REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 357 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101190

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

IT SEEMS LIKELY THAT 75-95 PERCENT OF THE CL ADDED TO A MUD WILL BE FIXED UPON THE MUD SOLIDS. THIS IS TRUE FOR CL CONCENTRATIONS OF (SYMBOL OMITTED) 1 LB/BBL TO (SYMBOL OMITTED) 21 LBS/BBL OF BOTH CLAY AND CLAY-BARITE SUSPENSIONS. THE MUD SOLIDS CL RATIO IS PARTICULARLY PERTINENT IN EXTRAPOLATING THESE DATA TO ACTUAL MUD SYSTEMS. FOR A GIVEN MUD, INCREASING THE SOLIDS DECREASES THE CL IN THE LIQUID PHASE.

THESE LABORATORY DATA SUGGEST THAT SOLIDS TO CL RATIOS FOUND IN THE FIELD MUDS ONLY ABOUT 5 TO 25% OF THE CL WOULD BE AVAILABLE IN THE FILTRATE. IF, FOR ILLUSTRATIVE PURPOSES, 10% OF THE CL IS ASSUMED TO BE AVAILAELE, THE CONCENTRATIONS IN THE FILTRATES OF FIELD MUDS A THROUGH D (TABLE V) WOULD RANGE FROM 24 PPM TO 6,675 PPM.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 358 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101191

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

OBSERVATIONS OF MUD AND CUTTINGS DISCHARGES. GENERAL

DURING DRILLING, DISCHARGED MUD AND CUTTINGS PRODUCE A PLUME OF MUDDY WATER THAN CAN BE DISTINGUISHED BY SURFACE OBSERVATIONS FOR A FEW HUNDRED FEET DOWN CURRENT AND PRODUCE AN ACCUMULATION OF CUTTINGS ON THE BOTTOM. IN THE GULF OF MEXICO AND ADJOINING COASTAL WATERS THIS DISCHARGE APPEARS TO HAVE NO EFFECT ON MARINE LIFE. A FAVORITE LEISURE ACTIVITY ON OFFSHORE PLATFORMS AND DRILLING RIGS IS FISHING, AND MANY FISH ARE CAUGHT WITHIN A FEW FEET OF THE DISCHARGE POINTS. THERE ARE, HOWEVER, BETTER DOCUMENTED OBSERVATIONS. TWO SEPARATE GROUPS OF INVESTIGATORS HAVE TAKEN SAMPLES AND MADE VISUAL INSPECTIONS THROUGHOUT THE WATER COLUMN DURING THE DISCHARGE OF CUTTINGS AND MUD. BOTH WERE DONE IN THE GULF OF MEXICO.

DIVER OBSERVATIONS AND SAMPLING RAY AND SHINN

RAY AND SHINN (1975) REPORTED ON 2 DAYS OF OBSERVATIONS MADE IN 1973 AT A PLATFORM OFF THE LOUISIANA COAST LOCATED IN 245 FEET OF WATER. SCUBA DIVERS OBSERVED THE DISCHARGES FROM A DISCHARGE PIPE LOCATED 35 FEET BELOW THE WATER SURFACE AND COLLECTED NUMEROUS WATER SAMPLES AROUND AND UP TO 60 YARDS FROM THE PLATFORM. AT EACH AREAL SAMPLING POINT, SURFACE MID-DEPTH, AND NEAR BOTTOM SAMPLES WERE TAKEN. THESE WERE RETURNED TO THE LABORATORY AND ANALYZED.

THE DIVERS OBSERVED NO ACUTE EFFECTS OF THE DISCHARGE ON MARINE ORGANISMS IN THE WATER COLUMN. THE LIGHTER AND FINER MATERIALS WERE SEEN TO RISE VERTICALLY, SPREAD HORIZONTALLY, AND DISPERSE IN THE CURRENT. THE LARGER CUTTINGS FELL ALMOST STRAIGHT TO THE BOTTOM. ENCRUSTING FORMS THAT GROW ON THE HARD SUBSTRATE AROUND THE PLATFORMS APPEARED TO BE UNAFFECTED BY THE DISCHARGES. BARNACLES WERE LIVING NOT ONLY ON AND BENEATH THE DOWNPIPE BUT ACTUALLY INSIDE IT WHERE THEY WOULD BE MOST AFFECTED BY THE DISCHARGES.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 359 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101192

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

THE SAMPLING LOCATIONS AND ANALYTICAL RESULTS ARE SHOWN IN TABLE VII. MEASUREMENTS INCLUDED ALKALINITY, TOTAL DISSOLVED SOLIDS, TOTAL SUSPENDED SOLIDS, TOTAL ORGANIC CARBON, AND TOTAL SUSPENDED SOLIDS MEASUREMENTS CLEARLY INDICATE THE PRESENCE OF MUD. THESE DATA APPEAR TO HAVE DETECTED SOME VERY SMALL AMOUNT OF MUD (DILUTED AT LEAST SEVERAL ORDERS OF MAGNITUDE) MIXED WITH SEA WATER 30 YARDS EAST AND WEST OF THE PLATFORM. NO MUD COULD BE DETECTED AT THE CLOSEST LOCATIONS NORTH AND SOUTH OF THE DISCHARGE POINT. OBVIOUSLY VERY RAPID SETTLING AND/OR DISPERSION AND DILUTION HAD TAKEN PLACE. MATHEMATICAL MODELING AS REPORTED BY RAY AND SHINN (1975) HAD PREDICTED THE RAPID DILUTION OF MUD DISCHARGES IN SEA WATER. IN ADDITION TO INITIAL CONVECTIVE MIXING, CURRENTS PLAY A LARGE ROLE IN DISPERSION AND DILUTION. THEIR LARGE SCALE MOVEMENT SPEEDS UP DIFFUSION (PROBABLY AIDED BY CONTINUED CONVECTION).

A THEORETICAL DILUTION RATIO, RD, (THE VOLUME FRACTION OF SEA WATER DIVIDED BY THAT OF THE DISCHARGED FLUID AT A PARTICULAR TIME AND PLACE) FOR STEADY STATE DIFFUSION FROM A POINT SOURCE (SUCH AS A DISCHARGE PIPE) CAN BE CALCULATED. RAY AND SHINN (1975) PRESENTED SUCH RESULTS FOR STEADY STATE DISCHARGES OF MUD AT 40 AND 250 BBL/HR (FIGURES 1 AND 2, RESPECTIVELY) WITH AMIXING DEPTH OF 245 FEET AND A CURRENT OF 0.29 KNOT (0.5 FT/SEC). FIGURE 1 SHOWS THAT AT 40BBL/HR (BELIEVED TO BE TYPICAL DURING DRILLING) THE DILUTION RATIO PERPENDICULAR TO THE CURRENT, WOULD REACH 1,000 TO 1 AT ABOUT 2 FEET FROM THE DISCHARGE POINT. EVEN DOWN CURRENT THE PREDICTED DILUTION IS 100 TO 1 ONLY 50 FEET FROM THE DISCHARGE POINT AND 1,000 TO 1 AT A LITTLE MORE THAN 1,000 FEET.

