United States
          Protecti
Agency
Office of
Public Affairs (A-1Q7)
Washington DC 20460
Volume 12
Number 2
March 1986
Environmental Perspeetr

                           .

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                                 EPA photograph of Mt. St. Helen's, near Vancouver, WA. Before this volcano erupted in
                                 May 1980, EPA's Environmental Monitoring Systems Laboratory photographed the site to
                                 detect hot spots. After the eruption, EPA continued aerial photograph)' to document the
                                 environmental impact of fallout and floods on the area and to search for missing people
                                 and vehicles. (See  related story on page 2j.
Environmental  Perspectives
< < rT1he environment is
   -L everywhere," and
environmental concerns
range from ocean oil  spills to
visibility in parks, from 1'ClHs
in office buildings to asbestos
in schools. This  issue of EPA
Journal includes articles
across the spectrum of
environmental protection.
  Leading off the issue is a
feature on aerial
photographic work in
support of  EPA's mission.
Another article reports on the
Agency's efforts  to deal with
widespread contamination
from PCDs in electrical
transformers. A third story
explains how a recent EPA
proposal would rid this
country of asbestos.
  A day in the hectic life of a
pesticide product
manager—one of only nine
such employees at EPA—is
featured. Another article
explains the "R" factor at
work as some pests develop
resistance to pesticides.
Developments that transform
the litter of rusting
automobile hulks into a
useful resource are
explained.
  An EPA oil spills expert
explains why we haven't
heard much about big spills
in recent years. Another
article explores the question
of whether environmental
disasters result in new
cleanup laws. A report
chronicles EPA Region 3's
organized effort to clean up
pollution from oil wells
operating in northwestern
Pennsylvania.
  Steps by EPA and the
National Park Service to
protect visibility in the
national parks are  described.
One of the fathers  of ecology
in America—Aldo
Leopold—is featured.
Another article describes a
special office in EPA set up
to help small business
comply with environmental
regulations.
  Concluding this  issue of
the Journal is the regular
feature—Update, a

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                               United States
                               Environmental Protection
                               Agency
                               Office of
                               Public Affairs (A-107)
                               Washington DC 20460
                               Volume 12
                               Number 2
                               March 1986
                           SEPA JOURNAL
                               Lee M. Thomas, Administrator
                               Jennifer Joy Manson, Assistant  Administrator for External Affairs
                               Linda Wilson Reed, 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 pro-
tect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and im-
plement actions which lead to a
compatible balance between hu-
man activities and the ability of
natural  systems to support and
nurture life.
  The EPA Journal is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the publica-
tion of this periodical is necessary
in the transaction of the public
business required by law of this
agency. Use of funds for printing
this periodical has been approved
by the Director of the Office of
Management and Budget. Views
expressed  by authors do not neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107),
Waterside  Mall, 401 M St., S.W.,
Washington, DC 20460. No per-
mission necessary to reproduce
contents except copyrighted photos
and other materials.
On Camera for EPA
by Susan Tejada

Cornering PCBs
by Margherita Pryor  •">

Moving to Rid America
of Asbestos
by Dave  Ryan

Of Watermelons, Flea
Collars,  and Cockroaches
by Carol Panasewich
Pests vs Pesticides:
the "R" Factor
by Julian Josephson
I
Shredding the
Junk Auto Problem
by James E. Fowler   14

Oil Spills:
No News Is Good News
by L. Michael Flaherty
   16
Do Environmental
Disasters Have a Good Side?
by Roy Popkin   IS

Fighting Pollution in
Pennsylvania's Oil Fields
by Michael J. Chern  2!
Pollution Where
You'd Least Expect It
by David  B. Joseph  23

"A Fierce Green Fire":
Remembering Aldo Leopold
by Jack  Lewis   -•>

Climbing
Compliance Mountian
by Karen V. Brown and Edgar
Berkey   M

Update   -(^
  N
                               Cover: Sign of spring, Photo by /on
                               Hiley, Folio Inc.
                               Design Credits:
                               Robert Flanagan;
                               Ron I'urruh.
  o
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the U.S. for the EPA Journal is
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-------
On  Camera
for  EPA
 by Susan Tejada
                                        h'.xhibit A.  In /I proved that •
                                                           isli.-d on tin: i
                                                       I orp. properly in
                                        Kingston, Nil in April l<>74.
  If Gertrude Stein had said, "A dump is
   a dump is a dump)," she would have
 been wrong.
   In fact, a dump may once have been a
 farm or a forest, and it may become a
 playground or a parking lot. How can an
 investigator find out if today's ballfield
 is yesterday's hazardous waste site? One
 way is by asking EPA's Environmental
 Photographic; Interpretation Center
 (EPIC).
   A field station of the Environmental
 Monitoring Systems Laboratory (EMSL)
 in Las Vegas, the center is housed in a
 nondescript concrete building on the
 Vint Hill Farms Army base near
 Warrenton, VA. EPIC provides remote
 monitoring technical support to EPA's
 four eastern regions. EMSL provides
 similar support to EPA's other six,
 regions.
   EPIC was set up 13 years ago. Today
 seven EPA staffers and approximately
 40 contract employees carry out  EPIC's
 mission: to collect and interpret  aerial
 imagery in support of EPA regulatory
 and enforcement programs.
 Of what possible  use, are a
 hunch of old pictures?
   Without EPIC, "we would have had to
 put a search party in a boat on a river
 that was raging out of control," says Dr.
 Joe Lafornara, recalling the turbulent
 floods that devastated Johnstown, PA, in
 1977. Lafornara, a member of EPA's
 Environmental Response Team, helped
 track oil and chemical spills caused by
 the flood.
 (Trjriif        i:-i
 journal.)

  "The flights went on every day for
two or three weeks," Lafornara relates.
Using photos from the flights, "we
could pinpoint the precise locations of
spills and floating barrels, and dispatch
cleanup crews only where they were
needed. Without the aerial photography,
it would have been impossible. Some of
the barrels would probably still be
there."
  The cameras that proved so
indispensable in the Johnstown
emergency were encased in a steamer
trunk-sized device known as an
"Enviro-pod." Designed for portability
and compatibility with commonly used
light aircraft, the pods are strapped to
the belly of the  aircraft. Each pod holds
two cameras, one shooting at an angle
and one shooting straight down.
  Unlike conventional framing cameras,
these panoramic cameras sweep across
the line of flight, producing a high
resolution (greatly detailed) strip image.
Although EPIC maintains several
Enviro-pods at Vint Hill  and in the
regions, it doesn't have any planes to
carry them. Commercial  pilots and
planes are hired for most missions, with
an EPA employee or contractor usually
going along to operate the camera.
  "We use the Enviro-pod almost
weekly," says Jim Butch, who works on
wetlands protection issues in EPA's
Region  3 office  in Philadelphia.
"For permitting purposes, we use aerial
imagery to learn about the details of an
ecosystem. We also use it to identify
high-value wetlands," that should not be
filled.
  "On a sortie basis," says EPIC's Chief,
Vernard "Curly" Webb, "there is
nothing to compare with the pod. When
we need to search for signs of midnight
dumping along a railroad track,  or
inspect a river for floating drums—in
other words, when we're looking for
something specific in a specific
place—the Enviro-pod does the job."
  There are times, though, when the
Enviro-pod isn't enough. Strapped onto
light aircraft that fly at low altitudes,
the pod's cameras cannot cover as large
an area as they could if flying higher.
When large-scale investigations are
needed, EPA, through the National
Aeronautics and Space Administration,
can also arrange for collection of
high-altitude aerial imagery such as that
obtained with panoramic camera
overflights in a U-2 plane flying at high
altitudes.
  "About once a year we work with
NASA," Webb explains.  "Next year, at
the request of Region 4, we're scheduled
to fly over Alabama to inventory strip
mines and gravel pits. In 1979,  we
inventoried Pennsylvania for landfills,
dumps,  pits, ponds, and lagoons. In
1980, we did the same for West
Virginia."
  A single frame of film  taken from an
optical bar camera in a U-2 is five feet
long and covers a land area of about 200
square miles! NASA needed only about
six hours to film  the entire state of
Pennsylvania with enough detail to
keep EPIC analysts busy for a year.

  In a large room  at Vint Hill stand
units of industrial shelving, stacked
with thousands of cannisters of film. In
another part of the same room are more
shelves, laden with flat frames of film.
This is EPIC's film library, full of a lot
more than just film. The cannisters and
frames on the shelves also contain
history.
  EPA has exposed more than 3,000
rolls of film. Over the years, other
federal agencies have also been
amassing aerial photographs. The U.S.
Geological Survey, Soil Conservation
Service, NASA, U.S. Forest Service, and
National Oceanic and Atmospheric
Administration have photographed the
United States from the air for such
purposes as  preparing county soil maps,
topographic maps, and navigation
charts.  Some of this photography is
preserved  at the National Archives,
                                                                                                        EPA JOURNAL

-------
sorne at the agencies themselves, and
some at EPIC's film library.
  So what? Of what possible use are a
bunch of old pictures?
  For starters, they can help answer the
question posed earlier: Is today's
ballfield yesterday's dump? EPIC's
trained interpreter/analysts can spot
"EPIC puts such a professional
product together that it
impresses both the prosecution
and the defense."
drainage patterns, stressed vegetation,
impoundments, land scars, and other
signs that might indicate the presence of
hazardous chemicals, even if those
chemicals were buried  long ago.
  The use of historical  imagery is
"fantastic:," claims Joe Lafornara. In
1982, Lafornara had to  look for traces of
dioxin at the site of a former pesticide
manufacturer in Edison, NJ. The
manufacturing had begun  there in the
1940s and stopped in the 1960s.  By the
time Lafornara arrived  on-site in  1982,
"there was nothing there but a few
concrete pads overgrown with weeds.
Without historical photography, we
would have had to take random samples
over the entire site, almost five acres."
  EPIC analyzed aerial photographs of
the site going back to the 1940s. As a
result, Lafornara explains, "we could
pinpoint where the loading and
unloading docks had been—the areas
where one could expect the most
spillage. We knew where the lagoons
had been,  what the historical  drainage
patterns had been, even which buildings
had been used for which chemical
processes. So we knew exactly where
we would have the highest  probability
of finding dioxin. Instead of 800
sampling stations, we only needed 50.
Sampling that could have taken up to
two months to complete took only one
week." The historical  photos, Lafornara
concludes, "make it immeasurably
easier to do an extent-of-r.ontamination
survey."
  )im Butch cites another solid reason
for using "a bunch of old pictures": they
are, he says simply, "great evidence."
  Once a wetland has been filled, Butch
explains, "it's hard to trace where the
original wetland met the upland. People
will tell you the fill has been there for
years and years. But through historical
photography, we can establish that the
fill has not been there for years and
years. The photographic evidence is
incontrovertible and court admissible. It
helps us  get compliance from violators."
  Dave Riggs, a criminal investigator
based in  EPA's Region 4 office in
Atlanta, confirms  the
enforcement-critical nature of historical
imagery.  "EPIC puts such a professional
product together," Riggs says, "that it
impresses both the prosecution and the
defense. It can be  extremely valuable in
convincing the U.S. Attorney's office to
prosecute a case for EPA, or in
convincing a defendant to make a plea."

  When the longest federal
environmental enforcement liability trial
in this country finally ended in
December 1985, the photographic: work
of EPIC had played an important role in
a decision that confirmed the authority
of EPA to hold hazardous waste
generators, transporters, and facility
owners and operators responsible for
past  and  future costs of cleanup and  for
protection of health and  the
environment.
                Continued to next page
MARCH 1986

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                                                                            Exhibit 0. Drums, .so/mi stocked on top of
                                                                            each other three deen, lit tlic Ultdfi ami
                                                                            GOKS site in  Kingston. \H. .\frnv (him -i.
                                                                            drums ivere  inurifcd  in tin's Bnviro-pod
                                                                            photograph.
  The case involved the Ottati and
Goss, Inc., and Great Lakes Container
Corporation (GLCC) sites in Kingston,
NH. Operations at the GLCC site
included a barrel reconditioning plant
which functioned for nearly 30 years
until 1980. On the adjacent parcel of
land, a waste storage and treatment
facility operated from March 1978 to
June 1979, when Ottati  and Goss
abandoned operations there.
  In May 1980, the U.S. Department of
Justice filed a civil action in U.S.
District Court in Concord, NH, seeking
injunctive relief and costs on behalf of
HP A against responsible parties
associated with the two sites. EPA had
spent about $1.5 million on removal of
the  drums from the site, and some
$850,000 on ground-water and related
studies and on  preparation of a
preliminary engineering plan for a
permanent cleanup.
  According to Philip Boxell, an
attorney with EPA's Region 1 office
based in Boston, EPIC's involvement in
the  Ottati  and Goss case "illustrates the
invaluable and  even critical role it can
play in Superfund enforcement," That
role focused on documenting the
existence of a waste lagoon on the GLCC
site, and thousands of drums filled  with
waste on the Ottati and Goss site.
  The generators sued by EPA claimed
that few drums had accumulated  on the
Ottati and Goss site during 1978.  Aerial
photography proved that this was not
so.
  At the request of the regional office,
EPIC had overflown the site with an
Enviro-pod once each year from 1978 to
1980. For the trial, EPIC's Terry
Slonecker analyzed photos from those
"The photography is worthless
unless our people hunched
over  their light tables can
extract from it the information
they need."
trips. Viewing du-positives, or
negatives, through a stereoscope,
Slonecker could see the images in three
dimensions and actually count the
drums, even those stacked two or three
deep (see photo above).
  The images revealed that, contrary to
the generators'  claim, at least 2,048
drums, and perhaps as many as 2,867,
were on site in September 1978, and
that that number had  increased to over
4,000 by November 1979. Along with
generator invoices, says Boxell, "aerial
photography of the site was critical to
demonstrate that, during the early stages
of the operation, thousands of drums
were on the site contributing to soil,
surface-water, and ground-water
contamination. The photographs were
very important to establish liability."
  Historical photography also came into
play in the trial. Hazardous liquids from
a caustic wash operation and residue
from an incinerator had been dumped
into a waste lagoon on the GLCC
property. The corporation that bought
the site in 1973 argued that it did not
operate the lagoon. The government
disagreed, contending that the lagoon
had not been closed until at least the
spring of 1974.
  During the trial, an aerial photograph
of the lagoon area taken for the county
in April 1974 by a  Massachusetts
surveying firm was located (see photo
pageS). Slonecker rushed to Concord to
analyze the photo on the spot, later
confirming the results back in Vint Hill
on an analytical stereo plotter.
  The photograph showed that in April
1974 a lagoon containing liquid did
exist. It was a depression about 20 by 25
feet, diked on three sides, with
light-toned material on the fourth side.
Debris and probably drums were located
in the general area.
  According to  Sheila Jones, a Justice
Department attorney who also tried the
case, Slonecker's testimony played a
critical role in determining how long
the lagoon had been in operation.

