United States
Environmental Protection
Agency
Office of
Public Affairs iA-107)
Washington DC 20460
Volume 12
Number 5
June/July 1986
EPA JOURNAL
Acid Rain:
Looking Ahead
-------
Dark clouds cast shadows over liic
Adirondack Mountains near Lake
Pkicid, NY. As part of the. .YufionuJ
Surface Water Survey, scientists
collected samples/rom Jakes in this
area to study the impact of arid ruin.
Acid Rain: Looking Ahead
On January H. lilt; I !.S. and
Canadian Special Envoys
presented their report on acid
rain to tin1 President ami the
Canadian Prime Minister.
Tin; report recommended
specific actions thai could he
taken to address (lie
international acid rain
problem. For this special
issue of the I'.'PA Journal, we
asked the EPA Administrator,
the Canadian Minister of tin;
Environment, spokesmen lor
industry, and
environmentalists to
their impressions of current
acid rain policy in light of
the Heport of the Special
Envoys. The Journal also
interviewed Drew Lewis, the
U.S. Special Envoy, tor his
impressions, in hindsight, of
the process and impact of the
report.
In addition, the issue
includes a six-part, 12-page
special supplement that
provides a current overview
of the acid rain problem. The
supplement includes a
definition and history of add
rain, an international
perspective, a summary of
current control technologies,
and a discussion of studies
now underway that are
helping EPA prepare to
implement an acid rain
control program if and when
such a program is necessary.
Other articles include a
piece on the successful and
popular effort at EPA to
employ older workers in a
Senior Environmental
Employment program and a
report on the effort to save
hot torn laud hardwoods.
The issue concludes with
two regular features—Update
and Appointments, c
-------
United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 12
Number 5
June/July 1986
vxEPA JOURNAL
Lee M. Thomas, Administrator
Jennifer Joy Wilson, 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
mitimial 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 KPA Journal is published by
the U.S. Environmental Protection
Agency. The Administrator of KPA
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 tnnds for printing
this periodical has been approved
by the Director of (lie Office of
Management and Budget. Views
expressed by authors do not neces-
sarily reflect KI'A policy. Contribu-
tions and inquiries should be ad-
dressed to tlie Editor (A-107).
Waterside Mall. 401 M St., S.W.,
Washington, D.C. 20460. \o per-
mission necessary to reproduce
contents except copyrighted photos
and other materials.
1
o
CsA
The Next Step
on Acid Rain
by Lee M. Thomas 2
Special Envoy,
Special Task
An Interview with
Drew Lewis 4
Why Canadians Worry
About Acid Rain
by Tom McMillan
Front cover: Sampling from ci
helicopter on an (.-astern I'.S. Juke
during EPA's National Surface
Water Survey. Results of the
Survey are helping !o determine
(he extenl and distribution of
acidic surface waters in regions
susceptible !o changes from acid
deposition. Photo courtesy of (In
National Surface Writer Survov.
The View
from Industry
by William H. Meyonnoll
The Perspective
of the Environmentalists
by David G. Hawkins
and Deborah A. Sheimun
Acid Rain:
An EPA Journal
Special Supplement
Seniors Contribute
In EPA's SEE Program
by Margherita Pryor 27
Caring About
Bottomland Hardwoods
by Tom Welborn
,ind Mill Kriic/.vnski 2!)
Update j i
Appointments 32
Design Credits:
Robert Flanagan:
Ron Farrah.
0
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-------
Tin's .smi.ill pi/nl srnir f.J.NfM combu
dt.'.siiiiN.'i/ Ir; n' •,!<;- ii -us from
'niniin,u facilities, is Ijrin.u •
ivilli hinds /roin J'.'i'
lirsccirrh /.
-------
burn large quantities of fossil fuels. We
are concerned for good reason: the
resources at risk from acid rain are
enormous and, in some cases, priceless.
But the seriousness of the concern does
not in itself argue for immediate control
actions. Current scientific data suggest
that environmental damage would not
worsen noticeably if acidic emissions
continued at their present levels for 10
or 20 more years. Acid rain is a serious
problem, but it is not an emergency.
Second, although the potential
economic and cultural losses due to
acid rain are staggering, relatively little
damage is occurring at the present time.
Early data from our comprehensive
National Surface Water Survey indicate
that only 3.4 percent of the lakes
sampled in the northeastern United
States, frequently cited as one of the
most acid-sensitive areas in the country,
have a pH of 5.0 or less. (A pH of 7,0 is
neutral; pH decreases with increasing
acidity.) Some studies have linked forest
damage in Europe and parts of eastern
North America with acid rain, but the
scientific evidence is spotty at best. It is
not clear that acidity is the cause of the
problem, or that reducing acidic
emissions would solve it. In short, at
this time the damage caused by acid
rain is mostly theoretical. Theoretical
damage should leave us on our guard,
but it should not force us to take
premature control actions.
Third, launching a major control
program would have serious
socioeconomic consequences. The
economic costs would be very high—on
the order of $30 billion to $70 billion
over 20 years. Those costs would not
fall evenly on all people across the
country. The economic effects would
vary depending on the control actions
taken, but without careful planning and
program design, the heaviest burden
would be borne by high-sulfur coal
miners and utility rate-payers in upper
mideastern states such as Ohio, Indiana,
and Illinois.
At the same time, it is difficult, if not
impossible, to predict with any certainty
to what extent acid deposition in any
specific area would be reduced by
JUNE/JULY 1986
emissions controls on any specific
sources. We can reduce total emissions
of sulfur dioxide and nitrogen oxides,
and we can be reasonably sure that total
acid deposition would be reduced in
similar proportion over wide areas and
over long times. But we have no way of
predicting the degree to which
environmental and economic losses
would be avoided in the sensitive areas
of concern. It seems irresponsible to
impose real and substantial costs on real
and identifiable groups of people for a
control program of uncertain
effectiveness and benefit.
Considering what we know and don't
know about acid rain, it seems prudent
to incorporate a measure of patience
into our acid rain policy. For this reason
we have not initiated an acid rain
Considering what we know
and don't know, it seems
prudent to incorporate a
measure of patience into our
acid rain policy.
control program. Nor have we decided
against one. Rather, we have
implemented a comprehensive research
and analytical process that will provide
us with the kind of information needed
to make reasonable decisions within a
reasonable time. That process
emphasizes the completion of research
that will help us better understand how
much emissions should be reduced,
where they should be reduced, and over
what time period.
When the two Special Envoys handed
their report on acid rain to their
respective governments last January,
they moved that process forward
another step. In their report the envoys
recognized that the acid rain issue
demanded ongoing attention at the
highest levels of the U.S. and Canadian
governments. They recommended that
the two nations continue and expand
bilateral research efforts. Most
importantly, they recommended that the
United States spend $5 billion over the
next five years demonstrating the
commercial feasibility of innovative
control technologies.
The Special Envoys understood the
long-term nature of the acid rain
problem, and the political and economic
difficulties inherent in any near-term
acid rain control program. They
believed the most useful thing we could
do to reduce near-term emissions and
prepare for a more substantial long-term
control effort would be to expand the
list of control technology options
available to us. If we could cut the cost
and/or improve the efficiency of sulfur
dioxide and nitrogen oxides controls,
then we would indeed move closer to a
solution to North America's acid rain
problem.
Some people have said that the
Report of the Special finvovs did not go
far enough. Others believe that it went
too far. But the expenditure of $5 billion
is not inconsequential. It is a sizable
investment in our capability to control
acidic emissions as needed in the
future. Furthermore, an expense of that
magnitude is justified both by the extent
of the resources at risk ami the
legitimate concerns of our Canadian
neighbors.
The Report of the Special Envoys did
not solve the U.S.-Canadian acid rain
problem. Reasonable people will
continue to disagree about the
effectiveness of a $5 billion technology
demonstration program. EPA and the
other involved federal agencies will
continue to carry out the research
essential to our defining both the
problem and the most effective
response. But the Report of the Speciol
Envoys undoubtedly has moved us a
step closer to our goal. The technologies
that will be demonstrated will improve
our ability to craft an economically
feasible and politically defensible
control program.
President Reagan has strongly
endorsed the Report of the Special
Envoys. Implementing the report's
recommendations is, I believe, the best
next step for EPA. a
-------
Special Envoy,
Special Task
An interview with Drew Lewis
For this issue of the EPA journal, Tom
Super interviewed Drew Lewis,
President Reagan's fanner Special
Envoy on acid rain. Super is in the
Policy Office of the HPA Office of Air
and Radiation. His report on the
interview follows:
ll'f'U I.rivi.i n! tile :
iVil/iiill' : ' 'iJild nircl
lllii! (In1 I 'mlrif
mi
iiinlii ! Miiii i.s
ntlv,
EPA JOURNAL
-------
The office of the chairman and chief
executive officer (CEO) of the Union
Pacific: Railroad offers a panoramic view
of downtown Omaha, the Missouri
River, and the Great Plains beyond. But
on this rainy spring evening, the CEO
has no time to admire the scenery. It's
only his second day on the job. and he
is working late. In the first week of
April 1981). Drew Lewis—former CEO of
Warner Amex Cable Communications,
former Secretary of Transportation, and
former Special Envoy on Acid
Rain—has strayed a long way from the
Washington-New York corridor.
That Drew Lewis should move from
Warner Amex, a cable TV company, to
the Union Pacific Railroad is not as
improbable as it may seem. As Secretary
of Transportation from 1981 to 19H;i.
Lewis worked first-hand with the U.S.
railroad industry. Before that, he
managed the reorganization of tilt-
Reading Railroad, and. as one of two
court-appointed trustees, lie guided its
merger into Conrail. Drew Lewis knows
something about railroads.
Less obvious is why President Ronald
Reagan chose to name him the U.S.
Special Envoy on Acid Rain. In March
of 1985, the President met with Prime
Minister Brian Mulroney of Canada, and
they agreed to appoint Special Envoys
to study the transhoundary acid rain
issue and then recommend a course of
action that would help to resolve it.
Prime Minister Mulroney named
William Davis, a former Premier of the
Province of Ontario. President Reagan
personally called Lewis to ask him to
serve as the U.S. counterpart.
The request came as some surprise to
Lewis. "My secretary walked into my
office one morning and said, 'The
President is on the phone.1 I said. 'The
President of what?' When I got on the
phone, the President asked me to take
on the job as Special Envoy. He said
that U.S. relations with Canada were
very important to him, and we had to
resolve our differences over acid rain."
Lewis readily admits that, at the time,
he was not especially familiar with tin-
issue. "I had read an article or two
about acid rain. I'm from Pennsylvania.
and the farmers in my neighborhood
sometimes complained about their roofs
rusting because of acid rain. Beyond
that, 1 didn't know a thing."
Lewis believes that politics is
the art of the possible, and
that acid rain is. above all. a
political problem.
But, in Lewis' opinion, that may have
been an advantage. The President may
have picked him precisely because he
had no preconceived notions about acid
rain. "Don't underestimate the
President's concern over U.S. Canadian
relations. He knew a key issue dividing
us was acid rain, and he knew then,- was
a great deal of uncertainty as to its
causes and effects. He told me to look
into it and come to my own conclusions
about the severity of the problem. Then
he wanted me to report back with
recommendations for action. In that
kind of situation, the fact that 1 had no
prior position on the issue was probably
a great advantage.
"The President gave me an enormous
amount of latitude. If 1 saw a .significant
problem, I was to recommend actions to
do something about it, regardless ol
budget constraints. You have to realize,
of course, that our conversation took
place before Gramm-Rudman. so in
some sense the rules of the game have
changed."
Over the next nine months, Lewis
immersed himself in the question of
acid rain. He spent one to two days per
week on the issue, while two of his staff
worked virtually full time. They talked
to all the major parties with an interest
in acid rain, and they listened to
virtually anyone who held an opinion
on the subject. They met with scientists,
environmentalists, the electric utility
industry, the coal industry, the timber
industry, fishermen, citizens, and
politicians on both sides of the border.
They toured emissions sources, and
they visited acid-sensitive ecological
areas.
Lewis emerged from that experience
with some strong impressions of the
different parties involved. "1 was
especially impressed by the
environmental scientists, people like
Gene Likens in Mew York. They had
obviously spent years studying tin-
question. Although some of thorn had
strong opinions about what the
government should do about it. they
were very capable of answering my
questions with scientific detachment, In
that sense, they were much bettor
sources of information than the industry
lobby."