THESE THEORETICAL DILUTIONS MAY BE CONSERVATIVE, AS RAY AND SHINN (1975) DETECTED NO MUD IN WATER SAMPLES COLLECTED AT MANY LOCATIONS ONLY 90 FEET FROM THE DISCHARGE POINT.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 360 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101193

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

TABLE VII

ANALYSIS OF SEA WATER AROUND PLATFORM (FROM RAY AND SHINN,

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 361 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101194

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

FIGURE 1. DILUTION RATIOS AT 40 BBL/HR (FROM RAY AND SHINN, 1975)

FIGURE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 362 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101195

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

FIGURE 2. DILUTION RATIOS AT 250 BBL/HR (FROM RAY AND SHINN, 1975)

TABLE OMITTED.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 363 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101196

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

ZINGULA

ZINGULA (1975) OBSERVED THE DISCHARGE OF MUD AND CUTTINGS AT A SOUTH TIMBALIER BLOCK 54 PLATFORM. HE TOOK SURFACE SAMPLES OF WATER AT THE DISCHARGE POINT, 300 FEET UPSTREAM, AND 300 FEET AND 660 FEET DOWNSTREAM (THE FARTHEST VISIBILTY MUDDY POINT). HE ALSO TOOK SAMPLES 30 FEET BELOW THE SURFACE AT THE DISCHARGE POINT AND 300 TO 660 FEET DOWNSTREAM. TABLE VIII SHOWS THESE SAMPLING LOCATIONS AND THE LABORATORY ANALYSES OF THE WATER.

AT 660 FEET DOWNSTREAM THE SUSPENDED SOLIDS CONTENT WAS AT BACKGROUND LEVELS (SYMBOL OMITTED)(5 PPM) FOR GULF OF MEXICO WATER. EVEN 300 FEET DOWNSTREAM ONLY TRACES OF MUD COULD BE FOUND (40 PPM SUSPENDED SOLIDS). FROM THE PLATFORM THE MUDDY WATER COULD BE CLEARLY SEEN ON THE SURFACE ABOVE THE DISCHARGE POINT. HOWEVER, THE SUSPENDED SOLIDS CONTENT AT THAT POINT WAS 278 PPM, WHILE THAT OF THE MUD BEING DISCHARGED WAS 350,000 PPM (JUST BELOW THE SHALE SHAKER). THIS INDICATES THAT THE MUD SOLIDS HAD ALREADY BEEN DILUTED BY 1,000 VOLUMES OF SEA WATER WHILE RISING TO THE SURFACE AND NEARLY TEN THOUSANDFOLD WHILE MOVING 300 FEET DOWNSTREAM. THESE OBSERVATIONS ALSO INDICATE THAT THE ACTUAL DILUTIONS WERE GREATER THAN CALCULATED BY THE DISPERSION MODEL.

ZINGULA OBSERVED NO ADVERSE EFFECTS ON FISH OR OTHER ORGANISMS IN THE WATER COLUMN DURING THIS SAMPLING. DURING PREVIOUS STUDIES IN OCTOBER, 1971, HE OBSERVED, PHOTOGRAPHED, AND SAMPLED CUTTINGS ACCUMULATED UNDER A DRILLING RIG IN SOUTH TIMBALIER BLOCK 111 IN 80 FEET OF WATER. HE OBSERVED CRABS AND GASTROPODS DIGGING IN THE CUTTINGS PILE, WHILE GROUPERS AND RED SNAPPERS WERE NOSING IN THE PILE, UNDISTURBED BY THE CHIPS STILL FALLING THROUGH THE WATER. SOME FISH WOULD EVEN TAKE CUTTINGS CHIPS IN THEIR MOUTHS, ONLY TO SPIT THEM OUT WHEN THEY DISCOVERED THEY WERE NOT EDIBLE.

ZINGULA CONSIDERS THE SCENES SHOWN IN FIGURES 3 AND 4 TYPICAL. FIGURE 3 SHOWS THE "NORMAL" SANDY MUD BOTTOM UNDER THE RIG, HIGHLY BURROWED AND DISPLAYING SMALL MOLLUSK FRAGMENTS. THE HOLE IN THE MOUND IN THE CENTER OF THE PHOTOGRAPH IS APPROXIMATELY 3 INCHES ACROSS. FIGURE 4 SHOWS THE CENTER OF THE CUTTINGS PILE.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 364 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101197

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

TABLE VIII

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 365 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101198

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

FIGURE 3. NORMAL SEA BOTTOM (80 FOOT DEPTH) UNDER THE DIXILYN 10 RIG, SOUTH TIMBALIER BLOCK III. (FROM ZINGULA, 1975).

FIGURE OMITTED

FIGURE 4. CENTER OF THE AREA OF CUTTINGS ACCUMULATION (FROM ZINGULA, 1975)

FIGURE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 366 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101199

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

THERE IS A SMALL FISH AT REST ON THE CLEARLY DISCERNIBLE CUTTINGS IN THE CENTER OF THE PHOTOGRAPH, AND OTHER FISH ARE SWIMMING IN THE BACKGROUND. WITH THE 15 INCH CLOSE UP LENS USED. THE HORIZONTAL FIELD OF VIEW IS ABOUT 12 INCHES AT THE DISTANCE OF THE SMALL FISH.

EVIDENCE EXISTS THAT FREE SWIMMING ORGANISMS ARE NOT REPELLED BY MUDDY DISCHARGES. LAWRENCE AND SCHERER (1974) GAVE LAKE WHITEFISH AND RAINBOW TROUT FREE ACCESS TO BOTH CLEAN WATER AND WATER CONTAINING 1,000 MICROLITERS OF MUD PER LITER OF SOLUTION (1,000 PPM). THE WHITEFISH SPENT MORE THAN 90% OF THEIR TIME IN THE MUDDY WATER; AND THE RAINBOW TROUT, 60%.

ENVIRONMENTAL IMPACT

THE STUDIES DISCUSSED ABOVE SHOW THAT ANY MUD AND INCLUDED TOXIC MATERIALS DISCHARGED WHILE DRILLING WOULD BE RAPIDLY DISPERSED AND DILUTED TO INNOCUOUS LEVELS. NO ADVERSE OR ACUTE EFFECTS ON ORGANISMS HAVE BEEN OBSERVED IN THE WATER COLUMN, AND BECAUSE OF RAPID DILUTION NONE SHOULD BE EXPECTED.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 367 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101200

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

BULK MUD DISPOSAL GENERAL

NO ONE HAS AS YET MEASURED THE DISPERSION AND DILUTION OF DISCHARGING BULK MUD, I.E., LARGE VOLUMES OF MUD, USUALLY DONE AFTER SETTING SURFACE CASINGS AND COMPLETING WELLS. UNTIL THIS CAN BE DONE, SOME INSIGHT AS TO THE EFFECTS CAN BE GAINED BY (1) EXAMINING THE AVAILABLE LABORATORY BIOASSAY DATA TO IDENTIFY ANY TOXIC COMPOUNDS IN THE MUD AND ESTABLISH THEIR TOXIC LEVELS, (2) ESTIMATING THE CONCENTRATIONS OF THESE COMPOUNDS IN SPECIFIC EXAMPLES OF FIELD MUDS TO FIND THE PROBABLE TOXICITY OF THE UNDILUTED MUD, AND (3) ESTIMATING THE PROBABLE DILUTION OF THE FIELD MUD WITH WATER AFTER DISCHARGE TO EVALUATE THE POSSIBLE ENVIRONMENTAL IMPACT.