  U-2s, Enviro-pods, stereo plotters:  the
sophisticated equipment at EPIC's
command seems like pretty high-tech
stuff. But Vern Webb cautions against
glorifying the technology. "The
photography is not an end product,"
Webb emphasizes.  "It is a means of
recording information. The photography
is worthless unless our people hunched
over their light tables can extract from  it
the information they need."
  As the  defendants in Ottati and Goss
and others are finding out, the
photography does yield that
information, and seeing is believing,  a
                                                                                                        EPA JOURNAL

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Cornering
RGBs
by Margherita Pryor
  It's early morning rounds in an office
  high-rise, but the grey mist in the
lobby isn't from dawn's early light. An
oily, acrid-smelling vapor is streaming
from the elevator shaft, and the building
lights are flickering ominously as a
gagging watchman runs to pull the fire
alarm.
  It's  not hard to find the source of the
smoke—a basement room housing four
electrical transformers. The room is also
the source of noises and vibrations, and
worried firefighters immediately arrange
for the local power company to
de-energize the equipment so they can
enter  safely. When the power company
checks its records, it finds that the
transformers contain polychlorinated
biphenyls, or PCBs.
  At that point, the entire chemical
emergency apparatus swings into gear.
The building is sealed, and hazardous
materials experts, local and state public
health officials, and representatives of
EPA and the National Institute of
Occupational Safety and Health all
converge at the scene. Yet despite the
clouds of thick black smoke that poured
out of the electrical room, no real flame
or fire ever appeared.
  Not the "Towering Inferno" most of
us expect in a  catastrophic fire, but it
illustrates one  of the greatest dangers
facing firefighters today—unwitting
exposure to toxic substances formed by
burning building materials and
electrical equipment, including PCB
transformers.
  The U.S.  Bureau of Standards has
found that many plastic materials  can
generate literally hundreds  of different
combustion products when burned,
among them toxic compounds such as
carbon monoxide, sulfur dioxide,
nitrogen oxide, ammonia, formaldehyde,
hydrogen cyanide, and hydrogen
chloride. The  insulating fluid used in
the electrical transformers that provide

(Pryor is Contributing hiiitor of the l-'t'A
journal.)
power to a building can also generate
toxic materials when burned,
particularly if the fluid contains PCBs.
  PCBs belong to the family of chemical
compounds known as chlorinated
hydrocarbons. PCBs have the extremely
useful properties of electrical
conductivity and non-flammability, and
they are also some of the most  stable
chemicals known,  taking decades to
A PCB fire in a museum could
contaminate  irreplaceable
national treasures forever and
close the structure for years.
decompose once they enter the
environment.
  Although EPA issued stringent
requirements for PCB disposal in 1978.
the National Research Council has
estimated that up to 150 million pounds
of PCBs have already entered the
environment due to indiscriminate
dumping and leaks. By now PCB
contamination is widespread. The
chemical has been found in soil, water,
fish, human breast milk and
tissue—even in Arctic snow.
  People absorb PCBs through food,
skin contact, and inhalation. The PCBs
accumulate in fatty tissues and body
organs, where they remain even after
direct exposure ceases. Laboratory tests
Cleanup • ••                    m u
sln(<                  .       nloii. \ V
in Frbiu          ,               n u
basemen) fmns'o:1
/'(.'/is thi>        at' hdi'ti

have shown that PCBs can harm
reproductive and developmental
processes, and cause gastric disorders.
skin  lesions, and tumors.
  Concerned over these serious health
effects, Congress in 1976 banned the
further manufacture and sale of PCBs,
and EPA began issuing controls on  their
use and disposal. Hut PCBs had been
used extensively as insulating fluid in
electrical transformers and capacitors.
This  equipment usually lasts 30 years or
more. Ten years after  the Congressional
ban on manufacturing, millions of
transformers and  capacitors containing
PCBs are still legally in use.
   Until recently, the  major risk of
 exposure to PCBs was thought to bo
 from leaks and spills and  improper
 disposal of PCBs and used PCB
 equipment. In 1982, EPA placed light
 controls on the use of PCB electrical
 equipment. But since that time, fires  in
 San  Francisco, Tulsa, Miami, Chicago.
 and  Binghamton, NY have shown that
 fires involving PCB transformers may
 pose an even greater  risk of exposure.
 EPA estimates that almost 80,000
 PCB-laden transformers are used and
MARCH 1986

-------
located in or near commercial buildings
such as office buildings, apartment
complexes, shopping malls, and subway
and train stations—all places where the
potential for human exposure is great.
  Transformer fires typically occur
because of electrical failure in the
transformer or its associated equipment.
High temperatures and pressures within
the unit can cause it to rupture,
releasing PCBs and incomplete
combustion byproducts in the form of
vapor and smoke. These incomplete
combustion byproducts can include
polychlorinated dibenzofurans (PCDFs)
and polychlorinated dibenzodioxins
[PCDDs), substances more toxic: than
PCBs themselves. During a fire, these
byproducts,  as well as PCBs, can spread
in smoke, soot, and vapor throughout
the interior of the building, resulting  in
widf(spread contamination,
  PCB contamination doesn't stop
inside the building, either. The water,
foam, and other materials used to
extinguish the fire can be contaminated
and must  be prevented from entering
storm sewers or seeping into the
ground. Hoses, equipment, and
Regulating 1'Clis has not been
easy, hut recent surveys of
PCB levels in human tissue
suggest that our exposure  to
PCBs already has lessened.
protective clothing are another
contamination problem, Kven the
equipment used in cleanup can become
contaminated.
  A 19B1  fire in Hinghamton, NY, for
example, started in a basement
transformer vault, but spread PCBs and
toxic byproducts throughout the
18-story building through the
ventilation system. Five years later, the
building is still closed. Almost
everything in it, including furniture and
office equipment,  has had to be
destroyed  because of contamination.
The walls, air vents, and building shafts
have required meticulous
decontamination with special solvents,
and cleanup costs so far have amounted
to about $30 million—for a building that
originally  cost $20 million.
  Although the rigors, and expense, of
decontaminating a high-rise office
building are great, a fire in a museum
could pose even more difficulties, Last
W.tt i:i>itl(int leaks from ci high voltage
electrical transformer in the Smithsonian
Institution's Museum  o/American
J li.slory.
summer, an inspection of the
Smithsonian Institution found leaking
PCB transformers in several of the most
popular museums. A PCB fire in a
museum could contaminate irreplaceable
national treasures forever and
close the structure for years, as well as
endanger visitors and  firefighters.
  Incidents like these convinced EPA
that the risks from PCB transformer fires
warranted new controls on PCB
equipment. In July 1985, the Agency
issued  new rules that:

• Required PCB  transformer owners
(usually the utility company or building
owner) to  register this equipment by
December 1, 1985, with fire departments
and building owners, as well as to mark
the exterior of all transformer locations.
All combustible  materials within  five
meters of PCB transformers were to be
removed, also by December 1;

• Require transformer owners to notify
the National Response Center
immediately in the event of a
fire-related incident involving a PCB
transformer, and to act as soon as safely
possible to contain any potential
releases of PCB-contaminated water;

• Require the removal by October 1990
of certain  commercial-building PCB
transformers which are more; prone to
failures due to electrical faults;

• Require the installation of enhanced
electrical protection for other types of
PCB transformers used in or near
commercial buildings; and

• Ban  the further installation of PCB
transformers in  or near commercial
buildings.
  Since promulgating these rules, the
Agency has been helping transformer
owners to comply with the  new
regulations, and has provided support
in responding to PCB and PCDF
contamination resulting from PCB fires.
EPA has also  been working with the
federal government's General Services
Administration  to explore ways to bring
the  large number of government-owned
PCB transformers into compliance with
the  new requirements. Last  summer,
some of these transformers were found
not  only in the  Smithsonian, but also in
the  White House and Executive Office
Building and  the Washington, DC
subway system.
  Other PCB issues before the Agency
include developing policy for cleaning
up spilled PCBs and ensuring safe
methods for disposing of PCBs.
Currently, the standards for cleanup of
areas contaminated by PCB  spills or
leaks are set at the Agency's regional
level, and the result has been differing
standards  across the country. EPA has
been working on a policy to ensure
nationally consistent cleanup standards.
The development of such national
standards  has been encouraged by
environmental organizations as well as
by industry groups and utilities.
  Of course, the new removal
requirements  and the increased
emphasis on adequate cleanup  will
require the availability of safe disposal
facilities and  disposal methods.
Landfilling and incineration are the
traditional disposal  methods, but there
are  very few approved disposal sites.
Since 1983, EPA has issued nine
permits for alternative disposal
methods, and is currently reviewing 17
more applications. These applications
include disposal alternatives such as
chemical treatments, mobile
incineration, and physical separation.
  Regulating PCBs has not been easy,
but  recent surveys of PCB levels in
human tissue suggest that our exposure
to PCBs already has lessened and will
decline further  as the PCB  equipment
still in use is  removed and disposed of
properly,  Q
                                                                                                         EPA JOURNAL

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Moving  to  Rid
America  of  Asbestos
 by Dave Ryan
Magnified closeiip of ushestos fibers
used in sonic of llie  products I'.l'A is
proposing lo ban.
fHvun is a Press Offieer in the K/V\
Of'fio! of PiibJie A//afj
    On January 29, 1986, EPA published
    a proposal in the FederaJ Register to
rid the United States of the "miracle"
fiber called asbestos.
  In the proposed rule, issued under
authority of the Toxic Substances
Control Act (TSCA), EPA invites public
opinion on its intent to immediately ban
five major asbestos  products and phase
out all  remaining uses of the substance
over the next 10 years.
  Why is EPA proposing such a
measure for a product long considered
so commercially important, and still so
pervasive throughout American society?
  Asbestos is really a common name for
a group of natural minerals—
silicates—that separate into
thin but strong fibers. The fibers are
chemically inert and heat-resistant, and
they cannot be destroyed or degraded
easily.
  Since  1900, over 30 million tons of
asbestos have been used in hundreds of
products. Much of it was sprayed on
ceilings  and other parts of schools and
public and private buildings for
fireproof ing, sound-deadening,
insulation, or decoration.
  Unfortunately, some  of the
characteristics that make this mineral
fiber so useful commercially—such as
its great stability—also help make it a
dangerous killer when  it is breathed in.
  Unless completely sealed into a
product, asbestos can easily break into a
dust or into tiny fibers. These fibers can
then float and be inhaled.  Once asbestos
gets into the body, it can remain there
for many years.
  "There can be no debate about the
health risks of asbestos," says EPA
Administrator Lee Thomas. A
well-documented cause of lung and
other cancers in humans, including
mesothelioma (a cancer of the chest and
abdominal lining), asbestos is now
generating up to 12,000 cancer cases a
year in the United  States, almost all of
which are fatal.  Aside from the cancer
threat, about 65,000 persons in this
country are  currently suffering from
asbestosis, a chronic scarring of the
lungs which makes breathing more and
more difficult and eventually causes
death.
  Cigarette smokers exposed to asbestos
face extra risk, having a much higher
chance of getting lung cancer than
exposed nonsmokers.
  Asbestos-caused  cancers can remain
latent and not occur for 15 to 40 years
after the first exposure. EPA also
believes that even small amounts of
asbestos in the air are dangerous.
  Asbestos is released into the air
throughout its entire life cycle:
manufacturing, use, destruction and
disposal. Since substitutes are, or will
soon be, available for nearly all uses of
 MARCH 1986

-------
the fiber, EPA has no feasible alternative
but to phase out asbestos and all its
products. This is what the January
proposal sets out to do.
  Prohibited would be the importing,
manufacture, and processing of five
products that account for as much as
one half of United  States asbestos
consumption. The bulk of these
products are used mainly in the
construction and renovation industry.
They are:
Saturated  and unsaturated roofing
felt—This is a product made of paper
felt and intended to cover or lie under
other roof coverings. Its  purpose is to
insulate and help prevent corrosion.
Flooring felt and asbestos felt-backed
sheet flooring—Used as  an underside
backing for vinyl sheet flooring, this felt
helps maintain original product shape
and helps prolong floor  life, especially
when moisture from below the surface
is a problem.

Vinyl-asbestos floor tile—Especially
popular for use in heavy traffic areas
such as in stores, kitchens, and entry
ways.
Asbestos-cement pipe and fittings—This
is used  primarily to carry water or
sewage, and to a lesser extent, as
conduit pipe for the protection of
electrical or telephone cable or for air
ducts.
Asbestos clothing—Not street  clothes,
but special occupational garments worn
by those needing protection from
extreme heat, such as firefighters.
  What about the rest of the asbestos
products iti use? EPA is  proposing to get
rid  of the asbestos  in these products
indirectly  by phasing down all domestic
mining and importing of asbestos by a
certain percentage each year over the
next 10 years. This phasedown  would
be carried out by allowing a company to
mine; or import an  annually decreasing
percentage of the amount of asbestos it
mined or imported during the years
1981-1983.
  EPA estimates that as  a result of what it
is proposing, about 1,900 cancer deaths
from asbestos will  be avoided.
  In the January notice,  the Agency also
lays out for public comment three
alternatives to this proposal, including
grouping asbestos products by use
category (such as construction, car
brakes, and clothing) and banning them
in stages. The goal of all options,
however, is the same: the ultimate
elimination of widespread asbestos use
in this country.
  Whatever alternative EPA pursues, it
intends that labels be put on all
products not immediately banned,
warning users that they contain
asbestos. EPA  hopes that these warnings
would encourage users to take steps to
reduce their exposure.
  For the five  products banned under
the proposal, EPA is convinced that
industry has adequate,  readily available
substitutes which should minimize the
economic impact of this action. The
10-year phase  out should give industry
time to develop good alternatives for all
remaining asbestos products.


EPA estimates that as a result
of what it is proposing, about
1,900 cancer deaths from
asbestos will be avoided.
  The issue of asbestos substitutes is
important because Congress requires
EPA to take not only health but
economic considerations into effect
when developing regulations.
  For example, vehicle brake
manufacturers use asbestos extensively
in linings—in fact, brake linings
represent one of the main uses of
asbestos  in the United States—but
substitutes are probably not yet
available for all applications. For this
reason, EPA id not proposing to ban
asbestos  in brake linings right now.
  "In encouraging the development of
substitutes, EPA will be promoting a
significant reduction in  risk," says Lee
Thomas. "Currently, products that are
replacing asbestos appear to present
lower risk. However, EPA will monitor
the development of substitutes,  and will
use TSCA to require testing of
substitutes if necessary to ensure their
safety."
  In fact, American businesses have
been significantly curtailing their
asbestos  consumption voluntarily since
the early 1970s, with use in products
down from about 800,000 tons annually
in the early  1970s to about 200,000 tons
a year today.
  Partly  for these reasons, EPA  expects
the cost for the average American of
meeting the proposed asbestos rules will
be small.
  Consumer costs, resulting from price
increases in asbestos products or
substitutes, are estimated at $1.5 billion;
spread across the whole population,
however, this would  average  less than
$10 per consumer over the next  15
years.
  Total producer costs of about $210
million would result when companies
can no longer use certain specialized
equipment for making asbestos
products. Much of this machinery,
however, can be readily converted to
the production of other goods.
  "EPA has weighed the health risks
from continued use of asbestos against
the cost of the proposed rule," Thomas
said, "and concluded that  the avoidance
of about 1,900 cancer cases and many
other cases of asbestos-related disease
substantially outweighs the economic
effects."
  As sweeping as the proposal is, it is
just the latest in a long series of actions
taken by EPA since the early 1970s to
reduce the risks from asbestos.
  EPA has issued water  pollution
standards  for asbestos manufacturers,
and, under the Clean Air Act, banned
the use of most sprayed-on asbestos.
The Agency has also taken steps to
reduce risks from asbestos already in
place in buildings. It has issued an air
standard to reduce emissions from
asbestos during renovation and
demolition; required inspection of
schools for asbestos-containing materials
and notification of parents and
employees if any are found; and
established an extensive technical
assistance program which  provides
guidance to public and private building
owners on the identification and
abatement of asbestos. EPA has  also
issued  a regulation to  protect certain
state and local public employees who
take part  in asbestos abatement
activities.
  Nor is EPA the only federal agency to
act against asbestos dangers.
  For example, both the Occupational
Safety  and Health Administration
[OSHA) and the  Mine Safety Health
Administration have set standards for
workers on the job (OSHA also plans to
lower its workplace standard); the Food
and Drug Administration has
established rules to prevent asbestos
release from some drug-filtering
processes; and the Consumer Product
Safety  Commission has banned  the use
of the substance in dry-wall patching
compounds and  ceramic logs.
  Federal  government actions such as
these—capped off by EPA's hard-hitting
ban and phaseout proposal—have
moved America well down the path
towards effective asbestos  control, a

  (Public hearings on EPA's proposed
rules are tentatively scheduled for
mid-May;  written public comments
must be submitted by April 29,  1986).
                                                                                                          EPA JOURNAL

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Of  Watermelons,  Flea
Collars,  and  Cockroaches
by Carol  Panasewich
   Last summer, you refused to buy your
   kids a watermelon because you
heard that some watermelons had been
pesticide-overdosed and might not be
safe to eat. The fleas from your cat have
established colonies in your carpeting
and upholstered furniture, but you
postpone calling in a pest control
company because you're afraid of the
insecticide spray it would  use.
  What do you have in common with
representatives of a number of chemical
companies, environmental and  public
interest groups, many state, federal, and
international officials, and certain upper
level managers at EPA?
  You all need Jay Ellenberger.
  Jay Ellenberger is a Product Manager
in the Registration Division of the
Agency's Office of Pesticide Programs
(OPP). One of only nine such employees
in EPA, he and his team of five
specialists oversee the regulatory affairs
of 80 to 90 chemical insecticides,
marketed in approximately 6,000
individual products.


