EPA JOURNAL
mancmg
Next Generation o.
Wastewater Treatment
-------
Financing
the Next
Generation of
Wastewater
Treatment
The question of how to pay
for the treatment of
municipal wastewater might
seem mundane. But because!
it involves one of tin;
country's biggest sources of
pollution, it is a major
environmental matter. In this
issue, EPA Journal explores
the subject.
Lawrence J. Jensen, KPA's
Assistant Administrator lor
Water, describes the challenges
as the nation enters a new era
of paying to treat municipal
wastewater.
Two articles describe
trends already underway in
states and communities
toward new ways of paying
wastewater treatment costs,
and a third article describes
innovative wastewater
treatment methods thai often
accompany alternative
financing. Another article
chronicles how municipal
wastewater treatment bili.s
have traditionally been paid
as the nation has undertaken
to clean up its waters. A final
piece describes KI'A's policy
of insisting on compliance by
cities with Clean Water Act
requirements in treating their
wastewaters.
Cither articles in this issue
of the /ounHil concern KI'A's
scrutiny of radio-frequency
radiation, and the recent
sampling of SOUK; Western
I I.S. lakes to determine
effects from acid deposition.
The question of how to
communicate environmental
risk to the public is
discussed by Milton Russell,
KI'A's Assistant
Administrator for Policy.
Planning and Evaluation.
Aeration basin for an activated sludge
jdcility, ivhere ira.stes (in; uerobicnlly
converted before being discharged.
Rules to be proposed soon for
regulating emissions from
new wood stoves are
explained.
The issue concludes with
two regular features—Update
and Appointments.
-------
United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 12
Number 9
November 1986
&EPA 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, anil
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and im-
plement actions which lead to a
compatible balance between hu-
man activities and the ability of
natural systems to support and
nurture life.
The EPA /ournul is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the publica-
tion of this periodical is necessary
in the transaction of the public
business required by law of this
agency. Use of funds for printing
this periodical has been approved
by the Director of the Office of
Management and Budget. Views
expressed by authors do not neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107),
Waterside Mall, 401 M St.. S.W.,
Washington, DC 20460. No permis-
sion necessary to reproduce con-
tents except copyrighted photos
and other materials.
The Challenge of
A New Generation
of Wastewater Treatment
by Lawrence J. Jensen 2
State Innovations
for Paving
The Wastewater Bill
by James H. Werntx.
and Margherita Pryor ;j
Some Communities
Move Ahead
Without EPA Dollars
by Roy Popkin 5
Trying Simpler Ways
To Treat Wastewater
by Peter Shanaghan
and John Flowers (i
EPA's Construction
Grants Program:
A History
by Jack Lewis 10
A National Policy
To Enforce
Wastewater Cleanup
by John W. Lyon
and Patricia D. Mott
Probing the Mysteries
Of Radiofrequency
Radiation
by Miles Kahn 15
Sampling Lakes
For Effects
From Acid Rain
by Cindy Chojnacky 17
Communicating Risk
To a Concerned Public
by Milton Russell i<)
Taking Steps
To Control
Wood Stove Pollution
by Roy Popkin 22
Update 24
Appointments 24
Front Cover: A dcirifier, where
clean ivoter is floated off in the
ivcisteirater purification process
and older materials drop !o the
bottom us sludge. Photo In Mike
MilcliL'll, Folio. Inc.
Design Credits:
Hubert Flanagan;
Hoii Furnih;
Donna U'asvlkhvsky/
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-------
The Challenge of
A New Generation
Of Wastewater Treatment
by Lawrence J. Jensen
When the (Mean \V;itor Act became
law ID 1972, the state of our
nation's water was causi; for public
anger, agitation, and even alarm. Water
quality had deteriorated so badly that it
threatened our health, disrupted our
recreation, and arrested our commercial
and industrial efforts.
(liven these conditions, it is not
surprising that there was broad popular
support and bipartisan consensus when
Congress passed the Act. even though it
instigated a massive federal gran!
program called Construction Grants.
Americans saw in the Act a
commitment to reversing a pollution
trend and reviving our nation's literal
life blood. And today, 15 years after it
became law, we can look on the
accomplishments forged under the Act's
statutory and financial provisions with
real pride—and a sigh of relief.
Over the last 15 years, more than $60
billion in federal, state, and local dollars
have been invested in the nation's
wastewater treatment infrastructure. Of
this, over $44 billion lias been in federal
grants to municipalities for the
construction, operation, and
maintenance of municipal wastewater
treatment facilities. Federal dollars were
also spent to beef up water quality
institutions and programs at the federal,
state, and local levels, Thanks to these
expenditures, we now find thousands of
dedicated water quality professionals
throughout the country.
More importantly, because of these
expenditures, we can also .speak of what
is bureaucratically called "significant
Clean Water Act compliance." The
translation is far more exciting, far more
encouraging than what that jargon
conveys. What it means is that we have
purchased with federal, stall!, and local
dollars real improvements in the quality
of the water—and thus in the quality of
life for millions of people in thousands
of communities across the country.
We are justifiably proud of these past
accomplishments. But our work to
restore and protect our waters is far
from complete.
We must protect our past investment
(/cnscn is K/'A's Assislmif
Administrator for IVufer.l
2
in clean water. It would take no more
than a few days, perhaps a few hours,
for all the gains of the past 15 years to
be lost if our treatment infrastructure
shut down. This startling conjecture
points out the importance of protecting
the clean water gains we have made by
assuring adequate operation and
maintenance of that infrastructure. At
the same time, we are facing new
challenges in the areas of continuing
population growth, unconventional new
pollutants, and a changing federal role.
The common denominator across all
these challenges is dollars, for clean
water momentum will not continue
without financial commitment. And the
words "financial commitment" will not
always evoke images of federal grants
and subsidies.
Look at the Clean Water Act
reauthorization proposals considered by
House and Senate conferees this past
session of Congress. While the House,
Senate, and Administration legislative
proposals varied in the duration of the
construction grants phaseout period and
the overall amount of funding, they all
advocated the ultimate elimination of
federal funding for construction grants.
They all affirmed that the management
and financing of wastewater treatment
systems is the rightful province of state
and local government. And. in light of
the recent veto of the Clean Water Act
reauthorization, we at EPA will do all
we can to help the 100th Congress
produce a fiscally responsible bill that
provides for a smooth phaseout of the
federal construction grants program.
The eventual phaseout of the
construction grants program does raise
important questions. Does the phaseout
mean that all treatment needs have been
financed? Of course not. In a growing
society, there will always be new
treatment needs. Does the phaseout
signal the passing of our nation's
commitment to clean water? To this
question there can be only one answer:
no.
Obviously there will be pitfalls in
these uncharted times beyond the
construction grants era. Like the
mythical mariner, some states and
localities are reluctant about sailing
forward, fearing the Scylla of the 1988
clean water compliance deadline and
the Charybdis of decreased federal
funding. The 1988 date is firm and, as
the Clean Water Act suggests, municipal
compliance with the Clean Water Act is
not contingent on receiving federal
funds. But as the mythical mariner was
motivated by benefits beyond the
pitfalls, so there will be benefits for
states which strike out boldly into the
de-federalized era.
Some have already discovered
benefits. The number of communities
using innovative, self-reliant methods to
meet their wastewater needs is growing.
Many that have chosen to proceed
without federal funding have been able
to realize substantial savings over
comparable federally financed projects,
thus making the grants tradeoff
worthwhile. Notable advantages have
included cheaper and faster
construction, ability to select local
design preferences, greater
responsiveness to economic growth,
fewer procedural requirements.
enhanced flexibility to address future
changes, and greater certainty as to the
timing of services to customers.
Naturally, these ventures have
required new techniques and
technologies. But because dollars are the
greatest challenge lying ahead, I have
been most impressed with the
flourishing innovation in the financial
arena. Currently, 16 .states have
operational revolving loan programs
capitalized at the state level and six
states have active bond banks; another
19 states are either studying alternative
financing programs or have proposed
legislation for them. No one can
question that these trends are positive.
Let me turn to one final element in
the clean water equation— the
individual. Greater emphasis on local
financing will likely lead to higher and
more realistic fees for wastewater
services. This means that users—you
and 1—will have to be more willing to
pay for clean water. Public opinion
polls suggest that we are. They suggest
that we expect clean water and that we
are willing to pay more for our
water-related community services in
order to ensure that we will always
have a usable supply. I find this
encouraging, for the days when we could
take clean, plentiful water for granted
are rapidly drawing to a close.
The Clean Water Act of 1972 added
"fishable and swimmable" to our
environmental wish list. With sewage
treatment finally joining the roster of
essential municipal services, that wish
is on its way to becoming reality. D
EPA JOURNAL
-------
State Innovations
For Paying
The Wastewater Bill
by James Werntz
and Margherita Pryor
The 1981 Clean Water Act
amendments clearly signaled that
the age of federal largesse for sewage
treatment plant construction was ending.
The level of funding for the
construction grants program was nearly
halved. But the reduction of federal
funds has not changed the federal
treatment requirements, EPA has made
it very clear that the Agency intends to
enforce compliance deadlines even if
municipalities haven't obtained federal
money to build the treatment plants. To
take up the slack from the impending
phase out of federal construction grants,
many states are accelerating their efforts
to establish and implement alternative
financing programs. The increase in
state institutional capability to finance
wastewater treatment facilities will play
a critical role in helping communities
attain and maintain compliance with
the Clean Water Act.
Wastewater treatment facilities are a
major infrastructure investment for any
community, with the average cost for a
new treatment plant varying markedly
with community size. (See Figure 1.)
The one-time investment per household
of four persons ranges from
approximately $1,400 for a one million
gallon per day (mgd) plant to $400 for a
100 mgd plant. The more than
three-fold difference in per capita costs
is due in part to economies of scale; the
cost of a large city plant is shared by a
greater number of people, thus lowering
the cost per capita.
What does this mean for communities
caught between the compliance
deadlines and the funding crunch?
One major development is that many
cities and towns are scrambling to
arrange independent project financing
and relying more heavily on state
alternative funding programs, In the
(U'enit/ is (/ Policy AiHiJvsf in (lie (K'ii e
'),' Municipal PnlJnliun (,'
-------
Bond banks or bond pools typically
aggregate the bond issues of several
municipalities into a single state bond
issue to be sold on the national market.
The interest rate paid on the bonds
becomes the rate that municipalities
must pay the bond pool for their loan.
Revolving loan funds are another way
of making a fixed sum go further.
Beginning with an initial appropriation
of "seed" money to the fund, loans are
made available for specific purposes
such as municipal treatment plant
construction. The loan repayments,
including interest, go directly back into
the fund to be used for other loans, thus
continuously recycling a limited money
supply. Depending on !he interest rates
charged on its loans, the fund can
maintain and even increase its
purchasing power.
Revolving loan funds are currently
one of the most popular new financing
tools; 35 states are either operating or
considering the establishment of such
programs, either alone or in conjunction
with other funding approaches.
