United States
Protecti
Agency
Office of
Public Affairs (A-1Q7)
Washington DC 20460
Volume 12
Number 2
March 1986
Environmental Perspeetr
.
-------
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
-------
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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-------
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
-------
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
-------
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
-------
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
-------
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
-------
.
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
-------
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
-------
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
-------
;/!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
-------
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
-------
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
-------
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 \
-------
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
-------
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!)
-------
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
-------
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
-------
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
EPA JOURNAL
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Pollution Where You'd
least Expect It
Sybavid B. Joseph
\ x\i
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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
-------
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
-------
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;
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is not /it't
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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
-------
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
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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
-------
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
-------
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
EPA JOURNAL
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Great blue heron in mating plumage
stalks a marsh area aiong Maryland's
eastern shore in search offish.
-------
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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