iv. transport, fate, and monitoring research - princeton

IV. Transport, Fate, and MonitoringResearch

IV. Transport, Fate,and Monitoring Research

1.

2.

3.

4.

5.

6.

7.

ISSUES LIST

ABSENCE OF INTEGRATED MONITORING RESPONSIBILITY . . . . 53Monitoring activities appear widely dispersed throughout ORD with nocomparability of methods, or quality assurance.

MONITORING SCREENING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . 54The current monitoring program may not be capable of detecting cer-tain toxic materials.

IN-STREAM BIOLOGICAL MONITORING . . . . . . . . . . . . . . . . . . . . . . . 57Current research monitoring efforts emphasize physical and chemicalmonitoring technology and neglect in situ (in-stream) biologicalmonitoring methods whose use was mandated by Congress whereverappropriate.

MEASUREMENT OF AMBlENT AIR QUALITY. . . . . . . . . . . . . . . . . . . . 57The EPA’s assessment of the hazards associated with the criteria pollut-ants other than CO are subject to question because the analyticalmethods prescribed by EPA for measuring ambient air quality yield, inmany cases, only indices of air pollution levels rather than concentra-tions of the actual pollutants whose control is being sought.

STANDARDIZATION OF ANALYTICAL TECHNIQUES FOR MONITOR-ING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58Improved measurement techniques and uniform analytical proceduresare needed.

SOURCE-EFFECT COUPLING MECHANISMS . . . . . . . . . . . . . . . . . . . . 60ORD may assign too low a priority to research into the complex of proc-esses that link source emissions and their effect on the biosphere.

GLOBAL BACKGROUND POLLUTANT CONCENTRATIONS . . . . . . 61International sources of many pollutants will loom increasingly impor-tant as controls within the United States become more effective and asindustrialization increases in the rest of the world. Significant pollu-tants carried by wind or water must be evaluated and background levelsmust be monitored in anticipation of ultimate international efforts tocoordinate controls.

49

Transport, Fate, and Monitoring Research

8.

9.

10.

11.

SPECIFICITY OF RESEARCH AND REGULATION . . . . . . . . . . . . . . . 62Ecosystems should be characterized in sufficient detail to accommodateregional variation in the potential impacts of pollution.

ALASKA ENVIRONMENTAL IMPACTS. . . . . . . . . . . . . . . . . . . . . . . . . . 64Is the involvement of EPA/ORD in Alaska sufficient to safeguard theenvironmental quality of this large and diverse State?

WATER TREATMENT AND FATE OF EFFLUENTS . . . . . . . . . . . . . . . 65Expanded and redirected research into control of wastewater effluentsand treatment of drinking water supplies is needed.

RECREATIONAL WATER STANDARDS . . . . . . . . . . . . . . . . . . . . .. ...68Expanded research into the question of tolerable pathogenic concentra-tions in primary contact recreational waters is desirable.

50

IV. Transport, Fate,and Monitoring Research

INTRODUCTION

Rational regulatory action for control of apollutant depends on an understanding of theways in which pollutants are transportedthroughout an ecosystem and how theychange or combine with other substances tobecome more or less troublesome.

Monitoring research is necessary to detectand document the movement and transforma-tion of pollutants. This broad field of studycombines two other large areas of EPA/ORDresearch: the control of sources, on the onehand, and the health of humans andecosystems, on the other hand.

Before discussing specific issues, a generalconcern should be noted. A substantial por-tion of the research on the transport and fateof pollutants and on ecological effects is con-t a i n e d w i t h i n t h e e n e r g y - r e l a t e dsubprograms. The importance of energy andenergy-environmental research is clearlyrecognized and not at issue here. However,the Office of Research and Development(ORD) Plan does not adequately reflect theclose ties that should exist between ad-ministratively separate, but scientifically simi-lar research. The fragmentation of theseefforts in the Plan hindered assessment of theoverall content and thrust of research on thetransport and fate of pollutants.

The review of the transport, fate, andmonitoring elements of the ORD 5-Year Planraises issues regarding monitoring andmeasurement technologies, research initia-tives, specific ecosystems, and water research.

Monitoring and MeasurementTechnologies

The results of diverse studies within EPAmust eventually be combined to set standardsand to forge the control strategies to imple-ment the standards. This requires a centrally

coordinated and technically strong monitor-ing effort beyond the apparently fragmentedresponsibility existing within ORD. (Issue 1)

The ORD Research Plan suggests the ab-sence of an adequate screening program todetect toxic materials singly or in combinationin air and water. A broad monitoring-screen-ing program will help avoid the “pollutant ofthe month” syndrome. (Issue 2)

In the ORD research monitoring program,physical and chemical techniques areemphasized to the neglect of biological needs.Neither biological monitoring research norguidelines to discharges on effective biologicalmonitoring are projected in the ORD Plan.(Issue 3)

EPA’s methods to analyze air quality at-tempt to define air pollution levels and notpollutant concentrations. Further research isneeded to develop analytical tools for themeasurement of specific hazards not currentlybeing researched. (Issue 4)

The variety and number of identified pollu-tant substances are steadily increasing. Ac-countability for analyzing these new sub-stances is fragmented; new methodologies re-quire extensive time for acceptance; and stand-ards for technique acceptance are ill defined.(Issue 5)

Research Initiatives

Rat ional control s t ra tegies requireknowledge extending beyond ambient levelsof pollutants and emissions and their precur-sors. It also is necessary to understand theprocesses of dilution, transport, transforma-tion, and removal that determine human andecosystem exposure. Complex interrelation-ships are involved; thus, the research cannotbe effectively performed in “bits and pieces.”Since results strongly influence the develop-