Legislative appropriations often are used
to capitalize these programs, but several
states use revenues from specific taxes
such as dedicated sewer and water,
excise, mineral severance, inheritance,
and even tobacco taxes.
The unique infrastructure needs and
priorities of each state lead to
considerable diversity in how it
packages its assistance to
municipalities. Some state programs
restrict their assistance to municipalities
with poor, or no, credit ratings; others
base their assistance on such factors as
affordability of the project, public health
benefits, and potential for economic
development. There are also less
restrictive programs that fund projects
on a first-come, first-serve basis, relying
only on the municipality's ability to
repay. All the programs, however, try to
prevent defaults by emphasizing strict
measures to anticipate potential loan
repayment problems. The advantage of
these alternative state programs is that
each has been creatively tailored to
address specific state needs.
Ohio, for example, uses
state-issued revenue bonds to finance a
revolving loan fund. Starting with an
original appropriation of $100 million
from the state legislature in 1969, Ohio's
Water Development Authority has
financed 435 projects with a total
construction cost of over $1.8 billion—a
return of almost 20-to-l on the initial
investment. Officials attribute its
success to several factors, of which one
of the most basic is the enforcement of
timely loan repayments. In 17 years,
only one community has failed to make
a semi-annual repayment on time. In
that case, the Authority sued
immediately and obtained a court order
requiring the community to raise its
utility rates.
Also important to Ohio's success is its
ability to take advantage of
sophisticated financing techniques, its
"fast pay" program for contractors, and
its policy of charging interest rates
based on current market rates, not the
rates at which the Authority borrows.
Most important, however, is the
simplicity of the program for local
governments. From an application to a
check in the bank can take as little as
one month from a community's initial
contact with the Authority.
Wyoming's Farm Loan program also
features minimal red tape and
turnaround time. Wyoming has a strong
grant program funded by royalties from
the coal and mineral industries, and a
revolving loan program funded by an
initial state appropriation of $100
million. Although the state constitution
prohibits the issuance of general
obligation bonds, the Farm Loan
program is empowered to issue revenue
bonds. Since it began in 1974, the
revolving fund has loaned over $62
million for water and wastewater
projects and the grant program has
awarded more than $127 million, with
all repayments deposited in the loan
program account. Funding has ranged
from $50,000 for adding chlorination
systems to an existing facility to $30
million for a complete treatment plant.
While the program offers no formal
technical assistance services, the
funding review staff does try to help
communities develop systems
appropriate to their local needs and
resources.
As in Ohio, Wyoming officials credit
the success of their program to its
simplicity and accessibility to
communities. The Farm Loan program
coordinates project financing with
several agencies, including the
Wyoming Water Development
Commission, the Farmers Home
Administration, and EPA. The program
makes an effort to minimize the
reporting and administrative burden on
the participating communities. In
addition, the program's ability to match
loans and grants from various sources
has encouraged communities to fund
improvements that they might not have
considered otherwise.
Some of the most innovative programs
recognize that many municipalities need
technical as well as financial assistance,
and several states have developed
comprehensive advisory programs to
help communities plan and build, as
well as finance their wastewater
treatment facilities. Such programs are
usually geared to improving
communication among state officials,
municipal officials, and operators of
wastewater treatment facilities;
increasing municipal awareness of the
fiscal impact of proposed facilities; and
coordinating requirements of potential
funding sources.
Tennessee offers loans and grants for
wastewater treatment construction, but
it also encourages communities to
consult with the University of
Tennessee's Municipal Technical
Advisory Service. Consultants from the
university advise local officials on grant
and loan planning and application,
wastewater project management,
financial management, and utility
administration. Since it began in late
1984, the program has helped over 100
Tennessee cities, leading to the award of
100 separate state and EPA wastewater
grants.
The State of New York has also
recognized that advice is sometimes
worth more than money, especially for
small, rural communities without the-
labor or financial means to maintain
complex treatment plants. The New
York State Self-Help Support System
assists such communities in developing
appropriate, locally affordable solutions
to their wastewater problems.
Co-sponsored by the New York
Departments of State, Environmental
Conservation, and Health, and the
Rensselaerville Institute and the Ford
Foundation, the program provides the
nuts and bolts expertise for small towns
to "do it themselves". Advice includes
showing town officials how to assess
their problems and develop simple
solutions; how to serve as their own
general contractors; and how to
maximize the use of local resources.
The program has even developed a
step-by-step guide to self-help entitled
The SeJ/-HeJp Handbook for Local
Government Officials.
The need for workable methods of
financing wastewater treatment projects
in the absence of adequate federal
dollars is inducing states to establish
innovative financial and technical
advisory programs. Federal, state, and
local responsibilities are being
redefined, and the states are clearly
preparing to take the lead role, o
EPA JOURNAL
-------
Some Communities
Move Ahead
Without EPA Dollars
by Roy Popkin
Thousands of communities will need
new or improved wastewater
collection and treatment systems before
the end of this century. Many will need
to construct new facilities or replace or
upgrade existing facilities by 1988 if
they are to meet the Clean Water Act
compliance deadline. The cost of
providing for all these needs is
estimated to be in the tens of billions of
dollars. For most of these
communities—whether the problem is
near-term compliance with the 1988
deadline or whether it is providing for
long-term delivery of service to
citi/.cns there is the all important
question of how to pay for the needed
planning, construction, and operation
and maintenance of the new or
expanded waste treatment facility.
Thousands of communities
will need new or improved
wastewater collection and
treatment systems before the
end of this century.
In the past, many communities
delayed action until they received
federal grant assistance. Such delays
resulted in continued pollution and
higher costs. Now, given efforts to
reduce federal spending and to increase
state responsibility, it is clear that there
simply won't be sufficient federal grant
funds to finance every town's needs.
Now that town officials realize that
many communities will not receive
grants, more and more communities are
finding alternate ways to solve their
wastewater problems and to fund the
needed construction. They are finding
engineers who know how to "think
small."
They are finding innovative ways
to financing the projects. They are
fPopkm is a ivriler ediior in the h'PA
airs.]
spending less than they might have if
they'd had to meet all of the procedural
requirements that go with federal
funding. They are educating their sewer
system customers to pay higher but
reasonable fees for the service and they
are looking more aggressively for
supplement revenues and ways to
reduce operating costs. Most
importantly, they are assuring their
communities of a continued supply of
clean water and making an important
contribution to local economic growth
and development.
• Auburn, AL
On September 12,1986,
this bustling university town
dedicated the H. C. Morgan Water
Pollution Control Facility, one of two
brand new treatment plants that
replaced an inadequate system that was
designed in 1958. Since going on line,
the new system has met Clean Water
Act treatment and discharge standards
and has been praised by the State of
Alabama for cleaning up the area's
polluted streams and for benefiting
Auburn's economy. City Manager Doug
Watson told the Birmingham News: "We
could not have accomplished so much
so quickly had we relied on federal
funding. Speaking of the cost to the
consumer," he added, "we had to
double our sewer rates (from 96 cents to
$1.92 per thousand gallons, but the
alternative, under traditional financing,
would have meant tripling our sewer
rates."
Auburn's solution? Privatization. The
city began planning for a new treatment
system 12 years ago. The wastewater
flow was more than the city's northside
plant could handle, and the pump
stations delivering wastewater to the
southside plant were deteriorating. Raw
sewage was backing up into homes or
overflowing into and polluting area
creeks. Despite the obvious need for
system improvements, Auburn was low
on the state's EPA funding priority list.
In 1983, the City Council began to
In lf)74. ivliilc rifv ivprkcrs tried to
rcpdiru broken pump at the sruuui'
piimpinu stuf/oit in Auburn. AL run
sciv
-------
Present di (he dedication of l/ie nen
ivrisfcivolrr trciitnirn) pir/nt in Auburn.
AL, on SepirmbiT /2 \\ere, I lo r.
Auburn Citv CoiincHnnm Dr. !/.(.'
.\forgnn; Auburn \hivoi )nn Dem
I'.'I'A f?i".;n>n -i Administrator fack
Htivmi; (Hid Hen Hmvls. preside/if ' ih<
I'inn (Jxil limit (lie sv.sfcm.
applications because of inadequate
sewage treatment capacity. As a result,
developers \vhose proposed projects
were ptil on hold rallied behind the
Sewer Privatization Review Committee.
Over the life of the Metcalf and Eddy
contract, Auburn expects to save $25
million. According to Auburn Mayor Jan
M. [)empse\, the project is "working out
fine. The company is meeting all of our
expectations. The plants both went on
line as scheduled. And. even before
they started up. we received a refund of
$35,721 representing money the
'company had saved while; operating our
old plants during the construction
period. We're using par! of that money
to landscape the area where the old
northside plant was and turn it into a
park. Wo think privatization is the way
to go."
The mayor was echoing city manager
Watson, who in March 1985 wrote, "on
a nation,il si,ale. Auburn's experience in
this public-private; partnership may
prove to he a model in the rebuilding of
the infrastructure needs of
communities,"
riven though KPA had granted no
money to Auburn for tin; project, the
September dedication was attended by
Region 4 Administrator Jack Ravan. He
said KPA must continue to enforce the
standards in tho Clean Wator Act oven if
federal construction funding is halted,
and predicted that during the next five
years "representatives from more than
1,000 cities from across the country will
come hero to see what Auburn has
done." Since the conception and
realization of the Auburn privatization
project, the tax benefits arising from
such projects have been severely
curtailed. However, the investment ami
engineering community is expected to
develop new concepts that will result in
the continued viability of privatization
lor ,i variety of communities.
• Camden, NY
"We never really thought about federal
money for improving our wastowater
treatment system," says David Barker,
Superintendent of Public Works for the
village ol Camtlon in Centra! New York
State. "We pursued state money for a
while but found the cost of just
applying for and getting the money
would add considerably to the cost of
meeting our needs." What they did,
instead, was redistribute resources and
use village employees for project labor.
Camden, a small agricultural/
industrial center in Onoida
County, has a population of about 2,700.
Its wastewater collection system, built
in 1925 and upgraded in 1973, consists
of preliminary treatment, an oxidation
ditch, and discharge to the west branch
of Fish Creek. The sludge treatment
process was recently upgraded to
handle increased solids.
In 1983, the treatment plant needed a
new boiler to heat the control building.
Instead of just installing a new boiler.
Barker and his staff found a more
efficient way to heat the building and
save fuel oil costs. They used a
geothermat heat pump, designed for
taking heat from ground water, to
extract heat from the effluent.
Department of Public Works (DPW)
employees installed the system. They
believe the estimated annual savings of
$900 to $1,100 should pay back the cost
of the municipal work force by the end
of 1987.
Then, in 1985, the wastewater
treatment plant began producing more
sludge than the system's three open
drying beds could handle. Working with
a local wastewater equipment sales
representative, the village treatment
plant operator looked at the alternative
sludge dewatertng technologies that
were available to small plants such as
Camclen's. To see how a screw feed
sludge press would work as compared
to a belt feed press, they rented a
portable one for a week, then ordered
two screw feed sludge presses and a
pre-fab building to house them. Again,
Camden DPW employees did the
installation at a net savings of
approximately $140,000 in capital costs.