"These are the kinds of cases
that keep most people here."


  Insecticides help make America a
land of agricultural plenty. But they
have a dark side, too. If used
improperly, some can cause immediate
or short-term health problems in people
and other accidental victims like birds
or pets. Others are potentially less
dangerous in the short term, but can
accumulate in the  tissues of animals,
plants, and people where they may
cause chronic, long-term health effects
like cancer, reproductive problems, or
genetic damage.
 (Panasewich is 
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                             .
     it, Oirectur nj (he Pcstirrdc
             :isfm(ion Division.
meeting in progress with his Branch
Chief, Mnrb Harrison, and several other
Product Managers (or PMs, as they are
known inside the program).
  Harrison has been asked for a status
report on  Registration  Standards
follow-up, and explains what is needed
to Ellenberger and his peers. As usual,
this information must  be generated
quickly—Ellenberger's deadline is five
days.
  Registration Standards development
and follow-up provide guidance for
re-registering existing pesticides to
reflect current scientific; knowledge, and
it takes as much time and attention as
the PM teams' registration
responsibilities  for new products and
new uses.
  9:15  a.m.—The meeting breaks up.
Ellenberger returns to his office, where
telephone messages already cover his
desk. He returns a call from the
representative of a small chemical
company that has been attempting for
several months  to obtain a "me-too"
registration (that is, a registration for a
product that is substantially similar to
one or more products already registered
and on the market) for a com insect
control product containing methomyl.
The company recently received  word of
EPA's approval of its registration
request, just in time to start producing,
labeling, and distributing its product for
the upcoming use season.
  By working closely with a major
methomyl producer, who already had
submitted some of the scientific studies
which the smaller company needed to
reference, and by gaining the big
company's cooperation, Ellenberger was
able to "push through" the smaller
company's application and register its
product in optimal time. In this
country's highly competitive, $4.7
billion pesticide business, gaining
market entry in time for a crop
growing/pesticide use season can mean
the difference between economic
success or failure, especially to a small
company.
  Notwithstanding the experience of the
small methomyl producer, Ellenberger is
quick to point out that "things don't
always go the registrant's way." He
describes a recent instance in which
When part of the  California
watermelon crop  was found  to
be contaminated with
aldicarb, the telephones "rang
off the hook" for several
weeks.
two small companies were trying
to put dog flea collars on the market at
the same time. Both were faced with
lengthy, expensive, toxicology  data
requirements. While one company was
able to complete the required new
studies successfully, its competitor was
not. Ellenberger registered the first
company's flea collar and sent  the
second company "back to the drawing
board" to rerun needed toxicology
 studies.
  10:00 a.m.—Ellenberger participates
in a "dress rehearsal" for his
presentation the following week before
the Agency's FIFRA Scientific: Advisory
Panel (SAP). The panel will be meeting
to consider the Agency's current
scientific and regulatory position on
amitraz and two other pesticide
chemicals that are regarded  as  weak
cancer agents. Specifically, the panel  is
interested in these pesticides as
examples of when and how EPA assigns
a "Category C" (possible human
carcinogen) classification to such
chemicals. The producers of amitraz
also will attend the actual SAP meeting.
  Rehearsing his presentation.
Ellenberger makes a brief statement on
EPA's cancer findings regarding amitraz,
and then fields questions composed on
the spot by the Secretary of the  SAP,
Steve Johnson, and Bill Jordan of EPA's
Office of General Counsel. Ellenberger
calls upon all his familiarity with the
chemical and with the regulatory,
scientific, and policy issues involved.
  He must maintain this detailed
familiarity with virtually all of the
pesticide chemicals he oversees. In this
respect, his job is much  like that of an
industry representative; the difference is
in the focus of their respective efforts
and in  the size and complexity of their
workloads—the industry counterpart
may handle only about six chemicals at
a time, while Ellenberger handles 80 to
90.
   ll:00a.m.—On the way back  to his
office, Ellenberger chances upon an
industry representative in the building.
They arrange a meeting for the
following morning so Ellenberger can
obtain additional information  to
complete a  Registration Standards
follow-up project.
  Ellenberger notes that  the cooperative
attitude on  the part of the representative
is typical. Just as the pesticide industry
calls on EPA for a great deal of service,
so EPA calls on the industry for certain
information. Cooperation is, after all, a
two-way street.
                                                                                                         EPA JOURNAL

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   Back in his office, Ellenberger talks
 with a member of his team, Dennis
 Edwards, about a call received that
 morning from a concerned citizen  living
 in a nearby community. The woman,
 who is pregnant,  is "petrified" because
 the apartment in which she and  her
 husband live has  been sprayed for
 roaches at the direction of the building
 manager without  her or her husband's
 prior knowledge or consent. The woman
 asks whether it is still safe for her  to
 live in the apartment, and whether there
 is any way that she can reduce risks to
 her unborn child.
  Ellenberger notes that calls  of this
 nature are not uncommon, if callers
 know which  insecticide product was
 used, Ellenberger or his team  members
 can provide information on the
 properties and effects of the chemical. If
 serious  effects are involved, the team
 refers callers  first to their
 physicians, then to the program's Health
 Effects Section for more detailed
 information and follow-up. Where
 pesticide misuse is suspected, the
 incident is referred to the  Agency's
 Compliance Monitoring Office for
 investigation  and  possible enforcement
 action. (It is a violation of FIFRA to use
 any registered pesticide product  in a
 manner inconsistent with  its labeling.
 Pesticide misuse is subject, therefore, to
 civil and criminal  penalties.)
  Last summer, when part of the
 California watermelon crop was found
 to be contaminated with aldicarb, one of
 Ellenberger's  insecticides,  the
 telephones "rang off the hook" for
 several weeks. The PM teams  must
 weather the crises surrounding their
 chemicals, without sacrificing any  of the
 routine registration or Registration
 Standards work.
  Before breaking for lunch, Ellenberger
calls several pesticide program staff
 members to check on the status of
 pending reviews of scientific studies.
  One of these calls is to Dr. Stuart
Cohen in the  Hazard Evaluation
Division to learn the status of a review
of aldoxycarb, a proposed new
insecticide which has been
demonstrated to leach to ground water.
  During the afternoon,  Ellenberger
attends  one more  meeting—this one on
the parathion Registration Standard. He
conducts more business—primarily with
pesticide program staff and industry
representatives—by telephone, juggling
information about several pesticides. He
begins drafting the memo he will submit
in response to his Registration
Standards follow-up assignment. He
signs some 30 letters informing
companies of decisions he and his  staff
have made on the companies' various
products.
At any given time, a  PM team
is working on some 300
registration actions,  and
completes nearly 2,000 actions
a year.
  At about 6:00 p.m., he meets his wife
for the ride back to his home and
greenhouse where, in his spare time. Jay
Ellenberger grows orchids.

  Each Product Manager and his team
face the dual responsibility of handling
both the "routine" registration
submissions and the Registration
Standards development activities
scheduled currently for their chemicals.
At any given time, a PM team is
working on some 300 registration
actions, and completes nearly 2,000
actions a year. These actions range from
the simple—permission to change a
product name, for example—to the
complex, like considering whether or
not to approve the registration of a new
pesticide suspected  of causing cancer,
or leaching to ground water, or both.
  Meanwhile, teams like Ellenberger's
are producing an average of four new
Registration Standards a year, and
following up on a dozen or more
standards that have already been
produced. Upper management in the
Registration Division concedes that an
enormous amount of pressure is placed
on the nine Product Managers to
produce in a timely way.
  What is it. then, thai keeps Jay
Ellenberger and his colleagues going, in
the face of this mountain of workload?
  For Ellenberger, at least, it is the
challenges that lie  in sorting out and
playing out the most complex—the most
"gut-wrenching"—regulatory situations,
where human risks must be weighed
against economic and social  benefits.
  Challenges also lie in breaking now
ground, in working through new
regulatory questions and problems, and
in contributing to decisions that will set
precedents for the future. Such
currently is the case with a subset of the
agricultural insecticides managed by
Ellenberger. Used in the fields, they
have the potential for traveling through
soil and  leaching into ground water.
The prototype of these insecticides,
aldicarb, is currently undergoing an
in-depth Special Review of its risks  and
benefits.
  Meanwhile, several  proposed new
insecticides, most notably  carbosulfan
and aldoxycarb, are in a holding pattern
pending the outcome ut num;
sophisticated and comprehensive
monitoring and other environmental fate
studies, as well as the outcome of the
aldicarb review. Ellenberger and his
team are proceeding step by step toward
decisions that will set the  Agency's
policies regarding the registration and
use of agricultural insecticides that may
leach to ground water.
  The give and take in these situations
is stressful, but "quite frankly, also
interesting," concludes Ellenberger.
"These are the kinds of cases that keep
most people here." a
MARCH 1986
                                                                                                                   11

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Pests  vs  Pesticides
the  "R"  Factor
 by Julian Josephson
   The "R" Factor is not the title of a
   spy movie, although the drama it
implies is just as intense in its own
way. It is "us against them," hut us
against crop pests rather than  foreign
nations.
  "R" stands for resistance—the
resistance or immunity that insect and
other crop pests develop to pesticides.
According to a  1984 study by  the World
Resources Institute (WRI), the  number of
species of insect pests resistant to one
or more pesticides  almost
doubled from 224 in H)fi!) to 428 by
1980. Entomologist Robert  L. Metcalf of
the University of Illinois predicts that
by 1995 this number could exceed
1,500; by the turn of tin; century.
virtually all  pest species will show
some "R."
  Not only insects  have developed
resistance to pesticides. By 1980,
scientists observed 150 species of
bacteria and fungi responsible for crop
plant diseases that  had developed such
resistance. Also, more than 50 species of
weeds were  found to be at  least partially
resistant to herbicides, and several
species of rodents were showing
resistance to poisons. According to  WRI,
insect resistance alone was costing  U.S.
farmers $150 million a year in crop
losses and increased applications of
chemicals in 1984.
  Because of the "R" factor, many
pesticides no longer prevent insect  and
other pests from proliferating.  The
problem is compounded by the apparent
                        U S Department of Agriculture

failure of "beneficial" insects—those
that prey on insect pests—to develop
resistance to pesticides. Because
insecticides continue to kill
"beneficials," but  not pests, the pests
are no longer controlled by their natural
enemies and they proliferate even more
rapidly.
  The widespread use of pesticides is
readily understood when one considers
the extent of food and  fiber crop losses
to insects, fungi, bacteria, viruses, and
rodents. In  1977, David Pimintel of
Cornell University estimated that such
losses averaged more than 40 percent of
the world's crops, accounting for many
billions of dollars, despite worldwide
use of 2.3 billion tons of pesticides that
year. These figures are probably  much
the same today.
  When insect pests, such as aphids,
flies, mosquitoes, and moths are first
exposed to  insecticides, almost all  of
them are killed. For some reason.
however, perhaps one  or two mating
pairs (out of thousands upon thousands)
survive the chemical onslaught. Among
the offspring of these resistant pests will
be a few that are resistant ("R") and
many that are still susceptible  ("S") to
the pesticide. As use of the pesticide
continues, the"S" insects are killed off.
But more "R" pests are concentrated in
the area being sprayed or dusted.
Eventually, the "R"  pests predominate
and the pesticide becomes ineffective.
In fact, some pests become resistant to
more than one type of pesticide.
  Frederick W. Plapp, Jr., and T.C.
Wang of Texas A&M University have
suggested  that the "R" factor in insects
develops in three ways:
• An insect may develop an ability to
keep more of  a pesticide out of its body
than a susceptible or  "S" insect does.

• Or the pest may develop the ability to
secrete enzymes that metabolize and
detoxify the pesticide within its body.
• Or the insect may develop a
desensitization of the specific body
parts through which the pesticide's
poison would work if the insect were
susceptible.

  Bacteria, fungi, and weeds apparently
attain "R" in similar ways, especially by
developing the ability to produce
pesticide-detoxifying enzymes. Also,
susceptible bacteria can become
resistant through exchange of packets of
genetic material,  known as plasmids.
These are donated by "R" bacteria
through a process similar to mating.
  Scientists find  the ability  of insect
pests to metabolize and detoxify
pesticides especially intriguing. Some
suggest that all pests could produce the
necessary enzymes. But in the "S"  pests,
the enzymes are never secreted in
amounts necessary to counteract the
pesticide. Because of genetic changes,
however, "R" pests seem to  be able to
 i.'
                                                                                                       EPA JOURNAL

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                             ;/!i;( hi;s
             •stfllHV (d JK'StlVl
produce perhaps up to thousands of
times more insecticide-detoxifying
enzymes than "S" pests can. These
enzymes chemically change the
insecticide's molecular structure,
making it harmless to the insect.
  Some methods of counteracting the
"R" factor in insects exist today. One
obvious approach is to stop using the
pesticides to which the target insect has
developed resistance,  and to use
alternatives instead. However, the target
insect may develop resistance to the
new pesticide without losing its
resistance to the original one.
  Suppose, for example, a leafhopper
which spreads plant diseases becomes
resistant  to the phosphorus-based
insecticide malathion. Perhaps a
carbamate insecticide, such as carbaryl,
does work. Eventually, however, the
leafhopper may become resistant to both
malathion and carbaryl.
  But if the use of malathion is stopped
entirely while the carbaryl is applied,
would the leafhopper's resistance to
malathion eventually  disappear? Many
entomologists say that the leafhopper's
resistance to malathion would decrease,
but not to its original  levels. If
malathion were reapplied, the
leafhopper's resistance to that chemical
would increase faster  than it originally
did. The use of alternative pesticides
can disrupt the "R" factor for a  while,
but not eliminate it.
  Another approach is trying insect pest
management methods that get around
the "R" factor. Biological control,  for
example, calls for introducing a pest's
natural enemies or inducing bacterial or
viral diseases in the target pest. For
instance, lacewings (also called aphis
lions) are deadly enemies of aphids. The
Japanese Beetle's nemesis is a
microbially induced illness known as
milky spore disease.
  Probably no level of "R" can protect
an insect pest against  a hungry predator.
But you can't be certain that predators,
most of which are migratory, will
remain in a given area long enough to
control target insects,  and you can't
know whether insect pests eventually
will develop resistance to miocrobial
diseases. Scientists at  the U.S.
Department of Agriculture's Grain
Marketing Research Laboratory in
Kansas have noted disturbing
indications that this does happen. They
have observed the resistance of a
species of grain pest to a bacteria!
disease caused by Bacillus thun'ngiensis,
a microbial insect control agent
increasingly used by organic farmers
and gardeners.
  Other weapons in the battle against
"R" include using hormones that
disrupt the life and growth cycles of
insect  pests, or chemicals that simulate
pheromones or sex  attractants that lure
pests into traps. Whether pests can
develop resistance to these hormones
and pheromones is  not yet known.
  Also, male insects can be sterilized by
irradiation; the females that mate with
them then lay infertile eggs. Since the
sterilization of male insects is not done
chemically, the "R" factor should  not
arise.
  In the future, scientists are  expected
to continue combatting the "R" factor by
attempting to counteract the resistance
phenomenon directly, and by managing
pests in such a manner that the "R"
factor's importance  is reduced.
  George P. Georghiou of the  University
of California at Riverside suggests three
updated methods for combatting "R" in
insects directly:
• "Management by  moderation"
includes  such approaches as applying
smaller doses of insecticides,  using
chemicals that break down in the
environment shortly after use, and not
necessarily trying to achieve a 100
percent insect kill.
• "Management by  saturation" calls for
finding ways of hitting a target insect
with dosages of insecticide high enough
to overwhelm the factors that  confer  its
resistance. This strategy also involves