BIOASSAY DATA

BIOASSAYS SHOW HOW ORGANISMS ARE AFFECTED BY MATERIALS. THE ORGANISMS ARE PLACE IN SOLUTIONS OF THE MATERIAL AND THEIR CONDITION MONITORED WITH TIME. ONE INDICATOR OF TOXICITY IS THE CONCENTRATION OF THE TEST MATERIAL REQUIRED TO KILL 50% OF THE TEST ORGANISMS (OR THAT ALLOWS 50% TO SURVIVE) IN A GIVEN TIME. THUS, MEDIAN TOLERANCE LEVELS (TL50) ARE REPORTED FOR 24 OR 96 HOURS. IN GENERAL, FOR NONVOLATILE MATERIALS, TOLERANCE LEVELS ARE HIGH FOR SHORT TIMES BUT DECREASE RAPIDLY.

LABORATORY BIOASSAY TESTS ARE OF VALUE IN COMPARING THE TOXICITY OF A GIVEN MATERIAL TO VARIOUS SPECIES OF ORGANISMS OR COMPARING TOXICITIES OF VARIOUS MATERIALS TO A GIVEN ORGANISM. THESE TOXICITY DATA CANNOT BE RELATED TO NATURAL CONDITIONS (SUCH AS DRILLING MUD DISCHARGE) BECAUSE THEY DO NOT CONSIDER DISPERSION AND DILUTION, SHORT EXPOSURE TIME, AND AVOIDANCE OF TOXICANT BY MOBILE ORGANISMS.

THE FOLLOWING DISCUSSION REVIEWS THE TOXICITIES OF DRILLING MUD COMPONENTS AND WHOLE DRILLING FLUIDS AND THEIR RELATION TO DRILLING DISCHARGE CONDITIONS.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 368 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101201

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

TOXICITY OF DRILLING MUD COMPONENTS

TABLE IX LISTS BIOASSAY DATA FOR MANY OF THE COMPONENTS OF DRILLING MUDS. THE PRINCIPAL SOLID COMPONENTS, BENTONITE AND BARITE (BASOR), ARE INSOLUBLE, INERT, AND NONTOXIC AND SHOULD NOT AFFECT MARINE LIFE. INVESTIGATORS HAVE BEEN UNABLE TO ADD ENOUGH BARITE OR BENTONITE TO A TEST SOLUTION TO ESTABLISH THROUGH BIOASSAYS A MEDIAN TOLERANCE LEVEL FOR THESE MATERIALS. IN SOME ENVIRONMENTAL STATEMENTS FOR OCS OFFSHORE LEASE SALES, COMMENTS APPEAR THAT BARIUM IN DRILLING MUDS PRESENTS A SERIOUS BUT AS YET UNDETERMINED THREAT TO AQUATIC IFE BECAUSE IT IS KNOWN THAT BARIUM COMPOUNDS HAVE A SEVERE, ALMOST STERLIZING EFFECT ON PLANT AND ANIMAL LIFE IN THE SOIL. THIS STATEMENT DOES NOT INDICATE THE BARIUM COMPOUNDS OR THEIR CONCENTRATIONS, BUT THEY CANNOT BE REFERRING TO BARIUM SULFATE (BARITE). A NUMBER OF BARIUM COMPOUNDS HAVE HIGH SOLUBILITIES IN WATER (BARIUM CHLORIDE, 390,000 PPM AT 0 DEGREES C; BARIUM CHLORATE, 200,000 PPM AT 0 DEGREES C; BARIUM TETRASULFIDE, 410,000 PPM AT 15 DEGREES C). BARITE (BARIUM SULFATE) USED IN DRILLING MUDS IS VERY INSOLUBLE (0.03 PPM IN SEA WATER AT 25 DEGREES C). THIS IS 30 TIMES LESS THAN THE 1.0 PPM ALLOWED IN PUBLIC DRINKING WATER SYSTEMS. BARITE IS ALSO USED BY PHYSICIANS AS AN OPAQUE SLURRY IN RADIOGRAPHY DIAGNOSIS AND IS NONPOISONOUS. THUS, BARITE DISCHARGE WITH DRILLING MUDS IS A NONTOXIC SUBSTANCE.

ALSO NONE OF THE OTHER INORGANIC CHEMICALS COMMONLY USED IN MUD CAN BE CONSIDERED TOXIC EITHER. SODIUM CARBONATE, SODIUM BICARBONATE, AND SODIUM ACID PYROPHOSPHATE ARE ADDED TO REACT WITH CALCIUM IONS WITH CALCIUM IONS WHICH ENTER THE MUD. THESE CHEMICALS REACT TO FORM THE INERT SOLIDS, CALCIUM CARBONATE OR A CALCIUM PHOSPHATE. SODIUM HYDROXIDE IS ADDED IN CONSIDERABLE QUANTITY OVER THE LIFE OF THE WELL TO CONTROL PH. THE HYDROXIDE ION IMMEDIATELY REACTS WITH HYDROGEN IONS, EFFECTIVELY NEUTRALIZING THE CAUSTIC. AT PH 10, USUAL FOR LIGNOSULFONATE MUDS, THE HYDROXIDE ION CONCENTRATION IS ONLY 1.7 PPM, EQUIVALENT TO ABOUT 4 PPM OF SODIUM HYDROXIDE. UPON DISCHARGE THE SMALL AMOUNT OF UNREACTED SODIUM HYDROXIDE IMMEDIATELY DILUTES AND/OR FURTHER REACTS WITH SEA WATER AND IS NEUTRALIZED.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 369 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101202

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

TABLE IX

ACUTE TOXICITY BIOASSAYS ON DRILLING MUD MATERIALS

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 370 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101203

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

IT IS NOT SURPRISING THAT NO MEDIAN TOLERANCE LEVELS (96 HR TL50) COULD BE ESTABLISHED FOR BARITE OR BENTONITE, THE MAIN SOLIDS ADDED TO DRILLING MUDS. TO BE EFFECTIVE THESE SOLIDS MUST BE INERT, SO THEY SHOULD NOT AFFECT MARINE LIFE AS LONG AS THERE IS SUFFICIENT FLUID FOR NORMAL SWIMMING AND/OR BREATHING.

OF MOST CONCERN ARE MATERIALS THAT DISSOLVE IN THE LIQUID PHASE OF THE MUD AND BECOME PART OF THE FILTRATE. THE MOST COMMON OF THESE ARE CHROME LIGNOSULFONATES, LIGNITES, AND SODIUM HYDROXIDE. SMALL AMOUNTS OF SODIUM ACID PYROPHOSPHATE, SODIUM CARBONATE, OR SODIUM BICARBONATE ALSO MIGHT BE ADDED TO REMOVE CALCIUM. CHROMIUM SALTS MAY BE ADDED IN EXTREMELY DEEP (HIGH TEMPERATURE) WELLS. ORGANIC SPECIALTY PRODUCTS MIGHT BE USED TO COMBAT FOAMING, CORROSION, OR BACTERIAL GROWTH.