51

—


ment and enforcement of regulations, suchresearch deserves high priority withinEPA/ORD. (Issue 6)

While pollution is often thought of in localor regional terms, it is also a global problem.To determine how global concentrations mayaffect us, it is necessary to have a fuller under-standing of the global movement of pollu-tants. For example, EPA does not allow thesale of DDT in this country, yet significantquantities could enter this country through at-mospheric circulation. (Issue 7)

Specific Ecosystems

Regional environmental concerns in studiesof the transport, fate, and effects of pollutantsdeserve stronger support. It may be helpful todevelop a taxonomy of ecosystems and, atleast, undertake studies of the most criticalones that may not be covered by moregeneralized ORD studies. (Issue 8) “

The ORD research Plan, while enumeratingthe environmental studies being carried outby several agencies in Alaska, does not indi-cate that EPA is coordinating efforts so theState’s environmental research needs arebeing thoroughly met. (Issue 9)

Water Research

M a n y b a s i c q u e s t i o n s r e l a t i n g t owastewater treatment and protection of watersupplies remain unanswered. The EPA Planpresents research approaches andbut they are not assigned prioritiesthe scale of effort or the perceivedof potential health risks. (Issue 10)

The ORD Plan to examine

programs,in terms ofmagnitude

tolerablepathogenic concentration in primary-contactrecreational waters is too limited. Theprogram does not currently include researchon viruses and other parasites. Since PublicLaw 92–500 stresses such research, theprogram warrants expansion. (Issue 11)

52

IV Transport, Fate,and Monitoring

ISSUES

ABSENCE OF INTEGRATEDMONITORING RESPONSIBILITY

Issue 1

Monitoring activities appear widely dis-persed throughout ORD with no provision forcentralized responsibility for accuracy of data,comparability of methods, or qualityassurance.

Summary

ORD’s Office of Monitoring and TechnicalSupport has responsibility for establishingFederal reference methods used in pollutantsampling and analysis, and for the engineer-ing development of new systems. Otheroffices are engaged in a wide variety ofprograms in which monitoring of pollutantl e v e l s p l a y a c e n t r a l r o l e , s u c h a sepidemiological studies of human healtheffects, emissions inventories, air- and water-quality model development, and trendanalysis of ambient pollutant levels.

The results of such diverse studies musteventually be combined to set standards andto forge the control strategies to implementthe standards.

The ORD Plan contains no provision to in-sure that the procedures and methods used inmaking these measurements will yield datathat are accurate and comparable. To the ex-tent these results are not comparable, controlstrategies cannot be designed with confidencethat allowable emission levels are neitheroverly stringent nor too lax.

Questions

1. Under current priorities and organiza-tion, what level of effort and what mecha-

75-387 0-76- 5

nisms

Research

are directed toward coordination andquality assurance in ORD’s monitoring ac-tivities?

2. Is this level of effort commensurate withthe critical nature of the problem?

3. How does the present organizationalstructure provide a means, formal or infor-mal, to insure that monitoring of activities andquality assurance are well coordinated ORD-wide? Agency wide?

4. How would the Agency respond to arecommendation that the currently frag-mented monitoring and quality assurance ac-tivities throughout the EPA be brought underthe direct control of a single, strong, properlyfunded central office within ORD?

5. How would the Agency respond to analternate recommendation that a centralauthority within ORD oversee and coordinatethese activities?

Background

The original organization of the Agency(1970) established the monitoring function asa major effort of the Agency’s Science Office.Subsequent policy review of the monitoringfunction in 1972 resulted in a new concept ofmonitoring and assigned responsibility forvarious aspects of monitoring to the in-dividual program offices. The Office of En-forcement and General Counsel was givenresponsibility for case preparation or com-pliance monitoring; i.e., monitoring which isundertaken to gather technical evidence for aspecific case, hearing, or other form of litiga-tion. The Offices of Air, Water, andCategorical Programs were given respon-sibility for ambient monitoring; i .e. ,monitoring which seeks to establish long-range environmental baselines against whichchanges can be measured.

53


Air pollution: industrial gases belching from a steel plant in Houston, Texas

The Offices of Air, Water, and CategoricalPrograms were also given responsibility formonitoring specific sources in all media tomeasure point discharges. The Office ofResearch and Monitoring (ORM) was givenresponsibility for research monitoring; i.e.,monitoring required in basic research experi-ments. Research monitoring, as defined,would be the smallest portion of themonitoring activity and of the least directenvironmental importance.

An immediate result of this decision wasthe reemphasis of monitoring within ORMand renaming that office, ‘‘The Office ofResearch and Development (ORD). ” Por-tions of the monitoring function left within

ORD, i.e., research monitoring, are furtherdispersed throughout ORD, and are not con-trolled or coordinated by the Office ofMonitoring and Technical Support. There isno center of cross-media monitoring expertisewithin the Agency.

MONITORING SCREENINGPROGRAM

Issue 2

The current monitoring program may notbe capable of detecting certain toxic materials.

54


Water pollution: industrial wastes pollute a salt marsh in Middleton, Rhode Island Regulationsrequire industry to obtain permits to discharge Into water supply outlets.

55


Summary

A monitoring screening program to detectundiscovered toxic materials in air and wateris needed. There are few Federal agenciessystematically testing a modest number ofsamples of polluted air and water to detect themyriad of toxic compounds which may befound in them, and assigning priorities tothose needing most urgent attention. (An ex-ample is the National Cancer Instituteprogram to screen 500 compounds for car-cinogenicity.)