   Going to  Extremes

   Occasionally, an insect not only
   develops  resistance to an
   insecticide; it actually becomes
   dependent on the chemical. A
   species of bees in Brazil seeks,
   collects, and ears DDT! Scientists
   from the University of Brasilia and
   the U.S. Army Environmental
   Hygiene Agency have found that
   these bees accumulate DDT in
   their bodies to concentrations as
   high as 42,000 parts per million,
   more than four percent of
   their total body weight. The bees
   show no ill effects. The normal
   lethal dose  of DDT for bees is 6
   ppm.
trying biochemical attacks on the
chromosomes and genes that impart
resistance, or using a pesticide together
with materials that can neutralize the
enzymes the resistant insect produces  to
detoxify the pesticide. The search is on
for such materials.
•  "Management by multiple attack"
entails using mixtures of pesticides to
which  the pest  is resistant and
alternative pesticides against which the
target insect has not yet developed the
"R" factor, or has lost it. J.D. Gilpatrick
of the New York State Agricultural
Experiment Station in Geneva, NY, has
proposed parallel strategies for
managing resistance in bacteria, fungi,
and nematodes.

  A promising  way of reducing the
importance of the "R" factor, rather than
combatting it head cm, may be
integrated pest  management (IPM). This
includes the systematic, balanced use  of
synthetic and naturally occurring
chemicals, biological approaches, and
cultural techniques.
  Well known examples of naturally
occurring pesticides are pyrethrins,
derived from a  species of
chrysanthemum, which control a large
number of insect species.
  Biological approaches encompass the
use of natural enemies, such as birds
and "beneficial" insects (for example,
ladybugs, lacewings,  and mantids) to
prey upon pests. They also involve
introducing diseases  in pest species—a
practical example of the age-old maxim
that every flea has  lesser fleas that bite
it. Cultural techniques include growing
a greater variety of crops in the same
area in which only one crop was
previously grown. This limits tht;
amount of food available to the pest of
that one particular crop. Crop rotation  is
another kind of cultural technique.
  IPM  may soon involve more
sophisticated methods. Through genetic
engineering, it may become possible to
develop crop plants that can produce
chemicals that give them an increased
ability  to repel  or kill insects, fungi,
bacteria, or nematodes. Another
approach may be to use the "R" factor
in man's favor;  to develop "beneficial"
insects that are  able to survive and
continue to prey on pests when
chemical pesticides must be used.
  The "R" factor presents a formidable
challenge to  scientists and others whose
job it is to control the pests that attack
man's supplies  of food and fiber. They
are responding  with the development of
an arsenal of techniques and systems to
meet this biological challenge. D
MARCH 1986
                                                                                                                    13

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Shredding  the
Junk  Auto  Problem
by James E. Fowler
    Rusting automobile hulks were a
    national problem and disgrace 25
years ago. Now, thanks to changes in
scrap processing technology, what was
once an environmental liability has
been transformed into an economic:
asset. It will remain a resource we can
continue to count on unless the trend is
reversed by increasing use of hazardous
materials in steel products.
  In the 1960s, cars were being
abandoned  at the rate of one every 30
seconds. It was estimated  that 20 to  30
million metal carcasses littered  the
countryside and city streets. The reason
was economic; low demand by
foundries and mills for scrap metal from
old cars meant low pri.ces  for the scrap
metal.  It was hardly worthwhile to go
through the costly and time-consuming
process of tearing the cars apart. As  a
result,  there was a nationwide backlog
of rusting junkers.
  Then the advent  of the shredder—a
giant machine that  literally rips
automobiles into fist-sized pieces of iron
and steel scrap—turned those cars into a
desirable source of man-made raw
materials for industry.
  Introduced in the 1960s, the
automobile shredder produced a
uniform grade of ferrous (iron and steel)
scrap that could be magnetically
separated from nonferrous and
nonmetallic scrap in a matter of
seconds. Steel mills and foundries could
use this type of material in their
furnaces and were willing to pay for its
uniform iron content. This increased the
demand for shredded scrap so that
shredder operators  could pay more for
automobile hulks. The economics of
the marketplace responded as collectors
and auto flatteners  realized they could
make a profit hauling old  cars to
iinti Dinvlnr nf I'uliln  HrJiitiom lor (lie
Institute nt Srnip Iron  mid Stocl, Inc.)
The advent of the shredder
turned those cars into a
desirable source of man-made
raw materials for industry.
shredders. Technology had not only
changed the form of scrap coming from
the rusting automobile hulks, but also
made possible increased recycling of the
junked cars.
  At first, the nonmagnetic
materials—aluminum, copper, brass,
zinc, stainless steel, along with glass,
rubber, plastics, textiles, and dirt—were
considered a waste byproduct of the
shredding process.  But the scrap
industry soon realized that the 50
pounds of nonferrous metals in the 900
pounds of residue from the shredding of
a typical  car had a  commercial value, if
those metals could  be recovered from
the dirt and glass.
  A cost-effective technology  was
developed, using gravity separation and
induction systems to separate the
nonferrous metals from  the nonmetallic
residue and to segregate the various
metals involved. Some processors also
refine the zinc die cast scrap, often into
pure high-grade zinc.
  In some parts of the country, the
motor blocks are removed prior to
processing. One popular brand of wood
burning stove is made from motor-block
scrap processed in  central
Massachusetts.
  As a result of all  these developments,
the junked automobile has become the
largest single source of recycled scrap in
the United States. This is certainly a
positive change from the mass
abandonment of old cars in the early
1960s, but, unfortunately,  the future
could see a backwards turn.
  The problem is the introduction of
hazardous materials into the
manufacture of steel products. This may
ultimately inhibit or prevent their
eventual  processing by the scrap
industry and the recycling of the metals
by scrap consumers. This is  a major
concern of the entire metallic scrap
processing industry.
  The issue, from the viewpoint of the
scrap industry, is really quite simple:
Designers and engineers must
consider the recyclability and
hazardous waste potential of the
materials they use in the manufacture of
various products. These critical factors
must be considered along with others,
such as durability and appearance, and
substitutes should be found  for
potentially hazardous materials.
  This should be done voluntarily by
manufacturers lest it be mandated for
them by legislative  action, as often
happens when environmental concerns
are ignored. For example, use of
cadmium in manufacturing is banned in
Sweden. In the United States cadmium,
though a hazardous material, is used as
a coating on selected automobile bolts
and as a coloring medium in some
enameled appliances and other
products. As Americans become more
concerned with  hazardous wastes as a
result of publicity surrounding
Superfund sites  and hazardous materials
disaster stories,  the safe recyclability of
a product should be an important
design and sales feature.
  For example, a highly visible
potential  hazard for the scrap industry
is the air  bag, as presently designed. Its
widespread use  could become a setback
for automobile recycling. The danger is
that an undetected unspent canister of
sodium azide, used to  inflate the bag,
could cause an explosion in a scrap
processing plant.
  The Institute of Scrap Iron and Steel
has argued against the wholesale
installation of air bags in cars since the
concept was first introduced in the
1970s. While the scrap industry claims
no expertise in highway safety, it does
know a great deal about processing
automobiles into scrap and potential
dangers faced by workers in scrap
processing plants.
14
                                                                                                      EPA JOURNAL

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                                                                               Kach one ul the junk cars  in i,1!;-
                                                                               ivi'li yidd  (ilxujt unc I"" oj iron and
                                                                                                            nailer
                                                                               and lighter, they will furnish lr~
                                                                                     re/ /or recycling.
Oner.1 (i piJr ol 'junk aufomobiJes, Ihi.s
mountain of shredded ferrous scrap ivill
be recycled into neiv iron (intJ steeJ
products.
  While the air bag danger is not in the
immediate future, because it will be at
least a few years before cars  with
airbags installed in them are ready for
the scrap heap (except for experimental
models or those involved in accidents),
now is the time to solve the  potential
hazard.
  The difficulty with air bags remaining
in automobile hulks is that processors
are unable to detect their presence. A
gasoline tank can be seen by a crane
operator when the hulk is being fed into
a shredder. But an unspent canister
cannot be seen by the operator as the
flattened remains of the car are lifted.
The scrap industry feels that air bags
should not be used until a way is found
to eliminate this risk to scrap plant
workers.
  The air  bag is a stark example of what
the scrap industry has been saying
about the  relationship of hazardous
materials to metallic scrap processors.
The industry believes that the regulation
of hazardous wastes should begin at the
point where manufacturers add
hazardous materials to their products,
rather than waiting until just  before the
products are to be recycled.
                                                                               As a result of all these
                                                                               developments, the junked
                                                                               automobile has become the
                                                                               largest single source of
                                                                               recycled scrap in the Lnited
                                                                               States.
  Fostering and protecting the
recyclability of metal products can be
quite significant in terms of saving
energy and minerals and protecting the
environment. EVA has reported, for
example, that using scrap leads to a  74
percent energy saving, that producing  a
ton of steel from automobile scrap takes
8,500 killowats less energy than
producing that steel from iron  ore. In
some areas of the country, thai much
energy could supply the electrical needs
of an average household tor an entire
year.
  In addition, the use of scrap instead
of iron ore results in an  H(> percent
reduction in air pollutants, a 76 percent
reduction in water pollution. 40 percent
savings in water used, a 90 percent
savings in virgin materials used, and a
97 percent reduction in  mining wastes.
  Relate  these figures  to the tact that six
to nine million cars are processed
annually by the scrap industry, and  the
energy, resource;, and environmental
savings they represent are tremendous.
  These figures and the  continuing need
to protect the human environment I'm in
hazardous wastes of all kinds should
encourage design  engineers to  think
ahead about their products. They nni.st
think of the materials used, and how
they can  be recycled, and consider
changes in design or materials
specification that could  make the
difference between efficient recycling
and hazardous waste disposal. By
designing recyclability into every  producl
before it  leaves the drawing board,
industry  can  help the nation preserve  its
finite resources and protect and enhance
the environment.  Q
MARCH 1986
                                                                                                                   15

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Oil  Spills:
No  News  Is Good   News
by L. Michael Flaherty
     We haven't heard much about huge
     oil spills at sea in recent years.
 The newspapers haven't carried tragic
 pictures of ruined beaches, tar-soaked
 waterfowl, or poisoned fish. Much of
 this is clue to a growing awareness on
 the part of governments and the!
 shipping industry of the importance of
 protecting the ocean evironment.
   Despite precautions and preventive
 measures, however, latest Coast Guard
 statistics show that  9 million gallons of
 oil wen; discharged into navigable
 waters of  the United States alone over
 the one-year period 1982-83. Of this
 total, 1.5 million gallons polluted U.S.
 territorial waters in Pacific Ocean, while
 another million gallons threatened the
 eastern seaboard and the Gulf Goast.

 Why No Headlines?

   A partial answer to this question  is
 that we have come a long way in spill
 countermeasure technology over the
 past 20 years.  In the United States, EPA
 and the U.S. Coast Guard have been at
 the forefront of research and
 development efforts to streamline
 emergency response to potential
 disasters through the use of new
 products and techniques and through
 new computerized clucisioninaking tools
 to make cleanup operations swift and
 effective;.
   When an oil spill occurs in shallow
 water, a dam of baled straw can absorb
 oil and trap or filter floating debris. In
 narrow, fast-moving streams, chicken
 wire can  he packed with straw arid  laid
 across the stream at an angle;. In
 slow-moving water, small booms with
 weighted aprons can be used for
 containment, and skimmers or earthen
 dikes may be constructed.
   Hut none  of these methods is
 adequate to prevent damage to the
 environment when a spill occurs on the
 high seas  and  threatens shore areas.
   Diversion booms, containment booms,
 skimmers, and sorbents have been used