Lewis was less favorably impressed
by environmental organizations. "On
this issue at least, the environmentalists
are their own worst enemies, They have
staked out an all-or-nothing,
uncompromising position, which has
forced industry to entrench just as
deeply. When I talked to industry
people in public, they all argued that
there was no acid rain problem. When 1
talked to thorn privately, many of them
said they believed (hi; environment was
being affected. But they refused to say
so publicly for fear the
environmentalists would use that as a
way to force a huge control program
way out of proportion to the real
problem. I don't think too many
industry people would fight against a
well-reasoned control program, but they
don't think the environmentalist lobby
is willing to compromise."
Continued to next page
JUNE/JULY 1986
-------
A .Vi'iv I f
-------
I*
*
was meant to propose long-term
solutions, which is why we were
deliberately vague about what
technologies should be funded.
"By the way, I wouldn't be too
surprised if some of the technologies we
funded didn't work very well. The
technologies are unproven. That is why
the federal government is putting up
half the money—to take half the risk.
But if we spend the money, take the
risk, and develop a wider range of
control options, then the money will
have been well spent. We'll be that
much closer to a long-term solution.
We'll have moved the process along a
step or two, and like I said, that's what
politics is all about."
Drew Lewis delivered the Report of
the Special Envoys to President Reagan
early on the morning of January 8, 1986.
He spent the rest of the day briefing
members of the Congress. He flew back
to New York the next day, and has not
spoken about acid rain in public since.
On the surface, it appears as if the
experience burnt him out. But Lewis
denies it, emphatically.
JUNE/JULY 1986
"The day after I delivered tin: report.
Union Pacific announced that I had
been named chairman and CEO. At that
point, my public credibility, my public
objectivity, was threatened. You see.
Union Pacific has a large stake in the
acid rain issue. The company would
love to see a massive coal-switching
program. They'd make money mining
low-sulfur coal, and they'd make money
hauling low-sulfur coal. In fact, a Union
Pacific representative flew to New York
when I was with Warner Amex to lobby
me strenuously about the advantages of
low-sulfur coal. His lobbying was
persistent, bordering on the abusive. He
was probably chagrined to discover a
few months later that I was going to be
his new boss.
"But my personal situation in some
ways neatly exemplifies the complexity
of the acid rain issue. Some coal
companies would love to see an acid
rain control program, and some
wouldn't. Some coal miners would love
to see an acid rain program, and some
wouldn't. The problem is, those who
would love it and those who wouldn't
live in different places. So the issue
becomes polarized, regionalized, and
that much more difficult to resolve.
"I dropped out of public sight because
I didn't want my new job to prejudice
public dismission of the report. My
recommendations stand on their own.
even though Union Pacific would have
preferred that I recommend something
quite different. In fact, my new
colleagues still give me a lot of
good-natured grief about how I sold out
Union Pacific: in the Report of tin-
Special Envoys."
The rain that falls in Omaha in the
spring is not very acidic:. If it were, it
would probably be a boon to the rich,
alkaline soils of Nebraska. Omaha is a
long way from the Adirondack^.
But Drew Lewis is still interested in
acid rain. He still reads about it, and he
still talks about it. Occasionally, ho calls
Washington to find out how the
recommendations in his report are
progressing, how and when they are
going to be implemented. He is not
burnt out on acid rain.
Would he do it all over again? "Of
course, if the President called again and
asked me to help" Q
-------
Why Canadians Worry
About Acid Rain
by Tom McMillan
Canada rarely impinges on American
consciousness except, perhaps, as
the home of relatives or a safe
destination I'or tourists. When (Canadian
and American politicians visit one
another's countries, tradition demands a
ritual mention of the world's longest
undefended border and stresses our
mutual bonds of friendship. Surely we
are now secure enough with each other
to take those familiar signposts as
givens. Let us consider, instead,
complex and more demanding realities:
how two genuinely separate; countries,
with contrasting histories, with suhtly
but substantially different perceptions
and government systems, are dealing
with their shared environmental future.
There are increasingly .sensitive trade
issues that affect both our
countries—freer trade proposals,
protectionist trends, common
market-type arrangements such as the
Canada-United States auto pact. And of
course, defense matters will always
remain high on our bilateral agenda as
long as NORAD and our common
membership in NATO continue. Ihit il
is what we are doing to each other's
natural environment that is fast
becoming the most contentious issue
between our two countries.
That is especially the case in Canada,
perhaps because geography and
population patterns give rise to
perspectives that are different from
those in the U.S. Consider the contrast
in productivity of our environment
compared to that of the United States.
With the exception of parts of its
Southwest, America's various regions
are all potentially productive. In
Canada, by contrast, a demanding
climate severely limits our productive
land to a narrow margin within 150
miles of the U.S. border. As a result,
more than 90 percent of our people live
along that thin line and are dependent
on its environment for their needs.
is ( 'iiiitidd 's Min
Spur/ fishing in Canada. uir-! uimfry's fuiinMii indtistiv mm u<
furvril fn i li ise !><•
-------
ac:id fallout in New England and 25
percent of all acid fallout in the,
Adirondacks,
Clearly, we are neighbors who,
however friendly, have been throwing
garbage onto each other's front lawns for
years. The results have been
horrendous.
• In Nova Scotia alone, where fishing is
a vital industry, 13 salmon-bearing
rivers have been killed.
• At least 1,600 of Ontario's lakes are
acid-dead: their shimmering stillness
may look idyllic, in pictures, but in
reality it is a sign that they no longer
sustain life.
• Almost om; million lakes in Quebec
and Ontario are in vulnerable condition,
and the death toll rises annually.
• By the year 2000, an estimated 600
fishing camps and lodges, part of
Canada's vital tourism industry, may be
forced to close as a consequence of
acid-rain damage to fish.
• About half of Canada's
productive forests are in areas of acidic
rainfall; according to the most recent
figures, these forests generate $14
billion worth of forest products.
• Eighty-six percent of all Canadians
(compared to approximately 50 percent
of Americans) live where acidic
depositions are high, a possible source
of health problems. A comparison of
school children living in polluted and
Canadian Parl/amenl buildings in
OKnivii. (,'Josi'iip s/ioivs (/(imtigr lo
buildings' stoneivork -dmmjgi' cduscii
in pail by
-------
• The federal and provincial
governments have agreed on timetables
and targets for slashing sulfur dioxide
emissions: by 1994, they will be half of
their 19HO levels.
• Recently, the province of Ontario
announced that it would undertake a
massive 67-percent reduction. The
province acknowledges that reducing
emissions by three large
polluters Ontario Hydro, International
Nickel, and Algoma Steel—will mean
increased costs to all consumers.
• Ten months ago, the province ot
Quebec issued regulations that will
redui e emissions by 45 percent; a newly
elected government in that province has
already confirmed its commitment to
those levels.
• The federal government has
introduced tighter nitrogen oxide
emission standards for cars and is
planning to do the same for heavy duty
vehicles. Recently, I announced a
program that will educate Canadian
consumers about the dangers of
misfueling (deliberately using leaded
gas in cars designed lor unleaded fuel);
by !!)92, all automotive fuel sold in
Canada will be lead-free.
Our most up-to-date estimate oi the
capita] cost ol reducing acid rain-
causing emissions is between $1.5
billion and $2 billion dollars by 1994.
Yet, repeated polling shows that there is
only one major public issue on which
Canadians have significantly changed
their minds since the end of World War
II: the environment. People in this
country repeatedly describe themselves
as concerned about the environment, as
worried that governments will not do
enough to protect their environment,
and as willing to make reasonable
economic, sacrifices to safeguard it.
This concern about the environment
may explain the lukewarm Canadian
media response to President Reagan's
acceptance of the report by Drew Lewis
and William Davis, the American and
Canadian .special envoys on acid rain.
The media dismissal of the envoys'
report and the President's response is
unfortunate. Mr. Reagan's
acknowledgement that acid rain is a
serious trans-boundary problem is, in
fact, an important move towards joint
action on the issue.
// we ignore acid ruin, the
greatest damage would be to
our mutual sense of trust in
each other.
Moreover, acid rain has now become
firmly established as a major,
continuing item in future summits
between Canada and the United States.
It is not, as Canadian cynics insisted it
would be, a one-summit wonder, to be
discreetly buried at the bottom of some
diplomatic closet and hauled out on the
basis of political expedience. U.S. and
Canadian officials now have the same
clear-cut understanding that it will
remain a key bilateral issue until it is
solved.
Canada's overall objectives can be
stated as follows: this country wants to
reach a Canada-United States accord to
solve our mutual trans-boundary air
problems once and for all, such an
accord to include early reductions in
American acid rain-causing emissions
falling onto Canada. We expect that the
U.S. Administration will act on acid
rain. We expect that existing
air-pollution programs and legislation
will be used to reduce trans-boundary
emissions. We expect approval of clean
coal demonstration funding that will
give priority to projects that would
reduce trans-boundary emissions. We
expect to cooperate on research and on
monitoring that will guide decisions
being made on emission cutbacks. Botli
countries are setting up machinery to
begin working towards such measures.
The history of our two countries and
our capacity to reach solutions together
give me, give the Canadian government,
and should give Canadians and
Americans alike, cause for optimism. At
the same time, Americans must accept
the fact that the acid-rain issue is not
just an environmental issue to most
Canadians. They see it as a litmus test
of whether Canadian-United States
cooperation works both ways. The
chilling fact is that, if we can't make
progress on acid rain, with its terrible
consequences for all of us, how can we
hope to work on other issues where
self-interest is less clear-cut?
Acid rain can bring us together in a
great victory of common sense and
realistic self-interest. Or, it can eat away
at our environment and at our
economic, social, and physical safety. If
we ignore acid rain, the greatest damage
would be to our mutual sense of trust in
each other. That is why it is urgent for
us, on both sides of the border, to build
on recent events and to tackle
environmental issues that can corrode
the genuine goodwill that underlies all
those verities about friendship and an
undefended border. There is a lot at
stake. But, as we have proven so often
in the past, both countries are up to the
challenge, t:
10
EPA JOURNAL
-------
The View
from Industry
by William H. Megonnell
.•\ftiT o sudden shower, u tnv glist
ivitli mmilnips. Vorious irilcrcsl.s d
iviii'tbrr in.it! lain is innocuous 01
harmful,
l is Director o_I Legislative
Alfm'rs IKnriroiimrn'J lor Ilir j.'disi
Electric Institiih- I
ACID RAIN! You read about it in
newspapers. You see and hear about
it on television. The very term conjures
up all sorts of horrible thoughts—dead
fish, stunted crops, dying trees,
crumbling structures, rusting bridges,
even pockmarked skin and scarred
lungs. Those are exactly the images the
death-and-destruction doomsayers want
you to envision whenever you hear or
read about "acid rain."
It is unfortunate that those who speak
first, loudest, and most often—no matter
how unsubstantiated or outlandish their
claims—receive wide attention and are
afforded more credibility than those
who follow quietly and calmly to
present verifiable facts. Once an
alarming allegation has captured the
headlines, scientific facts that refute, or
do not substantiate, preconceived
notions do not make catchy news.
For a moment, however, forget the
media stories, the political
pronouncements, and the statements of
professional environmentalists who try
to tell you what acid rain is doing to
you and your environment. They have
done an extremely effective job of
building massive public' misperceptions
by pointing to adverse effects—almost
any effect—and screaming "ACID
RAIN!" But, from your own
observations, can you personally attest
to any adverse effects of acid rain?
Perhaps you like to fish, but you
aren't catching any. If not. why not? Are
you using the right bait? Or is it simply
that there are no fish where there used
to be fish—or whore the "old timers"
say there used to be fish? Assuming the
last, why are there no fish? The quick
and easy answer, because yon remember
having read an article on the
Adirondack lakes in Now York: acid
rain!
But caruful .scientific study has shown
that answer is much too quick and
much too easy. Although nobody can
deny there are a relatively few t'ishluss
bodies of water, there is no cloar and
unambiguous relationship pointing to
acid rain as the cause, or even a major
cause. Even the much touted 1986
report by the prestigious National
Academy of Sciences, onco you ignore
the press releases and wade through its
tortuous 506 pages, succeeds only in
reaffirming those ambiquities. The
academy found that lakes in New
Hampshire have remained the same
over this century, Wisconsin lakes
actually have become less acidic, and
New York lakes (depending on one's
interpretation of historic measurements)
JUNE/JULY 1986
11
-------
either have; experienced no change or
may have increased in acidity. The
report cautioned th
-------
The Perspective
of the Environmentalists
by David G. Hawkins and
Deborah A. Sheiman
hcike in Colorado's Hock)' Mountain
NationaJ Park. Acid rain is a national
problem, say (lie authors, with si"MS of
damage showing up even in the
Rockies.