Time lost from other DPW work was
minimized, Barker says, by using the
crews "mostly on days when the
weather wouldn't let them work
outside."
The improved plant has a capacity of
800,000 gallons per day (gpd), higher
than its normal 750,000 gpd average
flow, and the new sludge system
provides secondary benefits in that the
old belts are being used for additional
drying capacity. At the same time,
Camden is getting what Barker calls,
"younger sludge," which may not have
as much copper in it as the older
output. This, in turn, may lead to sale of
the sludge or its use for fertilizing local
parklands.
• Johnson City, TN
This Appalachian mountain community
wearied of waiting to reach the top of
the state's priority list and took
advantage of a "pollution crisis" in
neighboring Bristol to gain public
support for funding a multimillion
dollar upgrading and expansion of its
sewage treatment system.
The Johnson City Knob Creek plant
was not in compliance with its permit
in 1983/1984, and the town's
management felt it could no longer
delay needed improvements. At the
same time, its Brush Creek plant was
approaching capacity, and they wanted
EPA JOURNAL
-------
to head off future problems. An
additional factor was that the EPA
wastewater treatment plan for the area
designated Johnson City as a regional
wastewater facilities provider. As a
result, there was a growing demand for
wastewater service from residential and
industrial developers. Inflation had
increased design costs while the city
waited for federal funding, and it was
obvious federal project requirements
would probably increase the costs even
further. To add to the pressures to move
ahead, Johnson City was under a state
commission compliance order directing
that its system be brought up to
state-enforced standards.
Coincidentally, pollution problems
and state enforcement actions in nearby
Bristol created negative publicity about
wastewater treatment in the entire
tri-city (Bristol-Johnson City-Kingsport)
area. Johnson City's pride and desire to
protect the community against the kind
of environmental notoriety that could
slow or stop development and growth
fostered support for doing what was
necessary as soon as possible and
funding the costs from city resources.
According to city manager John
Campbell, "We were able to start at the
best possible time for obtaining low
bids. The area was construction-hungry.
We wound up spending $9 million. We
completed the improvements in 15
months, giving the city system increased
capacity and enabling us to annex
additional growth areas. We saved a lot
of money by moving quickly,"
The construction was funded by a
combination of bond issues, tax
revenues, and increased sewer rates. "A
good education campaign created a
supportive community attitude,"
Campbell says.
• Louisa, VA
Louisa is a typical rural Virginia
comunity located not far from
Charlottesville. Although its population
is only about 1,000, growth and
development are accelerating both in
and around the city. New shopping
malls, industrial parks, and a nursing
home have moved into the area. A
nuclear power plant is just a few miles
away. In 1982 the prospect of this
growth led the town leaders to build
new treatment plant and sewer
extensions as an inducement to
potential developers. Since federal
funding prospects were dim, the town
financed the project itself. Louisa
was joined in the venture by the county.
which needed adequate sewer service
for an industrial air park outside the
Louisa town limits.
An engineer experienced in designing
small community projects helped the
The cost of providing for all
these needs is estimated to be
in the tens of billions of
dollars.
town and county design a 200.000 gpd
oxidation ditch to supplement the
existing 75,000 gpd trickling filter. The
state of Virginia approved the
recommended low-cost options.
The city manager, Gary Hart, became
a self-made creative financier. "The first
thing you do when you're looking for
money is talk to the money experts," he
told a Baltimore seminar on Small
Community Wastewater Technology in
November 1985. "You contact bankers,
loan agents, brokers, and get them to bid
for your business."
Louisa's share of the Si.2 million
dollar cost was funded primarily with a
$750,000 Farmers Home Administration
(FmHA) loan at 9.5 percent. But FmHA
doesn't provide funds while
construction is in progress; Hart needed
upfront money. He found short-term
loans at six percent and manipulated
them down to a net of three percent. In
addition, connection fees were collected
in advance from potential new
residential, shopping center, and
industrial park customers, providing
$125,000 for engineering and other
costs. And, because town meetings and
other educational efforts prepared
Louisa for increases in the sewer rates,
Louisa began gradually increasing the
monthly bills even before the new
system was fully completed, Hart told
the Baltimore seminar. "We'd had a
public meeting and our customers had
accepted the fact that we did need to
spend the money on the sewers and
treatment plant. And most of them were
ready to pay for it with higher rates."
Westboro, WI
This tiny central Wisconsin wood
pulping and farm community \vas under
pressure from the state's Department of
Natural Resources because 70 percent of
the septic tanks used by its 200
residents were failing. The failures
threatened the community's health and
underground well water supply. When
the problem first became a matter of
community concern in 1974. the cost of
installing even a small conventional
sewer and treatment system would have
been more than the entire assessed
value of the community. Nevertheless, it
was unlikely that federal construction
funding would be available.
Engineer Richard Otis, then with the
University of Wisconsin, studied
Westboro's problem and came up with a
less expensive solution: a
small-diameter pipe gravity sewer
system linking all of the community's
septic tanks to a soil absorption field.
When the new system was hooked up in
1977, the cost turned out to be about a
third less than Westboro would have
paid for the kind of conventional system
used in larger cities. Because Westbom
had the help of an engineer who knew
how to "think small," the community
had that much less to fund through the
FmHA and can pay it back through
users' fees.
The variety of approaches used by
this small sample of communities in
meeting wastewater treatment munis
illustrates that there are attractive,
workable options to communities in lien
of dwindling FPA construction grants.
Each community can evaluate best its
particular circumsl.iiK c.s and nerds ,is
well as the talents and capabilities it
has on hand. Whether the answer is
innovative financing for a conventional
system or reassessing the problem and
financing a lower cost conventional or
alternative technology, local
governments increasingly are mustering
their own technical expertise and
resources and are finding affordable and
effective solutions to local problems. Q
NOVEMBER 1986
-------
Trying Simpler Ways
To Treat Wastewater
by Peter Shanaghan
and John Flowers
Stinsmi Heurh. California, u snuill.
riMisldl oMnmiinily ivhere mmiuirnienl
of on-silc ivusteivnfer [retilmenl systems
is improving ivuter quulity.
Aternative financing is one factor in
developing local ami statt;
self-sufficiency in wastewater treatment:
alternative technology is another. Wise
technology choices can help reduce
capital costs, thus expanding financing
options, and also help to reduce
operation and maintenance costs.
Together, sensible, financing and
technology keep a community's
wastewater treatment costs affordable.
Proper planning and technology
choices are especially critical in small
communities. A limited tax base,
relatively low per capita income, and
difficulties in the bond market all limit
how much those; communities can
afford to spend. Small communities also
face the problems of dispersed
populations and limited technical and
managerial expertise. But, despite these
problems, many towns are meeting their
wastewater challenges successfully—not
with sophisticated processes, but by
adopting the KISS philosophy (Keep It
Small and Simple).
Some small communities, for
example, are finding that oil-site
wastewater systems under community
management can he a cost-effective
option. Such systems were once viewed
as second-rate; now they are recognized
as an alternative to centralized
treatment that can provide excellent,
reliable service at reasonable cost.
Septic tank/soil absorption systems,
for example, have remained the most
popular form of on-site treatment. The
advent of low-flow home plumbing
fixtures and modified soil absorption
methods, however, has greatly increased
their reliability and long-term
usefulness; the new methods also offer
hope that failing systems can be
renovated and retained for use. One
uin is (in Environmental
Kn.uinrcr ivitli Ihr Simi/l Communities
Section in KI'.Vs (HliVe oj U'uler and
Flmvrrs i,s (,'liiel o! (lie Section.]
new system uses a small pump to
periodically disperse septic tank
effluent under pressure to the soil
absorption field. Not only does this
make better use of the entire absorption
area; it allows the area to dry out
between doses, thus improving system
performance.
Stinson Beach is a good example of
on-site wastewater systems under
community management. An isolated
coastal community of about 1,800 north
Wise technology choices can
help reduce capital costs and
also operation and
maintenance costs.
of San Francisco, Stinson Beach was
having a problem with polluted ground
water due to failing on-site systems. In
the mid-1970s, the town formed an
on-site system management district to
repair failing systems and regulate all
on-site wastewater disposal. The plan
also included a program of water
conservation to reduce wastewater flow.
Since then, continuous monitoring of
streams and ground water has shown
significant improvement in water
quality. Yet, the cost of the program was
less than a third of the cost of a
conventional wastewater collection and
treatment system.
For those small communities where
on-site system management is not
feasible, other options are becoming
available, including alternative sewer
systems and treatment facilities.
Depending on conditions, these
facilities can be decentralized, serving
clusters of homes with local i/ed
problems, or they can serve the entire
town.
Alternative sewers are usually plastic
pipes, smaller in si/.e than conventional
concrete sewers and installed at shallow
depths. The smaller size and shallow
depth are possible because each
household's wastewater is pretreated on
site before going to a central facility.
Some systems also use small on-site
pumping units to help transport
wastewater through the sewers to the
treatment site. Various designs have
been developed to reduce the cost of
sewering in rural areas where
conventional sewer costs can amount to
80-90 percent of the capital costs of a
wastewater system.
Variable grade effluent sewers are
another emerging system. Developed in
Australia in 1968, these sewers carry
septic tank effluent from individual
homes to a common treatment site.
Sewers can be as small as 1-1/2 inches
in diameter and are laid at shallow
depths. In many instances, they can
follow the contour of the land and even
traverse small hills. Since almost all
solids settle out in the septic tank,
sewer clogging is rarely experienced,
even in low spots.
In addition to their low costs and ease
of maintenance, these systems are also
very simple to install. Only shallow,
narrow trenches are needed, and these
can easily be dug around trees and
buildings so as to minimize disruption
to the landscape. Simple clean-out
devices take the place of costly
manholes.
Maysville, Ohio recently installed 17
miles of variable grade sewers to serve
770 homes. The two-inch plastic sewers
run through residential back yards,
carrying effluent from individual septic
tanks to a neighboring treatment plant.
The entire sewer system was built for
$4.1 million—a dramatic savings over
conventional sewers which were priced
between $6 million and $8 million.
Low-cost, easily maintained sewers
are only part of the story for unsewered
communities. The rest of the story
involves low-cost, simple treatment
technologies.
EPA JOURNAL
-------
intermittent sand filtration is an
example of a dependable small
community technology that produces
high quality effluent. A similar process
is used for treating drinking water.
Intermittent sand filters are beds of sand
2-3 feet deep. Wastewater is periodically
dosed over the beds and allowed to
percolate through the sand. The filtered
wastewater then is collected and
disinfected before discharge. The filters
may be either exposed or covered and
require little energy or operator
attention.
Alicia, Arkansas, installed an
alternative sewer system and
community intermittent sand filter to
serve its nearly 1,000 residents.