                         .
where appropriate for ocean cleanup,
or to inhibit a spill's progress. However,
EPA now realizes that a key approach to
a major ocean spill threatening shore
areas is use of chemical
countermeasures, such as dispersants,
applied at sea before the oil can reach
shore.
  Oil on a water surface is naturally
broken up by the motion of waves. This
process, called natural dispersion, is
very slow, allowing an oil slick to travel
long distances before being broken up
completely. The process can take days,
weeks, or even months.
  Chemical dispersants speed up the
natural dispersion process by making it
easier for the sea to break up the oil
slick. When  dispersants are applied,
very small oil droplets are formed, and
these droplets are dispersed into the
upper 3-5 meters of the water column.
The droplets rapidly become diluted  in
the water and move away from the spill
site.  Dispersion can be almost complete
in a matter of minutes.
  Chemical countermeasures,  chiefly
dispersants,  still suffer from the stigma
that marked them in 1967 when the
tanker  Torrey Canyon grounded on the
shoals  off the English coast and spilled
30 million gallons of oil onto the shores
of Great Britain and France. The Torrey
Canyon incident prompted the first
major international effort to clean up an
oil spill, and many mistakes were made.
Chief among these was the improper
application of chemical products
dumped into the water to disperse the
oil.
  These products proved to be more
toxic: to aquatic life than the oil itself.
Dispersants became associated with
grim pictures of massive fish kills, and
of waterfowl drowning or dying of
hypothermia when the oil covering
deprived them of their natural
insulation. Though the dispersants used
were effective to a degree, the need to
reduce toxicity and refine application
techniques was clear.
  Dispersants on the market today bear
little similarity to those used on the
Torrey Canyon spill. Through research
and refinement, today's dispersants are
very low in toxicity and, in most cases,
are also biodegradable. Application
techniques have also been refined to
minimize the effect of the oil/dispersant
mixture on the environment.
  A different lesson was learned in
1978 when the Amoco Cadiz, a fully
loaded supertanker, lost its steering  and
drifted onto rocks in the English
Channel off the coast of Brittany. Before
it broke up, the Amoco Cadiz lost
almost all of its 59 million gallon load
of light Arabian crude and an additional
137,000 gallons of bunker fuel. More
than 30 ships responded to this spill,
and the French government spent $114
million on emergency response and
environmental restoration—a figure  that
does not even include expenses by other
governments, damage to the ship, loss of
oil, and military and volunteer labor
involved in the cleanup.
  Despite all  this effort and expense, a
lack  of contingency planning and
cooperation between the British and
French governments prevented the use
of dispersants on the spill, and  the
environment suffered significant damage
as a result.
  Dispersants finally came into their
own one year later in 1979, during the
Ixtoc episode in the Bay of Campeche
off the Gulf of Mexico. A well  head
blew out and the resulting oil discharge
continued for more than nine months,
dumping close to  137 million gallons of
oil into the water. Flying almost 500
missions, fixed-wing aircraft applied
dispersants which proved effective even
on this extremely  large spill. Less than
one percent of the discharged oil
reached the Texas coast.
  While dispersants are one of  the most
feasible treatments for spills on the  high
seas, other products and methodologies
now available are recognized as
A vf.'s.sr.'J tiquipfxul with .spray linom.s
applies dispersanls on 
-------
In \
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Do   Environmental   Disasters
Have  a  Good  Side?
by Roy Popkin
  It's an ill wind that blows no good,
  says the proverb, but is it really so? To
emergency managers, ill winds—storms,
hurricanes, tornadoes—often generate
beneficial hazard mitigation legislation
at the national  or local level.
Environmentalists aren't so sure this  is
true when the disaster involves some
form of air, water, or soil pollution. For
them, the ill wind carrying leaking
chemicals or smokestack wastes all too
often is just that—an ill wind.
  For people who deal with natural
ha/.ards such as floods, tornadoes, fires,
earthquakes, blizzards, and droughts, it
is an article of  faith that it usually takes
a major catastrophe to bring about
significant hazard mitigation or disaster
relief legislation.
  Examples of  such cause-and-effect
relationships are cited over and over  at
conferences where emergency managers
meet:
• Legislation authorizing the U.S.Army
Corps of Engineers to build flood
control works followed a series of floods
in the early part of this century.
• The first national flood insurance
program was enacted (but not funded]
in 1957, two years after catastrophic
floods in  the Northeast.
• The 1904 Good Friday earthquake in
Alaska ted to an Omnibus Disaster
Relief bill for that badly shaken state
and eventually  to legislation  in 1969
and 1970 that institutionalized the
federal role in disaster relief.
(Hoy /Yi/jkin joiner/ KRYs O/h'i:r of
Public A/friirs us n ivriler under ffic
      EnvironmentaJ Kmpi'
    nun ul'trr n'tij'int; from fix; Hrd
(rass Disri.sd.T Sen
Concern over Los Angeles
smog continued, grew in
intensity, and precipitated the
expenditure of millions of
dollars for research.
• In the midst of the Hurricane Betsy
relief actions in  1965, Congress
amended existing programs to "forgive
$1,500" of the amount borrowed under
low-interest disaster loan programs.
Subsequent amendments, increasing the
amount "forgiven," followed Hurricane
Camille in 1969, and Hurricane Agnes
in 1972.
• Spectacular dam breaks on the Teton
River and at Tacoa, GA, produced major
dam safety legislation and a dam
inspection program.
• Floods in the  early  1970s led
Congress  to expand and fund the
National Flood Insurance Program.
  Summing up the crisis-to-lawmaking
relationship, Professors Ian Burton,
Gilbert White, and Robert Kates, in their
1978 book,  Environment as Hazard,
note that  all major flood-related laws
but one in the twentieth century were
preceded by great floods somewhere in
the United States.
  Does the same proposition apply to
environmental crises involving air or
water pollution, chemical releases, or
poisoning by pesticides?
  In their book,  these  same authors
trace a direct line relationship between
London's 1952 "killer fog" in which
perhaps 4,700 people  died, the
subsequent Beaver Commission
investigation, and England's  1956 Clean
Air Act. But they find it more difficult
to link the English fog; the 1948 smog
that choked out scores of lives in
Donora, PA; and a lethal smog that
killed hundreds in New York City in
1953 to passage of the Clean Air Act by
the U.S. Congress in 1955.
  Professor Emeritus Arthur C. Stern of
the University of North Carolina would
agree. In an article published in  the
Journal of The  Air Pollution Control
Association, Stern states that
catastrophic events in Donora caused
only a "ripple of concern," while
concern over Los Angeles smog
continued, grew in intensity, and
precipitated the expenditure of millions
of dollars for research as to its cause
and cure, research that eventually
produced the first of a series of clean air
legislative actions.
  Although there seems to be a
"legislative mythology" that tries to link
a number of crisis  incidents to laws
under which EPA operates, the linkage
is only obvious in relation to Superfund
and the Toxic Substances Control Act
(TSCA), and, in the latter case, even that
is subject to question.
  There is an obvious relationship
between Superfund and the  community
furor and national media hype in the
late 1970s over the impact of abandoned
toxic wastes. Public attention focused
on Love Canal, Times Beach, and
Kentucky's "Valley  of the Drums."
Within a relatively short time, Congress
passed the Comprehensive
Environmental  Response, Compensation
and Liability Act of 1980. This created
Superfund, which added cleanup and
emergency response elements to  EPA's
hazardous waste dump permitting and
enforcement powers contained in the
Resource  Conservation and Recovery
Act, which passed well before the
aforementioned events.
  One frequently made connection is
that the fire on the oil-polluted
Cuyahoga River and the widely reported
"death" of Lake Erie had a major impact
on implementation  of subsequent Clean
18
                                                              EPA JOURNAL

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                                                                                At fhc bottom ot ii :<> loot deep
                                                                                          MI. repr:
                                                                                MiV.'ngun Fcinii Bureau and D<
                                                                                              supervis<
                                                                                       mtaminated u'ciry cattle.
                                                                                cnttlr were humanely killed in
                                                                                 HI7-4. By the end of thuf rear, some
                                                                                9.000 ronlaminutr,
                                                                                cli'str        d buried in Mi.
Water Act legislation. Steadman
Overman, Director of EPA's Office of
Legislative Analysis, thinks otherwise.
  Over the years, those who testified on
behalf of water pollution legislation.
Overman recalls, "never mentioned
either of those incidents. We kept
referring back to some cholera outbreaks
around 1918 and 1919." Clean water
legislation, he believes, was the result of
cumulatively mounting national concern
and not of single crisis situations.
  Overman does believe that a
cause-and-effect relationship may exist
between episodes of adverse health and
environmental effects and the passage of
TSCA in 1976. These episodes include
Kepone pollution of Virginia's James
River, PCB contamination of the Hudson
River and other waters, and PBB
contamination of  dairy cattle in
Michigan  that generated media coverage
of farmers slaughtering their cows.
  Experts in hazard mitigation and
emergency response seem to be in
general agreement that, while so-called
crisis or disastrous environmental
situations may occasionally have a
direct impact on the federal level, they
have much more clout at the state and
loca] level, influencing governments to
upgrade water quality or air emissions
standards, improve treatment facilities.
or take other environmental protection
actions.
  Natural disasters may also be
frequently followed by local actions
such as improvements in local warning
systems, changes in building codes,
enactment of hazard-related /.oiling
MARCH 1986
                                                                                                                     1!)

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                          KEPONE
                           ANT  and ROACH PASTt
                       For Control of Certain Ants and
                       WARNING.' Keep out of retch of cMfe
                           • •! pantt lor aM'tona! W**NING
                               USD* Reg No 216504
                                  Pal
                            ALLIED CHEMICAL CORPORATION
                                 AG*ICUUU«Al DIVISION
                                          , N.J.U.SX

laws, and relocation of populations at
risk. But Professor White sees a sharp
difference between natural disasters and
environmental crises.
  Floods, tornadoes, earthquakes, etc.,
leave; highly visible and dramatic scenes
of damage in their wake. TV screens are
filled with gut-wrenching interviews of
the victims.  Much less dramatic and
compelling are scenes of a burning
river, dead cattle, or interviews with
people upset about their water or their
chances of getting cancer some years
down the road.
  What's more, White says, the effects
of natural disasters are also much
simpler to deal with than those of
environmental disasters. Natural
disasters have an immediacy that can be
translated quickly into specific remedial
steps, including  legislation.
  Environmental disasters, on the  other
hand, are usually extremely slow to
become apparent and  the harm they
cause is often projected in a long-term
futuristic sc-n.se .  Environmental dangers
may take decades to reach the stage
where a national  problem becomes
obvious. To  the environmentalist or
scientist, the dangerous situation may
have been there all along, but it can
rarely be seen in dramatic TV news
footage or newspaper features.
  Environmental events, such as Earth
Day in 1970 or publication of books like
Rachel Carson's Silent Spring, rarely
produce a major legislative or regulatory
response. Even community-based
movements like the Breathers' Lobby of
the 1960s tend to fade away  after their
initial goals are achieved.
  Lacking a continuing series of
dramatic events like earthquakes,
tornadoes, and floods to build their
case, environmentalists must, therefore,
build a case with scientific research and
credibility. They must track  national or
regional patterns that can become the
concern of state and national agencies
and legislative bodies. Overflowing
sewers and polluted rivers in one area
need to be linked in the public  mind
with similar situations elsewhere. And,
because of our national penchant for
viewing dangers in the short term,
environmentalists need to find ways to
create public awareness and  concern
about problems such as increases in
cancer incidence or shortages of safe
drinking water that may develop 10, 20,
or more years down the road.
  EPA's scientists provide an
increasingly credible basis for regulatory
decisions. Their research and
                                                                                Environmental dangers take
                                                                                decades to reach the stage
                                                                                where a national problem
                                                                                becomes obvious.
monitoring programs provide the
information base on which EPA's risk
managers determine the need for and
nature of the regulations they
promulgate and enforce and  are a
resource for state and local regulatory
actions.
  But while the San Fernando
earthquake and a belief that  earthquake
prediction capability was just around
the corner moved Congress to pass the
Earthquake Hazard Mitigation Act of
1977, it is much less likely that there
will be comparable opportunities to
inspire environmental legislation, The
tragedy that cost so many lives at
Bhopal was a rare event in the history of
the chemical industry. EPA's response
to concerns raised by Bhopal—a
voluntary chemical emergency
preparedness plan based on  local
initiative—may well be the kind of
ongoing response that pays off in
environmental safety, and programs  like
that should not have to wait  for a lethal
chemical accident to be put  in place, o
20
                                                                                                         EPA JOURNAL

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Fighting  Pollution
in  Pennsylvania's  Oil  Fields
by Michael J. Chern


A lypicfjj oil production operation in
northwestern Pennsylvania, with oil
well, jack, unil .stock funk.
    i'n is o uTitcri-ditor in the Office ol
 Public /Affairs in h'PA's Hegion :JJ
   The world's first oil well was drilled
   over 125 years ago near Titusville,
PA. Shortly thereafter, oil rigs began
popping up throughout northwestern
Pennsylvania. Fortunes were being
made and little notice was taken of the
oil leaks and spills working their way to
streams in  the heavily forested area.
  Today, the center of American oil
production has shifted away from
Pennsylvania, but oil wells are still an
important part of the Commonwealth. A
few large companies maintain oil fields
in northwestern Pennsylvania, but many
fields are run by families or
independent operators who work just a
few wells. Small operators often wait to
                                                                          inspect their equipment until the oil
                                                                          flow slows or stops. Therefore, oil leaks
                                                                          can go undetected for months, even
                                                                          years. Abandoned leaking wells also
                                                                          present a problem.
                                                                            These wells are far different from the
                                                                          steel towers pictured in the television
                                                                          series, "Dallas." Surface pumping
                                                                          equipment, which looks a lot like basic
                                                                          outdoor water pumps, brings up the oil
                                                                          and sends it  in gravity-fed pipelines to
                                                                          collection points miles away. These
                                                                          pipes crisscross rugged terrain that is
                                                                          often inaccessible except on foot.


                                                                          He also saw a twig stuck in a
                                                                          pipe to stop a leak.
  EPA Region 3 Administrator James
Seif toured the area in October 1985 to
get a firsthand picture of the problem.
"It was disappointing," he said, "to see
environmental damage from oil
bubbling up from a well and spilling on
to the ground because someone had not
replaced a 25 cent washer." He also saw
a twig stuck in a pipe to stop a leak, and
he climbed steep hills to find the
sources of oil trickling into streams
down below.
  EPA and state environmental officials
began responding to oil spills and
regulating other facets of oil drilling
operations in the 1970s after passage of
the Clean Water Act. Over the  next
decade, EPA's Region 3 office
responded to many oil spills in
northwestern Pennsylvania, including
what is now the Allegheny National
Forest. Oil drilling there continues
because much of the forest land was
donated by parties who retained the
mineral rights.
  In 1984, U.S. Fish and Wildlife
Service and other officials pointed out
to EPA that some streams were almost
devoid of life when they should have
been prime trout-breeding areas. Forest
officials found birds and other wildlife
MARCH 1986
                                                                                                           21