(Hmvkins is a Senior Stall Attorney
ivith the Natural Resources JJefen.se
Council jNHDCj. SJieiman is a He.suurce
Specialist ivith NHDC's ('Jean .Air
Project.]
Acid rain kills fish and devastates
lakes and streams. !t degrades our
cultural heritage by eroding the
sculptural details of historical
monuments and statues. It stains the
skies with acid aerosols that dim
visibility in the city, the countryside,
and in our national parks. It is
implicated along with ozone as an agent
in the decline of forests. And (lie
pollutants that cause acid rain may be
threatening the respiratory health of the
American people.
Acid rain is one of the most
widespread environmental problems
facing our generation. Its effects are
cumulative and may be irreversible. U'e
know the cause: 50 million tons of
sulfur and nitrogen oxide pollution
emitted each year in North America.
and we know the cure: pollution
control. The technical means lo solve
the problem are in hand. Hut pollution
reductions will not be accomplished
voluntarily. It will require government
action to stem the emissions of millions
of tons of sulfur and nitrogen oxides
that pollute our air. our water, and our
land.
The prospects for action on acid rain
look brighter now than at any time since
the issue first appeared on the national
agenda. Several factors—botli technical
and political—have helped make the
issue ripe for resolution.
First, the; myths propagated by
anti-environmental forces have given
way to reason. Opponents ot pollution
control used to argue that not enough
was known about the causes and effects
of acid rain to justify doing anything
about the problem. 'I'llis line of
argument, that pollution is innocent
until proven guilty, is no longer viable
in the face of the overwhelming
consensus of the international scientific
community. Almost monthly.
authoritative scientific panels issue new
warnings. The latest is a March 1980
report of the National Academy ol
Sciences, which concluded that there is
a direct cause and eltect relationship
between emissions of sullur dioxide and
the acidification of the environment.
According to the report, sulfur dioxide
emissions ac.idifv precipitation, degrade)
visibility, pollute streams, and cloud the
air with acid aerosols.
There is also a growing scientific
consensus that acid rain is a broad
national problem, not just something of
concern in New England or Canada.
Signs of damage are showing up in (lie
Rockies and in the Boundary Waters, in
the Appalachians and the Adirondacks,
in Florida and in Chicago.
Continued to next page
JUNE/JULY 1986
13
-------
Second, politicians are showing
increased recognition of the need to take
action. On April 10, a bipartisan
coalition of 150 members of the House
of Representatives introduced H.R.
4567, the Acid Deposition Control Act
of 1986. A major victory occurred on
May 20, when the House Subcommittee
on Health and the Environment voted to
approve H. R. 4567. The bill was
introduced by representatives from all
parts of the country, including a
majority of members of the Health and
Environment Subcommittee and half the
members of the full Committee on
Energy and Commerce, The Sikorski
(D-MN)/Conte (R-MA)/Richardson
(D-NM)/Boehlert (R-NY) bill would
require a 10 million-ton reduction in
sulfur-oxide emissions from electric
utilities and other industrial sources by
1997. Nitrogen-oxide emissions that are
precursors to both acid rain and ozone
would be reduced by about four million
tons annually.
Acid rain is one of the most
widespread environmental
problems facing our
generation.
The Congressional Office of
Technology Assessment estimates that
average electricity rates would increase
by only two to three percent—about
$1.00 to $1.50 on the average electric
bill—and pegs the annual costs of the
legislation at $3.8 billion to $4.9 billion.
These are reasonable costs to protect the
environment from the ravaging effects of
acid rain, and the bill will certainly
yield economic and health benefits that
far exceed program costs.
Like all consensus legislation, H.R.
4567 is a compromise. Its emission
reduction requirements will not achieve
the 12 million-ton reduction in
sulfur-dioxide emissions needed to
halve acid deposition, as recommended
by the National Academy of Sciences in
1981. Its timetable, stretching out more
than a decade, seems excessive
considering the five years that states
and utilities have already had to prepare
for a control program. Further, the bill's
emission limits for many types of motor
vehicles simply codify EPA's current.
weak standards.
Despite these compromises,
environmentalists testified in support of
H.R. 4567 as a politically viable
measure that can begin to curtail the
damage caused by acid deposition.
Legislation introduced in the Senate
by Senator Robert Stafford (RAT) and a
majority of members of his Environment
and Public Works Committee is even
better from an environmental
perspective. S.2203. the New Clean Air
Act Amendments, is designed to
achieve a 12 million-ton reduction in
sulfur-dioxide emissions by imposing
limits directly on major sources, with
stricter limits applicable to power plants
that intend to generate base-load
electricity far into the future. In
addition, sources would have until 1995
to apply the best available technology to
reduce nitrogen-oxide emissions.
To control hydrocarbons and nitrogen
oxides, the precursors to ozone, and
carbon monoxide and diesel
particulates, S.2203 requires model-year
1990 cars and light-duty trucks to meet
emissions limits that reflect the
technology now employed by the
cleanest vehicles. Heavy-duty engines.
including notorious polluters like
trucks, buses, and construction
equipment, would be controlled by
1991.
Even the White House has decided to
acknowledge the seriousness of the
acid-rain problem. For the last five
years, the Reagan Administration's
position on acid rain has been that we
need more study before we can do
anything about it; to that end, the
government has been funding an $85
million per year research program to
investigate causes and effects.
In March 1986, the White House
announced the President's "full
endorsement" of the U.S. and Canadian
Special Envoys' report on acid rain.
This report stated:
"Acid rain is a serious environmental
problem in both the United States and
Canada. Acidic emissions transported
through the atmosphere undoubtedly
are contributing to the acidification of
sensitive areas in both countries. The
potential for long-term socio-economic
costs is high."
But rather than urging enactment of
controls, the report recommended a
five-year, $5 billion research program to
"demonstrate" new ways of burning
coal more cleanly.
The "clean-coal demonstration"
recommendation exemplifies how
desperation politics makes bad policy.
Reduced to its simplest terms, the
recommendation invents a problem and
then proposes to spend lots of
taxpayers' money to "solve" it. The
invented "problem" is the report's
implicit claim that adequate means to
reduce acid-rain causing pollution are
not now available. The "solution" is to
spend $5 billion to demonstrate means
to control acid rain.
The technical means to solve
the problem are in hand.
However, we have adequate
techniques now to control acid-rain
pollution. The report's recommendation
for a program to demonstrate "new"
technologies is not likely to help control
pollution at old plants. It is likely to
produce delay and to waste money.
The utility and high-sulfur coal
industries like the "clean coal
technology" recommendation because it
lets them argue that we should wait for
positive results before adopting new
controls. These industries have every
incentive to apply for and spend
taxpayers' money to prove that the
"holy grail" of better technology is still
just over the horizon.
Viewed in the context of Congress'
increasing desire to act on acid rain, the
report's recommendation for a
"demonstration" program is an attempt
by the Administration and several
industry allies to delay control
legislation by urging instead a new typo
of research program—this time research
into controls. It appears that Congress
will not fall for this latest decoy.
Members of Congress know that the
public is willing to pay for a cleaner
environment. Paying for an unnecessary
demonstration program with no
guaranteed environmental benefits just
is not an adequate substitute, u
EPA JOURNAL
-------
Few environmental problems have caused
so much controversy—and so much confusion . . .
People were worrying about pollution
problems related to acid rain hundreds of years ago
Now countries in several parts of the
world are working together to control it ...
Research into many different aspects of
acid rain is advancing . . .
And so is the technology to reduce it.
In this special supplement, the EPA Journal
takes a look at what we know about
acid rain—and what we don't know:
• The Acid Rain Phenomenon
• An Acid Rain Chronology
• An International Perspective
• Acid Rain Research
• Control Technologies
• Implementation Issues
-------
The Acid Rain Phenomenon
All rainfall is by nature somewhat
acidic. Decomposing organic matter,
the movement of the sea. and volcanic:
eruptions all contribute to the
accumulation of acidic chemicals in the
atmosphere, hut the principal factor is
atmospheric carbon dioxide, which
causes a slightly acidic rainfall |pl! of
5.6) even in the most pristine of
environments. (See box for an
explanation of pH.)
In some parts ol the world, the acidity
of rainfall has fallen well below 5.0. In
the northeastern United States, for
example!, the average pi I of rainfall is
4,6, and it is not unusual to have
rainfall with a pH of 4.0—which is 1000
limes more acidic than distilled water.
Although precipitation in the western
United States tends to be less acidic
than in the Mast, incidents of fog with a
pi I of less than ;!.() have been
documented in southern California.
There is no doubt that man-made
pollutants accelerate the acidification of
rainfall. We know that man-made
emissions of sulfur dioxide (SO.,) and
nitrogen oxides IN'OJ
transformed into acids in the
atmosphere, where they often travel
hundreds of miles before falling as
acidic rain. snow. dust, or gas. All these
wet and dry forms of acid deposition
are known loosely as "acid rain," which
is now recognized as a potentially
serious long-term air pollution problem
for many industrialized nations.
Emissions
and Deposition
Before the Clean Air Act was passed in
1970, U.S. SO2 and NOX emissions were
increasing dramatically. (See Table 1.)
Between 1940 and 1970. annual SO2
emissions had increased by more than
55 percent. Over the same period, NOX
emissions had almost tripled.
TABLE 1
Historic U.S. SO2 and NOX Emissions
(In Millions of Tons)
1940 1950 1960 1970 1980 1984
SO, 19.8 22.4 22.0 31.1 25.6 23.6
\'0X 7.5 10.3 14.1 20.0 22.5 21,7
The Clean Air Act helped to curb the
growth of these emissions. By 1984.
annual SO:, emissions had declined by
24 percent, and NOX emissions had
increased by only 9 percent. These
reductions in historical growth rates
took place despite the fact that the U.S.
economy and the combustion of fossil
fuels grew substantially over the same
period.
Acid-forming emissions are not
spread evenly over the United States.
Ten states in the central and upper
Midwest—Missouri, Illinois, Indiana,
Tennessee, Kentucky, Michigan. Ohio,
Pennsylvania, New York, and West
Virginia—produce 53 percent of total
U.S. SO, and 30 percent of total U.S.
NOX.
Table 2 lists the top ten SO, and XOX
emitting states. SO, emissions are
concentrated along the Ohio River
Valley in Ohio, Indiana. Pennsylvania.
Illinois, and West Virginia. These five
states, along with Missouri and
Tennessee, produce 44 percent of all
SO2 in the United States.
U.S. NOX emissions tend to he more
evenly distributed, but again, states
along the Ohio River are especially high
producers. Four of the Five highest
SO2-producing states—Ohio, Indiana.
Pennsylvania, and Illinois—are also
among the top ten NOx-producing states.
Thus, the Ohio River Valley and the
states immediately adjacent to it lead
the U.S. in emissions of both major
components of acid rain.
TABLE 2
Top Ten SO2 and NOx Producing
States in 1984 (In Millions of Tons)
SO, NO.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Ohio
Indiana
Pennsylvania
Illinois
Texas
Missouri
West Virginia
Florida
Georgia
Tennessee
2.58
1.87
1.60
1.38
1.24
1.18
1.02
0.99
0.93
0.92
Texas
California
Ohio
Illinois
Pennsylvania
Indiana
Florida
Michigan
Louisiana
New York
3.25
1.17
1.14
0.99
0.92
0.83
0.70
0.09
0.08
0.02
How "Acid" Is Acid Rain?
I.onion |ui(.r
\ Vinegar
l" Kain |5.li)
Distilled Water
Baking Soda
I 1
ACID R
1 1
1
AIN
1
ti 7 » 9 10 11 12 1314
xia.'TRAi. MASK;
Tim pi I scale ranges Irom 0 to 14. A value of
7.0 is neutral. Readings below 7.0 are acidic;
readings above 7.0 ;m; alkaline. Tin: more pi I
decreases below 7.0, (he more acidity
increases.
Because the pll scale is logarithmic, (here is
a tenfold difference between one number am!
till! one next to it. Therefore, a drop in pll
from (i.O to 5.0 represents it tenfold increase
in acidity, while a drop from (>.() to 4.0
represents a hundredfold increase.
All rain is slightly acidic. Only rain with a
pH below 5.(i is considered "acid rain."