A broad screening program would greatlyhelp EPA in identifying new pollutants of ma-jor concern. The program could be conductedby EPA and coordinated with other Federalagencies. At present, one of the major barriersto this program is the difficulty in obtaininginformation from industry on the nature andquantity of toxic materials which they release.

Questions

1. What monitoring research program at-tempts to detect all toxic pollutants of majorconcern present in the environment?

2. If such a program exists, how are itsfindings and predictions communicated to theORD planners for appropriate action?

3. Is new legislation required to allow EPAto conduct a major monitoring screeningprogram for toxic materials in the environ-ment, and to obtain the necessary informationon the materials in discharges?

4. How does ORD plan to collect adequatedata in relatively clean areas to compare withdata from more polluted areas? Will such datainclude information on whole ecosystems?

Background

A recent panel of the National ScienceFoundation, headed by Dr. Norton Nelson, at-tempted to develop an early-warning systemfor industrial organic toxic substances. Thepanel’s program was based on the recognitionthat there were not sufficient mechanisms foranticipating the presence of potentially toxicmaterials in the environment. The panel com-piled a list of materials, in order of impor-

56

tance, needing further study. Its work,however, fell short of the objective in partbecause of difficulties in obtaining appropri-ate information on the nature and amounts ofmajor toxic materials used in industrial pro-cesses. EPA should take responsibility for anongoing monitoring/screening program oftoxic materials in the environment. Thevarious transformations which chemicals ex-perience in ecosystems after release make itimportant to anticipate what might form inthe air or water from these emissions. For ex-ample, monitoring for the byproducts of emit-ted sulfur dioxide and nitrogen oxides couldhave been instituted long before they were ifappropriate chemical analysis of potentialtransformations had been made. Such an anti-cipatory monitoring program needs to be car-ried out by the Federal Government, not justby industry and municipalities.

The emphasis on performance standardsfor technology leads inevitably to monitor-ing for the effectiveness of pollutantremoval at the source. While some monitor-ing of ambient levels of pollutants in air andwater is conducted by EPA, the effort issmall in relation to need. There is little in-dication how EPA will determine which po-tential pollutants in the environment, otherthan those for which control levels have beenset, should be monitored. The proposedstudy of viruses in aerosols from wastewaterirrigation is useful, but many other morecritical problems appear neglected. Particularemphasis needs to be put on detecting andmeasuring in the environment:

●

●

●

●

synthetic organic compounds of potentialtoxic properties, for example, chlorinatedh y d r o c a r b o n s , p e s t i c i d e s , P C B s ,chloroform, and carbon tetrachloride,

other organics such as acrylamide,

heavy metals, especially mercury, cad-mium, arsenic, and lead in air, soil, andwater, and

viruses and other pathogens in water.

EPA will devote considerable attention inthe future to remote sensing technology anddevelopment of sophisticated automated


devices for measuring individual chemicals.While these efforts are valuable, they may beinsufficient unless coupled with a strongscreening program to determine which pollu-tants are being formed or found in the en-vironment other than already well-knownpollutants.

IN-STREAM BIOLOGICALMONITORING

Issue 3

Current research monitoring effortsemphasize physical and chemical monitoringtechnology and neglect in situ (in-stream)biological monitoring methods whose use wasmandated by Congress wherever appropriate.

Summary

Questions

1. What emphasis has EPA given thus farto in-stream biological monitoring of theeffects of pollutants on stream organisms?

2. Are guidelines available to dischargerson how to conduct the in-stream biologicalmonitoring mandated by Congress? If not,when will they be available?

Background

encouraged sampling for ambient levels ofsingle pollutants. In the case of toxic materialsw hich accum ulatc i n food chains (e.g., mer-cury, cadmium, copper, DDT), measuring thelevels of these materials in water or air givesno accurate indication of the extent they existin tissues of organisms in the affectedecosystem. The FWPCA mandates EPA to re-quire of dischargers, wherever appropriate,the monitoring of effects of their discharges onaquatic life in receiving waters, “including ac-cumulation of pollutants in tissue * * * [in]organisms representative of appropriate levelsof the food chain * * *“ (Sees. 308 and 504).

EPA proposes to continue measurement ofeffects of single pollutants in water usingsingle species in tanks. This technique doesnot adequately reflect the likely response of anorganism in a multispecies setting to a mix-ture of compounds. Hence, this technique is oflimited value. The EPA proposes to increaseresearch on pollutants in multispecies settingsin the laboratory (microcosms), which,though useful for testing of new chemicalsprior to full-scale production, does not ad-dress the need for in-stream biologicalmonitoring of effluents from existing facto-

Development of biological indicator organ-isms, in both air and water, and signs ofecosystem disturbance due to pollutant effectsalso need considerable emphasis; it is not clearfrom the Research Plan how much attentionthis area will receive. There is, for example, noindication that EPA is planning to characterizethe structure and function of ecosystems insufficient detail to develop indices or todevelop general guidelines for implementa-tion of the initial steps taken by segments ofthe Agency.

MEASUREMENT OFAMBlENT AIR QUALITY

Issue 4

EPA’s assessment of the hazards associatedwith the criteria pollutants other than CO are


subject to question because the analyticalmethods currently prescribed by EPA formeasuring ambient air quality yield, in manycases, only indices of air pollution levelsrather thn concentrations of the actual pollut-ants whose control is being sought.