ORGANIC SPECIALTY PRODUCTS, IF PRESENT AT ALL, ARE LIKELY TO BE AT VERY LOW CONCENTRATIONS (A FEW PPM). HOWEVER, SOME SUCH PRODUCTS CAN BE QUITE TOXIC (IN FACT, BACTERICIDES MUST BE), SO THEY ARE USED ONLY FOR SPECIFIC WELL PROBLEMS. WHEN DISCHARGED, CONCENTRATIONS ARE QUICKLY LOWERED BY DILUTION TO LEVELS WHERE THEY CAN BE RAPIDLY BIODEGRADED (GAWE) AND AND HUDDLESTON, 1972).

OF THE MATERIALS ADDED TO DRILLING MUDS IN APPRECIABLE QUANTITIES, THE TOXICITIES OF THE FERROCHROME AND CHROME LIGNOSULFONATES (WHEN TESTED AS INDIVIDUAL COMPONENTS) APPEAR TO BE THE HIGHEST. AS SHOWN IN TABLE IX, REPORTED 96 HR TL50 VALUES FOR AQUEOUS SOLUTIONS OF THESE COMPONENTS RANGE FROM 465 TO 12,200 PPM. TEST ORGANISMS INCLUDED WHITE SHRIMP, RAINBOW TROUT, AND SAILFIN MOLIES, SO SOME OF THE VARIATION PROBABLY REPRESENTS DIFFERING SENSITIVITIES OF THE TEST ORGANISMS.

WHOLE DRILLING MUDS.

AS DISCUSSED PREVIOUSLY, MOST OF THE LIGNOSULFONATE IS FIRMLY ADSORBED ON CLAYS AND BARITE AND IS NOT READILY AVAILABLE TO PLANTS OR ANIMALS. THE ADSORBED LIGNOSULFONATE MIGHT BE RELEASED SLOWLY AS THE MUD IS DILUTED UPON DISCHARGE OR RESIDING ON THE BOTTOM SEDIMENTS. HOWEVER, RAPID DILUTION OF ANY OF THE DESORBED MATERIAL SHOULD EASILY KEEP CONCENTRATIONS IN WATER VERY LOW.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 371 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101204

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

FERROCHROME OR CHROME LIGNOSULFONATES IN THE UNDILUTED LIQUID PHASE OF THE DRILLING MUD SHOULD NOT APPRECIABLY EXCEED THE 96 HR TL50 VALUES REPORTED ABOVE. TABLE VI REPORTS THE CL CONCENTRATIONS IN THE FILTRATES OF LABORATORY PREPARED DRILLING MUDS TO RANGE FROM 72 TO 4,864 PPM. CONCENTRATIONS OF LIGNOSULFONATES IN THE FILTRATE (LIQUID PHASE), FOR THE 4 FIELD MUDS PREVIOUSLY DISCUSSED, ARE ESTIMATED TO RANGE FROM 24 TO 6,675 PPM (TABLE V). THE HIGHER VALUES ARE LIKELY WHEN DRILLING BELOW 7,000 FEET. THE FILTRATE LIGNOSULFONATE CONCENTRATIONS (MEASURED) FOR THE LABORATORY PREPARED DRILLING MUDS AND ESTIMATED CONCENTRATIONS FOR FIELD MUDS ARE COMPARABLE TO THE 96 HR TL50 CONCENTRATIONS FOR THESE COMPOUNDS REPORTED IN TABLE IX. WITH DILUTION, LITTLE OR NO DETRIMENTAL ENVIRONMENTAL IMPACE WOULD RESULT FROM DISCHARGE OF WHOLE MUDS AT COASTAL OR OFFSHORE WELL LOCATIONS.

SUBSTANTIATION OF THE RELATIVELY LOW TOXICITIES OF WHOLE DRILLING MUDS IS REPORTED BY FALK AND LAWRENCE (1974) AND LAWRENCE AND SCHERER (1974). THEY CONDUCTED BIOASSAY TESTS USING ACTUAL LIGNOSULFONATE DRILLING FLUIDS (TABLE X). THE 96 HR TL50 LEVELS RANGED FROM 8,300 PPM TO 120,000 PPM (BY VOLUME). PARTIAL LISTS OF THE MATERIALS ADDED TO THESE SPECIFIC MUDS ARE GIVEN IN THEIR REPORTS BUT NOT MUD PROPERTIES OR SYSTEM VOLUMES; THEREFORE NO ESTIMATE OF THE LIGNOSULFONATE CONCENTRATIONS CAN BE MADE.

AS NOTED EARLIER, OBSERVED VERY HIGH DILUTIONS OF MUD DISCHARGED DURING NORMAL DRILLING MAY HAVE BEEN GREATER THAN THE CALCULATED VALUES. VERY LIKELY THE SAME WOULD OCCUR FOR BULK MUD. THE OBSERVATIONS OF ZINGULA (1975) AND RAY AND SHINN (1975) SUGGESTS THAT POSSIBLE TOXICITY SHOULD EXIST TO ONLY A FEW FEET FROM THE DISCHARGE POINT AND THEN ONLY DURING DISCHARGE (A FEW HOURS).

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 372 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101205

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

TABLE X

STATIC ACUTE TOXICITY BIOASSAYS ON DRILLING FLUIDS

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 373 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101206

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

COMPARISON OF WELL DISCHARGES WITH RIVER AND SHELF SEDIMENT TRANSPORT

WITH THE EXCEPTION OF LIGNOSULFONATES, LIGNITES, TANNINS, AND SPECIAL ORGANIC ADDITIVES, THE REMAINING MATERIALS IN DRILLING FLUIDS ARE NATURAL. THE MONTMORILLONITE CLAY (BENTONITE) IS THE SAME AS THAT FORMED IN THE WEATHERING OF SOILS AND DISCHARGED CONTINUOUSLY TO THE OCEANS. BARITE IS A NATURAL MINERAL AS ARE MOST OF THE INORGANIC CHEMICALS. THE CUTTINGS ARE SEDIMENTARY ROCKS DEPOSITED THROUGH GEOLOGICAL TIME AND ARE VERY SIMILAR IN MINERALOGICAL COMPOSITION TO SEDIMENTS ADDED BY NATURE TO THE WORLD OCEANS NOW AND IN THE PAST. ALSO, THE VOLUME OF CUTTINGS AND DRILLING FLUIDS DISCHARGED IS EXTREMELY SMALL WHEN COMPARED WITH SOLIDS VOLUMES BEING DISCHARGED BY RIVERS. CURRENTS AND WAVES, PARTICULARLY DURING STORMS, CAUSE TREMENDOUS AMOUNTS OF RESUSPENSION AND MOVEMENT OF BOTTOM SEDIMENTS.

HOLEMAN (1968) CONSIDERS THAT ONE THIRD OF THE LAND SURFACE IS CONTRIBUTING WATERBORNE SEDIMENT TO THE SEAS, AND HE ESTIMATES THAT THE WORLD'S RIVERS CONTRIBUTE 20 BILLION TONS OF SEDIMENT TO THE SEA EACH YEAR. THE MISSISSIPPI RIVER CONTRIBUTES AN ANNUAL AVERAGE SUSPENDED LOAD OF 344 MILLION TONS OF SEDIMENT, THE COLORADO RIVER 149 MILLION TONS, AND THE EEL RIVER IN NORTHERN CALIFORNIA 33 MILLION TONS.