Designed to meet stringent water quality
standards, the centralized treatment
system consists of a receiving tank with
pumps, a six-cell filter, and chlorination
equipment. The town also provides for
treatment of the pump-outs from
individual septic tanks. The cost for the
entire sewer system and treatment plant
was $322,000, only half the cost for
conventional gravity sewers and a
package treatment plant. Town officials
find the operation and maintenance of
the system extremely simple, involving
little more than weeding and tilling the
filter beds and servicing the pumps and
chlorinators at a cost of only
$5,000/year. And the good news for
Alicia homeowners is that se\ver service
costs only $9.50 per month.
Proper planning and
technology choices are
especially critical in small
communities.
The Mayo Peninsula on the
Chesapeake Bay south of Annapolis.
Maryland, is another illustration of
appropriate wastewater management for
small communities. Mayo residents
have been plagued for years by
wastewater management and public
health problems, but solutions didn't
come easily to this environmentally
sensitive area. It finally took a
combination of innovative systems to
deal with Mayo's difficulties.
One hundred homes on the
eight-square mile peninsula will
continue to use on-site systems
managed and operated by the utility
district. Ninety homes are in an area
unsuitable for on-site svstems, but also
too remote to connect to the planned
central treatment facility. These homes
will be served by two "cluster" systems
of alternative sewers carrying septic:
tank effluent to a nearby communal soil
absorption field.
The peninsula's remaining 2.200
homes will send their septic tank
effluent through alternative sewers to a
central intermittent sand filter.
Following filtration, the wasttnvaler will
flow through a series of artificial
marshes, then be collected and
disinfected using ultraviolet light which
leaves no toxic, residues. Though costly
because of the high degree of treatment
needed before discharge to the
Chesapeake Hay, this combination of
systems will still be 20 percent less
expensive than a conventional system,
and operation costs will lie drastically
less.
Clean water doesn't come easily. But
those small communities which have
opted for simple, innovative treatment
facilities are now in a good position to
show others how to solve their
wastewater problems through KISS and
tell. D
NOVEMBER 1986
-------
EPA's Construction
Grants Program:
A History
by Jack Lewis
U'idesprecid pollution of river* cnul
lakes hud. by (he Idle J'JIJOs. helped
prompt public deniund lor stronger
fion of ibe environ
Thii United States is not alone among
nations in its reluctance to confront
the legist charismatic of social problems:
how host to keep human organic waste
out of sight and out of whiffing
distance. All too ofttm, of course, out of
sight means out of mind. The invisible
wonders of modern plumbing have
contrived to lull Americans—like
residents of other advanced industrial
nut ions into false confidence that
inexpensive, inobtrusive wastewater
treatment is nothing short of a
birthright.
From the earliest days of the
American republic, the foe.us of our
businessmen, politicians, and citizens
has been on never-ending economic
progress. In less than 150 years, the
limitless expansion of trade and
manufacturing transformed the United
States from a sleepy agrarian backwater
into a booming bastion of industry.
Improved niunut>i>nu;nt is now
making uvvry Construction
(irunts dollar go much further
than it did in thv past.
During those, years of peak growth,
Americans had no appetite tor
Farsighted planning in the area of
wastewater treatment. Kadi of the 48
states zealously guarded its sovereignty
over all matters pertaining to
wastewaler treatment. Great Lakes
governors, for instance, never tired of
touting the then seemingly limitless
capacity of those; "sweet waters" for
assimilating human and industrial
waste.
It was not until after World War II
that attitudes began to change. The
nation's lawmakers decided the time
(Leivis is .\ssjv;|,mt Kdilor of (he LP V
Journal.)
had come to establish at least a
rudimentary federal presence in the
sphere of wastewater treatment.
Congress passed a ground-breaking
statute in 1948: the Federal Water
Pollution Control Act. This was the tiny
seed from which sprouted the ambitious
federal Construction Grants program of
the 1970s and 1980s.
The first federal Construction Grants
were disseminated in the mid 1950s.
Like their much larger descendants,
these early grants subsidized
improvements in the techological
capacity of municipal wastewater
treatment works. As the 1950s gave way
to the 1960s, these initially miniscule
grants gradually grew in size, but at a
very slow rate.
By the end of the 1960s, the American
public was clamoring for immediate
action to protect the long-neglected and
heavily polluted rivers and lakes of this
once pristine country. Fish kills in Lake
Erie, chemical fires on the Cuyahoga
River: the litany of water catastrophes
went on and on, with no apparent
solution in sight.
Responding to a frenzy of
environmental activism, President
Nixon agreed to set up a special federal
agency devoted exclusively to the
protection of our environment. EPA
opened its doors in December 1970.
The fledgling agency was given
responsibility lor the various versions of
the Water Pollution Control Act passed
since 1948. In the 1950s and 1960s, the
Department of Health, Education and
Welfare had been the steward of the
low-profile federal presence in
wastewater treatment.
The water pollution emergency was
felt to be so urgent that the Army Corps
of Engineers—acting in conjunction
with EPA—reactivated a long-dormant
law, the River and Harbor Act of 1899.
The Corps began to issue permits to
control the effluents discharged by
industrial and municipal polluters. In
1971, however, the courts ruled that the
Corps of Engineers lacked proper
jurisdiction in this area. A legal vacuum
existed, waiting to be filled.
Congress moved quickly in 1972 to
approve a momentous group of
amendments to the Water Pollution
Control Act. Generally known as "The
Clean Water Act," this legislation added
intra-state waters for the first time to
the jurisdiction of the federal
government. Previously, the federal role
in water pollution control had been
confined to interstate and coastal
waterways.
The new law. signed on October 18,
1972, provided for distribution of $18
billion in municipal wastewater
treatment grants. The grants were to pay
for 75 percent of the cost of approved
projects in qualified municipalities.
As with any large program.
Construction Grants got off to a slow
start. Then; was no way $18 billion
could be distributed in one fell swoop.
From 1973 to 1975, $9 billion in grants
were obligated. In 1976, the remaining
$9 billion was released to subsidize
more projects.
Even these phased disbursals of funds
proved to be more than the limited EPA
staff could directly administer. There
was an urgent need for trained
manpower, nor just in Washington but
in the states ;:nd local communities.
EPA was eager to delegate authority to
state governments willing and able to
take on direct administration of
Construction Grants projects as partners
to EPA.
Congress responded to this need by
passing new amendments to the Clean
Water Act in 1977. These enabled EPA
to delegate operational responsibility for
the Construction Grants program to state
governments qualified to take on the
job. In addition, funds were made
available to the states for financing their
new administrative expenses.
As a result, between fiscal years 1978
10
EPA JOURNAL
-------
and 1981, EPA delegated administration
of the Construction Grants program to
45 states. Later, the other five states also
qualified for delegated authority. At
present, there are 1500 state employees
who are directly involved in the
day-to-day management of the federal
Construction Grants program; they are
scattered through all the 50 states.
As an additional resource, the Corps
of Engineers has made its staff available
to provide inspection services during
the construction of a large number of
Construction Grants-funded wastewater
treatment projects.
But no program this challenging,
involving so much money and so much
coordination among different levels of
government, could ever be problem-free.
There were many complaints as the
program matured in the late "1970s.
Chief among these was that all the
detailed procedural requirements,
however necessary in the early stages of
the program, were becoming
burdensome.
"Mid-course correction" became the
order of the day in the Construction
Grants program. EPA worked to improve
its own administrative apparatus. At the
same time, the states moved more
quickly toward full assumption of their
responsibilities for managing the
program.
NOVEMBER 1986
New amendments to the Clean Water
Act, passed in 1981, marked another
major step toward returning to state and
local governments the responsibility for
meeting wastewater treatment needs. A
plan was adopted to reduce the federal
share of individual Construction Grants
projects from 75 percent to 55 percent,
starting in 1984. This provision of the
Approximately 2,500
Construction Grants projects,
costing over $8 billion, are
now underway.
1981 amendments made slate and local
governments virtually equal financial
partners with the federal government.
Another 1981 amendment fostered
sounder business practices at the state
and local levels. Congress instructed
EPA to provide guidance to program
managers on how best to evaluate the
ability of Construction Grants applicants
to pay for their share of construction
costs, as well as their share of operation
and maintenance costs for completed
projects. Applicants were to be
subjected to this kind of careful scrutiny
prior to their approval for grants and the
formal go-ahead for construction.
These and other measures made the
Construction Grants program a textbook
case of the "New Federalism" in action.
Decentralization has been the name of
the game in the 1980s. Improved
management at the local, state, and
federal levels of government is now
making every Construction Grants dollar
go much further than it did in the past.
Noteworthy among these managerial
changes:
• EPA has developed an efficient
monitoring apparatus for the
Construction Grants program.
Evaluations of the program are now part
of a sophisticated Management
Evaluation System formulated by KPA's
Office of Water and since adopted by
other major offices at KPA. Construction
Grant recipients are now required to
make performance commitments with
EPA, specifying what tasks must be
accomplished by what specific:
deadlines; these commitments establish
the criteria for subsequent management
evaluations.
• Improved computer tracking has
made it possible for KI'A to do a better
job of monitoring recipients ot
Construction Grants.
• EPA has upgraded the methods it
uses to identify what are known as
"infrastructure needs" at wastewater
treatment facilities; such needs include
overhauling or replacing old equipment,
as well as introducing new technologies
to improve operations.
• Through an Advanced Treatment
11
-------
review process, EPA has encouraged
municipalities to consider more
earH'ully what Advanced Treatment
processes are actually needed to meet
water quality-based standards under the
Clean Water Act.
From October 1972 to October 1986,
$44.h billion in Construction Grants was
appropriated. This level of expenditure
(hvni'ls all other programs in EPA.
Among all domestic federal programs, it
ranks second only to the highway
program al the Department of
Transportation—which has authorized
$198 billion in highway expenditures
.since its inception in 195(i.
The legislators who passed the
first Clean Water Act in 1972
dreamed of a day when the
U.S. could once again hoast of
"fishahle, swimmabte" rivers,
lakes, and streams.
What have these billions of dollars in
federal Construction Crants procured?
Plenty. Over the past 14 years,
approximately 4500 Construction
Grant-assisted wastewator treatment
facilities achieved fully operational
status in communities throughout the
United States. In addition, hundreds of
projects smaller in scale have been
snbsidi/ed at treatment works
throughout the United States.
Approximately 2500 Construction
Grants projects, costing over $8 billion,
are now under way. By the time federal
funding for the program ends, several
thousand additional projects will he "on
line."
Also heartening is the improved level
of compliance with the Clean Water
Act. By March 1980. only 12 percent of
U.S. municipalities that had completed
construction to meet Final Effluent
Fish kills in thr C.rcol Lakes
(hose "siveehvuler seas" iveir in dire
need ol cl
Limits under the Clean Water Act were;
still in significant non-compliance.
Some 67 percent of municipalities had
completed construction needed to
ensure full compliance.