Summary

The methods prescribed by EPA formeasuring criteria air pollutants are not, in allcases, specific to the air pollutants whose con-centrations are to be controlled. Additionalresearch is needed to develop analyticalmethods that measure specific pollutantswhose health effects are thought to be detri-mental and whose concentrations in ambientair may need control. ORD has the capabilityof doing this research and contributing to thedevelopment of improved techniques.

Questions

1. Do the currently prescribed analyticalmethods used to monitor concentrations ofhydrocarbons, SO2, NOx, and suspended par-ticles in ambient air really measure thesematerials? If not, what do they measure? Arebetter methods under development? If so,what hope for progress is there?

2. Is it possible to measure sulfatesseparately in current particle determina-tions? Are methods for measuring sulfatesand nitrates in the respirable size rangebeing developed?

3. All hydrocarbons are not equally reac-tive in photochemical smog formation. Canthe “reactive” species be measured as aunique group?

Background

From the time that the first ambient air-quality criteria documents were issued in1969, there has been a serious question as tothe validity of the analytical techniquesrecommended by EPA for measuring the con-centrations ofbient air. TheEPA was theprocedure as a

58

the criteria pollutants in am-first such case recognized byuse of the Jacobs-Hochheisermeasure of N02, It was found

to be inaccurate and imprecise. Since thattime, all measurements of concentrations ofcriteria pollutants in ambient air have beenchallenged.

It is well recognized that the dose-responserelationships for health effects caused by N02,hydrocarbons, oxidants, S02, and suspendedparticles have not been unequivocallyestablished by the epidemiological data in thepublic domain, This is attributable, in part, tothe fact that the determinations of the pollut-a nt conce nt ra t i ons were not accurately madeduring the studies. As a consequence, the con-clusions reached concerning the health effectsof the pollutants are vulnerable to question. Itis most important that additional research beconducted to develop better methods formeasuring individual pollutants in ambientair for future health-effect studies.

STANDARDIZATION OFANALYTICAL TECHNIQUES

FOR MONITORING

Issue 5

Improved measurement techniques anduniform analytical procedures are needed.

Summary

The variety and number of identified pollu-tant substances are steadily increasing. Theauthorities responsible for maintaining anddeveloping analytical methods are spreadthroughout EPA and other Federal agencies.In some instances, analytical methods recom-mended by one agency are unacceptable toanother agency. The introduction of improvedmethods is slow and cumbersome. The stan-dards for techniques are ill defined. A reviewprocess is needed to establish mutually accep-table present and future techniques for air,water, and terrestrial measurements.

Questions

1. What is the role of the Office of Monitor-ing and Technical Support in promulgatinguniform analytical procedures?


The pollution generated by this incinerator in south Houston Texasbecame so severe that citizen complaints and the cllosing of nearby schools forced

the local government to discont inue i ts operat ion in January 1974

The same incinerator after closlng July 1975

59


2. What is EPA’s method for stayingabreast of the rapid proliferation of pro-cedures?

3. What priority is assigned to the coor-dination of physical -chemical-biologicalmeasurements within the EPA and amongFederal, State, and local agencies?

4. Does the variety of recommendedanalytical procedures between EPA, NationalInstitute for Occupational Safety and Health(NIOSH), U.S. Geological Survey, and othersrepresent an unnecessary redundancy in themeasurement technology area ?

Background

A recent instance in which lack of reliableanalytical techniques frustrated efforts forpolicy implementation is that of photochemi-cal oxidant monitoring in southern California.The Los Angeles Air Pollution Control Districtwas using a different technique for measuringoxidants than was the State Air ResourcesBoard (ARB) or EPA, and was recording levelsof oxidant 20 to 30 percent lower than ARBand EPA. Further testing established that theLos Angeles Air Pollution Control Districttechnique, while less than perfect, was themost trustworthy. In the meantime, however,considerable confusion was generated amongthe public agencies, industrial emitters, andthe public. A means of thoroughly checkingthe validity of monitoring methods beforethey are recommended in EPA regulations,either as principal or alternative means ofmonitoring, is needed.

Needed improved instrumentation is cur-rently being introduced into the environmen-tal market. However, the administrative pro-cedures leading to acceptance of an improvedinstrument or procedure are inordinately timeconsuming, even after the technology hasbeen proven. Improved analytical methodscould be encouraged by establishing an effec-tive, rapid review for a suggested improvedtechnique. This review should not emphasizerapidity at the expense of quality.

SOURCE-EFFECT COUPLINGMECHANISMS

Issue 6

ORD may assign too low a priority toresearch into the complex of processes thatlink source emissions and their effect on thebiosphere.

Summary

The development of rational controlstrategies to reduce pollutants to medicallysafe and ecologically acceptable levels requiresunderstanding a complex web of processes.Pollutants, or their precursors, are emitted bysources and eventually affect the biosphere. Inbetween they undergo processes of dilution,transport, chemical transformation, andremoval. Thus, any strategy aimed at main-taining safe levels must properly reflect theseprocesses of change as well as ambient pollut-ant levels. Further complications followbecause variable and uncontrollable naturalconditions in the environment modify the en-tire chain of events. Regulations also fre-quently require protection for “worst case”conditions. Defining and achieving safe levelsrequires a research program which includes—

●

●

complete, integrated, and well-fundedresearch into the transport and fate ofpollutants,

assembly of results of such research foruse in control strategy development.

Questions

1. Is knowledge of the transport and fate ofpollutants adequate to define with reasonablecertainty how a change in emission levels (forexample, automotive reactive hydrocarbons)will influence subsequent achievement ofpollutant standards (for example, photo-chemical oxidant) ?