FIGURE 5 IS AN ERTS PHOTOGRAPH OF THE MISSISSIPPI RIVER DELTA AREA TAKEN JANUARY 16, 1973. THIS PICTURE SHOWS AN AREA 115 MI ON A SIDE, WITH THE CITY OF NEW ORLEANS IN THE UPPER LEFT QUADRANT AND THE SEVERAL MOUTHS OF THE MISSISSIPPI RIVER IN THE RIGHT CENTER OF THE PICTURE. THE VERY MUDDY WATER OF THE MISSISSIPPI MIXES WITH THE GULF WATERS, PRODUCING A LIGHT COLORED AREA ON THE PHOTO. AS IS CLEARLY SHOWN, THIS MUDDY WATERS PLUME EXTENDS OUTWARD FOR MORE THAN 20 MI, DOCUMENTING THE LARGE AMOUNT OF SEDIMENT DISCHARGE. RIVER FLOW AND SEDIMENT DISCHARGE BY THE MISSISSIPPI ARE EVEN HIGHER AT OTHER TIMES OF THE YEAR, PARTICULARLY IN THE SPRING MONTHS. THE AVERAGE MISSISSIPPI RIVER DISCHARGE IS ABOUT 1 MILLION TONS PER DAY. AS SHOWN EARLIER IN TABLE 1, A WELL DRILLED IN THE GULF OF MEXICO MIGHT TAKE 150 DAYS TO REACH 20,000 FEET AND WOULD CONTRIBUTE ABOUT 18,500 CU FEET OR ALMOST 1,500 TONS OF CUTTINGS OVER THE PERIOD OF DRILLING, OR ABOUT 10 TONS/DAY AVERAGE.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 374 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101207

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

THE MISSISSIPPI DISCHARGE IS FAIRLY CONSTANT WITH TIME, WHEREAS SOME RIVERS IN SEMI-ARID AREAS SUCH AS SOUTHERN CALIFORNIA SHOW MARKED SEASONAL VARIATIONS. FOR EXAMPLE, DRAKE ET AL. (1972) CITE THE TOTAL DISCHARGE OF SEDIMENT FROM THE SANTA CLARA RIVER FOR 1969 AS 50 MILLION METRIC TONS. HOWEVER, 22 MILLION METRIC TONS (44%) OF THIS WERE RECORDED ON FEBRUARY 25, 1969 DURING A FLOOD PERIOD. THIS RESULTED IN THE DEPOSITION OF SEDIMENT RANGING FROM 1 TO 15 CM IN PORTIONS OF THE EASTERN SANTA BARBARA CHANNEL. THESE SEDIMENTS WERE LATER REDISTRIBUTED OVER LARGER AREAS.

ANOTHER EXAMPLE OF DISCHARGE FROM MUCH SMALLER RIVERS IS SHOWN IN FIGURE 6. THIS ERTS PHOTOGRAPH MADE ON APRIL 24, 1973 SHOWS SEDIMENT DISCHARGE FROM THE EEL RIVER AND OTHER MINOR RIVERS IN NORTHERN CALIFORNIA. WHILE NOT AS DRAMATIC AS AT THE MISSISSIPPI DELTA, THE MUDDY WATER PLUMES FROM THESE WEST COAST RIVERS ARE CLEARLY VISIBLE AS LIGHTER AREAS ON THE PHOTOGRAPH, AND THEY EXTEND A FEW MILES OFFSHORE. LONGSHORE CURRENTS DISTRIBUTE THE SEDIMENTS FOR LONG DISTANCES ALONG THE COAST. MOST OF THE SEDIMENTS SHOWN IN THE OFFSHORE WATERS IS FROM THESE RIVERS BUT MAY ALSO INCLUDE RESUSPENSION OF BOTTOM SEDIMENTS AND NEARSHORE MATERIALS.

SEDIMENT TRANSPORT ON THE CONTINTAL SHELF IS DIFFICULT TO CALCULATE BUT IS KNOWN TO BE VERY HIGH. THUS, THE CONTRIBUTION OF DRILLING FLUID AND CUTTINGS TO COASTAL AND CONTINENTAL SHELF WATERS IS EXTREMELY MINOR COMPARED TO SIMILAR SEDIMENTS CONTRIBUTED BY RIVERS AND BY RESUSPENSION AND TRANSPORT OF BOTTOM SEDIMENTS.

OTHER MAN INDUCED EFFECTS INCLDE DREDGING, DISTURBANCE, AND RESUSPENSION OF THE SEA FLOOR BY BOTTOM TRAWLS FOR FISH AND SHELLFISH. IF 700 WELLS ARE DRILLED IN OFFSHORE AND COASTAL WATERS EACH YEAR, TOTAL SOLIDS (CUTTINGS AND DRILLING FLUIDS) WOULD BE LESS THAN 2% OF THE 38.5 MILLION TONS OF DREDGE SPOILS, MOSTLY FROM CHANNEL AND HARBOR DEVELOPMENT, DUMPED IN U.S. COASTAL WATERS IN 1968.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 375 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101208

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

LONG TERM EFFECTS

EVEN THOUGH MUD AND CUTTINGS DISPOSAL DO NOT ACUTELY AFFECT THE ENVIRONMENT, THERE REMAINS THE QUESTION OF LONG TERM ADVERSE EFFECTS. OBSERVATIONS IN THE GULF OF MEXICO AND ADJACENT COASTAL WATERS AND THE SANTA BARBARA CHANNEL HAVE DETECTED NO LONG TERM ADVERSE EFFECTS.

DRILLING MUD CANNOT BE DETECTED IN BOTTOM SEDIMENTS, EVEN IMMEDIATELY AFTER DRILLING. ZINGULA (1975) COULD NOT DETECT MUD SOLIDS IN THE BOTTOM SEDIMENTS AT LOCATIONS IN THE GULF OF MEXICO EITHER DURING DRILLING OR 8 MO AFTERWARD (AT ANOTHER WELL). THIS IS REASONABLE, AS THE SMALL PARTICLES OF BARITE AND CLAYS SHOULD BE CARRIED MUCH FARTHER BY THE WATER CURRENTS THAN THE LARGER SIZED CUTTINGS. WILLIAM AND JONES (1975) ESTIMATED THAT 75% OF THE BARITE PARTICLES DISCHARGED INTO 65 FOOT OF WATER WITH A O.3 KNOT CURRENT (AVERAGE FOR THE LOUISIANA OFFSHORE PRODUCING AREA) WOULD BE CARRIED 1 MILE. THE CLAYS WOULD BE CARRIED FURTHER.

OBSERVATIONS CONFIRM THE EXPECTATION THAT THESE NONTOXIC, INERT MUD SOLIDS MIXING WITH MUCH LARGER AMOUNTS OF NORMAL SEA BOTTOM SEDIMENTS DO NOT AFFECT BOTTOM DWELLING ORGANISMS. HEALTHY BOTTOM DWELLING COMMUNITIES HAVE BEEN OBSERVED IN THE MUDDY SEDIMENTS SURROUNDING A WELL SITE DURING DRILLING AND YEARS AFTERWARD (ZINGULA, 1975; FARRELL, 1975).

DURING DRILLING, INDIVIDUAL CUTTINGS DRIFT DOWN AND FORM A PILE BENEATH THE DISCHARGE PIPE. AS STATED EARLIER (ZINGULA, 1975), THE CUTTINGS PILES UNDER WELLS IN THE GULF OF MEXICO ARE TYPICALLY ABOUT 3 FT HIGH WHEN NEW AND 150 FT IN DIAMATER. THEIR AREAL OUTLINES ARE CIRCULAR, ELONGATE, OR STARBURST, DEPENDING UPON THE BOTTOM CURRENTS.