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lying dead after becoming mired in oil
pools and slicks. There was evidence
that oil production contaminants were
bioaccumulating in some animals.
  The Forest Service was beginning an
ambitious program to stop
sedimentation of area streams, and the
State of Pennsylvania and EPA were
asked to step up efforts to stop oil spills
and unpermitted discharges into them.
It was clear, over the succeeding
months, that these and other concerned
agencies should produce a comprehensive
multi-program effort  to save and protect
the natural  resources of northwestern
Pennsylvania.
  On July 8, 1985, EPA designated four
counties as the site of a "major oil spill
with multiple  sources" so the Agency
could take an  organized rather than
piecemeal approach to cleaning up the
mess. The Coast Guard, which
administers EPA's funds  for cleaning up
oil spills in  water, approved $2.5
million for the effort. The Regional
Response Team, made up of officials
from federal and state agencies
responsible  for coordinating
environmental emergency responses,
agreed to support the effort by providing
needed technical advice,  financial
assistance,  and staff.
  At the  same time, EPA's Water
Supply Branch was receiving
complaints from local residents who
claimed their  drinking water wells were
being contaminated by the improper
disposal of oil and gas drilling
brines-—saltwater fluids containing a
variety of sometimes toxic
pollutants—which are pumped from
wells along with the oil. Brimes  were
typically discharged  into streams
without treatment or injected back
underground for disposal or to increase
the production of old oil  wells. A less
common  practice was to discharge
brines  into shallow pits, called blow
boxes,  from which they percolated
through the soil  to contaminate ground
water and drinking water wells. EPA
initiated  activities to tackle that
problem, too.
  EPA also recognized that the
permitting of oil field brine discharges
into waterways had been neglected
because many other types of discharges
were considered to be more harmful.
EPA and the Commonwealth of
Pennsylvania  hadn't  had  the resources
to mount a major effort to permit the
thousands of small brine discharges in
the four-county area.
  A major step forward in addressing
many of the problems was taken in
September  1985  when EPA regional
management identified oil-drilling
activities as a significant environmental
problem in an Environmental
Management Report (EMR).
Management saw the value of
expanding  the oil spill cleanup effort
into a multi-faceted approach to past
and present oil problems in
northwestern Pennsylvania.
  A task force was organized to include
representatives from the oil spill
response program, the Underground
Injection Control program, the
wastewater discharge permit program,
and wetlands protection program. While
each program carries on its activities in
adherence  to the laws and regulations
that govern it, the task force ensures a
coordinated effort.
Oil leaks can go undetected
for months,  even years.
  The benefits of the organized
approach can be seen in the first phase
of the oil spill project. This is a survey
to systematically  identify actual or
imminent threats of oil discharges into
waterways within the four-county area
encompassing the Allegheny National
Forest. Coast Guard teams check out
every mile of stream in the four
watersheds that drain the forest.  They
also look for other potential
environmental violations such as illegal
brine disposal. This information  is
passed on to other EPA programs or the
state for  action.
  When  the teams discover oil in the
water, the on-scene coordinator orders
an immediate cleanup, although
whenever possible, owners or operators
of the facility involved are asked to
voluntarily clean up.
  Most of the information gathered
through the watershed survey is
analyzed by EPA's national
Environmental Response Team in
Edison, NJ, and by the National Oceanic
and Atmospheric Administration.
Findings are ranked according to the
severity of the problems.
  The cleanup effort has already shown
results. For example, a small stream,
Pine Run, was devoid of life just a year
ago. During the early stages of the oil
spill initiative, ten individual spills
were cleaned up along Pine Run. A
recent bioassay shows that small aquatic
life has already returned to the stream.
  Other activities may take longer to
show actual environmental
improvement. EPA's Underground
Injection Control program hopes to
eliminate unacceptable disposal
practices like blow boxes. They also
hope to offer to oil well operators a safe
alternative for  disposing of brines by
permitting injection wells  that put brine
back underground in areas where it will
not affect drinking water. An  active
enforcement program will  further assure
that the oil industry implements
requirements designed  to protect
underground sources of drinking water.
  As another part of the task force
effort, Region 3 has raised  the priority
for issuing permits for brine discharges
into waterways. The regional  office has
offered the state technical  assistance in
locating unpermitted discharges, and  is
working with the state  and industry to
develop a generic brine discharge
permit to facilitate the  process.
  EPA personnel also found increasing
evidence that area wetlands were being
filled through  oil drilling-related
construction activities such as access
road development and  drilling pad and
pond construction.
  EPA's Environmental Photographic
Interpretation  Center (EPIC) in
Warrenton, VA, will produce  and
analyze aerial  photographs of the forest
to assist in identifying  both oil spills
and wetlands areas. Follow-up field
surveyors will seek out illegal filling
and take appropriate enforcement
action. Prior to initiating any
enforcement action, EPA will coordinate
with the appropriate parties.
  A most important part of the oil field
initiative is the outreach program
involving the oil industry  and area
residents. Several meetings have been
held in the area to discuss the goals of
the project. Although the project was
first met with  skepticism,  EPA's
outreach efforts, in conjunction with the
Pennsylvania Oil and Gas  Association.
have produced cooperation. Several oil
well operators have initiated cleanups
on their own and have  improved
maintenance of their equipment to
prevent spills.
  Region 3  hopes to enhance  this effort
by a series of workshops to educate oil
well operators on their responsibilities
under environmental law.  Seminar
topics include oil spills, wastewater
discharge, underground injection
control, and wetlands programs.
  Region 3's northwest Pennsylvania  oil
fields initiative is an example of the
Agency's attempts to implement
programs in a  way that brings
demonstrable  environmental results
rather than just measuring success by
the number of permits  issued or
enforcement actions taken. A  number of
individual programs whose goals are
quite different have been brought
together in a coordinated effort. D
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                                      Pollution  Where  You'd
                                     least  Expect  It
                                      Sybavid  B. Joseph
                             \        x\i
                      *'     \  ;  ' '    SS
                           *r.
   '                 t -i
      ..i       •.. .-t
Richard Frear, Nations! Park Service
    You ease your station wagon into the
    parking lot alongside the Grand
Canyon. You've driven your family two
thousand miles to see one of the eight
wonders of the world. The kids
scramble to be the first to drop a coin
into the viewing scope on the  canyon's
rim. They look down at the distant
bottom of the  great gorge, then across to
the other side. Do they see a
magnificent and  dramatic work of
nature? Of course they often do. But on
occasion they  may see murk and haze,
the product of industries, traffic, and
other sources  of airborne pollutants that
may have travelled hundreds of miles
from southern California or from the
copper smelters of southwestern
Arizona,
  Visible air pollution in the form  of
smoke plumes, brown clouds,  and  gray
and white haze is associated in most

(Joseph is iviffi [he Air Qualify n
National Pcirk  .Service, in Denver. (.'().
people's minds with urban and
industrial areas. People in Los Angeles
know there are days when you can't see
the street from the tower room atop City
Hall. Denver residents know there are
many days when industrial and
automotive air pollution blocks the
Rocky Mountains from the view of
drivers on the highway going past
Denver to the airport. And Washington,
DC, commuters have driven into town
in the morning without being able to see
the Washington Monument through a
summer's smog.
  These same people might not expect
to have similar visibility problems in
our national parks, especially in parks
in isolated reaches of this country.
  But, as the National  Park Service told
a Congressional subcomittee last May,
"even in remote areas such as Grand
Canyon National Park, visitors
sometimes cannot see the opposite
canyon rim or the canyon depths
because of poor visibility. At Yosemite
National Park, smoke from fires
fll Vir               'ks (Slit over <:
vieiv of the Hiue Hidge mnund:
Shenundi        ••mil I'm k
siilliites (ire responsible lor mosl
     li'fv  i/e<:md
-------
  "Visibility pollution" is one of the
pollution problems that concern the
Department of the Interior and EPA.
Since the National Park Service was
established in  1916, the Secretary of
Interior's mandate has been to preserve
and protect the scenery and the natural
and historic resources of  its lands for
the enjoyment of present and future
generations.
  In  response  to this mandate and
additional goals and  requirements of the
1977 Clean Air Act amendments, the
National Park  Service (NFS) conducts
an extensive research and monitoring
program to determine the impact of air
pollution on visibility of  national parks,
monuments, and wilderness areas. The
NFS also works with the  EPA and
numerous states to develop regulations
that  protect visibility.
In  Shenandoah  National Park,
the "Blue Ridge." often
appears an unnatural white,
gray, or brown.
  To determine the seriousness of the
visibility pollution problem in the
national parks, NPS currently monitors
visibility at more than 30 sites from the
Olympic peninsula on the northwest
Pacific Coast to the Florida Everglades,
and from Death Valley, CA, to Acadia
National Park on  the rocky Maine coast.
NPS monitors use color photography,
teleradiometry, and the collection and
analysis of particles in the air.
  The color photography documents the
important elements of the scene and
how they vary with changing air
pollution levels, weather conditions,
and sunlight. Teleradiometry uses a
special telescope  to measure the
contrast between  the sky in  the
background and dark  landscape features
so that changes in contrast caused by
pollution or climatic change can be
recorded.
  Together, the photography and
teleradiometry can be used to establish
standard visual ranges—the distance
from an observer at which a large dark
object such as a forested mountain
would just disappear against the
horizon. Collecting and analyzing small
particles in the air gives the NPS
scientists a wealth of information on the;
particles' possible  origin and their effect
on visibility.
  The focus is on very fine particles
(those smaller than 2.5 micrometers in
diameter—one tenth the diameter of a
human hair) which generally cause  most
of the visibility problems.
  What has this NPS monitoring found
out?

• More than 90 percent of the time,
man-made pollution affected scenic
views to some degree  at all NPS
monitoring sites.

• Best average visibility is  in northern
Nevada, Utah, and southern Idaho. The
area that includes  Grand Canyon, Bryce
Canyon, and Canyonlands National
Parks is next  best.

• The lowest visual range in the west is
in the coastal areas of California and
Washington.

• The very worst visibility recorded by
NPS is in  the eastern United States,
where there are higher relative humidity
and background air pollution levels. In
the summer of 1983, for instance, the
median  visibility  range at the
Shenandoah National Park  in Virginia
was 19 kilometers, as  compared to 100
to 200 kilometers for most western
parks.

• Visibility is generally best in the
winter and worst  in the summer.
  The NPS research and monitoring
effort has  provided much evidence to
establish particulates as the major
contributor to visibility impairment in
the parks. The very fine particles are
especially adept at scattering light and
producing visibility impairment, much
more so than big particles which
actually form a larger percentage of the
pollution  mass. This is particularly  true
for sulfates, which are the largest single
fraction of the total collected fine
particle mass.
  What's more, sulfates are optically
active particles that are very efficient at
scattering light and reducing visibility.
These particles are the end product of
atmospheric chemical transformation of
gaseous sulfur dioxide that comes from
such air pollution sources as power
plants, smelters, refineries, and oil and
gas fields.
  How pervasive are sulfate particles as
visibility impairers? NPS found them to
be the number one villain everywhere
except in the northwest, where carbon
particles took the lead. In  the Colorado
Plateau, where Grand and Bryce
Canyons are located, sulfate particles
were responsible for 40 to 65 percent of
the visibility impairment and in the
Shenandoah National Park for over 70
percent.
  In the Southwest, windblown dust,
emissions from construction activities,
and traffic on unpaved roads
contributed  10 to 30 percent of the
visibility reduction, while fine-particle
carbons and nitrates accounted for
another 20 percent.
  NPS scientists are beginning to
believe that  volatile aerosols—small
airborne particles that quickly evaporate
and are difficult for currently used
particulate samplers to collect'—may be
responsible for a significant share of the
visibility problem. One special study at
Grand Canyon National Park suggests
that aerosols more volatile than
ammonium  sulfate may account for 30
to 40 percent of the visibility reduction
there.
  Because sulfates are such an
important bad actor in terms of
visibility pollution, NPS has conducted
extensive analyses to determine where
the sulfate aerosols measured at the
monitoring stations come  from. The
agency's scientists developed a
technique called "back trajectory
residence time analysis" to estimate the
probable paths that sulfur particles
travel from the original pollution  source
to the park.
  They found, for example, that air
masses bringing high sulfur
concentrations  to Grand Canyon come
mostly from urban southern California.
Under different  climatic conditions the
particle-laden air came from the copper
smelter regions of southern Arizona. On
days when the particle concentrations
                                                                                                          EPA JOURNAL

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were low and the air clean, the clean air
mass was more likely to have come
from the north. Similar trajectory
analyses were performed in a number of
parks and monuments in the West;
these results, too, suggested that sulfur
emissions from distant urban and
industrial source areas contributed to
the reduced visibility at those locations.
  In the 1977 amendments to the Clean
Air Act, the Congress required
development of regulations to protect
visibility in national parks and
 Air musses bringing high
 sulfur concentrations to Grand
 Canyon  come mostly from
 urban southern California.
wilderness areas. NFS has been working
with EPA and state air pollution
agencies to reach this national visibility
goal, which includes both remedying
existing visibility impairment caused by
man-made air pollution and preventing
future problems. The  amendments
directed EPA to develop regulations to
assure reasonable progress toward
meeting the national goal and to provide
the states with guidelines for
implementing visibility protection
programs through State Implementation
Plans,
  The regulatory program mandates
EPA or the states with federally
approved visibility programs to:
• Evaluate and control new sources of
air pollution to prevent future visibility
impairment in national parks and
wilderness areas.

• Evaluate and control significant
visibility impairment in such areas that
can be traced to specific sources  of air
pollution.
• Adopt and implement  long-term
strategies for making reasonable
progress toward the national visibility
goal.

  The program  also gives states the
discretion to extend the visibility
protection to views of specific
landmarks  or scenic panoramas that can
be seen from within a national park but
which are outside its boundaries. Such
views are called "integral vistas." The
states will determine which of these
scenic attractions need protection, and
how much. NPS is working with  the
states to help them incorporate
consideration of scenic park features in
their rulemaking and protective actions.
  Although administrative and judicial
review actions delayed implementation
of visibility actions, EPA published in
July 1985 a federal approach to
monitoring visibility for 19 states and a
plan for determining new sources of
parkland pollution in 16 states. Other
states submitted State Implementation
Plans for EPA review. Because EPA has
found 32 states deficient  in some
aspects of the visibility rules, the
Agency intends later this year to
propose federal plans to remedy those
deficiencies.
  The federal monitoring effort involves
both EPA and federal land managers in
a cooperative network. A technical
steering committee which includes
members of the associated agencies  is
implementing the monitoring program
and is now in the process of selecting
the methods and locations to be used.
  In the original 1980 regulations, the
EPA focused  on visibility impairment
caused by single sources because of
scientific and technical limitations in
identifying sources of widespread
regional haze or complex urban plumes.
EPA committed itself to dealing with
these issues in future rulemakings.
  In 1984, EPA's Deputy  Administrator
established an Interagency Task Force to
look at the development of strategies for
addressing visibility  problems created
by pollution-derived ha/.e. to study the
links  between haze and such  problems
as acid deposition and fine  particulars,
and to recommend a five to ten year
program to deal with haze. In 1985,  the
Task Force reported its findings and
recommendations in the areas of
research needs, policy analyses, and
interim regulatory and legislative
considerations. The recommendations
have resulted in additional research
commitments and are being considered
in developing federal plans.
  In the few years since Congress
amended the  Clean Air Act to include
the problem of visibility degradation,
the Park Service visibility and research
monitoring program has done a great
deal to promote a better understanding
of the  problem. This  program is
providing the necessary basis for
informed and effective decisions on
visibility protection issues, regulation
development, and the ultimate success
of National Park Service efforts to
manage and preserve the parks for
present and future generations who
want to enjoy the beauty and  inspiration
that comes from sharing nature's
wonders, n
MARCH 1986
                                                                                                                   25

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"A  Fierce  Green   Fire":
Remembering  Aldo  Leopold
 by Jack Lewis
   Aldo Leopold has found a secure
    niche in the pantheon of American
naturalists. It is not uncommon to see
his work ranked with that of such giants
as Henry David Thoreau, John Muir,
and Rachel Carson. Historian Stephen
Fox has called  Leopold's A Sand
County Almanac "easily the  most
admired, most  quoted,  most influential
book in modem conservation," and
Leopold's  career "perhaps the most
distinguished ... in twentieth-century
conservation."
  Yet Aldo Leopold is  not as well
known as  the luminaries now judged to
be his peers. Several factors have
obscured his brilliance. Leopold the
man was gentlemanly and professorial,
never a self-promoter. Moreover, he did
not live to bask in the praise heaped on
his most famous book, A Sand County
Almanac.  Thus, the growth of the Aldo
Leopold cult has been slow: one
enthusiastic reader of A Sand County
Almanac recommending it to another,
in a word-of-mouth network that now
embraces tens  of thousands of admirers
the world  over.
  Integral  to that cult is the story of
Leopold's  tragic death. On April 21.
1948, Leopold  joined the fight against a
grass fire that was threatening his rustic
farm in the Sand Country of west
central Wisconsin. Only the week
before, he had  received a
long-distance call from the Oxford
University Press confirming that A Sand
County Almanac had been accepted for
publication. Ironically, some of the most
stirring passages in the Almanac were
devoted to condemning the scorched
earth policy of pioneers who had set
fires to clear the same  terrain decades
before,
  Now Leopold was face to face with
the fiery enemy. Overcome by smoke,
he suffered a fatal heart attack. Leopold
was only 61 when death enshrined him
for future  generations as a martyr to the
environmental cause.
  Aldo Leopold's life began on January
11, 1887, in the small town of
Burlington, IA. He was born to a

