification procedures to control the
increased formaldehyde emissions from
cars designed to run on methanol fuel.
Other actions include development of
testing protocols for new fuels and fuel
additives, as well as continued
re-evaluation of motor vehicle
standards.
There is a long way to go before toxic
emissions will be controlled to the
agency's satisfaction. But real progress
has been made and will continue to be
made in the motor vehicle area, n
A'-:
EPA JOURNAL
-------
Tracing the History
of ERAMS
by Miles N. Kahn
In October of 1976, routine monitoring
activities at the Peach Bottom Atomic
Power Plant detected radioactive
iodine-131 on the hands and shoes of
plant personnel. Further tests revealed
that the area around the complex was
"highly contaminated." Personnel
notified the Pennsylvania Department of
Environmental Resources that there was
an external radiation problem at the
plant.
The day after the initial report, plant
safety personnel began decontaminating
employees' shoes and vehicles and
sending nonessential workers home.
Radio stations began broadcasting ,
reports that workers were being sent
home because of an accident at the
facility. The plant's management made a
public statement verifying that
radioactive contamination had been
found in the vicinity, even though they
were not sure of the contamination's
source. Things started to get tense.
Fortunately, EPA's Environmental
Radiation Ambient Monitoring System
(ERAMS) was in full operation. Both the
ERAMS active air sampling networks
and the standby stations were already
collecting and analyzing samples
because of a Chinese nuclear test
conducted the previous month.
By the evening of the second day of
the "Peach Bottom Incident," it became
apparent that fallout from the Chinese
test was occurring from New England
through Virginia, with Florida and
South Carolina also reporting increased
radioactivity measurements. Analyses of
the ERAMS air data revealed that the
iodine-131 was due to fallout and not
an accident at the plant.
KHAMS uir
slufions operator
changing filters
in fiir sampling
unit. Filters (ire
chunked tu'ire
weekly.
Based on the ERAMS analyses, press
releases were then drafted by EPA and
the state explaining the increased
radioactivity. Public concern over safety
of the plant was greatly reduced.
Since ERAMS is the nation's single
major source for gathering and
analyzing environmental radiation data,
the system has, over the years, played
major roles in fallout-related incidents,
such as Peach Bottom. It has also made
important contributions involving
radiation from other sources. More
recently, its potential for monitoring
pollutants other than radiation has also
been demonstrated.
ERAMS. run by EPA's Office of
Radiation Programs (ORP). comprises
five measurement programs (drinking
water, surface water, air participates,
pasteurized milk, and external gamma
radiation) totaling 268 sampling stations
across the nation. The drinking water
stations take samples representative of
the drinking water of about 30 percent
of the U.S. population. The air sampling
stations also cover about 30 percent of
the population, while the milk sampling
stations cover over 40 percent of the
milk consumed by U.S. citizens.
Samples for all monitoring programs
are continuously collected by state and
local personnel according to
predetermined schedules and sent to the
ORP Eastern Environmental Radiation
Facility for analysis. The facility,
located in Montgomery. Ala., reimburses
station operators for equipment and
supplies needed to install ami operate
monitoring stations.
ERAMS is a direct outgrowth of the
early concern over radioactive fallout
from the atmospheric testing of nuclear
weapons. In li)(i(), this country
established several programs to
routinely monitor levels of
environmental radiation on a national
basis. These programs were known
collectively as the Radiation Alert
Network (RAN). The network was run
by the Public Health Service in the old
Department of Health, Education, and
Welfare. In 1962, a moratorium on
atmospheric nuclear testing was
declared and essentially ended
aboveground testing until the Chinese
resumed tests in the mid-1970s.
SEPTEMBER 1985
-------
Fortunately, the RAN was maintained as
a precaution. In 1970, when EPA was
established, ORP assumed the federal
responsibility for monitoring
environmental radiation.
In 1973, ORP restructured and
consolidated the existing monitoring
networks to create the current system.
Although the primary function of
ERAMS remains that of monitoring
radioactivity from fallout, ERAMS is
extremely versatile because of the
system's extensive, continuous sampling
and its analytical capabilities.
In January 1981, a situation similar to
"Peach Bottom" developed when
increased radioactivity was detected in
air samples near the General Atomic
Technologies industrial plant in San
Diego. Since it was well known that the
plant produced radioactive iodine, its
detection in local air samples began to
cause increasing public concern. These
local samples were sent to EPA's
radiation facility for further analysis,
and the presence of iodine-131 was
verified.