Acid Rain Precursors
44%
34%
Transportation
Electrical
Utilities
NITROGEN OXIDES (NOx|
19.7 million metric tons NOX
18%
1%
Industrial
Processes
and Fuel
Combustion
Commercial/
Industrial/
Residential
Other
16
EPA JOURNAL
-------
Although we can't be certain of
long-term trends in acid deposition, it is
possible to draw conclusions about
current patterns. A comparison of the
pH of U.S. rainfall with the status
producing the greatest SOv and X()x
emissions clearly shows the solid link
between acidic emissions and acidic
deposition. Data collected by several
different monitoring networks show that
the areas of the U.S. receiving the most
acid rainfall are downwind and
northeast of those states with the
highest SO2 and NOX emissions.
Effects
of Acid Rain
The environmental effects of acid rain
are usually classified into four general
categories: aquatic:, terrestrial, materials.
and human health. Although there is
evidence that acid rain can cause;
certain effects in each category, the
extent of those effects is very uncertain.
The risks these effects may pose to
public health and welfare are also
unclear and very difficult to quantify.
The extent of damage caused by acid
rain depends on the total acidity
deposited in a particular area and the
sensitivity of the area receiving it. Areas
with acid-neutralizing compounds in
the soil, for example, can experience
years of acid deposition without
problems. Soils like this are common
throughout the; midwestern United
States. On the other hand, the thin soils
of the mountainous Northeast have very
little acid-buffering capacity, making
them vulnerable to damage from acid
rain.
Aquatic Effects
The adverse effects of acid rain are seen
most clearly in aquatic ecosystems. The
most common impact appears to be on
reproductive cycles. When exposed to
acidic water, female fish, frogs,
salamanders, etc:., may fail to produce
eggs or produce eggs that fail to develop
normally.
Low pH levels also impair the health
of fully developed organisms. Some
scientists believe that acidic water can
kill fish and amphibian reptiles by
altering their metabolism, but we have
little evidence that this is happening
now.
We do know, however, that acid rain
plays a role in what scientists call the
"mobilization" of toxic metals. These
metals remain inert in the soil until acid
rain moves through the ground. The
acidity of this precipitation is capable of
dissolving and "mobilizing" metals such
as aluminum, manganese, and mercury.
Transported by acid rain, these toxic
metals can then accumulate in lakes and
streams, where they may threaten
aquatic organisms.
Some lakes in areas of high add
deposition and low buffering capacity
have been found to be both highly
acidic and lifeless. Yet other lakes in
similarly sensitive areas have not.
Different lakes vary in the time it takes
to reach an acidic condition, and rates
of recovery from acidification also seem
to vary.
Scientists are using field studies,
long-term water quality data, studies of
fish population declines, and lake
sediment studies to analyze the
acidification of various lakes. However.
both the data and the theoretical models
currently available are unproven in their
ability to make an accurate prediction of
the effects of continued acidic:
emissions.
Terrestrial Effects
We know less about acid rain's effects
on forests and crops than we do about
effects on aquatic systems. The most
extreme form of damage some have
attributed to acid rain is the
phenomenon known as "dieback."
Dieback is a term applied to the
unexplained death of whole sections of
a once-thriving forest. At this time.
however, we have little direct evidence
linking acid rain to forest dieback.
Scientists do agree that acid rain can
lead to other, less extreme effects on
soil and forest systems. It can leach
nutrients from soil and foliage while
inhibiting photosynthesis. Acid rain can
also kill certain essential
microogranisms, The toxic metals it
mobilizes when passing through soil
can be harmful not just to aquatic lift;
but to trees and crops as well. But.
again, we have little evidence that such
damage is occurring now because of
acid rain.
Some experts even point to data
indicating that acid deposition may
actually benefit certain trees and crops.
For example, some pitch pine seedlings
SULFUR DIOXIDE (SO;,)
21.4 million niotric tons SO:-
Commercial/
Industrial/
Residential
Industrial
Processes
and Fuel
Combustion
Electrical
Utilities
Transportation
JUNE/JULY 1986
-------
An Acid Rain Chronology
have grown better when treated with
increasingly acidic water, and exposure
to combinations of acid rain and mist
has stimulated red spruce growth. It is
possible that nitrates derived from the
nitrogen oxides in acid rain confer some
nutritional benefits on trees and plants.
Materials Effects
Acid rain can also damage man-made
materials, such as those used in
construction and sculpture. We are all
familiar with photographs of statues that
are losing their features and shape, with
acid rain often cited as the culprit.
The problem is far more than
aesthetic. Building materials, too, can be
degraded by acidity. For example,
limestone, marble, carbonate-based
paints, and galvanized steel all can be
eroded and weakened by the kind of
dilute acids found in acid deposition.
Since materials naturally deteriorate
with time, it is difficult to differentiate
the effects of acid rain from damage
caused by normal weathering. It is also
hard to identify the specific damage
caused by specific pollutants or
combinations of pollutants. As a result,
the particular role played by acid rain
in the deterioration of materials is still a
major unknown.
Human Health Effects
So lar, we don't know of any human
health problems resulting from direct
contact with add rain. Inhaling acidic
particles in acid fog may possibly carry
some health risk, but more research is
needed to confirm whether this
constitutes a real risk.
Acid rain may also indirectly affect
human health when it mobilizes toxic
trace metals such as aluminum and
mercury. When dissolved in acidic
water, these metals can be ingested by
fish and animals, building up in the
human food chain. Acidic water could
also leach lead out of pipe solder and
into drinking water supplies.
Hut these are only possibilities. No
one has established that current
emissions of SO2 and NOX are actually
causing such damage, or that such
damage will continue or increase in the
future if SO^ and NOX emissions are not
reduced.
.../rsJiSf •'•
•
A IfdiJ chamber
onstructed bv
I'lt/i (.cnlury
sh M'it'nd'sl
igus Smith
irrimrnlul
irch
iiilo air quality.
'
1661-2: English investigators John
Evelyn and John Graunt publish
separate studies speculating on the
adverse influence of industrial
emissions on the health of plants and
people. They mention the problem of
transboundary exchange of pollutants
between England and France. They also
recommend remedial measures such as
locating industry outside of towns and
using taller chimneys to spread "smoke"
into "distant parts."
1734: Swedish scientist C.V. Linne
describes a 500-year-old smelter at
Falun, Sweden: ". . . we felt a strong
smell of sulphur . . . rising to the west
of the city ... a poisonous, pungent
sulphur smoke, poisoning the air wide
around . . . corroding the earth so that
no herbs can grow around it."
IK
1872: English scientist Robert Angus
Smith coins the term "acid rain" in a
book called Air and Rain: The
Beginnings of a Chemical Climatology,
Smith is the first to note acid rain
damage to plants and materials. Me
proposes detailed procedures for the
collection and chemical analysis of
precipitation.
1911: English scientists C. Crowther and
H.G. Ruston demonstrate that acidity of
precipitation decreases the further one
moves from the center of Leeds,
England. They associate these levels of
acidity with coal combustion at Leeds
factories.
1923: American scientists W.H.
Maclntyre and I.E. Young conduct the
first detailed study of precipitation
chemistry in the United States. The
focus of their work is the importance of
airborne nutrients to crop growth.
1948: Swedish scientist Hans Egner,
working in the same vein of agricultural
science as Maclntyre and Young, sets up
the first large-scale precipitation
chemistry network in Europe. Acidity of
precipitation is one of the parameters
tested.
EPA JOURNAL
-------
An International Perspective
1954 : Swedish scientists Carl Gustav
Rossby and Erik Eriksson help to
expand Egner's regional network into
the continent-wide European Air
Chemistry Network. Their pioneering
work in atmospheric chemistry
generates new insights into the
long-distance dispersal of air pollutants.
1972: Two Canadian scientists, R.J.
Beamish and H.H. Harvey, report
declines in fish populations due to
acidification of Canadian lake waters.
1975: Scientists gather at Ohio State
University for the First International
Symposium on Acid Precipitation and
the Forest Ecosystem.
1977: The U.N. Economic Commission for
Europe (ECE) sets up a Cooperative
Programme for Monitoring and
Evaluating the Long-Range Transmission
of Air Pollutants in Europe.
1979: The U.N.'s World Health
Organization establishes acceptable
ambient levels for SO2 and NOX.
Thirty-one industrialized nations sign
the Convention on Long-Range
Transboundary Air Pollution under the
aegis of the ECE.
1980: The U.S. Congress passes an Acid
Deposition Act providing for a 10-year
acid rain research program under the
direction of the National Acid
Precipitation Assessment Program.
1980: The U.S. and Canada sign a
Memorandum of Intent to develop a
bilateral agreement on transboundary air
pollution, including "the already serious
problem of acid rain."
1985: The ECE sets 1993 as the target
date to reduce SO2 emissions or their
transboundary fluxes by at least 30
percent from 1980 levels.
1986: On January 8, the Canadian and
U.S. Special Envoys on Acid Rain
present a joint report to their respective
governments calling for a $5 billion
control technology demonstration
program.
1986: In March, President Ronald
Reagan and Prime Minister Brian
Mulroney of Canada endorse the Report
of the Special Envoys and agree to
continue to work together to solve the
acid rain problem.
Principal source: EJIis B. Cowling,
"Acid Precipitation in Historical
Perspective," Environmental Science
and Technology, Volume 16, Number 2,
1982.
A:id rain is not considered a threat to
the global environment. Large parts
of the earth are not now, and probably
never will be, at risk from the effects of
man-made acidity. But concern about
acid rain is definitely growing.
Although acid rain comes from the
burning of fossil fuels in industrial
areas, its effects can be felt on rural
ecosystems hundreds of miles
downwind. And, if the affected area is
in a different country, the economic
interests of different nations can come
into conflict.
Such international disputes can be
especially difficult to resolve because
we do not yet know how to pinpoint the
sources in one country that are
contributing to environmental damage
in another.
Concerns about acid rain tend to be
raised whenever large-scale sources of
acidic emissions are located upwind of
international borders, japan, for
example, has not yet suffered any
environmental damage due to acid rain,
but the Japanese are worried about the
potential downwind effects of China's
rapidly increasing industrialization. A
similar problem has risen on the
U.S.-Mexican border, where some
people are worried that Mexico's new
copper smelter at Nacozari could cause
acid rain on the pristine peaks of the
Rocky Mountains. Besides scattered
instances such as these, acid rain has
emerged as a serious international issue
only in two places: western Europe and
northeastern North America.
Europe
Diplomatic problems related to
cross-boundary air pollution first
surfaced in Europe in the 1950s, when
the Scandinavian countries began to
complain about industrial emissions
traveling across the North Sea from
Great Britain. Since then, acid
deposition has been linked to ecological
damage in Norway, Sweden, and West
Germany, and low-pH rainfall has been
measured in a number of other
European countries. (See map on this
page for the average pH of rainfall over
Europe in 1980.)
The political and scientific
controversies over acid rain are
multiplied in Europe because so many
countries are involved. Table 3 lists the
SO2 emissions of 21 European nations
in 1980.
A comparison of the pH map with
Table 3 reveals that some countries
producing very low amounts of SO-, are
nevertheless experiencing low-pH
rainfall and high rates of acid
deposition. Norway, for example,
produced approximately 137,000 metric
tons of SO2 in 1980, yet received
depositions of about 300.000 metric
tons. Clearly, Norway, like a number of
other European nations, is being
subjected to acid deposition that
originates outside its borders.
Sweden pioneered the development of
extensive and consistent monitoring lor
acid precipitation in the late 1940s. In
1954, the Swedish monitoring program
TABLE 3
European SQ2 Emissions in 1980
(In Thousands of Metric Tons)
This nuip slimv.s average plf lewis in
Ixisrd on dutu gathered Ix-fuv
I~M mid Dncrnilicr I 9i
Austria
Belgium
Bulgaria
Czechoslovakia
Denmark
Finland
France
Federal Republic.
of Germany
Greece
Hungary
Italy
Netherlands
Norway
Poland
Portugal
Romania
Sweden
Switzerland
United Kingdom
USSR
Yugoslavia
•440
809
1,000
3,100
399
600
3.270
3,580
700
1,663
3.800
487
137
2,755
149
200
450
119
4,680
25,500
3,000
(Figures from U.S. Department of State)
JUNE/JULY 1986
19
-------
was expanded to include other
Europium countries. The results of this
monitoring revealed the high acidity of
rainfall over much of western Europe.
Prompted by these findings, the U.N.
Conference on the Human Environment
recommended a study of the impact of
acid rain, and in July 1972. the U.N.
Organization for Economic Cooperation
and Development (OECD) began an
inquiry into "the question of acidity in
atmospheric precipitation." In 1979, a
U.N. Economic Commission for Europe
(KCK) conference in Stockholm
approved a multi-national "Convention"
for addressing the problem of long-range
transboundary air pollution, lioth the
United States and Canada joined the
European signatories. Since; Ihi-ri. a
number of European countries,
including France, West Cennanv.