However, this improvement has
lagged behind the progress made by
non-municipal (primarily industrial)
treatment systems, 94 percent of which
had completed construction needed for
full compliance as of March. 198(>.
To close this compliance gap,
EPA's then Administrator William
Ruckelshaus formulated a National
Municipal Policy in 1984. EPA's new
Municipal Policy set schedules that
have put many cities with previously
lackluster records on the road to
compliance with the law of the land.
Ruckelshaus' successor, EPA's current
Administrator Lee M. Thomas, took
another major step forward in 1985
when he ordered an increased
enforcement effort aimed at the problem
of untreated toxic industrial waste that
had long been routinely discharged by
some companies into municipal
wastewater systems.
These discharges have been a source
of grave anxiety to citizens living in
industrial communities. Not only have
they fouled treatment works with
unidentified, untreated, and frequently
untrealable hazardous substances; also.
on occasion, they have upset the
water-purifying technology in place for
the primary and secondary treatment of
human organic waste. In one
spectacular instance, this sort of
"interference" with municipal sewage
systems by toxic dischargers led to an
explosion that destroyed an entire block
in Louisville, Kentucky, in February
1981.
The foundation now exists for further
advances in the area of pretreatment. As
of October 1986, 1429 publicly owned
treatment works in industrialized
communities had EPA-sanctioned
"pretreatment programs" in place. When
fully operational, these programs will
ensure that industries intending to
persist in pumping waste from factories
into sewers will treat such waste prior
to its discharge.
The legislators who passed the first
Clean Water Act in 1972 dreamed of a
day 10 years hence when the United
States could once again boast of
"fishable, swimmable" rivers, lakes, and
streams. EPA's Construction Grants
program has gone a long way toward
making that goal a reality.
Consider these sterling figures
compiled in 1982 by the Association of
State and Interstate Water Pollution
Control Administrators. Even though the
population of the United States grew 11
percent from 1972 to 1982:
• 47,000 stream miles improved in
quality over that 10-year period.
• 390,000 acres of lakes improved in
quality.
• 142 million people were receiving
secondary or more advanced levels of
sewage treatment by 1982—57 million
more than received such treatment in
1972.
Fishermen and wind-surfers can now
be seen along the Potomac; River and
other less symbolic rivers throughout
the United States. Toxic pollution has
raised new concerns, but human sewage
is much less a problem today than it
was 14 years ago. Of this, EPA and the
nation have every right to be proud. D
EPA JOURNAL
-------
A National Policy
To Enforce
Wastewater Cleanup
by John W. Lyon
and Patricia D. Mott
The clean water legislation of the
1970s required industries ami
municipalities to meet stringent
treatment standards for their
wastevvaters. These standards are
applied through permits that limit the
amounts of pollutants discharged from
each facility based on its unique
conditions. For most municipal
treatment plants (also known as
publicly owned treatment works or
POTWs), these limits typically are set at
least at a level known as secondary
treatment. Such treatment generally uses
biological processes to remove organic
matter in sewage.
When Congress imposed treatment
requirements, it also imposed deadlines
for compliance. But it recognized
that most cities would have to
undertake major construction programs
in order to comply. To help them do
this, Congress established a carrot and
stick program of construction grants
coupled with statutory deadlines.
Fourteen years, several deadline
extensions, and nearly $45 billion later,
some 1300 major POTWs still need at
least some construction to meet their
permit limits. Hut direct federal
funding, already reduced as a
percentage of construction costs through
the 1980s, is now expected to be phased
out completely by the beginning of the
next decade.
From Policy To Action
Diminishing federal funding has raised
the issue of compliance with permit
requirements. Would cities be forced to
comply with discharge limits despite
the lack of federal funds?
Over the last ten years, the courts
have ruled repeatedly that cities must
comply, regardless of the availablility of
such funding. EPA's National Municipal
ll.ynn is m; Assistant Knlorrrmeitf
Counsel for Wafer ui KP.A's Office ol
Kfiforci'mcnl nnd Compliance
Monitoring. .Mod is ci uutcr rnlurcrmcn!
ullorney in the .sunn; office.)
NOVEMBER 1986
Policy, issued in January 1984, builds
on these rulings. The policy makes clear
that, with or without federal funds.
municipalities must meet their permit
requirements no later than July 1, 1988.
The sole exceptions are those
municipalities that can prove that they
are physically or financially unable to
Diminishing federal funding
has raised the issue of
compliance with permit
requirements.
complete construction by deadline; but
they, too, must abide by
court-enforceable completion schedules.
Since the policy was issued, EPA has
undertaken more than 60 lawsuits.
suing municipalities in 20 states, plus
the District of Columbia, Puerto Rico,
and the Virgin Islands, and including
systems ranging from 500 million
gallons per day down to one million
gallons per day.
Compliance with deadlines and
permits is not all that EPA seeks to
obtain through its enforcement efforts.
It's also looking for monetary penalties.
Although EPA takes into account a
city's ability to pay and its good faith
efforts to comply when assessing
penalties, it also considers equally
important factors such as the severity of
the permit violations and the economic:
benefits a city may have enjoyed by
delaying compliance. Penalties have
been as high as $625,000, but most have
been far lower.
Although the National Municipal
Policy has emphasized enforcement, it
has other facets as well. The Agency is
making a major effort to help cities and
POTWs with technical advice and other
non-financial assistance. For example,
this November, EPA is co-sponsoring a
National Municipal Conference to
discuss financing alternatives to federal
grants. In addition, some of the states
and EPA regional offices are providing
"trouble-shooters" to help
non-complying POTWs improve their
performance or get better results from
their existing systems.
In the long run, however, a tough
enforcement policy is still the Agency's
most effective tool for obtaining
o o
Do you think f-.'P.A could just innke [Jicsc
"sivrmmublr." mid forgrl nhtnil (hi- "
-------
municipal compliance, ;iml KPA \\rill
continue to push cities by filing more
cases. The majority of the major
PGTWs needing further construction to
meet their permit requirements have
already agreed to enforceable
construction schedules. Hut KPA is
prepared to take enforcement action if
these schedules are not met. In fact,
suits against municipalities for schedule
delay may become the most common
type of case by the end of this fiscal
year.
KI'A is also expecting more
enforcement help from the states
themselves. Thirty-seven of them are
authorized to administer and enforce
I'll*A is prepared to take
enforcement action if these
schedules are not met.
permits under the Clean Water Act. and
in tin; future, more municipal cases
should be brought by the states than by
Kl'A. Until recently, in cases where the
Agency was suing directly, the state was
named with the municipality as a
defendant. This was to ensure that any
judgment against the municipality
would IK: paid by the state if state law
prevents municipalities from paying
themselves. KPA is now working with
the Department of justice to develop
procedures that will allow a state to join
enforcement suits as a plaintiff with the
Agency,
The National Municipal Policy was
developed after more than a year of
drafting and consultation with the
states. Their growing support for the
policy and KPA's continuing
enforcement resolve should provide the
momentum to bring municipalities into
timely compliance with their permits
and to achieves the goals of the Clean
Water Act. u
Getting Down to Business
The city is committing itself to
treatment und management
improvements that could cost
more than $2.3 billion.
One of the most dramatic
breakthroughs as a result of the
National Municipal Policy is the
recent consent agreement between
EPA and the City of Los Angeles.
Los Angeles was first sued for
violating its discharge permits in
1977. Hut after almost 10 years of
construction problems, funding
holdups, and other delays, the
city's main treatment facility—the
Hyperion plant—still pumps more
than a million gallons of primary
sewage sludge into Santa Monica
Bay every day. That's 4,000 tons
discharged into the ocean daily,
not including storm water runoff.
And the Hyperion plant also
consistently violates its permit
limits for suspended solids,
biochemical oxygen demand, and
oil and grease, with occasional
violations of limits for residual
chlorine, lead, silver, /inc. and
nickel.
It took almost a decade, but the
municipal policy finally allowed
EPA to put its figurative foot
down.
Under the terms of the consent
agreement, Los Angeles not only
must pay the highest civil penalty
ever assessed to a municipality
under the Clean Water Act
($625,000), it must also carry out a
storm water control project over
the next three years that may cost
as much as $3.3 million. Most
importantly, the city is committing
itself to treatment and management
improvements that could cost
more than $2.3 billion over the
next 12 years. Specifically, Los
Angeles has agreed to:
• End all ocean discharge of
sludge by December 31, 1987.
Until then, the city will
immediately begin hauling at least
2,000 wet tons of sludge per
month from the Hyperion plant for
disposal elsewhere; within six
months, at least 5,000 tons must be
disposed of monthly.
• Achieve secondary wastewater
treatment by December 1998, in
the meantime meeting interim
limits. Given the magnitude of
construction involved, 1998 is the
earliest date by which Los Angeles
can complete the necessary plant
improvements to achieve
secondary treatment.
• Complete construction and
begin operating the sludge
treatment and disposal process
known as Ihe Hyperion Energy
Recovery System (HERS) by June
30, 1989.
• Maintain a specific number of
staff for plant operation and
maintenance.
One of more than 60 municipal
cases filed or settled since the
Agency first issued the policy in
1984, the Los Angeles agreement
proves that EPA and cities are
serious about getting down to
business, o
14
EPA JOURNAL
-------
Probing the Mysteries
Of Radiofrequency Radiation
by Miles Kahn
IVrrlu'd on u brixu: er in
Purflumf. (Jivuon. n ivoj :
tit'iv KM (ijitrniui.
is a certain mystique about
L radiofrequency (RF) radiation that
surrounds few other environmental
intruders. Although more is becoming
known about the biological effects of RF
radiation, it is still not a well
understood subject, even among the
experts.
The hazards associated with exposure
to unusually high doses of RF radiation
have been brought to light mostly over
the-last 15 years. One area in which a
lot of progress has been made is that of
making field measurements to
determine exposure of nearby
populations to RF radiation from
sources such as broadcast towers and
microwave relay stations.
EPA, through the unique capabilities
of the Electromagnetics Branch of the
Office of Radiation Programs (C)RF). has
made what is possibly the major
contribution. In the process of pushing
RF measurement technology, the
physicists of the Las Vegas-based
Electromagnetics Branch have been
involved in what have to be considered
some of the more unusual and
interesting situations confronting any
EPA field unit.
In February of 1983, a unique
combination of circumstances enabled
the Branch to make detailed
measurements of radiation fields around
an AM radio station. EPA had been
requested to make measurements at a
dairy farm located near an AM
broadcast tower, to determine if
radiowaves from the tower were
responsible for dramatically reduced
milk production of the farmer's dairy
herd.
Branch Chief Richard Tell and his
crew made measurements indicating
that the broadcast tower was not
responsible for the farmer's plight.
Fortunately, Tell's investigation did
(K'rilm is ii PuliJii.- AJ'luirs Spcnulisl in
/','PA's O///rr nf HmJiii/iuti PmL>runt.s.)
NOVEMBER 1986
15'
-------
reveal a possible cause of the problem.