However, before the results were
released, EPA analyzed ERAMS samples
collected from Los Angeles, Berkeley,
Santa FK, and Las Vegas. These analyses
showed the same basic results as did
the analyses of the samples taken near
the San Diego industrial site. After
further consideration, the increased
radioactivity in all the tested samples
was determined to be caused by the
Chinese atmospheric test of October IB,
1980. An appropriate press release was
drafted by ORP and distributed by the
agency, reassuring the public that the
General Atomic Technologies plant was
not the source of the radioactive iodine.
Routine ERAMS monitoring of the
October, 1980, Chinese test also figured
in efforts to reassure the public
concerning the environmental impact of
the Three Mile Island (TMI) accident of
March, 1979. Because of expected
trends documented by past ERAMS
data, the agency was aware that
increased radioactivity from the Chinese
test could be detected around TMI. The
agency subsequently issued a press
release to that effect, since a number of
private citizens were monitoring
radiation in the TMI vicinity with their
own instruments and could easily
misinterpret any increased radiation
readings. Also, selected ERAMS stations
in Pennsylvania and surrounding states
wore activated immediately after the
accident. ERAMS data reflected no
increased environmental radiation from
the plant, a welcome reassurance in an
otherwise turbulent episode.
Collecting ci surface ivaler sample
(iclj'nccnf to the Montgomery. Aid., ivater
treatment plant. Such samples ore
collected quarterly a I KHA.VLS surface
water sampling stations.
The TMI accident was not the first
major involvement of ERAMS in a
radiation situation dealing with
something other than fallout. For
example, in January, 1978, the ERAMS
air sampling network was placed on
alert as part of Project Morning Light.
which put the entire federal radiological
emergency response apparatus on alert.
At that time, a Russian satellite carrying
radioactive materials was about to fall
out of orbit and re-enter the earth's
atmosphere,
ERAMS was put on alert because of
the possibility of residual radioactivity
occurring in the lower atmosphere upon
satellite burnup. Ultimately, the satellite
did not fall in the U.S.. and Project
Morning Light was disbanded. A similar
mobilization of the federal radiological
emergency forces occurred in January of
1983, when the Cosmos 4102 satellite,
carrying 100 pounds of uramum-235,
was out of control and due to plunge to
earth. The network's air sampling
stations were again alerted but, as
before, their information was not
needed, since no pieces of the satellite
fell in the U.S.
Another important demonstration of
ERAMS versatility occurred in 1980
when an ERAMS water sampling station
located downstream of the Cooper
Nuclear Power Plant in Rulo, Neb.,
picked up increased levels of
radioactivity. In this case, ERAMS
periodic water sampling happened to
coincide with an accidental release of a
small amount of radioactivity from the
plant. The plant operators were unaware
of the release at the time. After plant
management was informed of the
sample results, the plant was shut down
briefly while corrective actions were
taken, possibly avoiding more serious
future problems.
By 1981. ERAMS had proved its
applicability to many types of radiation
situations, and there was a growing
belief among ORP staff that the system
could be used to monitor other
pollutants. In the fall of that year, a milk
monitoring project was initiated that
demonstrated that ERAMS could also
monitor pesticides and toxic substances.
Samples from ail ERAMS milk stations
were analyzed for pesticides and toxics,
with trace amounts showing up in
samples from 25 percent of the
locations. Except for one location, the
findings did not indicate any significant
health risk, and resulting state action at
that location reduced pesticide
concentrations to acceptable levels. The
EPA Office of Pesticide Programs is now
actively studying using ERAMS for its
routine milk monitoring.
In addition to the possible application
of ERAMS to other EPA programs, the
utility of the system's routine data is
already widely recognized outside the
agency. For instance, the data,
distributed in quarterly Environmental
Radiation Data reports, are used by the
Department of Energy national
laboratories, many universities, the
Nuclear Regulatory Commission, and
the nuclear power industry to establish
baseline environmental information. In
addition, the World Health Organization
also routinely distributes ERAMS data.