2. Is the proposed research program intothe transport and fate of pollutants strongenough and focused so that deficiencies inpresent knowledge will be systematicallyeliminated ?

60

3. Will research into the transport and fateof pollutants be related organizationally toregulatory needs so that the flow of new infor-mation permits periodic reevaluation and ad-justment of control programs?

Background

Control strategies are now being developedand applied throughout the Nation in order toreduce or eliminate adverse effects of air andwater pollutants. However, pollutants are ex-posed to an open lengthy, complex sequenceof processes which may modify them beforethey reach sensitive elements of the biosphere.

Examples illustrating the importance ofmodifying processes are readily available. Inair, formation of oxidant or photochemicalsmog is a classic case. The conversion ofsulfur-containing combustion byproducts tosulfuric acid and sulfates is another importantexample. In both instances, control to avoidadverse effects is an important need, yet isdifficult to achieve.

One approach to relating control require-ments to emissions is based on the collectionof comprehensive empirical data. Then, asemissions are reduced, the response of sensi-tive organisms can be observed. Controls canbe eased when it is seen that impacts arereduced to acceptably low levels. Such a fac-tual, direct basis for control may be an essen-tial element of any strategy. But, unfor-tunate y, this approach demands vastamounts of data unique to each air basin ordrainage. Also, some of the data obtainedwould be inexact. Therefore, an alternative,parallel approach is essential.

There is a common bond in the basicphysics and chemistry of dilution, transport,transformation, and removal that intervenebetween the emission of a pollutant to thebiosphere and its eventual deleterious effectson human health and ecological systems. Avigorous research program into this areacould produce results with general ap-plicability, and thus make best use of limitedresources. Such a program is essential becausecurrent control decisions are evolving in an


atmosphere of uncertainty. Better evidence isneeded for making the difficult choices ahead.

GLOBAL BACKGROUNDPOLLUTANT CONCENTRATIONS

Issue 7

International sources of many pollutantswill become increasingly important as con-trols within the United States become moreeffective and as industrialization increases inthe rest of the world. Significant pollutantscarried by wind or water must be evaluatedand background levels must be monitored inanticipation of ultimate international effortsto coordinate controls.

Summary

Experiences with nuclear fallout and DDThave demonstrated that significant quantitiesof pollutants can be readily disseminated byglobal atmospheric circulation. Comparablybroad distribution by means of ocean currentsis possible. As the economies of the INorthernHemisphere continue to expand, the signifi-cance of such international transport of pollut-ants will increase. International cooperationin pollution control becomes increasinglydesirable, necessitating a careful appraisal bythe U.S. Government. Moreover, it is plausibleto expect that chemicals such as DDT, whichthe EPA allows to be sold only for use outsidethe United States, may reenter the country insignificant quantities through the atmosphere.

Questions

1. What steps is the EPA taking to insurethat it has an adequate understanding ofglobal movement of pollutants, either throughits own research or through that of otherFederal or international agencies? What infor-mation exchange programs exist with othercountries in this field?

2. What steps is the EPA taking to under-stand and monitor t natural sources ofpollutants prior to setting standards?

61


and its territories, including its territorial

Background

The recent controversy over the role offluorocarbons in the destruction of ozone inthe upper atmosphere is an excellent exampleof a difficult-to-anticipate problem whichcould best be addressed by reliance on basic

waters.

SPECIFICITY OF RESEARCHAND REGULATION

research. It is also a problem which requiresIssue 8analysis of global processes of chemical

transport and transformation. To date, these Ecosystems should be characterized inareas have received little attention from EPA. sufficient detail to accommodate regionalThere are several understandable reasons for variation in the potential impacts of pollution.this. Analyses of global processes have littleapparent immediate relevance to the Agency’sregulatory responsibilities, are expensive, andseemingly overlap with the jurisdiction ofother agencies, NOAA in particular. Nonethe-less, it appears necessary that EPA take actionto insure that its specific data requirements foratmospheric, oceanic, and biosphericphenomena are met.

It appears probable that serious gaps willoccur in the data base compiled by NOAA,NSF, and DOD in these areas of researchunless the EPA undertakes its own reviews ofthe state of the art in global studies, and seesto it that the gaps are filled wherever feasible.This potential is illustrated by the record ofDDT research, in which few measures weremade of DDT in the atmosphere prior to 1970,despite the discovery through global model-ing that the atmosphere must be a majorreservoir of DDT. The lack of data was ap-parently not because of an inability tomeasure DDT in air prior to that time, butmerely a failure to attempt to assess the poten-tial magnitude of DDT transfers between en-vironmental media.

In general, a similar failure to examine en-vironmental problems in a sufficiently broadconceptual framework is present in the EPAPlan, raising the possibility of simple over-sights in current appraisals of pollutanthazards. The remedy appears to be vigorousappraisal of the fate of pollutants at several

Summary

Effective regulation of pollutants requiresappraisals of the toxicity, transport, transfer -

these sources of variation have received atten-tion, but EPA has disproportionatelyemphasized pollutant-specific phenomena.The resulting regulations have not accommo-dated regional variations and have loweredthe credibility of controls even where they arefully appropriate. Variation in the sensitivityof environments can be accommodated intoregulations by increasing the specificity of thecircumstances under which controls are re-quired. A significant step in this directioncould be achieved by increasing the specificityof the environmental distinctions alreadymade in the EPA’s regulations, such as dis-criminating between major lake types as op-posed to merely discriminating between

,not carry into regulations nor does there ap-pear to be a systematic attempt to explore therange of environmental sensitivities beforeregulations are formulated.