Apparently, laulty connections from
local power lines and either improper
wiring or faulty electrical equipment on
the farm caused a phenomenon called
stray voltage. Stray voltage has been
associated in technical literature with
disruption of milk production in dairy
cattle.
Unfortunately, the; power company's
help in correcting the problem came too
late to avert the farmer's bankruptcy.
In addition to responding to selected
stall! requests lor field measurements.
the Branch's capabilities are employed
by other federal agencies, most notably
the Federal Communications
Commission (FCC).
Stray voltage has been
associated in technical
literature with disruption of
milk production in dairy
cattle.
In April HI84, the FCC requested that
measurements be made in Honolulu.
near broadcast lowers there. Normally,
broadcast towers are sited in remote
locations at the highest elevations
possible. In Hawaii, however, state
regulations prevent the placement of
broadcast towers in the scenic hillsides.
Consequently, many towers are located
in densely populated downtown areas at
the same elevations as high-rise
buildings. This increases the risk that
nearby individuals may be exposed to
elevated levels of KF radiation.
These unusual circumstances led to
one of the more interesting of all the
Electromagnetics Branch field trips, "In
addition to the extremely interesting
aspects of our scientific work." says
Tell, "we found some situations right
out of the Twilight Zone." Radiowaves,
explains Tell, can induce electrical
currents in conductive objects. In one
case, the proprietor of a dress shop with
a tower in its parking lot received KF
burns whenever she touched her sewing
equipment. In another instance.
construction workers actually walked
off the job because they continually
received electrical shocks from touching
their tools. Tell himself was burned as
he and his colleagues were measuring
tin; current induced in a long cable used
in window washing operations.
To measure the induced current
caused by a nearby tower. Tell had a
steel cable dropped from the roof and
hooked to a ground connection in the
parking lot. 40 stories below. "This was
the first time anything like this had
been done," Teli recalls. The electrical
current was measured at 20.000 volts!
(Normal household current is 120 volts.)
Thus, it was not surprising that window
washers were experiencing strong
electrical shocks when steel cables
suspending their scaffolds touched the
building.
Tell decided to take the experiment
one step further. He disconnected the
cable from the ground. This
immediately resulted in an electrical arc
between the two points. Using insulated
tongs, Tell then exposed a penny to the
arc, The face of the coin vaporized as it
began to melt; Tell was burned on the
finger as his hand momentarily slipped;
and music could be heard coming from
the electrical arc. As Tell notes, "That
part wasn't too scientific, but it sure
made a point!"
In another unusual occurrence several
Honolulu residents were reportedly
awakened one morning by an explosion
that appeared to emanate from a nearby
AM broadcast tower. As they walked
onto their balconies to investigate, a
second explosion occurred. The words
"Praise the Lord!"—magnified many
times normal volume—resounded
through the neighborhood. Baffled
witnesses thought they were hearing the
voice of God.
According to Tell there was a
plausible earthly explanation. The
ceramic insulators at the bottom of the
tower in question had apparently
become filled with water after a recent
rain, thereby losing their insulating
properties. A sudden electrical
connection to the ground caused an arc:
of electricity to boil the water. At the
precise moment of the second arc the
flame vibrated at the same frequency as
a religious broadcast beamed by the
tower. This coincidence sent the words
"Praise the Lord" booming through the
neighborhood.
Tell is quick to point out that in only
a couple of cases were nearby residents
of Honolulu exposed to RF radiation
levels exceeding American National
Standards Institute radiation protection
guidelines. In the worst cases, the FCC
has instituted corrective measures.
"Nationwide," Tell adds, "only one
percent of the population is exposed to
more than one microwatt per square
centimeter. And those people are in the
immediate vicinity of broadcast towers."
That fact was firmly established by a
major study conducted by ORP
from 1975-1977. Scientists took
measurements at 30 to 40 locations in
15 cities, from Boston to Los Angeles.
Exposure estimates for each city were
made through the use of computer
models. From these, an estimate was
made of national levels of exposure to
RF radiation. The study demonstrated,
according to ORP Director Sheldon
Meyers, that, "Despite some
apprehension among .small segments of
the public, aside from some
occupational problems. RF radiation
poses a potential problem for only a
small portion of the general population."
More recently, the ORP Las Vegas
crew have advanced the state of the art
in RF monitoring equipment. They have
developed a Fiber Optic Isolated
Spherical Dipol antenna (FOISD).
Previous antennae used to monitor RF
radiation were connected to
instrumentation and power sources by
standard electrical cables. In many
cases, the RF fields were perturbed by
the metallic cable connecting the
antenna to the instrumentation.
The words "Praise the Lord!"
resounded through the
neighborhood.
With the FOISD, however, there are
no electrical cables used to power the
unit or to transmit signals to the
monitoring instrumentation. This
revolutionary new antenna uses an
internal battery and transmits its signals
via fiber optic linkages. This prevents
the distortions inherent in conventional
technology and results in more accurale
readings.
Greater measurement precision.
especially in the wake of F.PA's recent
proposal of federal guidance options for
limiting RF exposure among the general
population, is extremely important. The
Washington staff of ORP is now
reviewing public: comments on FI'A's
proposed guidance. As ORP's Meyers
says, "No matter which option is
selected, accurate measurements will
become increasingly important as the
public becomes more aware of the RF
issue and as more becomes known
about the biological effects. And EPA is
leading the way in RF Monitoring." D
16
EPA JOURNAL
-------
Sampling Lakes
For Effects from
Acid Rain
by Cindy Chojnacky
To reneh (i niounftiin Inkc. members til n forest Service livnn c/iui/i
-------
dry stills anil lid- vests, dvo
Fup'.sf .Sr/vin1 tcdm lin .iillnlr the
ruff (hut ivill rdcry llicin lo fin dee •
port of (Ins lake in lh<> Shoshu/ic
Xdfidnul Fnir.st. U'Ju.'rc tliry \\'ill col/oct
iviilcr Mimplos. A third (com
riglil. dssists IJK.'in.
from the lake to the lab in 4 hours," said
Pete Stender, Regional Hydrologist for
the Forest Service's Interniountain
Region. If it touk nnit;!i longer, hi: said, a
sample's chemical composition might
change. Slender headed the Utah,
western Wyoming and southern
Montana portion of the wilderness lake
survey. His area included vast tracts
such as the High I'inta Wilderness in
Utah and the Bridger Wilderness in
Wyoming where lakes are many miles
into the backcountry. In some rugged
areas, the lakes chosen for sampling
were in trailless basins surrounded by
sheer cliffs. In the Cloud Peak
Wilderness in Wyoming, for instance,
(lie Forest Service contracted with a
mountain climbing group to get to some
uf the lakes.
In each instance, the, object nf
the quest was a gallon jug of
water!
Teams usually included two
samplers someone who knew the area,
and either a hydrologist or fisheries
biologist—along with a horse wrangler
and the runners. If the team had to hike
in. more helpers, dubbed "sherpas" after
the famed 1 limalayan mountain
climbing "porters," packed in 152
pounds of sampling equipment,
40-pound rubber rafts, "dry suits" (worn
to keep from getting wet), and personal
gear.
Samplers had to take a raft to the
middle of each lake, find the deepest
part (using a line with a weight on it),
and lake samples from a depth of five
lent. Once collected, tin: water sample
was transferred to a plastic container. In
addition, two small amounts of the
sample water—one for testing pH and
line to test for dissolved inorganic
carbon content—were drawn from the
sample by syringe and put in separate
containers. This method prevented
contamination from contact with the
atmosphere. The samples were
transported in coolers loaded with
fro/en gel packs to keep them cool.
The timing was critical. "We had to
sample when each lake, was
isothermal—when it had a uniform
temperature—so we could get a
thoroughly mixed sample," Slender
explains. High mountain lakes are
warmer near the surface in the summer
but in the fall they "turn" as surface
water cools and begins to sink until the
lake is one temperature top to bottom.
Samples had to be taken alter turnover
but before freeze-over.
An HP A contractor determined that
the correct "sampling window" for the
mountainous areas was a week-long
period, except for the weather.
Winter came early last year, tree/.ing
many lakes in the Rockies and the
Sierra Nevada and sending snowstorms
whipping through Montana, Wyoming.
and Utah. "We hit snow conditions in
every place," Slender recalls. "The
weather was just terrible."
Bob Hurley, Ashley National Forest
fisheries biologist, rode horseback 18
miles in the rain his first day into the
High Uintas Wilderness area. The rain
turned to snow at night. After sampling
six Uinta lakes, Hurley and three other
Ashley employees went to the Wind
River Range in the Bridger Wilderness
in Wyoming and promptly hit another
snowstorm. "It was so cold on the lake
that when we'd take a sample out of the
bottle, the last couple of drops would
immediately freeze," Hurley remembers.
His raft blew up just before he sampled
his last lake. "But only one of the three
compartments was ruined. We had our
dry suits and life preservers so we went
out on the lake anyway."
On the eastern side of the Wind
Rivers, one crew had to slide rafts
out onto the thin ice of a just-frozen
lake, walking alongside, ready to jump
in if the ice broke. In contrast, on an
unfrozen lake, another crew
encountered waves up to three feet high
with a force which broke paddles.
"It was an ocean experience." Skip
Shoutis of the Shoshone National Forest
told a Wyoming newspaper reporter.
"We thought the ice was much more
fun."
"A lot of people were tested to
the limits of their endurance.
But they went in there and did
it." —Pete Stender.
The teams faced still other hazards.
One horse rider carrying a sample out of
the Wind Rivers encountered a bear at a
creek crossing and lost half the water
when his horse spooked. And in the
Selway-Bitterroot Wilderness in
Montana, a supply packer enroute to a
.sampling crew was knocked out when a
moose disrupted his string of horses.
Thirteen lakes wen; either frozen or
inaccessible in his subregion. but
Stender notes that the wilderness crews
still were able to give EPA a reasonable
sample.
As an extra by-product, participation
in the study gave national forest
officials important information on how
they organize and communicate.
"A lot of people were tested to the
limits of their endurance. But they went
in there and did it," Stender said. "1
look at the spinoff benefits as probably
just as valuable as that jug of water.
And it was great for morale." 'J
EPA JOURNAL
-------
Communicating Risk
To a Concerned Public
by Milton Russell
l-.'f'.A's d' uce lend in
line will help protect liuoii
thousands »i children fron
•:nint:. Vet tilt- .Alii' :il>h'(
ly took notice of the si
decision.
(Earlier tin's year. Milton Russell, EPA
Assistant Administrator for Policy,
Planning and Evaluation, spoke to
network news directors and reporters at
the Columbia School of Journalism on
Reporting of Health Risk Information by
Television. The following article is
adapted/rom that speech.)
Risk communication is the most
important problem in environmental
protection this country faces.
Real people are suffering and dying
because they don't know when to worry
and when to calm down. They don't
know when to demand action to reduce
risk and when to relax because risks are
trivial or even nonexistent.