According to ORP Acting Director
Sheldon Meyers, "while ERAMS is
crucial in our national effort to assess
and control human exposures to
radiation, there is increasing recognition
that the system may be applied to other
pollutants besides radiation." As Meyers
points out, "when you understand some
of its history, you understand the:
potential of ERAMS." D
(Kahn is a public affairs specialist on
the staff of EPA's Office of Hadiat/on
Programs.)
EPA JOURNAL
-------
Update
A review
of recent major EPA activities
and developments in the
pollution control program
areas
AIR
Visibility in Pristine Areas
Final regulations have been
announced under the Clean
Air Act establishing new
source review procedures
and monitoring strategies for
visibility in 19 states and one
territory.
The agency is establishing
federal visibility procedures
for Arizona, California,
Colorado, Florida, Hawaii,
Idaho, Maine, Michigan,
Minnesota, Nevada, New
Hampshire, New Jersey,
North Dakota, South Dakota,
South Carolina, Texas,
Vermont, Virginia, West
Virginia, and the Virgin
Islands. EPA is taking this
action by disapproving
individual State
Implementation Plans and
promulgating a federal plan
in their place.
The rules will require that
new industrial sources or
major modifications of
existing sources of air
pollution near national parks
or wilderness areas which
have been designated as
pristine areas under the
Clean Air Act meet specific
federal new source review or
monitoring requirements.
Standards for Residential
Wood Burning Stoves
The agency announced its
plans for accelerated
development of performance
standards for reducing
pollutants from new
residential wood-burning
stoves. EPA's regulations
will propose that all new
wood-burning stoves be built
with state-of-the-art
technology which will
significantly reduce
particulate matter, carbon
monoxide, hydrocarbons, and
polycyclic organic matter
pollution.
The wood-burning stove
regulations are one element
in EPA's recently announced
strategy to deal with toxic air
pollutants. It is estimated
that wood-burning stoves
account for almost half the
national emissions of
polycyclic organic matter, a
group of volatile organics
which include several known
or suspected human
carcinogens (cancer-causing
substances).
Nissan to Recall Certain
1981 Cars
Nissan Motor Corporation
will recall approximately
67,000 1981 model year"
vehicles that may be
exceeding the federal
hydrocarbon and carbon
monoxide emission
standards. Nissan will recall
280ZJC and Maxima vehicles
equipped with 2.4 and 2.8
liter engines produced for
sale in the U.S., except
California.
EPA and Nissan conducted
emission testing, which
showed that the deterioration
of the exhaust gas oxygen
sensor caused excess
emissions. The sensor
monitors the amount of
oxygen in the exhaust gas,
allowing the fuel injection
control unit to adjust the
air/fuel mixture for efficient
operation of the catalytic
converter. The oxygen sensor
will be inspected and
replaced if necessary.
Chrysler Recalls 129,000
1981 and 1982 Cars
Chrysler Corporation is
recalling approximately
129,000 1981 and 1982
model year passenger cars
manufactured by Mitsubishi
in Japan. The purpose of the
recall is to assure that the
vehicles meet federal exhaust
standards for hydrocarbons.
carbon monoxide, and oxides
of nitrogen.
The affected cars are the
Dodge Colt and Plymouth
Champ. The 1981 models of
these cars are equipped with
either 1.4 liter or 1.6 liter,
four-cylinder engines, and
the 1982 models are
equipped with 1.4 liter
engines. California vehicles
are not included in the recall.
Chrysler agreed to recall
the cars after EPA testing
revealed that the 1981 cars
were exceeding the agency's
hydrocarbon, carbon
monoxide, and oxides of
nitrogen exhaust standards,
and the 1982 cars were
exceeding the carbon
monoxide exhaust standard.
PESTICIDES
Coyote Control
EPA has granted registration
to the pesticide Compound
1080 in the Livestock
Protection Collar for limited
use on sheep and goats to
control coyotes that prey on
these farm animals.
The collar consists of a
rubber reservoir containing a
solution of Compound 1080
and is attached to the neck of
the lamb or goat. If a coyote
or other predatory animal
attacks and breaks the
reservoir, it will usually
receive a fatal dose. Coyotes
normally kill by bites to the
throat.
Rodent Control
EPA has placed a series of
restrictions on the use of
Compound 1018 to
control rodents on range and
crop lands.
EPA also is requiring
additional data from
producers of the rodent baits
to assure that current
registration standards are
being met under the Federal
Insecticide, Fungicide, and
Rodenticide Act.