SIDESCAN SONAR RECORDS FROM THE GULF OF MEXICO AND SANTA BARBARA CHANNEL SHOW THAT SEVERAL MONTHS AFTER DRILLING IS COMPLETED THE CUTTINGS PILES ARE LESS THAN 6 INCHES (THE RESOLUTION OF THE EQUIPMENT) ABOVE SEE BOTTOM. THIS MEANS THAT NATURAL FORCES DESTROY THE PILES FAIRLY RAPIDLY.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 376 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101209

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

IN THE GULF WHEN DIVERS EXAMINED ONE SUCH PILE 8 1/2 MO AFTER DRILLING WAS COMPLETED THE CUTTINGS WERE COVERED WITH A THIN LAYER OF UNCONSOLIDATED SEDIMENT, AS WAS THE SURROUNDING SEA BOTTOM. THE INDIVIDUAL CUTTINGS WERE STILL PRESENT BUT WERE SOMEWHAT ROUNDED BY SWELLING OF THE CLAYS AND/OR ABRASION BY CURRENTS. CLAY CHIPS SHOWED BROWNISH OXIDATION STAINS, INDICATING THAT THEY ARE WEATHERING AND WILL NOT LONG RETAIN THEIR IDENTITIES. FARRELL (1975) OBSERVED CUTTINGS PILES DURING THE GULF UNIVERSITIES RESEARCH CONSORTIUM (GURC) OFFSHORE ECOLOGY INVESTIGATION IN TIMBALIER BAY AND OFFSHORE LOUISIANA. HE BELIEVES THAT WEATHERING IS ESSENTIALLY COMPLETE IN 10 YEARS.

ORGANISMS IMMEDIATELY POPULATE THESE CUTTINGS PILES AND ESTABLISH HEALTHY COMMUNITIES. ZINGULA (1975) OBSERVED CRABS AND GASTROPODS DIGGING AND GROUPERS AND RED SNAPPERS NOSING IN A PILE EVEN WHILE THE CHIPS WERE STILL FALLING THROUGH THE WATER. A MULTITUDE OF BURROWS AND INFAUNA INDICATED A HEALTHY BENTHIC COMMUNITY IN A CUTTINGS PILE 8 1/2 MO OLD. THE FINDINGS OF FARRELL (1975) SUGGEST THAT HEALTHY COMMUNITIES EXIST AT DRILLING SITES IN COASTAL AREAS (TIMBALIER BAY) AND IN THE GULF OF MEXICO AFTER 10 YEARS. IN THIS SOUTH TIMBALIER AREA ZINGULA (1976) ALSO OBSERVED MANY ORGANISMS GROWING ON THE PLATFORM STRUCTURAL MEMBERS, AND FISH WERE CONGREGATED THERE (FIGURES 7 AND 8). THERE HAS BEEN SIMILAR EXPERIENCE IN CALIFORNIA. HAUSER (1974) DESCRIBED THE PROLIFIC GROWTH OF ORGANISM NOW UNDER PLATFORM HILDA INSTALLED IN THE SANTA BARBARA CHANNEL.

CONCLUSIONS

THE EVIDENCE IS VERY CLEAR. DISCHARGE OF CUTTINGS AND/OR DRILLING MUDS UNDER PRESENT DRILLING PRACTICES DO NOT CAUSE EITHER SHORT- OR LONG-TERM DAMAGE TO MARINE ORGANISMS AT COASTAL OR OFFSHORE LOCATIONS. THE ENVIRONMENTAL IMPACT OF CUTTINGS AND MUD DISCHARGES IS NEGLIGIBLE.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 377 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101210

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

APPENDIX TABLE A-1

MUD MATERIALS USED - WELL A

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 378 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101211

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

APPENDIX TABLE A-2

MUD MATERIALS USED - WELL B

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 379 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101212

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

APPENDIX TABLE A 3

MUD MATERIALS USED WELL C

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 380 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101213

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

APPENDIX TABLE A 4

MUD MATERIALS USED WELL D

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 381 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101214

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

REFERENCES.

CHESSER, B. G., AND MCKENZIE, W.H., "USE OF A BIOASSAY TEST IN EVALUATING THE TOXICITY OF DRILLING FLUID ADDITIVES ON GALVESTON BAY SHRIMP, PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS, SPONSORED BY ENVIRONMENTAL PROTECTION AGENCY'S OFFICE OF TOXIC SUBSTANCES, HOUSTON, TEXAS, MAY 21-23, 1975.

COUNCIL ON ENVIRONMENTAL QUALITY, "OCEAN DISCHARGE A NATIONAL POLICY," A REPORT TO THE PRESIDENT PREPARED BY THE COUNCIL ON ENVIRONMENTAL QUALITY, U.S. GOVERNMENT PRINTING OFFICE, WASHINGTON, D.C., X-45, 1970.

DAUGHERTY, F.M., "EFFECTS OF SOME CHEMICALS USED FOR OIL WELL DRILLING ON MARINE ANIMALS," SEW. IND. WASTE, VOL. 23, PP. 1282-1287, 1951.

DRAKE, D.E., KOLPACK, R.L., AND FISCHER, P.J., "SEDIMENT TRANSPORT ON THE SANTA BARBARA OXNARD SHELF, SANTA BARBARA CHANNEL, CALIFORNIA," SHELF SEDIMENT TRANSPORT PROCESS AND PATTERN, EDITED BY D.J.P. SWIFT, DOWDEN, HUTCHINSON, AND ROSS, INC., STROUDSBURG, PP. 307.331, 1972.

DRILLING FLUIDS FILE, WORLD OIL, PP. 53-80, JANUARY, 1974.

FALK, M.R., AND LAWRENCE, M.J., "ACUTE TOXICITY OF PETRO CHEMICAL DRILLING FLUIDS COMPONENTS AND WASTES TO FISH," TECHNICAL REPORT SERIES NO. CEN-T-73-1, RESOURCE MANAGEMENT BRANCH, CENTRAL REGION, ENVIRONMENT CANADA. 1973.

FARRELL, DOUGLAS, "BENTHIC COMMUNITIES IN THE VICINITY OF PRODUCING OIL WELLS IN TIMBALIER BAY, LOUISIANA," REPORT TO GULF UNIVERSITIES RESEARCH CONSORTIUM (GURC) OFFSHORE ECOLOGY INVESTIGATION, 1975.

GAWEL, L.J., AND HUDDLESTON, R.L., "THE BIODEGRADABILITY OF LOW CONCENTRATIONS OF CERTAIN QUATERNARY AMMONIUM ANTI MICROBIALS BY BACTERIA," PRESENTED AT AMERICAN OIL CHEMISTS' SOCIETY NATIONAL MEETING, LOS ANGELES, CALIFORNIA, APRIL 23-26, 1975.

GRANTHAM, C.K., AND SLOAN, J.P., "TOXICITY STUDY - DRILLING FLUID CHEMICALS ON AQUATIC LIFE," PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS, SPONSORED BY ENVIRONMENTAL PORTECTION AGENCY'S OFFICE OF TOXIC SUBSTANCES, HOUSTON, TEXAS, MAY 21-23, 1975.