Czechoslovakia, and all the
Scandinavian countries, have agreed to
reduce their HMt.'i SO:, emissions by at
least 30 percent from 1980 levels.
More, recently, ECE members decided
in 19i),r> to broaden their goals to
include the control of nitrogen oxides,
which have been gaining recognition as
important acid rain precursors.
Workshops are now underway to
determine the nature and extent of \OX
pollution in various countries, as well
as possible approaches for controlling it.
North America
Tin,' United States and Canada share the
longest undefended bonier in the world
and billions of dollars in trade every
year. We also share a number' ol
environmental problems, foremost
among them the problem of acid rain.
In both countries, acidic emissions are
concentrated relatively close to our
mutual border. Canadian emissions
originate primarily in southern Ontario
and Quebec, while a majority of U.S.
emissions originate along the Ohio River
Valley. Each country is contributing to
acid rain in the other. Hut because of
prevailing wind patterns and the greater
quantities of U.S. emissions, the United
States sends much more acidity to
Canada than Canada sends to us. In
1980. for example, the U.S. produced
over 23 million metric tons of SOL, and
over 20 million metric: tons of NOX;
Canada produced 4.6 million metric
tons of SO:. and 1,7 million tons of NOX.
In the early 1970s, Canadian scientists
began to report on the adverse
environmental effects of acidity in lake
water, and to link fish kills in acidic
lakes and streams in eastern Canada to
U.S. emissions. By the late 1970s, acid
rain had become a serious diplomatic
issue affecting the relationship of the
two countries.
In 1980. we took our first joint step
towards resolving the issue with a
Memorandum of Intent that called for
shared research and other bilateral
efforts to analyze and control acid rain.
One of the most spectacular projects
was a high-altitude experiment called
"CAPTEX." Trace elements of various
chemicals were inserted into SO2
plumes from coal-fired power plants in
the Midwest. Their dispersion was
monitored along a path extending across
the northeastern United States to
Canada. These and other experiments
have helped scientists gain new data on
the formation and distribution of acid
rain.
When Brian Mulroney became Prime
Minister of Canada in 1984. he pressed
for more than research; he wanted
bilateral action to control acid rain. At
the first "Shamrock Summit" in March
1985, Mulroney and President Reagan
agreed that Canada and the United
States would each appoint a high-level
Special Envoy to study acid rain. The
Special Envoys would be charged with
recommending a plan to alleviate both
the environmental and the political
damage caused by acid rain.
William Davis, former Premier of
Ontario, and Drew Lewis, former U.S.
Secretary of Transportation, were named
Prime Minister fjn'nn Mulroney. lef(. of
(,'u/Kidu. ond Pros/dent Ronald Hcdgim
discuss flic Report of the Special Envoys
on Acid Rain cit the second Shamrock
Summit, held in Washington, PC, in
March 79Hf>.
Special Envoys. In January 1986, the
two men presented their joint
recommendations for U.S.-Canadian
action. They proposed a So billion U.S.
technology demonstration program,
ongoing bilateral consultations at the
highest diplomatic levels, and
cooperative research projects.
Western Europe and North America
are highly industrialized, and it is likely
that acid rain will continue to be a
serious concern in both areas for the
foreseeable future. But the nations
involved are coming to terms with their
common problem. In Europe, several
nations have already taken steps to
reduce transboundary air pollution.
In North America, the President of the
United Stats-s has endorsed the proposal
to invest $5 billion to demonstrate
innovative technologies that can be used
to reduce transboundary air pollution.
And in both Europe and North America,
the diplomatic groundwork for
long-term cooperative activities has
been established.
20
EPA JOURNAL
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Acid Rain Research
Despite intensive research into most
aspects of add rain, scientists still
have many areas of uncertainty and
disagreement. That is why the United
States emphasizes the importance of
further research into acid rain.
Scientific research into acid rain has
accelerated significantly in the 1980s. In
1982, the federal agencies (see box)
involved in the National Acid
Precipitation Assessment Program
(NAPAP) budgeted $14.4 million for
acid rain research. For 1987. the
President is requesting S85 million for
acid rain research: a more than fivefold
increase in as many years.
The increased funding has shown
results. Scientists today have a much
greater understanding of the chemistry
of acid rain than they did in 1980. But
they are still seeking a better grasp of
the effects of acid rain on lakes, streams,
forests, and construction materials.
National
Surface Water Survey
The National Surface Water Survey is
EPA's primary source of data on the
impact of acid rain on America's lakes
and streams. Plans for the project began
in 1983, with the first of three planned
phases completed by the fall of 1984.
The goal of Phase I was to measure
the acidity of U.S. lakes and streams. It
was not feasible to sample all the lakes
and streams in potentially susceptible
areas, so methods of statistical sampling
The National Acid
Precipitation Assessment
Program
With a dozen federal agencies
involved, acid rain research can be
complicated organizationally as
well as scientifically. To prevent
duplication of effort and foster
creative cooperation among the
agencies, the National Acid
Precipitation Assessment Program
(NAPAP) was set up in 1980.
NAPAP is chaired jointly by
EPA, the President's Council on
Environmental Quality, the
National Oceanic and Atmospheric
Administration, and the
Departments of Agriculture,
Energy, and Interior.
EPA plays a major role in
several of NAPAP's key research
initiatives:
• Expansion of the National
Trends Network, which gathers
definitive acid rain data at
monitoring stations throughout the
nation. This network currently
monitors wet deposition at 150
locations around the country, and
it is being extended to include 100
dry deposition monitoring stations.
• Investigations into
"source-receptor relationships,"
the relation between changes in
emissions and changes in
deposition levels at distant
locations. EPA's Atmospheric
Processes Program is developing
an ambitious Regional Acid
Deposition Model that will enable
scientists to predict the amounts of
acid rain resulting from given
levels of emissions. With the
model's predictive powers,
policy-makers will be able to weigh
the benefits and drawbacks of
different regulatory scenarios.
• The Delayed/Direct Response
Project, which is working to
determine the rate at which hikes
acidify and to identify factors that
hasten or retard that process, such
as the acid-neutralizing capacity of
surrounding soil. A "delayed"
response is one that takes 10 years
or longer. A "direct" response is
acidification occurring in fewer
than "10 years. Under this program,
EPA has sampled 145 watersheds
in New England with the help of
the Soil Conservation Service.
The Forest Service used Humus us well
us horses
-------
it took a lot of hard work to gather the
data that formed the basis of these
findings. Scientists on the helicopter
sampling crews had to cope with the
pressure of weeks of constant travel as
well as tin; hazards posed by erratic
weather conditions. At all times and
under all conditions, scientists had to
observe rigid test procedures to protect
the validity of their data.
Nature didn't help, either. Survey
work had to be completed in the fall,
because chemical variations within
lakes were lowest then. But during the
Western Lake Survey, premature winter
weather froze many lakes in the Rockies
and the Sierra Nevada, and snow and
high winds whipped Wyoming and
Colorado. Helicopter teams had to
curtail their flying schedules to avoid
treacherous afternoon wind storms. And
some ground teams were trapped in
blizzards and had to be rescued.
Ground teams were needed for the
Western Lake Survey because many of
the 757 lakes sampled in that part of the
country were in areas protected by the
Wilderness Act. Because the Act forbids
any mechanized means of transport in
wilderness areas, the U.S. Forest Service
would not permit EPA's flotation
helicopters to land there. Instead, Forest
Service teams had to hike to remote
lakes to complete their sampling.
The Forest Service did permit EPA to
sample 50 wilderness lakes with both
helicopter and ground-access crews,
enabling the Agency to check samples
obtained by ground crews against those
obtained by helicopter teams.
Expertise gained during Phase 1 of the
National Surface Water Survey is
already proving useful in Phase II,
which was initiated in the Northeast at
the end of 1985. Phase II researchers are
looking for variations in surface water
chemistry from region to region and
from season to season. They are also
planning to calculate the fish
population at selected lakes and streams
surveyed in Phase I. This data will be
valuable as scientists try to evaluate the
impact of acid rain on aquatic life.
For Phase III, EPA plans to modify a
long-term monitoring project already in
progress. The goal of Phase III will be to
identify trends in surface water
chemistry using long-term monitoring
data. The work, which is planned to
continue indefinitely, is being designed
to be adaptable to other surface water
pollution problems as well as acid
rain.
Materials Effects
Research
Scientists who specialize in the
materials effects of acid rain still don't
know how wet and dry acid deposition
affects the natural processes of decay.
One way to answer this question is to
measure tombstones. EPA recently
sponsored research into the rates of
deterioration of headstones at 18
A Day in the Life of a
National Surface Water
Survey Helicopter Team
Helicopter teams involved in
Phase I of the National Surface
Water Survey faced demanding
schedules. With nearly 1600 lakes
to sample within a few weeks in
thn fall of 1984, they had to stay
on the go constantly.
When flying conditions were
good, the teams had daily
itineraries that could include as
many as six lakes within a
hundred-mile radius. Poor weather
conditions, on the other hand,
could force cancellation of an
entire day of sampling.
Just verifying the identities of
the lakes to be sampled was a big
job. Map coordinates used by the
helicopter's navigation system had
to hi; double-checked against U.S.
Geological Survey maps, and the
lakes had to be photographed to
further verify their identities. Once
landed on the lake surface, the
helicopters had to maintain stable
positions in the water while the
scientists took samples and
measured lake waters for depth,
pH, conductivity, temperature, and
transparency. The completed
samples were then rushed back to
mobile field laboratories, usually
by 6 or 7 p.m. The helicopter
teams could then relax for the
evening, although their usually
isolated base stations rarely offered
much in the way of recreational
activities.
But for the chemists in the field
lab trailer, the night was just
beginning. Procedures for the
survey required that the samples
be processed and filtered
immediately after their delivery to
the base station. Work in the
lab trailer often stretched long past
midnight. Ghemists had to put in
extra hours to make sure the
samples were ready by daybreak
for the flight to a cooperating
laboratory, where they were
further analyzed for 20 chemical
variables.
By morning, yesterday's samples
were on their way to the lab.
Meanwhile, at another set of lakes,
the helicopter teams were
gathering additional samples. And
so the process was repeated until
1592 lakes in four areas east of the
Mississippi had been sampled. The
thousands of samples collected
during Phase I of the Surface
Water Survey will help
scientists understand much more
clearly the effects of acid rain on
aquatic ecosystems.
Inside (i mobile laboratory, ival
drum! (nun ljotlli:s In lie i;he< I :
dissolved un^mir curlion. The uufer
tvus roller/I'd /rum Xeu s
(lie rreiv u| (he helienpler seen thru
(lie lull irlndoiv. Kuril .sumple ivuv
analyzed 2(1 differenl ivuvs us purl of
(lie National Smlcice IVulrr Survfiv.
22
hPAJOURNAL
-------
Veterans Administration cemeteries.
Two of the cemeteries provided
particularly valuable data. One was
located in an industrial area close to
New York City, while the other was in a
semi-rural area of Long Island. New
York University had previously traced
changes in the thickness of tombstones
at both cemeteries, as well as the depth
of their emblem inscriptions. Using
these data to calculate weathering rates
at the two cemeteries, scientists
compared them with estimates of rates
of increase in S02 in New York City
from 1880 to 1980. They found what is
known as a "linear" relation between
the two rates. In other words, increased
S02 concentrations were directly
proportional to increased weathering
rates.
This correlation enabled scientists to
develop a formula for calculating the
damage caused to materials in the New
York area by S02: 10 millimeters of fine
grain marble will be worn away every
century for every part per million of
SQ2 in the air.
This study was the first statistically
significant proof of damage to stone
from an acid rain precursor. It would be
difficult to carry out other experiments
of this kind, because historical data on
air pollution levels are extremely rare.
But it is clear that decay accelerated by
acid deposition has ramifications far
beyond the graveyard.
Some acid rain concerns are primarily
cultural. For example, the rapid
deterioration of the Acropolis in modern
times prompted EPA to join a recently
completed NATO pilot study on the
conservation and restoration of
monuments. Scientists from 10
countries monitored acid rain damage to
monuments, developed formats and
procedures for documenting acid rain
damage, and evaluated various means of
conserving and restoring damaged
monuments.