This action concludes the
agency's special review
(Rebuttable Presumption
Against Registration) of these
uses of Compound 1080. EPA
initiated the review because
of information indicating that
use of this compound may be
a hazard to nontarget
wildlife, particularly
threatened or endangered
species such as the California
condor and the black-footed
ferret.
TOXICS
PCB Transformer Fires
Final regulations have been
announced by EPA that
would further restrict the use
of polychlorinated biphenyls
(PCBs} in transformers in
public buildings.
The rules are designed to
protect the public from
potential health risks posed
by fires from transformers
containing PCBs.
SEPTEMBER 1985
31
-------
The action was prompted
by concern over the risks that
resulted from transformer
fires in Binghamton, N.Y.,
San Francisco, and Chicago.
The agency has been
concerned about the health
effects of PCBs for a number
of years. Laboratory tests on
animals show that PCBs can
harm reproduction and
growth and can cause skin
lesions and tumors. EPA has
issued a number of previous
regulations designed to
prevent public exposure to
PCBs.
Chemical Reporting Failure
EPA announced that
Diamond Shamrock Chemical
Co. has agreed to pay a
$900,000 fine for failing to
notify the agency before it
manufactured or imported
three new chemicals. The
penalty is the single highest
ever collected under the
premanufacture notification
provision of the Toxic
Substances Control Act.
Also, EPA is fining seven
companies a total of $160,000
for failing to comply with
chemical reporting
requirements of the Toxic
Substances Control Act.
EPA fined the companies
for failing to keep and report
information on the
manufacture, processing, use,
and disposal of certain
chemicals, as well as
estimates of human exposure.
The firms cited either failed
to report information to EPA,
or failed to file a timely
report. Six of the violations
involved asbestos reporting
rules.
WATER
Appointments at EPA
Final Water Rules for
Petroleum Refiners
EPA issued final water
pollution rules requiring the
petroleum refining industry
to more stringently control
the discharge of certain
wastewater pollutants as well
as pollutants in storm water
runoff from refinery property.
The rules will require the
U.S. crude oil processing
industry to significantly
reduce allowable discharges
to the environment.
Final Water Rules for
Nonferrous Metals Industry
EPA issued final rules to
control the discharge of
certain wastewater pollutants
from nonferrous metal
forming plants.
The regulation covers
discharges from plants
forming all nonferrous metal
alloys except aluminum,
beryllium, and copper. EPA
issued copper and aluminum
regulations earlier and will
issue beryllium regulations in
the future.
The announced rule will
result in a 97 percent
reduction in the discharge of
toxic pollutants from
nonferrous industry plants.
The nonferrous metal alloys
regulated include
lead-tin-bismuth, magnesium,
nickel-cobalt, precious
metals, titanium, zinc,
zirconium-hafnium, and
metal powders. This
reduction will remove 5,530
pounds per year of toxic
pollutants from direct
discharges into streams and
an additional 54,500 pounds
per year of pollutants
discharged to sewage
treatment facilities.
Donald J. Ehreth has been named
Acting Assistant Administrator for
EPA's Office of Research and
Development (ORD), effective
immediately.
Ehreth has been with EPA since 1972,
initially in the water program, and in
ORD since 1980.
In October, 1983, he assumed the
position of Deputy Assistant
Administrator of ORD. In that position,
he has designed research programs and
conducted assessments aimed at
determining the need for regulatory
controls as well as measuring the
effectiveness of existing regulatory
programs aimed at alleviating pollution.
His background is as a Chemical
Engineer and Technical Manager
specializing in wastewater treatment,
water quality management, and
hazardous and toxics waste
management.
He earned a B.S. in Chemical
Engineering from the University of
North Dakota and an M.S. in
Engineering Administration from the
Geroge Washington University.
32
EPA JOURNAL
-------
Scouts at this year's Boy Scout
Jamboree July''24 to 30 lit Fort A.P. Hill
in Virginia, through exhibits mid
demonstrations, EPA sought to interest
the scouts in environmental issues.
Back cover; Rowers in a racing shell.
Photo by Robert Shafer, Folio, Inc.
-------
.«*•.
f
United States
Environmental Protection
Ayency
Washington DC 20460
Official Business
Penalty for Private Use
$300
Third Class Bulk
Postage and Fees Paid
EPA
Permit No. G 35
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