The nation is operating on worry
overload. Some people react with
free-floating anxiety; others, with
defensive indifference. Why bother to
wear seatbelts, reduce indoor radon, or
stop smoking if everything causes
cancer anyway?
But anxiety and stress can themselves
be public health hazards. And worry
focused on phantom or insignificant
risks can divert attention, money, and
effort from real risks that can be
reduced.
The key is to pick the right worries
and the right actions. Unfortunately,
when it comes to health and the
environment, we don't do that very
well. The government and media
together have failed to communicate
clearly what is a risk and what is not a
risk.
Categories of risk include non-fixable
risks that can never be substantially
reduced, such as cancer-causing
sunlight or cosmic radiation and fixable
risks, some big and some small. More of
these fixable risks exist that can ever be
successfully attacked, so choices must
be made.
When it comes to risk reduction, the
outcome should be to get the most
reduction possible, taking into account
that people fear some risks more than
others. This means we should
concentrate on the big fixable targets,
and leave the others until later or, if
necessary, until never.
Risk communication comes into play
because citizens ultimately determine
which risks government agencies attack.
They do this through the statutes and
budgets their elected representatives
pass, and they do it through public
opinion. If citizens misjudge risk, their
orders still come through, and the
government machine still delivers, but
the results don't necessarily leave
people better off.
Let's imagine risk reduction as
-------
against deadlines, striving to explain
complicated issues, seeking to capture
an audience, they present the news of
the day. Based on those presentations,
consumers of the news decide to buy
the news or not. use it or misuse it, and
change their behavior or demand that
public, officials change theirs.
There is sometimes an alarming
disjoint between the actual risk
information on which we act, and the
perceptions of risk that are fed back to
us bv citi/ens. Take, for example, public
reaction to two recent environmental
issues: lead in gasoline and at-sea
incineration.
To EPA, lead in gasoline posed very
big risks- risks of learning disabilities,
mental retardation, and worse—to
hundreds of thousands of children. I
rank EPA's decision to reduce lead in
gasoline as Ibe most significant
protective action the agency has taken
during my tenure here. But the public
reacted to the issue with virtual
indifference.
On the other hand, citi/.ens threatened
to lie clown bodily in front of trucks
and blockade harbors to stop EPA's
proposal to allow final testing of
incineration-at-sea technology. This
reaction occurred despite every
indication that the risk involved was
small, and that the technology might
replace more risky alternatives now in
use.
Why such imbalance?
Ironically, part of the reason is
because the people involved in
communicating information did their
jobs too well. They accomplished their
objectives. Unfortunately, their
objectives didn't include effective
communication of risk.
The professionals at EPA—the
manufacturers and wholesalers—insist
on being precise in the statements they
deliver. Their job is to present a
scientifically defensible product, so they
add qualifiers and use scientific terms.
Then the; journalists who retail the
20
statements to the public; have to
translate them to make them
understandable. The journalists also
have to restructure the statements so
they will be short, so they will sell,
compete with other messages for air
time, and win the attention of viewers.
The result? A misunderstanding of
actual risk.
Public attention often doesn't
have much to do with level of
risk.
Let's put the problem in focus. Here is
one paragraph from a recent EPA news
release, with the chemical names
changed.
The draft notice of intent to cancel
action is based on lifetime animnl
feeding sludies which showed that
dinitrachickenwire caused
carcinogenic effects in mice and
rats. This pesticide also
metabolizes or breaks down into
1,1-dimethyl double death fUDDDJ
in the presence of water and acid
pH levels. UDDD a/so has been
shown to be carcinogenic; in
animals. Residues of both
dinitrochickenwire and UDDD are
found in nnv agricultural
commodities and processed food.
How would a journalist translate this
for readers or viewers? Probably
something like this:
EPA announced today (hat it is
about to pull yet another
cancer-causing pesticide off (he
market. The pesticide is now
found in pears, avocados, and
kiwi fruit.
On TV, if time allowed, the picture
would probably then cut to a grocery
fruit bin, with a voiceover from an
"expert." Depending on what side of the
issue the expert was on, he or she might
contend either that "EPA was derelict in
not acting sooner," or that "EPA was
destroying American agriculture." There
would almost certainly be no time for
evaluating the qualifications or special
interests motivating that spokesperson.
Whatever viewers take away from the
program, it won't be an understanding
of the uncertainties of the science, nor
of the fact that EPA errs on the side of
protection. Nor will they understand
that the risks are chronic, not acute.
with the EPA decision based on
extrapolating a lifetime of exposure.
They certainly won't have any sense of
how much this pesticide, if it causes
cancer, adds to the 450,000 cancer
deaths that already occur each year.
And they won't know that eliminating
to the point of detection all such
man-made chemicals in the
environment would have little impact
on that total.
In short, they won't take away any
sense of perspective, whether to worry
or whether to calm down. And they
won't take away any sense ol
confidence that the message is reliable,
that it is honest and based on the best
judgment science can offer.
When citizens understand a risk, and
the cost of reducing it, they can
determine for themselves if control
actions are too lax, too stringent, or, like;
Baby Bear's porridge, "just right." But
too often such understanding remains
out of reach. Three examples illustrate
this point: EDB, indoor radon, and
uranium mill tailings.
EDB should have been a good news
story. A pesticide in use for 30 years
was found to present a chronic; risk: the
risk was removed; and people were
safer.
Instead, EDB was a disaster story. The
media featured pictures of muffin mix
with skull and crossbones
superimposed. State after state started
pulling food off the shelves, in some
cases sending out squad cars to do the
job.
EPA JOURNAL
-------
Hurnini; Mu/urdoiis ivusto on
mrinrrcilion ships (it sen i-
ronfrovrrsidJ issue involving (lie
question o/' hoiv to romiiiimiVritc cx.tuul
risk.
Agency scientists were saving,
essentially, "EDB isn't good for you. but
it's not an acute threat either." But the
country, getting the message about EDB
risk from news reports, panicked.
Perspective came finally when one
credible voice, Bill Ruckelshaus, went
on national TV and told people why, in
understandable terms, they should calm
down.
In this case. EPA did its own
retailing—and had the communicator
who could do the job. But, until that
happened, much anxiety and economic
loss was suffered unnecessarily,
As for radon, three facts tell the
essence of the story:
• A reasonable estimate of annual
deaths caused by naturally occurring
radon in homes is 5,000 to 20,000 per
year; some estimates go as high as
30,000.
• Some homes show estimated risks as
high as would be posed by smoking
over 100 packs of cigarettes a day.
• Calculated risks from spending less
than an hour in some
radon-contaminated homes is equivalent
to that of a li/efime of exposure to
citizens most at risk from PCB
incineration at sea.
People panicked over EDB. They
dread at-sea incineration. Yet, the story
of indoor radon, which potentially
presents much graver risks, plays very
differently. Public attention often
doesn't have much to do with level of
risk.
The story of uranium mill tailings
makes a similar point. EPA risk
assessments show that, due to escaping
NOVEMBER 1986
radon, uncovered mill tailings piles will
cause about 600 cancer cases per
century, or about six per year. EPA
promulgated regulations that required
covering the piles with about eight feet
of earth to reduce risk by about 95
percent, or to one case of cancer every
three years. Estimated exist of
implementing the regulation was $390
million.
Environmental group reaction was
intense. EPA was severely attacked for
not requiring seven more feet of dirt, at
an additional cost of $180 million, to
reduce the risk to one case of cancer
every 30 years.
We ut EPA need to speak
more clearly, and journalists
need to listen more critically.
To put the issue in perspective,
remember that indoor radon causes
5,000 to 20,000 deaths a year, and
uncovered uranium mill tailings piles
cause six deaths a year.
These cases demonstrate to me that
the risk message is not getting through
to people who need to know when to
demand action and when to calm down.
The answer is not to communicate more
information, but more pertinent
information.
We at EPA need to differentiate the
risk information we distribute to our
two major consumers: the scientific
community and the public. Talking
among ourselves, to other scientists, and
to professionals who use and monitor
our work, we speak in scientific
niceties, complete with caveats and
uncertainties. Unfortunately we use the
same words to communicate through
the press to the public.
Journalists don't need those words.
Instead, they need three pieces of
information that rarely come through
clearly: How big is the risk? What is
being done about it? What will it cost':'
This is the kind of information that
would enable citizens to put risks in
proper perspective, to judge whether
that extra seven feet of dirt makes sense
or not.
To make matters worse, our
statements often have no sense of
history. We fail to convey that, while
today's risk may be important.
yesterday's risk may be more important,
and may still need sustained media and
public interest. The result is the
Chemical of the Week Syndrome, where
the immediate drives out the important.
It needn't be this way. We at Kl'A
need to speak more clearly, and
journalists need to listen more critically.
so they can evaluate and transmit the
significance of the message.
Stories about risk should he no
different from others on which daily
news judgments are made. I recognize
that every risk story that comes across
the desk is going to be carrying
emotional flag words like "cancel'" or
"birth defects." Nevertheless, 1 still
believe it is possible for the media to
weigh and deliver information on
environmental and health risks
-------
Taking Steps
To Control
Wood Stove Pollution
by Roy Popkin
The picturesque chimney smoke; that
rises from millions of wood stoves
and fireplace inserts in American homes
has become an environmental health
threat akin to pollution from industrial
smokestacks.
New EPA regulations, to be proposed
early in 1987. are designed to sharply
reduce the emission of pollutants from
wood stoves used for heating and
cooking in private homes. Although the
new regulations will apply only to units
manufactured after July 1. 1988, or sold
after July 1, 1990. it is hoped that over
the next 15 years the 800.01)0 new wood
stoves sold each year will gradually
replace most of the 12 million older,
dirtier models now in use.
Prior to the mid-1970s, wood
stove-generated smoke pollution was
liy I9ti(), wood stuvv so/as
n;m:/)«r/ two million a your.
not considered a serious problem in the
United States. At the beginning of that
decade, perhaps two percent of
American homes burned wood as u
primary heat source. Hut the sharp
increase in fuel prices led to widespread
interest in alternative heating
sources such as wood, especially in
parts of the country where wood was
cheap and plentiful. By 1980, wood
stove sales reached two million a year.
and the number in use is growing by
hundreds of thousands annually.
While use of the "old fashioned"
devices provided relatively inexpensive
heat, in some parts of the
country- notably heavily wooded areas
of New England, the Rockies, the
Southwest, and the Northwest—they soon
became a major source of pollutants and
drew the concern of environmentalists
and governmental agencies.
The three main air pollutants
generated by wood stoves are participate
matter or "total suspended participates"
(TSP), carbon monoxide (CO), and
polycyclic organic matter (POM), which
are unburnt residues containing
carcinogenic substances. EPA monitors
national emissions of TSP and CO
because they are two of the six criteria
pollutants for which EPA has set
National Ambient Air Quality
Standards. The Agency estimates that
wood-burning stoves and fireplace
inserts produce over 15 percent of the
particulates and as much 40 percent of
the potentially cancer-causing POMs
nationwide.