But acid rain threatens more than
cultural artifacts. Though experts cannot
yet fix an exact dollar value to the
materials damage caused by acid rain,
they agree that it damages homes,
commercial buildings, highways,
bridges, and other structures vital to our
everyday lives. EPA is now working
with the U.S. Army Corps of Engineers
to develop a list of materials subject to
acid rain damage. This inventory will
draw together the data needed to assess
the magnitude of acid rain-induced
materials damage. Estimates should be
ready by 1990.
Forest Response Program
In the early 1980s, experts began to see
unexplained growth reductions and
foliage damage in U.S. forests. The
evidence was first spotted in New York
and New England, but similar problems
have now been detected in the
Appalachians and the Carolinas. Even
worse forest deterioration has occurred
in Europe, where whole stands of
European trees, especially on mountain
peaks, have gone into an unprecedented
decline.
Scientists are still uncertain of acid
rain's role in such instances. Many
factors other than acid rain could be
responsible for forest damage. Changes
in soil or climate could play a role, as
could changes in insect or pathogen
activity. For these reasons, among
others, the evidence for acid rain
damage to forests is thought to be
weaker than corresponding evidence of
damage to aquatic systems.
To clarify the effects of acid rain on
trees and other vegetation, EPA began
the Forest Response Project (FRP) in
1985. FRP scientists are studying the
role of acid rain and other pollutants in
causing or contributing to forest damage
in the United States. They are also
trying to determine the mechanisms
causing the damage, and the
relationship between various "doses" of
acid deposition and the "responses"
they are suspected of causing.
Initial research is studying two types
of U.S. forests that have experienced
damage or decline. The first type of
forest, common to New England and
New York, contains spruce and fir. The
second, known as "Southern
commercial," includes several species of
pines valuable to the economy of the
southeastern United States. At two sites
in New England and three sites in the
Southeast, trees are being classified and
checked for height and radial growth.
Scientists are also conducting field
experiments to compare the growth of
trees in open-top chambers with those
in rain-exclusion chambers. Control
chambers in laboratories permit
comparable experiments with seedlings,
although it is still difficult to
extrapolate from seedlings to mature
trees.
EPA is also setting up a "Mountain
Cloud" data-gathering network to study
the effects of various acid rain patterns
on forests at differing elevations.
"Mountain Cloud" sites will be
co-located with biological stations that
measure plant growth and productivity,
as well as soil chemistry.
This work and other studies planned
for eastern haidwood forests and
western conifers should begin to give us
a clearer idea of the kind of threat acid
rain poses to the $38.5 billion forest
products industry.
The Future
Many challenges confront acid rain
scientists. There is still a need to
increase scientific understanding of the
effects of acid rain, and the rate at
which those effects occur. As yet,
scientists lack reliable methods of
extrapolating on a regional level what is
known about the effects of acid rain in
small-scale environments. They also
need to determine the level of acid
deposition that is realistically
compatible with protecting our valuable
resources. As these and other questions
are answered, we will have a much
clearer understanding of the type of
control program needed to protect all
the resources at risk from acid rain.
A videotape documentary entitled "The
National Lake Survey" is available for
loan from the Audio-Visual Division of
the EPA Office of Public Affairs (A-107),
Room 2435, 401 M Street SW,
Washington DC 20460. Phone (202]
382-2044. This 15-minute overview of
the Jakes portion of the National
Surface Water Survey o_ffers a first-hand
look at acid rain sampling in action.
JUNE/JULY 1986
23
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Control Technologies
Over the last few years, the U.S.
Congress lias considered several
pieces of legislation proposing acid rain
control programs. Most of them have
called for SO:, and N()x reductions of 8
to 10 million tons a year.
To achieve that level of control, many
existing sources of SO:; and
NOX—especially utility and industrial
coal-fired boilers—would have to be
retrofitted with control equipment. But
the availability, cost, and technical
complexity of existing retrofit controls
leave much to be; desired.
Existing
Control Options
A number of different methods oi
equipping new boilers with NOX
controls have been developed and
tested. But, overall, N()N control
technologies have not been
commercially retrofitted on existing
boilers as extensively as S()^ controls.
At present, there are three techniques
available for reducing the amount of
SO;j emitted from existing coal-fired
boilers: coal-switching, coal-cleaning,
and flue gas desulfurization.
Unfortunately, each of these techniques
Ohio Edison's Edgeivaler Sfulion. n
coal-/ueled fxnvfr generating ;>lv Mnn:h 1*187.
has drawbacks that limit their ability to
reduce SO2 emissions by 8 to 10 million
tons per year.
A coal-burning facility could cut
down on SO2 emissions by switching
from a high-sulfur to a low-sulfur coal.
However, this fuel shift could damage
some kinds of boiler equipment. It
could also generate regional hostility by
causing shifts in existing coal markets.
A second option is for sulfur to be
cleaned from coal before it is burned.
Physical coal-cleaning technologies are
available commercially today. A
substantial amount of coal already is
being cleaned because of the savings
that result from lower shipping costs,
lower boiler-maintenance costs, and the
higher energy content of the cleaned
coal. However, coal is cleaned primarily
to rid it of ash and other
non-combustibles. Not enough SQ2
could be cleaned from coal to hit the
emissions reduction target of a
large-scale acid rain control program.
Currently, there is only one
technology available that could reduce
SO2 emissions to the extent required by
an ambitious acid rain control program:
flue gas desulfurization (FGD), a process
better known as "scrubbing." FGD uses
"sorbents" such as limestone to soak up
(or "scrub") SO2 from exhaust gases.
This technology, which is capable of
reducing SO2 emissions by up to 95
percent, can be added to existing
coal-fired boilers.
FGD does have several drawbacks.
The control equipment is very
expensive and very bulky. Smaller
facilities do not always have the capital
or the space needed for FGD equipment.
Even some larger power plants would
find it technically very difficult to
retrofit FGD systems on older cramped
facilities.
Expanding Our
Control Options
The Report of the Special Envovs on
Acid Rain, presented to President
Reagan on January 8, 1980, recognized
the political and economic problems
that stem from having only a limited
menu of pollution control options. The
report stated: "The availability of
cheaper, more efficient control
technologies would improve our ability
to formulate a national response that is
politically and economically
acceptable." The Special Envoys went
on to recommend a $5 billion U.S.
program to fund the commercial
demonstration of control technologies
that promise greater emissions
reductions, lower costs, or applicability
to a wider range of existing sources.
They also recommended that special
consideration be given to projects that
have the potential to reduce SO2
emissions from existing facilities that
burn high-sulfur coal.
Over the past several years, millions
of dollars have been spent researching a
variety of innovative approaches to the
control of SO2 and NOX emissions from
existing coal-fired utility and industrial
boilers. Major federal research programs
are being funded by the Environmental
Protection Agency, the Department of
Energy, the national laboratories
(Argonne, Brookhaven, Lawrence
Berkeley, and Oak Ridge) and the
Tennessee Valley Authority. In addition,
the Electric Power Research Institute is
cooperating with different electric
utilities to improve the control of utility
boilers. This research and testing have
already generated a number of attractive
candidates for the kind of commercial
demonstrations recommended in the
Report of the Special Envoys.
The four technologies described here
represent just a few of the wide range of
potential candidates for funding as
commercial demonstration projects. The
EPA JOURNAL
-------
purpose of these projects will be to
determine whether technologies such as
these can be proven to work in existing
commercial facilities.
LIMB
The Limestone Injection Multistage
Burner (LIMB) is an emerging control
technology that can be retrofitted on a
large portion of existing coal-fired
boilers, both utility and industrial. Its
broad applicability makes it an
attractive candidate for funding under
the proposed commercial demonstration
program.
In a LIMB system, an SO2 sorbent
(e.g., limestone) is injected into a boiler
equipped with low NOX burners. The
sorbent absorbs the SO2, and the
low NOX burners limit the amount of
NOX formed. Thus, LIMB is capable of
reducing both SO2 and NOX by about 50
to 60 percent.
LIMB technology will not be applied
widely until a number of technical
problems are solved. The sorbent
injected into the boiler tends to increase
slagging and fouling, which in turn
increase operation and maintenance
costs. Because boilers retrofitted with
LIMB tend to produce more particulates
of smaller sizes, particulate control
becomes more difficult. Furthermore,
technical questions remain as to what
sorbents are most effective in a LIMB
system, and how and where to inject the
sorbents.
EPA has a major research and
development program in progress to
improve LIMB technology. A full-scale
demonstration of LIMB is underway on
a utility boiler in Lorain, OH. The
retrofitted boiler will be started up in
the spring of 1987, and the results of
early tests will help determine whether
LIMB technology is a suitable candidate
for funding under the proposed
commercial demonstration program.
In-Duct Spraying
LIMB controls SO2 and NOX emissions
during the combustion process itself. It
is also possible to control S02 after
combustion by cleaning it out of the
exhaust gases. The scrubbers now in use
apply this kind of post-combustion
technology. If ways could be found to
reduce the technical complexity and
economic costs of scrubbing,
post-combustion controls would become
a more attractive method of reducing
SOa emissions.
EPA, DOE, and private industry are
involved in efforts to improve flue gas
desulfurization (FGD) technology. Much
of the research focuses on the
development of more effective sorbent
materials. In addition, the possibility of
injecting a sorbent directly into existing
exhaust ductwork is being investigated.
An in-duct spray drying FGD system
would improve on traditional scrubbers
in several ways. Current scrubbers
require the construction of very large
reaction vessels where the exhaust gases
and sorbent can mix to extract the S02.
These vessels are very expensive, and
sometimes the space they demand
simply isn't available at existing
facilities.
If, however, the sorbent could be
injected into existing ductwork, the cost
of the reaction vessel could be
eliminated, and it would be much easier
to retrofit controls on a wider range of
sources. Space constraints would no
longer be a limiting factor.
In order to test and improve in-duct
scrubbing techniques, a demonstration
control system is in the process of being
tested at a utility in Beverly, OH. The
Department of Energy plans to fund
another demonstration project in the
near future. Even if this research is
successful, it is unlikely that in-duct
FGD systems will achieve an SO2
control rate of much more than 50 to 60
percent. But if they can be retrofitted
widely and at relatively low cost,
in-duct FBC systems could join LIMB as
an attractive candidate for a commercial
demonstration program.
Reburning
Another relatively new technology
known as reburning, or fuel staging, is
capable of reducing NOX emissions in
existing boilers. In a coal-fired boiler,
reburning is accomplished by
substituting 15 to 20 percent of the coal
with natural gas or low sulfur oil and
burning it at a location downstream of
the primary combustion zone of the
boiler. Oxides of nitrogen formed in the
primary zone are reduced to nitrogen
,and water vapor as they pass through
the reburn zone. Additional air is
injected downstream of the reburn zone
to complete the combustion process at a
lower temperature.
In general, NOX reductions of 50
percent or more are achievable by
reburning. When combined with other
low NOX technologies, such as low NOX
burners, NOX reductions of up to 90
percent may be achievable.
Reburning tests have been performed
by EPA on gas-, oil-, and coal-fired
research combustion systems. EPA and
the Gas Research Institute are preparing
to co-sponsor reburning tests at a large
industrial or utility coal- or oil-fired
boiler.
Fluidized Bed Combustion
Fluidized bed combustion (FBCj is an
innovative approach to SO2 and NOX
control in both utility and industrial
boilers. In an FBC boiler, pulverized
coal is burned while suspended over a
turbulent cushion of injected air. This
technique is promising from an
economic perspective, because FBC
boilers allow improved combustion
efficiencies and reduced boiler fouling
and corrosion. Such boilers also are
capable of burning different kinds of
low-grade fuels like refuse, wood bark,
and sewage sludge.
In addition, FBC offers a number of
environmental advantages. If the coal is
mixed with limestone or some other
sorbent material during combustion, the
SO2 is captured and retained in the ash.
FBC boilers have another
environmental advantage over typical
coal-fired boilers: they have the
potential to control NOX as well as S02.
FBC boilers must operate within a
narrow temperature range (1500-1600
degrees Fahrenheit) that is substantially
lower than typical boiler temperatures.
Lower combustion temperatures
inherently limit the formation of NOX.
Thus, FBC boilers may be able to
control NOX by 50 to 75 percent at the
same time as they control S02 by up to
90 percent.
An FBC system does have one major
drawback: it requires the construction of
a new boiler. Thus, it is more of a
replacement technology than a retrofit.
The number of existing boilers that
could be replaced with FBC boilers at
reasonable cost is limited, and its
promise is more likely to be realized on
new sources.
A Less Limited Future
Limestone injection multistage burners,
in-duct sprayers, reburners, and
fluidized bed combustion systems: these
and several other technologies are
capable of expanding the current rather
limited "menu" of acid rain control
options. If they can be proven to work
on existing commercial facilities, state
and federal lawmakers will have much
more latitude as they frame legislation
for controlling acid rain.