Questions

1. What steps has the EPA taken towardthe development of a comprehensive anddetailed taxonomy of ecosystems?

2. How does ORD select ecosystems forstudy? How does ORD plan to extrapolateresults from the limited number of ecosystemswhich it can study to the varied ecosystemswhich it cannot study?

3. What procedures are used to inventoryregional problems and establish priorities forresearch? What are examples of regionalresearch funded under these procedures?

4. To what extent does criteria setting de-pend on characterization of the environmen-tal context in which the regulations will be ap-plied? Would this activity benefit from anexpanded effort in i n t e g r a t i o n /characterization studies?

5. What efforts are made to use regionalproblems (for example, high ultraviolet radia-tion and high CO levels along the front rangeof the Rockies or air pollution in the LosAngeles basin) to anticipate effects of potentialnational problems or to determine long-termsensitivity of human populations to somepollutants?

6. Given that the need for rapid action andthe paucity of appropriate data bases mayoften limit EPA’s ability to set very specificstandards initially, what procedures mightORD and the regulatory arm of EPA jointlyinstitute to allow periodic refinement ofregulations as research progresses?

Background

Primary standards are designed to protecthuman health from direct effects of pollutants.As such, they are designed for a single targetorgna n ism ( i .e., humans) and national stand-ards for exposure to pollutants are appropri-ate. H owever, the persistence of pollutants inthe natural environment and the rate of their

dispersal vary regionally. Consequently, thehazards to humans associated with a givenrelease of a pollutant vary with time andplace. Regulations regarding the release of cri-teria pollutants should also reflect these varia-tions if they are to adequately protect thepublic without excessive use of controls. Inpractice, this means that EPA’s research andregulatory arms must use a taxonomy ofecosystems more detailed than is exemplified,for example, in the regulatory division offresh waters into lakes and streams, so thatboth research and regulation can be tailored tothe great diversity of landscapes present inthe United States and its Trust Territories.

The same arguments apply to secondarystandards, which are designed to protecthuman welfare from indirect effects of pollut -ants upon ecosystems which suppor or affecthumans in the broadest sense. Adequate ap-praisals of the potential for such impacts re-quire a discrimination among ecosystem typesat least as detailed as that implied by the dis-tinctions between coniferous and deciduousforests in the health and environmental effectssection of the research Plan, preferably moreso,

Recommendation of use of a detailed tax-onomy of ecosystems is not meant to implyeach ecosystem type be examined. Rather,usage of a richly detailed conceptual frame-work is recommended as a means for tuningthe regulatory system and extrapolatingresearch results. Nor is it meant to imply thatadjustment of standards should be only in thedirection of relaxation. Indeed, care must betaken to avoid errors arising from overrelaxa -tion of standards when there is a possibility ofdirect or indirect impact on more sensitiveecosystems. To avoid this, effects should beappraised. at levels o f biological organizationabove and below the one of regulatory in-terest. For example, regulation designed forsecondary standards requires ecosystem-levelresearch, and should consider effects at thebiosphere and population levels of biologicalorganization to obtain an adequate perspec-tive on the context in which regulations are tooperate. A sufficiently broad approach is re-quired to avoid value judgments based on a

6.3

Transport, Fate,

limited view

and Monitoring Research

of the significance of naturalecosystems, such as their utility as sources oftimber and food, while other values such asrecreation are overlooked.

ALASKA ENVIRONMENTALIMPACTS

Issue 9

Is the involvement of EPA/ORD in Alaskasufficient to safeguard the environmentalquality of this large and diverse State?

Summary

Alaska is unique among the 50 Statesbecause much of its vast area lies within arcticand subarctic ecosystems which have ex-perienced virtually no human impact in thepast. The scene is now changing rapidly.Federal lands are being apportioned to na-tives, to the State, and to the multiple Federaldesignations as a result of the Alaska NativeClaims Settlement Act, the Statehood Act, andsubsequent legislation. Pressures for acceler-ated development of Alaska’s energy andother resources are strong. EPA’s respon-sibility in Alaska is exceptionally largebecause of the immense national interest inAlaska as a source of energy and otherresources to meet national needs, because ofthe large share that all Americans hold in theextensive Federal lands in Alaska, and becauseof the high value many Americans place onAlaska’s relatively undisturbed natural en-vironment. The ORD research Plan, whileenumerating the environmental studies beingcarried out by several agencies in Alaska, doesnot indicate that EPA is coordinating theseefforts so the State’s environmental researchneeds are met. (The same holds for similar en-vironments in the northern part of the GreatLakes States and the northern Rockies.) In ad-dition, there is need for followup studies onthe environmental impacts of large develop-ment projects such as the Trans-Alaska OilPipeline. Such studies could serve as a basisfor assessing the effectiveness of environmen-

tal impact evaluations made prior to the proj-ects. Such studies coulld also assess the effec-t iveness of environmental stipulationsgoverningi construction which resulted fromthe environmental impact evaluations.

Questions

1. Is research which has been initiated toassess the effects of spilled oil in the arcticmarine environment sufficiently comprehen-sive to provide information on how a majoroilspill would influence sea ice albedo, marinefish, mammals, birds, and invertebrates? Thereference to such work in the Plan is quitevague.

2. Is EPA or the Department of Transporta-tion monitoring the environmental effects ofcommercial polar flights which are nowknown to enter the stratosphere in the polarregion ?