GRAY, GEORGE R., "WHERE THE INDUSTRY'S MUD MONEY GOES," THE OIL AND GAS JOURNAL, VOL., 68, PP. 157-159, APRIL 6, 1970.

HAUSER, HILLARY, "HILDA'S HIDDEN HAVEN" EXXON USA FOURTH QUARTER, 1974, PP. 16-21, 1974.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 382 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

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SENATE

HOLEMAN, J.N., "THE SEDIMENT YIELD OF MAJOR RIVERS OF THE WORLD," WATER RESOURCES RESEARCH, PP. 737-747, AUGUST, 1968.

HOLLINGSWORTH, J.W., AND LOCKHART, R.A., "FISH TOXICITY OF DISPERSED CLAY DRILLING MUD DEFLOCCULANTS," PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS SPONSORED BY ENVIRONMENTAL PROTECTION AGENCY'S OFFICE OF TOXIC SUBSTANCES, HOUSTON, TEXAS, MAY 21-23, 1975.

JESSEN, F.W., AND JOHNSON, C.A., "THE MECHANISM OF ABSORPTION OF LIGNOSULFONATES ON CLAY SUSPENSIONS," AIME SOCIETY OF PETROLEUM ENGINEERS JOURNAL, SPETEMBER, 1963.

LAWRENCE, M., AND SCHERER, E., "BEHAVIOURAL RESPONSES OF WHITEFISH AND RAINBOW TROUT TO DRILLING FLUIDS, " TECHNICAL REPORT NO. 502, FISHERIES AND MARINE SERVICE, ENVIRONMENT CANADA, 1974.

LOGAN, WILLIAM J., SPRAGUE, JOHN B., AND HICKS, BRADLEYD., "ACUTE LETHAL TOXICITY TO TROUT OF DRILLING FLUIDS AND THEIR CONSTITUENT CHEMICALS AS USED IN THE NORTHWEST TERRITORIES," REPORT OF THE FISHERIES SERVICE, CENTRAL REGION, RESOURCE DEVELOPMENT BRANCH, ENVIRONMENT CANADA, APRIL 30, 1973 (APPENDIX TO FALK, MR, AND LAWRENCE, M.J., "ACUTE TOXICITY OF PETROCHEMICAL DRILLING FLUIDS COMPONENTS AND WASTES TO FISH," TECHNICAL REPORT SERIES NO. CEN T 73 1 RESOURCE MANAGEMENT BRANCH, CENTRAL REGION, ENVIRONMENT CANADA, 1973).

MCATEE, JAMES L., JR., AND SMITH, NANCY R., "FERROCHROME LIGNOSULFONATES I. X-RAY ABSORPTION EDGE FINE STRUCTURE SPECTROSCOPY; II. INTERACTION WITH ION EXCHANGE RESIN AND CLAYS," JOURNAL OF COLLOID AND INTERFACE SCIENCE, VOL. 29, NO. 3, MARCH, 1969.

MCMORDIE, W.C., JR. (OIL BASE, INC.), COMMENTS AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS, MAY 23, 1975; TRANSCRIPT PREPARED BY T.B. RIGLER AND ASSOCIATES, HOUSTON,TX, P. 175 C.

MONAGHAN, P.H., "HEAVY FLUIDS FOR EXTREME WELL CONDITIONS," PRESENTED AT AMERICAN PETROLEUM INSTITUTE SOUTHERN DISTRICT MEETING, HOUSTON, TEXAS, 1961 (TEXT AVAILABLE FROM AUTHOR).

RAY, JAMES P., AND SHINN, E.A. 'ENVIRONMENTAL EFFECTS OF DRILLING MUDS AND CUTTINGS," PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS, SPONSORED BY ENVIRONMENTAL PROTECTION AGENCYS OFFICE OF TOXIC SUBSTANCES, HOUSTON,T EXAS, MAY 21-23, 1975.

ROBICHAUX, T.J., "BACTERICIDES USED IN DRILLING AND COMPLETION OPERATIONS, PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL PROTECTION AGENCY'S OFFICE OF TOXIC SUBSTANCES, HOUSTON TEXAS, MAY 21-23, 1975.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 383 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101216

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SENATE

SKELLY, W.G., AND KJELLSTAND, J.A., "THE THERMAL DEGRADATION OF MODIFIED LIGNOSULFONATES IN DRILLING MUD," PRESENTED AT AMERICAN PETROLEUM INSTITUTE SPRING MEETING OF THE SOURTHERN DISTRICT, DIVISION OF PRODUCTION, HOUSTON, TEXAS, MARCH 2-4 1966.

WALLEN, E.I., "THE DIRECT EFFECT OF TURBIDITY ON FISHES," OKLAHOMA AGRICULTURAL AND MECHANICAL COLLEGE, ARTS AND SCIENCES STUDIES, BIOLOGY SERIES NO.2, VOL. 48, NO. 2, PP. 1-27, 1951.

WILLIAMS, S.E., AND JONES, J.I., "THE DISTRIBUTION AND ORIGIN OF BOTTOM SEDIMENTS IN THE LOUISIANA OIL PATCH ADJACENT TO TIMBALIER BAY, LOUISIANA," REPORT TO GULF UNIVERSITIES RESEARCH CONSORTIUM (GURC) OFFSHORE ECOLOGY INVESTIGATION, 1975.

ZINGULA, R.P., "EFFECTS OF DRILLING OPERATIONS ON THE MARINE ENVIRONMENT, PRESENTED AT THE CONFERENCE ON ENVIRONMENTAL ASPECTS OF CHEMICAL USE IN WELL DRILLING OPERATIONS,SPONSORED BY ENVIRONMENTAL PROTECTION AGENCY'S OFFICE OF TOXIC SUBSTANCES, HOUSTON, TEXAS, MAY 21-23, 1975.

ZINGULA, R.P., PRIVATE COMMUNICATION, 1976.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 384 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101217

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TRANSCRIPT

SENATE

COVER SHEET OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 385 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101218

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

ENVIRONMENTAL ASPECTS OF PRODUCED WATERS FROM OIL AND GAS EXTRACTION OPERATIONS IN OFFSHORE AND COASTAL WATERS

PREPARED BY SHEEN TECHNICAL SUBCOMMITTEE OFFSHORE OPERATIONS COMMITTEE

SEPTEMBER 30, 1975

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 386 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101219

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REPORT PREPARED BY PANEL ON ENVIRONMENTAL ISSUES: - DR. C.B. KOONS, EXXON PRODUCTION RESEARCH, HOUSTON. - DR. C.D. MCAULIFFE, CHEVRON OIL FIELD RESEARCH COMPANY LA HABRA, CALIFORNIA. - DR. F.T. WEISS (CHAIRMAN), SHELL DEVELOPMENT COMPANY, HOUSTON.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 387 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101220

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SENATE

I. SUMMARY AND CONCLUSIONS.

THIS REPORT REVIEWS THE CONSTITUENTS OF PRODUCED WATERS AND THEIR EFFECTS ON THE MARINE ENVIRONMENT BOTH IN OFFSHORE AND COASTAL AREAS. THE CONSIDERABLE DATA WHICH ARE AT HAND AND WHICH ARE DISCUSSED IN THIS REPORT SHOW CLEARLY THAT THE TOXICITY OF PRODUCED WATERS IS LOW. CONSEQUENTLY, PRODUCED WATERS DO NOT HAVE A DETRIMENTAL EFFECT ON THE MARINE ENVIRONMENT OR ON MARINE BIOTA. REFERENCES ARE LISTED WHICH PROVIDE AN EXTENSIVE BACKGROUND AND CONTAIN MUCH FURTHER, DETAILED INFORMATION.