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prosperous German-American family
that had made its fortune manufacturing
fine walnut desks. The Iowa of the
1880s and 1890s was still the  luxuriant
paradise depicted in the paintings of
Grant Wood and the novels of Willa
Gather. A huge variety of flora and
fauna graced Leopold's childhood
environment. The spacious frame house
where the future forester and naturalist
grew up stood on a bluff overlooking
the game-rich marshes of the
Mississippi River.
  Aldo and his brothers, Carl  and
Frederick, spent countless hours
stalking partridges and ducks  in these
Iowa marshes. Aldo acquired a passion
for hunting from his father, Carl,  a
sportsman who tried to give all his sons
Leopold lived most of his life
alienated from the attitudes of
his colleagues in "the land of
neckties and boiled shirts."
a sense of fairness and self-restraint. To
Aldo the  boy, self-restraint came to
mean sparing the treed partridge and
taking aim only at the partridge on the
wing. To  Aldo the man, self-restraint
took the form of substituting bow and
arrow for rifle and bullet. But who can
doubt that this self-restraint cost a real
effort to Leopold, who was capable of
writing: "Compared with a treed
partridge, the devil and his seven
kingdoms was a mild  temptation."
  There was something almost
primordial about the intensity of the
young Aldo's bloodlust. Frederick
Leopold—Aldo's brother, still hale and
hearty at  90-might have been describing
Cain himself when he recently recalled:
"Father gave Aldo his LeFever, ... a
16-gauge  double. Aldo wore it out. At
the rate 1  was going in my hunting
heyday, I could live to be a good many
years older than I am  now and not have
killed near as much game as Aldo did."
  Aldo Leopold was, in short, no
tree-hugging wimp. He was an avid
hunter  and outdoorsman with a healthy
Darwinian respect for "nature red in
tooth and claw." He regarded the
hunting instinct as native to man, just
as it is to other animals, and he was
never  one to sentimentalize the
never-ending struggle of species against
species. Leopold minced no words in
Sand County Almanac: "If all are to
survive," he asserted, "each must
ceaselessly feed and fight, breed and
die."
  Leopold himself was a child of
privilege, insulated from the harder
realities of social  striving. He left Iowa
at an early age to  enter exclusive
Lawrenceville Prep in New  Jersey. After
spending several years at Yale's
Sheffield Scientific School,  he became
one of the first students at Yale's new
School of Forestry.
  It was in these ivied bastions of
Eastern privilege that Leopold gained
his grounding in the  sciences, but it was
also at Lawrenceville  and Yale that he
developed the dandified ways that were
to mark him for the rest of his days as,
quite definitely, "not one of the boys."
Leopold took to sporting hand-made
shirts  and Brooks Brothers suits, and he
was visibly proud of  his lean form and
patrician profile. "He was always
well-dressed in the field," one of
Leopold's graduate students later
recalled, "and around his neck hung
that dog whistle and  the Zeiss
binoculars. He was a gentleman to the
core."
  When Leopold graduated  from the
Yale School of Forestry in 1909, he was
one of only a hundred trained foresters
in the United States.  There  was a crying
need for Aldo's skills in the U.S. Forest
Service, an organization Gifford Pinchot
had formed in 1905 with the blessing of
Theodore Roosevelt. The lands
controlled by the  federal government
were vast, and so were the
responsibilities devolving on the first
professional forest rangers. Leopold had
been a ranger only one year when he
was appointed  deputy supervisor of the
Carson National Forest in north central
New Mexico. The following year he was
named supervisor. In  1913,  Leopold
became assistant district forester for the
whole Southwest district of the Forest
Service.
  That same year, Leopold married
Estella Bergere, the daughter of a
Spanish land-grant family. Aldo and
Stella  moved into a house near the
forest  at Tres Piedras, NM, and began to
raise a family of five  children. Carl
Leopold, Aldo's youngest son, now
Professor of Horticulture at  Cornell,
reports that his father "meticulously
avoided" forcing the  sciences on his
                                                                                                     EPA JOURNAL

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children. But all five, perhaps acting out
of some subconscious desire to  delight
their father, gravitated toward the
sciences.
  Starker, the first-born, who died in
1983, became a wildlife ecologist. His
scientific interests most closely
resembled his father's. Starker's brother
Luna is a celebrated hydrologist, now
teaching at the University of California
at Berkeley. The next-born, Estella, is a
palynologist and geomorphologist at  the
University of Washington. Her sister,
Nina, an ecologist married to a
geologist, is the only Leopold child who
has no formal schooling in the sciences.
She lives with her husband on the old
Leopold farm in Wisconsin,
which—along with a thousand
neighboring acres—is now preserved as
"The Leopold Memorial Reserve." The
youngest Leopold child, Carl, is not
only an expert on plant physiology but
also  an accomplished classical guitarist.
  So honored has the Leopold clan
become that journalist George Stanley
sees  no hyperbole in the statement that
the "name Leopold is to wildlife
conservation what Fonda is to movies
and Bach is to music." It surely is
remarkable that three of Aide's
offspring—sons Starker and Luna and
daughter Estella—are scientists  of such
distinction that they have gained
election to  the National Academy of
Sciences. Never before or since have so
many siblings from a single family been
admitted to the Academy. There is
ample reason to believe that not just the
genes but the patient tutelage of Aldo
Leopold made this feat possible.
  Observe the passing of esoteric
knowledge from generation to
generation. Aldo's brother Frederick
speaks of the way their father, Carl—the
originating Leopold patriarch—"planted
a seed, and it took in all of us. Of
course, Aldo developed it  further than
anyone else. . . . My father remembered
seeing the big flights of passenger
pigeons. He lived for hunting and the
outdoors. He used to tell me his shoes
were so bad when he was  a boy he had
to stuff newspapers in them to keep his
feet warm.  But he went out nonetheless,
in all seasons, and he raised us the same
way. He started teaching us to 'read
sign' when we were very small. We'd go
to a woods or swamp or prairie, and
he'd open up a hollow  log with an ax
and show us the mice and insects living
inside. He'd point out where a mink
had dug into a muskrat house, looking
for a meal.  He'd identify the animals
that had been around by looking at their
scat—These are a raccoon's droppings,'
he'd say. 'Look at the wild grape seeds
and skins, and the bits  of bleached
shells from crayfish he's been eating.'"
  Aldo's  daughter, Estella, a brilliant
exemplar of the current generation of
Leopolds, recalls: "Whether we were
hunting or not, long walks with Dad
always involved ecological analyses.
There was much stopping  and
discussing  tracks and sign, what the
                                                                                Aldo Leopold examines one of f/ii.'
                                                                                thousands         he and ;
                                                                                planted on their U'isronsin I'lirni.
 animal was eating, etc. I don't think he
 missed seeing much that was going on
 in the landscape. He knew every species
 of bird, plant, and mammal, and usually
 talked about them as individuals. All
 this made the biotic community very
 real and  exciting."
  Later, when Leopold became a
 professor at the University of
 Wisconsin, he initiated his students to
 the mysteries of "reading sign." By the
 time they completed his series of
 lectures and  field excursions, Leopold
 expected his students to be able to see
 patterns hiding in the most disparate
 evidence. A typical Leopold quiz might
 present the student with the following
 particulars: "A road flanked on one side
 by a subsiding telephone pole, then a
 pink granitic boulder, bluestem, oat
 stubble bearing ragweed, some young
 pine, poorer  oat stubble; on the other
 side a Siiphium, double-forked sumac,
 another pink rock, a fence post, and bit
 of corn stubble. A rabbit lay dead on the
 road."
  Sherlock Holmes himself might have
 hesitated before answering questions
 such as these: "How long ago was the
 last hard winter?" Answer: Two years, a
 fact that could be deduced from the
 sumac's double fork. "What sex is the
 rabbit?" Answer: Male, because females
 stay close to  home in spring. El cetera.
  It was thus through laborious
 instruction that Aldo Leopold sought to
 revive the lost arts of the wilderness
 adventurer. All along, he was well
 aware of  a central irony: namely, that
 American pioneers schooled in
 "nature's infinite book of secrecy" could
 have breezed through the very lessons
 that  dumbfounded their grandchildren
 and great-grandchildren.
  It was in 1924 that Aldo Leopold
 began his migration from the
then-daredevil world of the Civil
 Service forester to the tamer Groves of
Academe. He was 37 years old when he
was named associate director of the  U.S.
Forest Service Products Laboratory  in
Madison, WI. This lab, located in the
 same town as the University of
 Wisconsin, was the major research arm
 of the Forest  Service. Leopold knew of
 the commercial orientation of most of
 the research undertaken at the lab, and
 what he knew made him extremely
 reluctant to leave the Southwest. He
 accepted  the  new position only with the
MARCH 1986
                                                                                                                   27

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tacit understanding that he would soon
become director of the lab.
  Four years later, that ambition still
thwarted, Leopold quit the civil service
and started work as a private forestry
and wildlife consultant. He ran a
considerable risk in doing so, what with
five children and a wife to support, and
no private income. One of Aldo's major
projects over the next few years entailed
conducting a game survey of the north
centra! states for the  Sporting Arms and
Manufacturing Institute of America.
  The year 1933 proved to the world
that  Leopold's bold gamble had paid  off.
Not only were the results of his game
survey published, to considerable
acclaim, but so was his spectacularly
successful book Game, MriiKigement, a
comprehensive study that was quickly
recogni/od as the classic text on that
subject. Leopold's  book was so
pioneering and so  definitive that a
group ul I miversity (it Wisconsin
alumni  funded a special chair  for him
as America's first Professor of  Game
Management. Clapping a remarkable year
was  Leopold's appointment by Franklin
Roosevelt to a special Committee on
Wildlife Restoration.
 Leopold was convinced thai
 ecology, in and of itself, could
 not protect nature against
 man.
   The Madison campus of the
 University of Wisconsin  is located a few
 miles south of the state's "Sand
 Country." Mesa-like bluffs form steep
 cliffs throughout the Sand Country, an
 otherwise flat and sparsely populated
 region known for its sandy and marshy
 soil. Seeking a weekend and  summer
 retreat, Aldo Leopold picked out  "a
 cheap farm" in a part of the Sand
 Country extremely vulnerable to  April
 flooding. Unprepossessing though it
 was, Leopold came to love this farm
 with a passion approaching delirium.
   A Sand County Almanac records
 Leopold's observations of life on  his
 farm from January to December of a
 single year. These observations are all
 variations on the value of "wildness,"
 and the  evil of encroaching civilization.
 Leopold revelled in the wildness of his
 isolated  and marshy farm. Me had
 nothing  but contempt for city dwellers
 who satisfy themselves with  limited
 glimpses dl naluiv and seek dull
 security "astride a radiator."  Even the

 Working for tin            Service in
 ifMi. Alao l.f.'opold i\-/  tin;
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business of education practiced in
Madison struck Leopold as suspect: "Is
education  possibly a process of trading
awareness for things of lesser worth?
The goose who trades his is soon a pile
of feathers."
  Leopold attached almost  mystical
importance to one glimpse  of wildness
he had caught years before  in the
Southwest. A mother wolf and her pups
suddenly bore down on Leopold's
encampment. He sent out a hail of
bullets "with more excitement than
accuracy," then hurried down to watch
the death agonies of the mother wolf:
   We reached the old wolf in time to
   watch a  fierce green tire dying in her
   eyes. / realized then, and have
   known ever since, that there was
   something new to me in those
   eyes—something known only to her
   and to the mountain. I was young
   then, and full of trigger-itch;  I
   thought that because fewer wolves
   meant more deer, that no wolves
   would mean hunters' paradise. But
   after seeing the green fire die, I
   sensed that neither the wolf nor the
   mountain agreed with such a view.

   Leopold recorded this adventure in
one of his Sand County "sketches"
called "Thinking Like a Mountain." No
one can emerge from a close reading of
Aldo Leopold without acquiring some
idea, however vague, of what it is like to
think like a  mountain, a marsh, a crane,
a grebe, a  jackpine, a burr oak, a
meadow mouse, or a hawk. From such
exotic excursions into the wild world
beyond our  overheated doorstep, we
emerge more fully aware of what it
means to be living, sentient creatures in
a hostile world.
  There is something wonderfully
evocative about certain phrases in
Leopold's prose: "What one remembers
is the invisible hermit thrush pouring
silver chords from impenetrable
shadows"; "Through the open window  1
heard the heart-stirring whistle of an
upland plover; time was when his
forebears followed the buffalo as they
trudged shoulder-deep through an
illimitable garden of forgotten blooms."
  Leopold was able to wax poetic
without descending to the sentimental
excesses of the late Victorian happy
hearts. In Round River, a posthumous
collection of prose fragments published
in 1953, Leopold  heaped ridicule on
"the era of dickey-bird ornithology,  of
botany expressed in bad verse, of
ejaculatory vapors such as 'Ain't nature
grand?1" But he was also careful to
distance himself from the desiccated
writing of his scientific colleagues in
the academic world.
  Leopold was, in other words, that
rarity in academia, science, and
environmentalism: a self-conscious and
highly skilled literary artist.  Beneath a
cultivated and genteel demeanor, he
harbored a poetic alter ego, an untamed
Adam of the Arcadian marshes, capable
of happiness only in some long-lost age
when "man and beast, plant and soil
lived on and with each other in mutual
toleration, to the mutual benefit of all."
As a result,  Leopold lived most of his
life alienated from the attitudes of his
colleagues in "the land of neckties and
boiled shirts":
  There are men charged with the duty
  of examining the construction of the
  plants, animals, and soils which are
  the greatest instruments of the great
  orchestra. These men are called
  professors. Each  selects one
  instrument and spends his life taking
  it apart and describing its strings and
  sounding boards. This process of
  dismemberment  is called research.
  The place for dismemberment is
  called a  university.
    A professor may pluck the strings
  of his own instrument, but never that
  of another, and if he listens for music
  he must never admit it to his fellows
  or his  students.  For all are restrained
  by an  ironbound taboo which
  decrees that the  construction of
  instruments is the domain of science,
  while the detection of harmony is the
  domain of poets.

  There is something poignant about
that passage, just as there is  some
suggestion of false modesty  in Leopold's
reference to himself as "me, a mere
                          EPA JOURNAL

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 professor." Yet Leopold's students
 report that he cherished being called
 "The Professor."
   Such contradictions are characteristic
 of Aldo Leopold. Perhaps  his valiant
 death fighting that grass fire in 1948
 was in some sense an escape from the
 soul-rending conflicts that divided him:
 scientist versus poet, family man  versus
 wild hermit, Over every line of A Sand
 County AJmanac, there hangs a heavy
 shroud of impending  doom. Leopold's
 land was doomed, and so  was the
 scholar-poet uniquely capable of
 capturing the aura of  its vanishing
 beauty.
 His writings have helped to
 create an atmosphere
 conducive to environmental
 progress.
  Leopold had no doubt that the
marshes he loved so much faced swift
and total destruction. "The marshlands
that once sprawled over the prairie from
the Illinois to the Athabasca are
shrinking northward. . . . Some day my
marsh, dyked and pumped, will lie
forgotten under the  wheat, just as today
and yesterday will lie forgotten under
the years."
  Like many another man obsessed with
the threat of oblivion, Aldo Leopold
sought strength in science, but he found
his only real consolation in art. Even if
his marshes were doomed to die,
Leopold hoped that his immortal prose
poems would keep those marshes alive
on the printed page,  if not under the
blinding sun and the soothing moon.
Gentleman, hunter, artist, scientist,
genius,  Leopold  knew that his
"minority" view was vastly superior to
the muddled thinking of "the
shallow-minded  modern."
  How to transform mass man  into a
creature less shallow and less
destructive was to Aldo Leopold  an
unanswerable question. He  despaired of
any real progress toward "land health"
as long as Americans took the attitude
that government would pick up the
pieces after every outburst of mindless
rapacity. The clumsy mistakes of the
New Deal had cured Leopold of that
delusion once and for all. He believed
that the best hope for the future lay with
schemes of subtle coercion, designed  to
exploit man's curiosity and selfishness,
and channel these powerful drives
toward altruistic ends.
  Leopold was convinced that ecology,
in and of itself, could not protect nature
against man. "The question is, does the
educated citizen know he is only a cog
in an ecological mechanism? That if he
will work with that mechanism his
mental health and his material wealth
can expand indefinitely? But that if he
refuses to work with it, it will
ultimately grind him to dust? If
education does not teach us these
things, then what is education for?
  "Conservationists have, I fear, adopted
the pedagogical method of the  prophets:
we mutter darkly about impending
doom  if people don't mend their ways.
The doom is impending,  all right; no
one can be an ecologist, even an
amateur one, without seeing it. But do
people mend their ways for fear of
calamity? I doubt it. They are more
likely to do it out of pure curiosity  and
interest."
  In building game management into a
profession, Aldo Leopold exploited the
bloodlust of hunters fearful of losing
their prey, but his  objective—then as
always—was to "get action from human
beings as now constituted." The
long-range goal, which Leopold always
kept in view, was to use that game
consciousness as the leavening core of a
wider awareness "capable of expanding
in time into that new social concept
toward which conservation is groping."
  A society sensitive to the demands of
animals and plants is today far more a
reality than it was  in Aldo Leopold's
lifetime. His writings have helped to
create an atmosphere conducive to
environmental progress. Moreover, they
have inspired many activists to devote
                  :Mr ivhc;
             fuill. but I should no;
                            is not /it't
 his hd( ivhen
 Aldo i,<:upoJ(i
their lives to protecting America's
natural treasures.
  Shortly before he died, Leopold wrote
a tribute  to one of his old Forest Service
colleagues, C. K. Cooperrider. It
appeared in the July  1948 Jouniul of
Wildlife Management, the same issue
that carried his own obituary. Aldo
Leopold might have been describing
himself when he spoke of prophets and
prophecies: "A  prophet is one who
recognizes  the birth of an idea in  the
collective mind, and  who defines and
changes,  with his life, its meaning ami
its implications."
  Generations of future Americans will
be drawn to the writings of Aldo
Leopold,  and to his personal example.
Aldo Leopold the prophet, still scarcely
known outside environmental circles.
will always be there to haunt us and to
taunt us when  we forget the value of
pure wildness. The ghost of Aldo
Leopold will beckon  to us from the
marshes as  we sit, discontented, in our
overheated  parlors  in front of our
flickering video screens. He will be
there always, beckoning to us from
within  the "fierce green fire" where all
the splendor and glory of nature reside.
His spirit will never die. rj
MARCH 1986