3. Does EPA’s monitoring program includeicefield sampling in Alaska to record long-term changes in fallout levels of industrialsource pollutants as is being done in Green-land and Antarctica?

4. Are lichen plant communities, which areessential as winter range for caribou and rein-deer, included in EPA’s program to studypollution-sensitive vegetation types? (Earlyinterests by NSF and the oil industry for sup-port of this research have waned and no com-prehensive studies have been initiated.)

5 . What program exis ts to assessthoroughly the capacity of Alaska’s rivers andstreams to sustain the increased demandsbeing placed on them as domestic watersources and effluent recipients due to the ac-celerated program to develop public waterand sewage systems in rural Alaskan villages?What coordination exists with the Fish andWildlife Service, the Corps of Engineers, andother agencies in this regard?

6. Is EPA accumulating data to anticipatethe water and air pollution problems whichwill be associated with an expandedpetrochemical industry in Alaska, assuming atrans-Alaska gas pipeline and liquefactionfacility and additional oil and gas discoveriesin Alaska?

64

7. What support could the EPA provide theState Department in the event of negotiationsregarding trans-Canadian pipelines?

Background

Alaska’s Outer Continental Shelf is con-sidered to have an oil potential greater thanthat of any other State, yet the waters involvedalso support the largest commercial fisheryharvest of all of our Continental Shelf areas.Oil and gas exploration and development onAlaska’s Outer Continental Shelf should beconducted in concert with the collection andassessment of comprehensive marine, coastal,and estuarine ecological data. Such data areessential for setting guidelines to minimize theimpacts on fisheries, marine mammal, seabird, and other natural resource values.

The major anticipated environmental im-pacts associated with large-scale petroleumdevelopment in arctic Alaska apparently hasbeen overlooked by EPA and other Federalagencies responsible for environmental pro-tection. The Prudhoe Bay oil discovery, onState land, has attracted little Federal atten-tion.

Since the initial environmental assessmentsnecessary for the development of an environ-mental impact statement for the Trans-AlaskaOil Pipeline, the Federal Government hasrestricted its attention to pipeline surveillanceduring the construction period. The oil indus-try is preoccupied with the task of pipelineconstruction. The unique opportunity to carryout research on pipeline, road construction,and associated developments in northern en-vironments has been largely overlooked.Several unexpected environmental problemshave arisen as a result of pipeline constructionand there is a need for research to assess theirconsequences, These include blowing roaddust along the haul road which causes pre-mature snowmelt—thereby exposing underly-ing vegetation and leading to concentrationsof water fowl, caribou, and other wildlife—and S02 fallout from pumping stations on ad-jacent caribou lichen winter ranges.

Unanticipated widespread oil explorationand development on U.S. Naval Petroleum


Reserve No. 4, and adjacent Federal lands andnative selected lands, apparently falls outsidethe responsibilities of Federal research intoenvironmental consequences of large-scaleenergy development, which is aimed atwestern oil-shale lands and the Outer Conti-nental Shelf. Comprehensive environmentalresearch in these arctic ecosystems is essentialas a basis for prescribing guidelines fordevelopment activities. EPA should assumeoverview responsibility to insure that theneeded information is being collected. Thesearctic and subarctic ecosystems are the basisfor the subsistence economies of Eskimos, In-dians, Aleuts, and many other Alaskans aswell as supporting commercial harvests ofrenewable resources of great importance toAlaska and the Nation.

EPA’s responsibility for coordinating en-vironmental research also provides the incen-tive for development of a comprehensivesystem of information exchange with coun-tries with similar northern ecosystems, associ-ated problems, and experience in dealing withthem. Full opportunity should be taken to useexisting bilateral exchange agreements withthe U.S.S.R. and to establish similar agree-ments where they do not exist with Canada,D e n m a r k ( G r e e n l a n d ) , a n d N o r w a y(Spitsbergen) to foster the exchange of infor-mation on problems of northern develop-ment. The international Man and theBiosphere Program (MAB) Project No. 6—Mountain and Tundra Systems—provides onesuch mechanism.

WATER TREATMENT ANDFATE OF EFFLUENTS

Issue 10

Expanded and redirected research into con-trol of wastewater effluents and treatment ofdrinking water supplies is needed.

Summary

The EPA Plan expresses concern for the po-tential hazards to human health presented by

65


Sewage treatment plant, Blue Plains, Maryland

the growing amounts of wastewater and of and so bypassing natural purification process.water treatment byproducts entering the The ORD Plan lists research approaches andwater system. There is reason for concern programs in this subject area primarily inbecause today’s wastewater effluent becomes general and nonspecific terms, without in-tomorrow’s water supply. And with growing dicating priorities in terms of scale of effort ordemand, there is a movement toward perceived magnitude of potential health risks.shortcutting portions of the hydrologic cycle In constrast, emphasis is given to the potential

66

hazard of dispersion of viruses in aerosolform from irrigation with wastewater sludges.But this specific proposal is not matched, forexample, by corresponding concern for thehealth effects of chemical toxicants from thesame sources.

Many basic questions related to wastewatertreatment and protection of water supplies re-main unanswered, for example: the effective-ness of chlorine and ozone for virus inactiva-tion, the effectiveness of removal of organiccompounds, and the mechnisms for thetransport and removal of viruses or car-cinogens within aquifers. Proliferation oftreatment plants and increased use ofwastewater in irrigation, use of sludges inland treatment, and potential contaminationof water for recreational use and drinkingwater supplies demand a direct and yet broad-based research effort. Balanced concern isneeded across the full range of classes ofagents: pathogenic micro-organisms (bacteriaand viruses), and chemical toxicants (metals,pesticides, carcinogens, and other toxic sub-stances) .