The wood heaters now in use account
for about 2.5 million mogagrams (about
2.75 million tons) of particulate matter
annually. "Airtight" wood heaters also
account for most of the POM emissions
from stationary sources. Without
regulations, EPA experts estimate that
particulate emissions would increase at
a rate of about 121,000 tons annually,
but under the proposed rules would
increase by only 31.000 tons per year.
As concern about wood stove air
pollution grew. Oregon and Colorado
developed regulations for new
wood stoves. A number of communities
either banned wood heaters or put
limitations on their use. Other states
such as Maine, Vermont, Massachusetts,
and Washington are considering
legislative actions.
In August 1985, after considering the
problem of pollution from wood stoves
for about a year, the Agency announced
its intention to propose national New
Source Performance Standards (NSPS)
for wood stoves. Two articles which had
appeared side by side in the April 1985,
edition of EPA Journal began to seem
prophetic. One, by Tom Super of the
EPA Office of Air and Radiation, told of
the growing concern about wood
stove-related air pollution. The next
article, by EPA 'management consultant
Cynthia Croce, told of the Agency's
experiments with negotiated
rulemaking, a process which, she wrote,
"brings the parties together to air their
concerns and resolve conflicts in
face-to-face negotiations before the
proposed rules are published. The
desired end-product is consensus on all
key issues." Super's article pointed to
the problem; Croce's, to a method of
resolution which, subsequently, was
applied to that problem.
After EPA published its intention to
develop the rules, pressures from
manufacturers on one side and
environmentalists on the other made it
appear that a negotiated regulation
process was the way to go. After
consulting with individuals and groups
that would be affected by the standard,
a "reg neg" committee was established
under the Federal Advisory Committee
Act to work out agreed-upon standards.
The committee included representatives
of EPA, state agencies, manufacturers of
wood stoves, environmental and
consumer groups, catalyst
manufacturers, and testing laboratories.
The committee met for six two-day
sessions starting in March 198(i.
Differing viewpoints and concerns that
might otherwise have been argued in
the news media or protracted lawsuits
were hashed out across the table and
fashioned into an agreement by the
committee at its final meeting on
August 21.
Commenting on the process in an
interview with the Washington Post,
David Doniger, senior attorney for the
Natural Resources Defense Council, said
the Council agreed to forgo some
provisions it favored in the interest of
time. "By agreeing on a standard two
years ahead of schedule, we will
include over one and a half million
stoves sold during that period that
otherwise would not have been
covered," he said.
EPA JOURNAL
-------
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KP.\ rrgulfjtioiis u ill propose slmrp (ills
in fir: -i;m ivond s( i
manufactured after
The proposed regulations apply only
to new, not existing, wood heaters, hut
gradual replacement of those now in use
will eventually reduce the amount of air
pollution emitted by wood stoves, EPA
believes. Although the rules set
emission limits only for participate
matter, the required catalytic converters
or secondary combustion chambers also
reduce the amount of carbon monixide,
POM, and other pollutants found in
wood smoke.
The proposed standards control
particulate emissions from wood heaters
manufactured after July 1, 1988, or sole!
after July 1, 1990. Stricter limits will be
in force on July 1, 1990, for heaters
manufactered after that date or sold
after July 1, 1992. Small manufacturers
producing less than 2000 heaters a year
will have an extra year in which to
comply with the first phase standard.
The standard applies to virtually all
kinds of "airtight" wood stoves or
fireplace inserts made for home use. It
does not apply to open fireplaces,
boilers, and furnaces, nor does it
include wood-burning industrial
equipment.
Units now in use release about 30-35
grams of particulates each hour,
depending on their efficiency and how
their owners operate and maintain
them. The new regulations would
require reducing the emissions to 5.5
grams per hour for catalytic burners and
8.5 per hour for noncatalytic: ones
manufactured after July 1, 1988, and 4.1
and 7.5 grams per hour, respectively.
beginning July 1, 1990. Although the
stoves with catalytic converters will
initially emit less pollution, omissions
will increase over time due to the
"The new rules will reduce air
pollutants from wood stoves
significantly and should result
in net savings to
consumers."—}. Craig Potter.
catalyst wearing out. Catalysts must be
replaced periodically to maintain high
efficiency and low pollution.
When implemented, the standard
would require a certification program
under which the manufacturer submits
a sample heater to an EPA-accredited
laboratory for testing. Model lines
which have been certified by the Oregon
Department of Environmental Quality
and which meet minimal bum rate
requirements may be certified by EPA
(for the 1988 standard) without further
testing.
Certification records would be
reflected in labels on all new wood
heaters offered for sale, and would be
used by enforcement personnel to
determine compliance status. Purchasers
would use temporary labels to make
comparisons in emissions and
efficiency, and to compare heat output
in much the same manner as home
appliance buyers can now compare
labels indicating the items' energy
consumption. Further, quality assurance
programs would be required of
manufacturers, and retailers would be
required to keep records of the names
and addresses of individual purchasers.
EPA estimates that the new stoves
and fireplace inserts will cost Si0(1-5250
more than conventional stoves, it will
cost about $75 to replace the catalytic
combustors (honeycombed ceramic
chambers containing the catalyst). These
combustors will have to be replaced
about every 10.000 operating hours.
According to EPA Assistant
Administrator for Air and Radiation |.
Craig Potter, "The new rules will reduce
air pollutants from wood stoves
significantly and should result in net
savings to consumers." Because of the
clean burning of the new units, this
savings should be realized over the life
of the device if it is properly maintained
and operated. In fact, most methods of
controlling wood stove emissions save
money for the owners. Less wood is
burned for the same amount of heat.
Less creosote builds up in the
chimneys. This means less frequent
chimney cleaning and could mean lewe.r
chimney fires. To help assure savings
and cleaner air, EPA plans to promote
the proper use of the heaters.
When the prospective savings for
wood stove owners are added to the
potential savings in environmental and
health costs, the net social savings have
been estimated as high as $29 million
dollars annually, o
NOVEMBER 1986
23
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Update
A review of recent major EPA activities and developments in the pollution control program areas
HAZARDOUS WASTE
Waste Reduction
EPA said that a survey of 22
industrial processes
indicates that industry has
the potential to reduce the
amount of hazardous wa..;e it
currently produces by
one-third or more.
J. Winston Porter. EPA's
Assistant Administrator for
Solid Waste and Emergency
Response, said, "EPA found
that industry has significant
potential to reduce public
health and environmental
risks by minimizing its
hazardous waste production."
He further stated that "as a
result, KPA will encourage
industry to find ways to
reduce both the volume and
toxicity of its waste ..."
The; Agency also said in its
report to Congress that it
would develop the first
national data base on
hazardous waste reduction
techniques and that it would
also provide technical
assistance to help companies
achieve waste reductions.
PESTICIDES
Ban on Dinoseb
Administrator Lee M.
Thomas has ordered the
immediate emergency
suspension of all uses of the
pesticide dinoseb because of
the risks posed by exposure
from field application.
The Agency estimates that
as much as 25 percent of the
total annual usage of dinoseb
would occur during field
applications. As many as
25,400 workers (including
1,300 females) could be
occupationally exposed to
dinoseb during this period.
Approximately 45,000
workers are exposed
throughout the entire year.
Administrator Thomas
stated that "exposure to
dinoseb during or shortly
after field applicaton poses a
very serious risk of birth
defects to the unborn
children of pregnant women,
particularly if exposed during
the early stages of the
pregnancy." Thomas also
stated that "dinoseb exposure
from field application may
also pose a risk of sterility for
male workers."
Restrictions on Dinocap
The agency has proposed
numerous restrictions on the
continued use of the
pesticide dinocap in order to
reduce the health risks to
workers who mix, load, and
apply this product.
EPA began a special review
of dinocap in January 1985
based on laboratory tests that
showed that the pesticide
causes birth defects in
rabbits.
Some of the proposed
restrictions include requiring
enclosed cabs for applicators
using ground boom, air blast,
and mist blower equipment;
and requiring applicators,
mixers, and loaders to wear
long-sleeved shirts and long
pants; in addition,
mixer/loaders must wear
chemical resistant gloves,
and applicators must wear
chemical resistant gloves
when exiting the cab and
working on the equipment.
WATER
New Wetlands Office
Stressing the importance of
saving the natural resource of
wetlands, EPA Administrator
Lee M. Thomas announced
the creation of a new Office
of Wetlands Protection in the
Of I ice of Water. The wetlands
program had been
administered by a division in
the Office of Federal
Activities, under EPA's
Assistant Administrator for
External Affairs. Thomas
stated that elevating the
program from division to
separate office status will
"result in enhanced attention
to wetlands matters. The
program will benefit from the
technical expertise and
strong enforcement
capabilities of marine,
estuarine and ground-water
protection programs ongoing
in the Office of Water."
Wastewater Treatment Plants
Administrator Lee M.
Thomas honored six
wastewater treatment plants
in cities throughout the U.S.
with outstanding
performance awards.
The awards were given to
six cities whose wastewater
treatment facilities were
outstanding in 1985 in
operations and maintenance,
compliance with government
pollution standards, and
commitment to clean water.
Thomas stated, "what sets
these six operations apart is
their 'do-it-yourself attitude.
In many cases, these
operators and their staffs
have gone beyond their
normal duties to adopt
innovative practices, fix old
equipment, and get approval
for needed facilities."
This is the first year that
awards were presented. EPA
plans to make this an annual
event.
The following cities
received awards:
Kokomo, Indiana
Statesboro, Georgia
Spearfish, South Dakota
Albuquerque, New Mexico
East Providence, Rhode
Island
Hebron, Nebraska a
Appointments
Robert S. Cahill has been appointed to
the position of Associate Administrator
for Regional Operations.
He previously served in that position
in an acting capacity; prior to that he
was a special assistant in EPA's Office
of the Administrator/Deputy
Administrator. Prior to EPA service, he
was an assistant to William D.
Ruckelshaus and to the vice president
for public affairs at the Weyerhaeuser
Co. in Takoma, Washington.
He received his B.S in civil
engineering in 1972 and his MBA in
1975 from the University of
Washington.
Richard E. Sanderson has been named
Director of EPA's Office of Federal
Activities.
He has previously served as Associate
Assistant Administrator, Acting
Assistant Administrator, and Deputy
Assistant Administrator in EPA's Office
of External Affairs. Sanderson brings
with him a wide range of government
experience. He has served at the Federal
Emergency Management Agency, the
Department of Housing and Urban
Development, the Executive Office of
the President, the Philadelphia regional
office of Emergency Preparedness, the
Philadelphia regional office of Economic
Opportunity, and the Headquarters
Ground Electronic Engineering
Installation of the U.S. Air Force.
He received his bachelor's degree
from Harvard in 1958.
24
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Along (i country mud. Maryland, )!)()).
Back Cover: At home on the ivnfcr.
1'hofu ln- Ron C.'olhroth, FoJfo. Inc.
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