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Climbing
Compliance  Mountain
 by Karen V.  Brown
 and  Edgar Berkey
     Many owners and operators of small
      businesses view the task of
complying with environmental
regulations much like the cartoon hikers
beginning to climb "Compliance
Mountain."
  Up ahead, they can see many
obstacles in their path, some easier to
overcome than others, a few that seem
overwhelming. The best route to  follow
is not clear, and the climb looks like a
formidable  challenge. In fact, the top of
the mountain—the goal of successful
compliance—is not even  visible.  The
situation leaves them wondering  and
bewildered. How high is  the mountain?
How long is the climb? And above all,
what will it cost before we're through?
  To many businesses, achieving
environmental compliance can seem
expensive and complex. In spite  of good
intentions, climbing "Compliance
Mountain"  is not an inviting
undertaking. Regulations are difficult  to
understand, and clear information on
requirements is difficult to obtain.
Regulators can seem bureaucratic,
inflexible, and not really  interested in
small business needs and problems.
Because of these complexities, many
small businesses often wonder if it
really matters. By virtue of their large
numbers, they feel the chances of
enforcement are slim.
  Unfortunately, this misconception
leads some small business people to
decide against scaling "Compliance
Mountain," even though substances they
handle and activities they perform pose
potentially  serious threats to the
environment. Because they are so
occupied in operating a business, they
often do not realize that unsafe practices
in using, discharging, and disposing of
      : i.-. f-.'I'.Y.s .Similj liusinr.';.s
    •ni/smdii (iiui Hockey is /'n.'sidunt <>'
       • nisiiltants, Jnc.)
chemicals can be harmful even though
the volumes involved are relatively
small. The collective significance of
these actions is far out of proportion to
their individual magnitude.
  Over the past few years, mounting
evidence has indicated that small,
uncontrolled sources of pollution can
result in serious problems. Toxic
chemicals improperly placed on land
have contaminated water wells and
aquifers. Badly packaged hazardous
waste has ignited, injuring workers. And
chemicals disposed of in drains have
disrupted  sewage treatment plant
operations. These circumstances have
led to increasing regulatory attention at
both the federal and state levels.
They are honest, tax-paying
citizens, but how far will they
go; how far can they afford to
go?
  During EPA's early years, attention
was quite properly focused on major
sources of pollution  and large industrial
dischargers. As progress was made in
these areas, it became more and more
apparent that further significant
improvement in the  protection of our
health  and environment would not
occur unless many of the smaller and
more numerous sources of pollution
(like small businesses)  were brought
under some form of regulation.
  Environmental regulations put into
place since 1980 have affected hundreds
of thousands of small businesses across
the country: from manufacturing and
chemical plants to Main Street
businesses such as service and retail
store operations. Regulations have
covered control of air pollution,
treatment of water discharges, and
management of hazardous waste. Many
businesses affected have never before
been required to comply with
environmental regulations. They are
mostly firms having fewer than 100
employees, with no particular employee
assigned responsibility for addressing
environmental requirements even on a
part-time basis.
  And more  regulations are coming!  In
a recent review, the EPA Small Business
Ombudsman's staff determined that the
agency has more than 25 regulations
under development that will have a
significant impact  on small business.
EPA is required to consider the effect of
these regulations on small business and
to develop approaches that can
minimize unnecessary burdens.
However, this is not as easy as it sounds
because of the agency's limited
experience in dealing with small
businesses.
  Fortunately, many small business
people appear willing to start the climb
up "Compliance Mountain" in spite of
the  many obstacles they will encounter.
They are honest, tax-paying citizens, but
how far will  they go; how far can they
afford to go?
  If EPA is to successfully promote
widespread small business compliance,
the  agency's  traditional regulatory and
enforcement approaches will require
major alteration and revision. The
special characteristics and needs of
small business owners and managers
will have to be considered in
communicating with this segment of our
economy as well as developing
regulations that minimize unnecessary
reporting burdens. Adversarial
relationships with regulators will need
to be tempered, and the regulators'
sensitivity to legitimate small business
concerns must be cultivated.
  Small  businesses play a vital role in
our nation's economy. Collectively they
produce 40 percent of the gross national
product and  employ 52 percent of the
nation's  workforce. They have created
60 percent of jobs  recently added by
industry. For every R&D dollar spent in
 30
                                                              EPA JOURNAL

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our nation today, small businesses are a
source of technical innovation 24 times
more productive than large companies.
It is EPA's continuing task to work
toward reasonable environmental
regulations that take into consideration
the special  needs and concerns of this
large segment of our economy and to
provide it with guidance and assistance
in bringing about increased voluntary
compliance. It is a sizable undertaking,
but a challenge well worth the required
effort. D
EPA's Small Business Ombudsman
The position of Small Business
Ombudsman, established at EPA in
early 1982, involves a rather uncommon
task within a federal regulatory agency:
to provide assistance to large segments
of the community it regulates.
  The Ombudsman's functions,  located
in the Office of Small and
Disadvantaged Business Utilization in
the Office of the Administrator,  are
broad in scope and intended to promote
cooperative  working relationships  both
inside and outside the agency. Major
duties and accomplishments of the
Ombudsman over the past three years
include:

• Participation in Regulatory
Development. The Ombudsman's staff
monitors and participates in regulatory
work groups developing regulations that
may have significant impact on small
businesses. The staff conveys to group
members the needs and concerns of the
small business community as they relate
to a specific regulation.

• Small Business Hotline. A toll-free
telephone number (800-368-5888) is
operated to provide  small businesses
with a convenient and confidential way
to reach EPA. Currently, the Hotline is
responding to more  than 400 calls  per
month,  with more than 50 percent
related to hazardous waste management
issues.

• Regulatory Information. The Hotline
helps small businesses understand and
comply with environmental
requirements. Trained staff provides
answers to specific questions, as well as
assistance interpreting regulations.
Requests for EPA reports or documents
needed by the callers are filled. A
special brochure listing more than 70
publications on environmental subjects
of interest to small business has been
compiled and sent to over 7,000
organizations  which represent small
business interests. Last year, more than
10,000 documents were distributed.
• Communicating with the
Small Business Community. The
Ombudsman provides a focal point for
communications between EPA and the
small business community, actively
meeting with  small business
organizations. At least twice a year, the
Ombudsman sends out an informational
memorandum to more than 7,000
individuals and groups interested in
small business environmental issues to
keep them informed on  recent
developments at EPA.

• Working  with EPA Personnel. The
Ombudsman's staff works closely with
other EPA staff members to increase
understanding of small businesses.
Periodically, the Ombudsman's office
prepares a SmaJJ Business Update for
more than 400 managers to keep them
informed on important small business
problems. A Small Business Task Group
composed of senior level managers from
EPA program and regional offices led a
15-month effort during 1983 and 1984
to formulate a new strategy, approved
by top management, to improve EPA's
regulation of small businesses and to
encourage voluntary compliance with
those regulations.
• Regional and Program Office Liaison.
Each Assistant and Regional
Administrator has selected a person
within his or her offices to serve as an
official Small Business Liaison with the
Ombudsman's office. Inquiries and
complaints are often funneled through
the Small Business Liaisons for
handling and disposition.

• Dispute Resolution. The Ombudsman
can assist businesses engaged in a
dispute  with EPA. Individual cases
brought to the staff's attention are
investigated, facts are determined, and,
if warranted, attempts are made to work
with the parties toward an equitable
resolution. Disputes  in an early stage of
development can be resolved.
MARCH 1986
                                                                                                                31

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Update
A review of recent major EPA activities and developments in the pollution control program areas.
 AIR
 Stratospheric Ozone
 The Agency has announced
 its strategy and timetable for
 examining the issue of
 stratospheric ozone
 protection.
   Tlic plan is expected to
 provide necessary technical
 information for possible
 future regulatory decisions
 on chlorofluorocarbons
 (CFCs) or other chemicals
 that may affect the ozone
 layer.
   The plan places emphasis
 on U.S. participation  in
 current international research
 and discussion of global
 strategies for protecting the
 ozone layer.
   In  1978, EPA and other
 agencies limited the use of
 CFCs as a propellant in most
 aerosal spray  cans. Several
 other countries also acted to
 reduce use of CFCs, but they
 still are used  in this country
 and worldwide for many
 industrial and commercial
 processes, including
 refrigeration, air
 conditioning and foam
 blowing, and  as a solvent by
 the electronics industry.
   By preventing most
 potentially harmful
 ultraviolet radiation (UV-B
 radiation) from penetrating to
 the earth's surface, the ozone
 layer acts as an important
 shield protecting human
 health, welfare, and the
 environment.

 Emission Balancing
 EPA  is proposing  a new
 policy which  would allow
 industries affected by EPA's
 new  stack height regulations
 to  lessen the costs of
 compliance by buying
 reductions from other
 pollution sources.
   The new policy, known as
 "emissions balancing," if
 adopted as proposed,  would
 give  an industry subject to
 the stack height regulation
 the option of contracting
 with  another source of sulfur
 emissions in the same area to
 achieve a required reduction
 in  emission. This  could be
 more cost-effective for the
 industry than achieving
 reductions at  the original
 source.
          The emissions balancing
        would not eliminate the need
        to comply with other basic
        requirements of the Clean Air
        Act, such as attainment of air
        quality standards, nor would
        it allow sources to delay
        compliance with the stack
        height regulations. Proposed
        emission balancing contracts
        would have to be submitted
        within six months after
        revised emission limitations
        are due at EPA, and would
        be subject to  public review
        and comment procedures.
         HAZARDOUS WASTE

         Land Disposal Phasedown
         The Agency is initiating a
         process which will ultimately
         end the land disposal of most
         untreated hazardous  wastes.
          This proposal will
         ultimately affect 33 billion
         gallons of hazardous wastes
         (out of 71.3  billion gallons
         generated annually) that now
         are disposed of untreated on
         land.
          EPA is proposing to
         prohibit land disposal of
         most untreated wastes
         containing solvents and
         dioxins, two of the most
         toxic and difficult substances
         to manage through land
         disposal.
          The 1984  amendments to
         the Resource Conservation
         and Recovery Act (RCRA),
         the federal hazardous waste
         management and disposal
         law, prohibit land disposal of
         regulated hazardous  waste,
         over the next five years
         (1990) unless the Agency
         determines that a waste can
         be made safe for disposal
         through a technological
         treatment process.
          The proposed treatment
         standard for dioxin calls for
         incineration to levels where
         the dioxin contamination
         cannot be detected. Because
         no incinerators have been
         permitted to burn dioxin
         wastes, EPA is proposing to
         extend the statutory  effective
         date for two years or until
         there is certified incineration
         capacity.
          Dioxins are a group of 75
         related chemical compounds
         unavoidably produced as
         byproducts  in the
manufacture of some
chemical products. Dioxins
are highly toxic and have
caused cancer and other
serious adverse health effects
in laboratory animals.
Controls on Spent Solvents
EPA announced that it is
acting to bring certain spent
solvents considered
hazardous waste under
control of the Resource
Conservation  and Recovery
Act.
  The new regulation will
close a loophole that left
certain mixtures of wastes
containing highly toxic spent
solvents uncontrolled. When
improperly managed, such
mixtures could pose health
or environmental hazards.
  Previously, EPA proposed
to amend RCRA regulation
for hazardous waste by
redefining the spent solvent
listings to include mixtures
containing 10 percent or
more total listed solvents.
  The listings covered only
the technical grade or pure
form of the solvents, leaving
mixtures containing one or
more of these toxic solvents
unregulated. Agency
information indicates that
solvents are frequently
blended to increase "solvent
power" and to achieve faster
drying. Such solvent
mixtures also may contain
from 15 to 50 percent or
more of toxic chlorinated
solvents. (A solvent is
considered "spent" when it
has been used and is no
longer effective).
PESTICIDES
Daminozide

EPA has announced that a
number of interim regulatory
measures have been imposed
as a condition for the
continued use of the
pesticide daminozide, also
known as alar.
  Daminozide is a plant
growth regulator used
primarily on apples intended
for the fresh produce market
(38 percent of the U.S. fresh
market apples).
  The new measures the
Agency is  imposing include
reducing application rates
and requiring extensive new
data to support continued
use.
  The exposure reduction
measures include a change in
the rate of application of
daminozide on apples from
four to three pounds  per acre
for mid- and late-season
treatments: and setting a
production limit on the
amount of daminozide that
can be produced for use on
grapes.
  This pesticide promotes
uniform fruits  and fruit
firmness, which  reduces
bruises  in handling and
shipping and increases
storage  life.
TOXICS
Asbestos Violations
EPA and the U.S. Department
of Justice filed 11 lawsuits
against 28 defendants
throughout the nation,
charging them with violating
Clean Air Act rules
protecting people from
asbestos exposure during
building demolition and
renovation.
  The cases all involve
buildings containing friable
asbestos, the type that can be
easily crumbled, releasing
fibers into the surrounding
air where they can be
breathed by humans.
Inhaled asbestos is a human
carcinogen that causes lung
cancer and mesothelioma (a
cancer of the  chest and
abdominal  lining), as well as
asbestosis (scarring of the
lungs).
  The regulations require the
owner or operator of a
demolition or renovation firm
to notify EPA (and a state
agency, if EPA has delegated
the authority) in advance of
beginning demolition or
renovation involving friable
asbestos.
  If the amounts of asbestos
are equal to or greater than
260 linear or  160 square feet,
the asbestos must be removed
before any  wrecking or
dismantling that would break
up the asbestos material,  Q
32
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Great blue heron in mating plumage
stalks a marsh area aiong Maryland's
eastern shore in search offish.

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United States
Environmental Protection
Agency
Washington DC 20460
Official Business
Penalty for Private Use $300
        ":iass Bulk
  Postage and Fees Paid

  Pern-
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