Questions

1. How ef fec t ive are convent ionalwastewater treatment methods in removingtoxic chemicals? Do removal processes addundesirable constituents?

2. How may constituents of particular con-cern, such as viruses and toxic chemicals, becarried from a wastewater source to arelatively nearby water source location?

3. How effective is inactivation of virusesusing chlorine and conventional wastewatertreatment methods? How do results comparewith use of ozone and ultraviolet radiation?What is the extent of the research effort pro-posed in these areas?

4. What research is being done into thetechnology of removing organic compoundsfrom drinking water?

5. How much is known about the typesand extent of pollution of air, ground waterand surface water supplies arising from sitesused for sludge disposal ?


6. What research is being done to assess theeffects of land disposal of sewage in place ofsecondary, not just tertiary, treatment ofwastewater ?

Background

Under Public Law 93-523 (Safe DrinkingWater Act) an increased effort is to be made toinsure the safety of the Nation’s drinkingwater supplies. To accomplish this, many newareas of research need development and asubstantial commitment of resources must bemade. One important reason for this growthin research need is that the quality of watersupply is closely linked to wastewater treat-ment effectiveness. And since the time whenstandard methods of wastewater treatmentwere established, a great variety of newchemical contaminants (largely of industrialorigin) have been introduced. The list includestoxic heavy metals such as mercury, car-cinogenic materials such as asbestos fibers,highly persistent organic chemicals of hightoxicity (including carcinogenic potential)such as polychlorinated biphenyls (PCB’s),and the ever-increasing variety of pesticides.

In the past, it has generally been assumedthat pollutants in wastewater will be dilutedand dispersed when they reach large bodies ofwater. At this point all hazards to humanhealth would be removed. This is notnecessarily the case, however, particularlywhen growing demands for water dictate cir-cumstances such as development of waterrecreation sites close upon wastewater dis-posal or sludge disposal locations. Both thetransport and fate of potentially hazardousconstituents, microbiological and chemical,must be thoroughly understood so that risk tothe health of users in such instances can becontrolled. This requires development of anaugmented, balanced research program.

In addition, there still are basic researchneeds with respect to conventional water sup-ply and treatment processes that have not yetbeen met. For example, the question of howstandard disinfectants inactivate viruses, andwhether or not the mechanism is similar tothat of bacterial inactivation, needs to be

67

—


answered. Halogenated organics, found to beformed through use of chlorine during nor-mal - disinfection practice, are suspected ofbeing carcinogens. The present EPA researchprogram to find alternate routes to disinfec-tion appears inadequate.

A multiplicity of organic compounds hasbeen found in the drinking water of severalcities. The EPA is considering a standard fororganics in drinking water. However, unlesstechnology to achieve a standard is rapidlydeveloped, States and local agencies may findthemselves in the uncomfortable position ofnot being able to comply with the standard.

Pathogenic micro-organisms, bacteria andviruses, are present in raw sewage and con-stitute a threat to human health. These orga-nisms can escape deactivation if the treatmentprocesses are bypassed in times of floodingoverloads. Both are likely to persist to somedegree in sludges which are a result of treat-ment processes and may be used as a fertilizeror soil conditioner. Thus, a wide range ofways are open through which such micro-organisms may persist (as in soil), may betaken up and even concentrated by livingorganisms, and may contaminate streams andrivers by runoff or percolation. Much moreresearch remains to be done in this area.

RECREATIONAL WATERSTANDARDS

Issue 11

Expanded research on the question oftolerable pathogenic concentrations in pri-mary-contact recreational waters is desirable.

Summary

EPA’s program to determine tolerablepathogenic concentrations that may occurwithout jeopardizing health of humans in pri-mary recreational contact with marine watersis too limited, The program should be ex-panded and include consideration of virusesand other parasites. This need relates directly

to the congressional mandate in Public Law92–500 relative to recreation in and on thewaters.

Questions

1. Is there a correlation between recrea-tional water standards and hazards to humanhealth? Is there a significant public healthhazard associated with present standards fornatural surface waters?

2. Has the question of deterioration o fwater quality resulting from bather loads innatural water bodies and impoundments beenevaluated ?

3. Are there pathogens of concern forwhich no standards have

Background

Public Law 92-500 hasquiring the upgrading of

been set?

had the effect of re-many areas of sur-

face waters to swimmable quality by 1983. Theneed to carefully study the human healthhazards relating to this mandate is of utmostimportance. The present standards for swim-ming in natural waters should be carefully ex-amined and evaluated. The question of con-tamination of the waters by the bathers them-selves should be examined, since there is evi-dence that a considerable pollution loadcomes from this source.

In many natural water, bodies, the waterquality may appear satisfactory for swimmingas long as there are no bathers, but maybecome unsatisfactory when there are bathers.

The common indices of water quality in-Clude counts of total and fecal coliform orga-nisms. These have long been useful indicatorsof treated-water quality because chlorinationadequate to protect health reduces coliformlevels to very low values. However, manyuntreated waters may contain coliform orga-.nisms which have a soil or animal origin andmay be in no way indicative of any importanthealth risk. At the same time, tests for otherbacteria and for viruses are not commonly in-cluded as a part of untreated-water qualitydetermination. To show that this is not anacademic distinction, recent research on thequality of natural waters used for recreation

68

iv. transport, fate, and monitoring research - princeton

Documents