Clearly, it would be inefficient and
ineffective to try to implement a major
acid rain control program before
technically viable and economically
affordable technologies are available.
Thus, the proposed five-year, $5 billion
program for commercial demonstration
of acid rain control technologies fills a
very real need.
JUNE/JULY 1986
25
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Implementation Issues
Solving problems can sometimes
create problems. Take, for example,
the implementation of a major new
regulatory program. Enacted to control
one problem, it can generate many
problems of its own. If the undertaking
is complicated, expensive, and
time-consuming, it can catch state
governments unprepared.
What would happen if the U.S.
Congress passed a law controlling acid
rain? Under several bills now being
considered, experts foresee the
following difficulties:
• New reductions would probably be
required in a shorter time—and at
greater marginal cost—than those
already achieved under the Clean Air
Act.
• Requirements for control of acid rain
precursors (SO^ and NOX) could
generate conflict and confusion as to
which sources should be controlled.
Who would make these choices, and on
what grounds?
• It would be hard to develop a
convincing rationale, in terms of local
costs incurred, for an acid rain control
program because most of the
environmental benefits would accrue in
another stale. Existing air pollution
programs did not face this problem,
because they tended to impose costs in
the same areas where environmental
quality was improved. Acid rain
controls, on the other hand, would be
intended to protect whole regions, but
the costs would not be spread evenly
over the region.
However, some of the cost of
controlling acid rain would be felt on a
regional scale1. Controls imposed on a
utility in one state would, to varying
degrees, affect utility rates in
neighboring states, because electric
power is often generated in one state and
sold in another. There would also be
shifts in the cost of high- and low-sulfur
coal, in the cost of manufactured goods,
and in employment. These shifts would
be felt in the economies of whole
regions, not just states.
Policy-makers must consider all these
factors as they design a major acid rain
control program. They must also
recognize that a control effort will have
significant impacts on many sectors:
electric utilities as well as other
industries, public utility commissions as
well as state executive and legislative
offices. Therefore, the concerns of these
and other parties must be incorporated
into the decision-making process.
State Acid Rain Programs
To help prepare for the complexity of
implementing a major acid rain control
program, EPA has committed to work
with the states on these kinds of issues.
With a special Congressional
appropriation EPA established the State
Acid Rain (STAR) program to identify
and resolve potential problems. It is
now funding studies in 36 states on
such implementation questions as:
• How should control obligations be
allocated to individual pollution sources
so that statewide emissions reduction
targets can be met?
• What techniques are available to
control each source, and what are their
economic and social costs?
• How can the gains secured for the
environment be maintained in the
future without impeding economic
growth?
Projects in Progress
Different states and regions are using
their STAR grants in different ways.
Wisconsin, for example, has substantial
SO2 emissions in excess of the
quantitative limitation incorporated in
many acid .rain control proposals.
Therefore, Wisconsin is faced with the
possibility of a very substantial
emissions reduction requirement. To
prepare for whatever may come, the
state's air pollution control officials
decided to develop complete mode!
programs for hypothetical statewide
emissions reductions of 30, 50, and 70
percent. The broad issues of data base,
available control techniques, control
strategy, and maintenance of achieved
emissions reductions are all being
studied.
Wisconsin's air officials, together with
those of Minnesota and Michigan, are
also studying possible tri-state
emissions reduction plans. In
recognition of the crucial role that
existing regulation of utility rates will
play in acid rain control, they are also
bringing together environmental officials
and utility regulatory officials of the
midwestern states to pool their
knowledge and coordinate their
planning.
A group of eight northeastern states
decided to look in greater depth at the
technologies available for controlling
their specific acid rain sources. They
wanted to be ready in case they needed
to prepare state or regional strategies for
controlling acid rain. They are also
beginning the essential task of
coordinating the ideas, plans, and
policies of their environmental agencies
with those of their public: utility
commissions.
These northeastern states are also
studying various ways of maintaining
environmental goals while permitting
economic growth. One approach
recommends an initial period of
over-control to build up a margin of
compliance that permits later economic
growth. Another suggests offsetting
emissions from new sources with new
controls on older sources.
Another noteworthy STAR program is
being conducted by the states of
Tennessee, Kentucky, and Alabama, in
conjunction with the Tennessee Valley
Authority. This project is examining
alternative emission reduction strategies
for a multistate utility system.
State Acid Rain (or STAR) projects are
enabling environmental professionals to
study the interrelated problems that an
acid rain control program is likely to
raise, and to search for equitable and
efficient solutions. The states involved
in the STAR program have very
different views of the policy questions
raised by acid rain. Their citizens have
very different, and very large, interests
at stake. Nevertheless, the air pollution
professionals in the states and at EPA
have agreed to put any policy
disagreements to one side while they
seek answers to the questions that will
have to be resolved if any acid rain
control program is to be successfully
implemented, Q
EPA JOURNAL
-------
Seniors Contribute
In EPA's SEE Program
by Margherita Pryor
Forget the saying about old dogs and
new tricks. The truth is that some of
the most important tricks—such as tact,
judgment, and skill—are usually
acquired only through age and
experience. And it's these "people"
talents that seem to be increasingly rare
even as they become increasingly
necessary.
EPA is fortunate. For the last 10 years,
it has been able to draw on an enormous
and largely untapped source of just
these skills: the growing number of
retired and older Americans who are
participating in the Agency's Senior
Environmental Employment (SEE)
program.
Retirement and the problems of older
people in general have become
prominent issues in the last few years.
Back in 1935, it made sense for one
writer to muse that "old age is the most
unexpected of all the things that happen
to a man." After all, not many people
lived to experience it. Even as late as
the turn of the century, most infants
1 died in their first 12 months and the
average life expectancy was less than 50
years.
The demographics are different today.
Modern medicine and public health
measures have combined to extend the
average American life span by several
decades. Those who reach the age of 65
can expect to live another 15 years or
more. In 1980, 25 million Americans
were 65 or older. By the year 2000, that
number will increase to 32 million—one
out of every eight people in the country.
And, if current trends continue, most of
them will be retired by then.
What do all these projections mean?
On a national level, it means that the
number of Social Security beneficiaries
is increasing more rapidly than the
number of contributors. Today, the ratio
of contributors to beneficiaries is 3-to-l;
by the next century, the ratio will be
2-to-l. At the same time, the number of
young workers entering the labor force
will also decline. It doesn't take a
(I'jyoj- is Contributing h'dilor of Hie Kl'A
Journal.I
crystal ball to predict a financial crunch
in the system.
On the individual level, too, there are
problems. Even with Social Security,
almost one of every seven Americans
over 65 lives in poverty: for widowed
black women, the number of poor
increases to one in two. In addition,
many employees don't want to retire. In
a 1981 poll, almost 80 percent of
EPA's SEE Corps could be
called a solution ahead of its
time.
employees 55 and over said they
preferred to continue working after the
normal retirement age, preferably
part-time. These stated preferences are
borne out by the statistics: 25 percent of
all retirees do take jobs again, and many
more try to find work but fail.
In KIM Hi'nion 3, Senior Environmental
Employees Kux (Joslaivski. /Yif.
-------
the American Association ot Retired
Persons (AARP), "EPA gets a really good
deal. For littli! more than minimum
wage, the Agency is getting people with
fantastic credentials—people like a
former commissioner from the Nuclear
Regulatory Commission, or oil
specialists from (lit! petroleum
companies, even chemists who used to
work on the very chemicals EPA is now
regulating. How can you lose?"
Pat Powers agrees. She administers
KPA's (Mid of the SKK program and is
convinced that it gives the Agency the
most hang for its buck. "The first year
we had to inspect for asbestos," she
says, "we paid a regular contractor
S<)00.000. I'sing SKK employees, who
include engineers and architects, we
paid S;i4(). I was a staff
researcher at the National Institutes of
Health for five years and a guest
scientist there for one year. I never
would have left research voluntarily,
but at the time (late 1970s), the typical
scientific attitude toward women.
particularly 'old' women, was—to put it
mildly about as stinky as you can get.
The only way to get a permanent
position was to turn out reams of
papers, and they wouldn't provide the
technical support. So i worked for a
has grown from a pilot
project of about 200
participants to a full-scale
program involving ten times
that mam'.
year with a public interest research
group and did some volunteer work lor
Representative Cllaude Pepper's
subcommittee."
"I heard about the SKK program when
I joined the AARP. Within two weeks
alter I applied. 1 received a letter saying
that F,PA could use my technical
background. Of course. I'm not in
research here at all. but I find they're
very good to the SKK people here. My
family is very important to me, and the
flexibility in this job is great. I'm in an
artists' cooperative, too. so this gives me
time to work on my art shows."
These varied interests art: typical of
SKK participants. Anna Johnson, tor
example, is a counselor for KPA's
imported car program. As a counselor.
she answers questions from the public
about how to import foreign cars into
the United States and has compiled a
training manual about the program to be
used by student assistants, contractors.
new professionals, and other seniors.
That's 20 hours per week. The rest of
her time she does free-lance
audio/visual production, teaches film
animation for the Washington, DC),
recreation department, and builds
miniatures and custom dollhouses. "Hut
I enjoy the work at EPA," she says,
"giving service to the public. There's a
maturity aspect in this work. We're able
to handle person-to-person situations,
and that's basically how we see our
job."
Stan Durkee. coordinator of the SEE
program in Johnson's office, couldn't
agree more. "The SEE people are just
great." he says. "They're eager to take
responsibility, they're cooperative, they
want to be respected and effective.
They've reached the age where they
want to use their experience. In fact,
we've just reorganized the office to use
them as positive communications links
between our student assistants and their
supervisors. This program meets
everyone's needs. EPA gets a job done
well, and the SEE people get jobs with
training and flexibility. As a supervisor,
I'm totally enthusiastic."
Another enthusiast is SEKer Bob
Cunningham. "I found this opportunity
to work with EPA very exciting because
1 have so much respect for the Agency. 1
started out a long ways back as a
reporter with United Press International,
then went into public relations work. I
started out here as a writer/editor for the
asbestos program and then stayed with
the Office of Toxic Substances in a
varied capacity. 1 guess you could say
I'm a sort of support service for the
program managers. While I don't do any
real writing, I'm still pleased and proud
to be part of the team."
"1 was first interested in SEE because
I wanted to keep active. If we keep
active, we enjoy better health mentally
and physically. 1 think we're in a
transitional period. People have been
finding out that we don't have to decay
into senility at some particular age.
More people will need to work longer,
and more people will want to. My peer
group over the years has tended to look
towards retirement, but some have
retired and started their own
businesses."
"I see this happening with my
children. They don't see themselves as
ever retiring. There are more options
today. Some companies are no longer
asking people to retire at a mandatory
age. Not to use people with experience
is such a waste."
"You know," says Jack Everett,
"AARP is the second-largest
membership organi/.ation in the world.
Right now, we have 20 million
members, and we get 100,000 new ones
every month. Our magazine, Modern
Muturitv, has the third-largest
circulation in the country. That should
tell you something about where the
population figures are going. Programs
like SKK are just the beginning." n
28
EPA JOURNAL
-------
Caring About
Bottomland Hardwoods
by Tom Welborn
and Bill Kruczynski
:\ hunhvuod forrst in Mississippi.
I V'.spiir (heir ecoJogical productivity,
bottom/and lumfwood uvthmds on1
brin;; mm crlri/ f<> agricuJturaJ use (it
(VVcllinni is ci life scientist in the
Wetlands S<;r:(ion of KKA H<;gi
-------
Eastern Cougar and Bachman's warbler
now live only in the wetlands forests of
the southeastern United States. Other
species of special concern, such as the
black bear, bobcat, and wood duck, also
depend on the wetlands habitat of these
forests.
But farmers, too, find the bottomland
hardwood wetlands attractive. There is
much more money to be made growing
and harvesting soybeans, for example,
than in cutting what useable timber
remains in the often mismanaged
forests. Although some big Southern
lumber companies have carefully
reforested their lands, in most privately
owned wetlands the bigger trees have
long since been cut down, leaving
marginally valuable forests behind. At
one time, wetland forests in the South
were important commercial sources of
white oak for whiskey barrels; now most
of those trees are gone. Although the
forest resource has declined in acreage
and quality, it remains important for
production of veneer and lumber for
furniture, flooring, and other products.
One-half of the nation's wetlands have
been lost to development, and of these,
the overwhelming majority— 87
percent—were lost due to agricultural
conversion of the land.
r'orested wetlands account for
approximately half of the total
wetlands loss.
In the South, some 30 million acres of
bottomland hardwood forests occupy
the floodplains of major rivers in the
southeastern United States, from
Virginia to Texas. The largest single area
is in the Mississippi Valley. One
hundred thousand acres of these
valuable wetlands are being cleared and
converted to other uses, mainly
agricultural, every year.
The bottomland hardwood wetlands
system begins at the headwaters of
tributary streams and ends in estuaries,
where rivers meet the sea, or in lakes. A
cycle of yearly floods from winter and
spring rains or melting snowpacks
further north maintains the system. In
winter and spring, overflowing streams
flood the bottomland forests, depositing
sediments and associated pollutants,
and being cleansed in the process.
The flooding also makes large areas of
habitat available to fish for spawning
and nursery areas, and provides food
and refuge for migratory birds. When
the floodwaters recede, they carry
organic and inorganic nutrients back to
the rivers, streams, and lakes. The
forests also improve water quality by
filtering nonpoint source runoff from
adjacent upland areas and by shading
streams, thus mediating temperature
changes.
The driving force in the creation,
maintenance, and function of
bottomland forests is water. An annual
flooding cycle maintains the system and
periodic inundation and drying are
critical to the various functions
provided by wetlands. One of these
important functions is to ease the
flooding of downstream areas during the
winter and spring flood seasons. During
this period, water overflows the stream
channels and spreads throughout the
bottomland forest, which becomes a
storage reservoir for the excess water.
Bottomland vegetation retards the
movement of the floodwaters down the
flood plain or back into the stream
channel, thus reducing the peak level of
the floodwaters in downstream farms or
residential areas.
EPA programs are critical to the future
of the 50 percent of the nation's original
wetlands that still remain after
generations of uncontrolled conversion
or depredations.
Under Section 404 of the Clean Water
Act, the Agency has significant
responsibilities for wetland protection.
Although the U.S. Army Corps of
Engineers administers the Section 404
permitting program covering use of
wetlands for various developmental
purposes. EPA reviews public
notices issued by the Corps, provides
relevant environmental criteria for
wetland protection through issuance of
guidelines, uses its authority to prohibit
use of discharge sites, and initiates
enforcement actions for unauthorized
discharges into wetlands. EPA is also
responsible for ensuring that the
geographical jurisdiction over wetlands
by federal agencies is determined in an
appropriate manner, and this affects the
regulatory requirements that apply to
millions of acres of bottomland
hardwood forests.
In fulfilling its responsibilities for
wetlands protection, EPA has initiated a
comprehensive study of bottomland
hardwood ecosystems. Each EPA region
is required to provide a regulatory plan
for the bottomland hardwood wetlands
in its jurisdiction.
Final Agency policy on protection of
this valuable resource is expected later
this year. A number of other agencies,
including the U.S. Army Corps of
Engineers, the U.S. Fish and Wildlife
Service, the U.S. Forest Service, the Soil
Conservation Service, and state water
quality, natural resources, and
conservation departments, have
Because of concern over loss
rates of this major
environmental resource, EPA
is giving a high priority to
protecting bottomland
hardwood wetlands.
participated in a series of scientific
workshops sponsored by EPA to
develop the basis for the policy.
Communication of this policy is of
major importance. Congressional
delegations, state and other federal
agencies, public interest groups, and the
general public will be informed
regularly through public meetings,
workshops, letters, press releases, and
direct contacts,
Regional EPA staff members will meet
with Corps of Engineers district
personnel to promote coordinated
efforts toward wetland protection goals.
Wetland training courses and field
surveys will be joint EPA-Corps
activities, and enforcement will be
coordinated with the Corps. Work is
under way toward a joint EPA and
Corps methodology to establish
wetlands boundaries.
It is hoped that through rigorous
regional implementation of Agency
policy, a strong regulatory program will
halt the unnecessary destruction of our
nation's dwindling wetland resources
and result in their recovery and
preservation, a
EPA JOURNAL
-------
Update
A review of recent major EPA activities and developments in the pollution control program areas.
AIR
PESTICIDES
Lead-in-Gasoline Violations
EPA announced that it has
proposed civil penalties
totaling 52,573.090 against
Gulf States Oil & Refining Co.
of Houston. Texas, for
exceeding federal standards
for lead content in gasoline.
Gulf States exceeded the
allowable lead limits during
five calendar quarters from
October 1. 1983, through
December 31, 1984. at the
company's refinery in
Pasadena, Texas. Gulf States
notified EPA when it
discovered that two of its
I'liiplovces prepared lalsr,
reports of lead usage.
The Agency reported that
Gulf States used
approximately 300 million
more grams of lead than
allowed for the volume of
leaded gasoline produced
during that period.
EPA recently promulgated
more stringent gasoline lead
standards to protect the
public from adverse health
effects of leaded gasoline.
Since January 1, 1986,
refiners have been limited to
an average quarterly standard
of .10 gram of lead per gallon
of leaded gasoline.
GM Recalls
General Motors Corporation
is recalling about 133,000
1982 model-year
gasoline-powered Chevrolet
Chevettes and Pontiac
T-lOOOs to correct a defect in
the air injection system.
Vehicles with the problem
exceed federal limits for
hydrocarbons and
carbon monoxide emissions.
GM recalled about a half
million 1981 model-year
Chevette and T-1000 vehicles
last September to correct a
similar problem.
Field Testing
EPA has issued two
experimental use permits to
Dr. Steven E. Lindow of the
University of California at
Berkeley to conduct
small-scale field tests using
two strains of genetically
altered bacteria to retard
early frost formation on
plants.
In the field tests,
genetically altered bacteria
will be applied to potato seed
pieces before planting and
will also be sprayed on the
plants soon after they emerge
from the, ground. The
experiments will take place
on property of the University
of California Agricultural
Experiment Station at
Tulelake in northern
California.
The bacterial strains of
Pseudomonas syringae used
by Dr. Lindow are commonly
found on plants. They
produce a protein which
serves as a seed for the
formation of ice crystals in a
process known as ice
nucleation, The Berkeley
team deleted the genetic
material which instructs ice
nucleating active bacteria
(INA + ) to produce the
protein. As a result, the
genetically altered bacteria
(INA) are incapable of
producing the protein, and
ice is less likely to form on
plant surfaces colonized by
the altered bacteria.
TOXICS
Asbestos Protection Rule
The Agency has issued a
final rule to protect state and
local government employees
from the potential hazards of
asbestos abatement work.
EPA issued the rule in
proposed form on July 12,
1985, and made it effective
immediately so it would
cover asbestos abatement
activities in schools during
the school break.
The final rule was issued
under authority of the Toxic
Substances Control Act. It
extends Occupational Safety
and Health Administration
(OSHA) worker protection
requirements for asbestos
abatement projects to state
and local employees,
including school
maintenance workers such as
janitors.
The EPA regulation is
similar to the current OSHA
standard. It establishes
exposure limits of two fibers
per cubic centimeter of air
for an eight-hour,
time-weighted average and 10
fibers per cubic centimeter as
a maximum concentration at
any one time. It requires
work practices such as the
wetting of asbestos, use of
personal protective
equipment, and provision of
special clothing. The
regulation also requires
environmental monitoring.
the posting of caution signs,
and the cleanup and proper
disposal of asbestos waste. In
addition, it requires medical
examinations for some
employees and the retention
of medical examination and
environmental monitoring
records.
WATER
EPA Bars Shopping Center
Plans
Stating that the project would
have "unacceptable adverse
effects on wildlife and
wildlife habitat," EPA has
ruled against construction of
a shopping center on
Sweeclens Swamp in
Attleboro, Massachusetts.
The ruling, by the EPA's
Assistant Administrator for
External Affairs, Jennifer Joy
Wilson, specifically
found that plans by the
builder, Pyramid Companies,
to "mitigate" its destruction
of the swamp by creating an
artificial wetland nearby
were unacceptable under the
Clean Water Act, in view of
EPA's findings that the
impacts could have been
avoided through use of a
practicable alternative site.
Wilson added that the
agency "did not want to set a
precedent across this nation
of substituting artificial
wetlands for the natural,
functioning wetlands without
consideration of the need for
destroying those natural
wetlands."
Section 404 of the Clean
Water Act gives EPA a
number of responsibilities to
assure that the environment
will be protected from the
discharge of dredged or fill
materials.
Funding for Construction
Grants
EPA announced that it will
provide states with $96
million from construction
grants funds to continue
managing their wastowater
treatment plant construction
programs under the Clean
Water Act.
The action follows a ruling
by EPA's Office of General
Counsel that four percent of
the full $2.4 billion budgeted
for construction grants during
fiscal year 1986 could be
made available for state
management, even though
$1.8 billion of this has not
yet been made available by
Congress.
The construction grants
program makes monies
available to municipalities to
build and upgrade sewage
treatment systems. Under the
Act, states may reserve up to
four percent of the pro rnfci
share of the total that
Congress provides for
construction grants in order
to manage the program. :
JUNE/JULY 1986
31
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Appointments
EPA Administrator Lee M. Thomas
has announced the reassignment of
11 senior Agency executives as part of
an ongoing management program.
Dick Bauer, Director, Environmental
Services Division in Region 10, was
selected to join the Senior Executive
Service (SES) and has been appointed to
the position of Deputy Regional
Administrator for that region. He brings
a broad regional background to this new
assignment.
Bill Brungs, the Director of EPA's
Environmental Research Lab in
Narragansett, is going on a 120-day
detail with Region I. He will chair an
interagency task force of state and
federal personnel, which will develop a
draft model mixing-zone policy to
provide a basis for regional action in
review of state water quality standards.
Mike Callahan has been selected to join
the SES and has been appointed
Director of the Exposure Assessment
Group in the Office of Health and
Environmental Assessment in the Office
of Research and Development (ORD). He
bring with him broad environmental
program experience, having served as
the Chief of the Exposure Assessment
Branch in the Exposure Evaluation
Division of the Office of Toxic
Substances and as an environmental
scientist in the Office of Water.
Don Clay, Director, Office of Toxic
Substances, Office of Pesticides and
Toxic Substances (OPTS), has been
selected to be Deputy Assistant
Administrator for the Office of Air and
Radiation. He brings with him broad
experience in assessing and managing
risks. He has also served as Acting
Assistant Administrator of OPTS.
Alan Eckert, who was Senior Litigator
in the Office of the General Counsel, has
been selected to be Associate General
Counsel for the Air and Radiation
Division. He will be responsible for
advising the Agency's air and radiation
programs and defending them in
litigation.
Jim Elder, Deputy Director, Office of
Water Enforcement and Permits, has
been selected to be Director of that
office. One of his primary
responsibilities will be to carry through
on the National Municipal Policy, an
initiative for which he was one of the
principal architects.
Rebecca Hanmer, Director, Office of
Water Enforcement and Permits, has
been named Deputy Assistant
Administrator, Office of Water (OW).
She brings to this position an array of
regional and program experiences at
different management levels.
Norb Jaworski will replace Bill Brungs
as the Director of the Environmental
Research Laboratory in Narragansett. He
will apply his 26 years of scientific and
management experience in the marine
and freshwater resources areas to the
problems associated with estuarine and
ocean discharges.
Mike Quigley, Deputy Director, Office of
Municipal Pollution Control, is being
named Director of that office. He brings
with him broad experience in the
environmental field. He will be
responsible for keeping the construction
grants program running smoothly.
Pat Tobin, Director, Criteria and
Standards Division, OW, has been
selected as the Director of the Waste
Management Division in Region 4. He
has been with EPA and the Department
of Interior for 18 years.
Bill Whittington, Director, Office of
Municipal Pollution Control, OW, will
become the Director, Office of Water
Regulations and Standards (OWRS). He
will direct the office in its post effluent
guideline phase. D
32
EPA JOURNAL
-------
Correction: The photograph used for the
cover of tin: April, 198(>, h'PA Journal is
of a blast furnace operation. lil'A does
not currently regulate waste from blast
furnaces as hazardous. Thus, use of the
picture leaves an unjustified impression,
inasmuch as the theme of the April
issue of the Journal was on controlling
hazardous waste. EPA Journal regrets
the mistake.
Stack emissions (it a coal-fired poiver
plant can In; a source of sulfur dioxide
and nitrogen oxides ivln'cli c
-------
United States
Environmental'Protection
Agency
Washington DC 20460
Official Business -,
Penalty for Private Use $300, ?
Third-Class Bulk
Postage and Fees Paid
EPA
Permit No. G-35
i .,
i
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