A REVIEW OF THE LARGE AMOUNT OF DATA DISCUSSED IN THE REPORT LEADS TO THE FOLLOWING CONCLUSIONS:

1) NATURAL FORCES, INCLUDING DILUTION, EVAPORATION, AND CHEMICAL AND BIOLOGICAL REACTIONS, RAPIDLY ACT TO REDUCE THE CONCENTRATION OF HYDROCARBONS AND INORGANIC COMPONENTS IN PRODUCED WATERS.

2) BECAUSE OF THESE NATURAL FORCES, PRODUCED WATERS HAVE NOT BEEN FOUND TO CAUSE MEASURABLE EFFECTS ON THE COMPOSITION, APPEARANCE, OR THE BIOTA OF THE MARINE ENVIRONMENT.

3) FIELD STUDIES IN PETROLEUM PRODUCING AREAS SHOW THAT THE LOW LEVEL DISCHARGE OF HYDROCARBONS AND INORGANIC COMPONENTS WHICH ARISE FROM PETROLEUM OPERATIONS DO NOT HAVE A DETRIMENTAL EFFECT ON THE MARINE ENVIRONMENT OR THE MARINE BIOTA.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 388 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101221

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SENATE

/FN1/ 1. COLLINS, A.G. (1974), "SALINE GROUNDWATERS PRODUCED WITH OIL AND GAS," PROJECT 16060 EQQ. PREPARED FOR OFFICE OF RESEARCH AND MONITORING U.S. ENVIRONMENTAL PROTECTION AGENCY, U.S. DEPARTMENT OF INTERIOR, BUREAU OF MINES, BARTLESVILLE, OKLAHOMA, 74003.

/FN2/ 2. COLLINS, A.G. (1974) "GEOCHEMISTRY OF LIQUIDS, GASES, AND ROCKS FROM THE SMACKOVER FORMATION," REPORT OF INVESTIGATIONS 7897, U.S. DEPARTMENT OF THE INTERIOR, BARTLESVILLE ENERGY RESEARCH CENTER, BARTLESVILLE, OKLAHOMA 74003.

/FN3/ 3. COLLINS, A.G. (1975), "GEOCHEMISTRY OF OIL FIELD WATERS," AMERICAN ELSEVIER SCIENTIFIC PUBLISHING COMPANY, INC., NEW YORK.

/FN4/ 4. RITTENHOUSE, G., FULTON, R.B. III, GRABOWSKI, R.J. AND BERNARD, J.L. (1969), "MINOR ELEMENTS IN OIL FIELD WATERS," CHEMICAL GEOLOGY 4, PAGES 182-209.

II. COMPOSITION OF PRODUCED WATERS

PRODUCED WATERS GENERALLY CONTAIN APPRECIABLE CONCENTRATIONS OF DISSOLVED INORGANIC SALTS /1,2,3,4/ IN WHICH THE PRINCIPAL CATIONS ARE SODIUM, MAGNESIUM, CALCIUM. THE PRINCIPAL ANIONS ARE CHLORIDE, SULFATE, CARBONATE AND BICARBONATE. THE CONCENTRATIONS OF TOTAL DISSOLVED CONSTITUTENTS CAN VARY OVER A WIDE RANGE SUCH AS FROM A FEW MILLIGRAMS PER LITER TO AS MUCH AS 350,000 MG/LITER. COLLINS /1,3/ REVIEWED THE COMPOSITION OF MANY OIL FIELD WATERS AND FOUND THAT THE MAJORITY CONTAINED HIGH CHLORIDE CONCENTRATIONS. MORE DETAILED INFORMATION ON THE INORGANIC COMPONENTS IS GIVEN IN SECTION VI OF THIS REPORT.

TABLE 1 GIVES SOME DATA ON THE CONSTITUENTS AND THE TOXICITY BIOASSAY RESULTS OF A TYPICAL PRODUCED WATER FROM A CALIFORNIA OFFSHORE OPERATION. THESE SAMPLES WERE TAKEN FROM PLATFORM HARRY IN THE STATE OF CALIFORNIA WATERS OFF POINT CONCEPTION. THE TOXICITY DATA ARE EXPRESSED IN TERMS OF TLM (MEDIAN TOLERANCE LIMIT). THIS IS A STANDARD BIOASSAY TECHNIQUE USED TO DETERMINE THE CONCENTRATION OF THE TEST MATERIAL REQUIRED TO KILL HALF THE TEST ORGANISMS IN THE TIME INDICATED. THE READINGS OF TLM OF 100 PERCENT SHOW THAT MORE THAN HALF THE FISH (STICKLEBACK) SUBJECTED TO THE TEST SURVIVED FOR AT LEAST 96 HOURS IN THAT SAMPLE OF UNDILUTED PRODUCED WATER. THE 75 PERCENT VALUE INDICATES THAT NORMALLY MORE THAN HALF THE FISH SUBJECTED TO THE TEST SURVIVED FOR 96 HOURS IN A MIXTURE OF 75 PERCENT PRODUCED WATER AND 25 PERCENT SEAWATER.

HYDROCARBONS AND SOME ORGANIC COMPOUNDS MAY BE PRESENTED IN PRODUCED WATERS AT PART PER MILLION LEVELS. THEIR DETAILED COMPOSITIONS ARE DESCRIBED SUBSEQUENTLY. DISSOLVED OXYGEN MAY BE PRESENT AT LOW CONCENTRATION IN PRODUCED WATERS.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 389 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101222

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TABLE 1

VALUES REPORTED FOR COMPISITION AND TOXICITY OF PRODUCED WATER FROM PLATFORM HARRY, CALIFORNIA

TABLE OMITTED

A) THIS INFORMATION WAS RECEIVED FROM THE CALIFORNIA WATER QUALITY CONTROL BOARD, CENTRAL COAST REGION. TAKEN FROM REFERENCE /5/ PAGE 111-23.

/FN5/ 5. DRAFT ENVIRONMENTAL STATEMENT, DES 75-35, (1975), U.S. DEPARTMENT OF THE INTERIOR, ON OIL AND GAS DEVELOPMENT IN THE SANTA BARBARA CHANNEL, OUTER CONTINENTAL SHELF OFF CALIFORNIA, J-NE 6, PAGE 111-22.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 390 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101223

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TRANSCRIPT

SENATE

/FN6/ 6. GULF UNIVERSITIES RESEARCH CONSORTIUM (1974), "FINAL PROJECT PLANNING COUNCIL CONSENSUS REPORT," OFFSHORE ECOLOGY INVESTIGATION, REPORT NO. 138, SEPTEMBER 20.

/FN7/ 7. FARRELL, D. (1974), "BENTHIC COMMUNITIES IN THE VICINITY OF PRODUCING OIL WELLS IN THE SHALLOW LOUISIANA CONTINENTAL SHELF," PROJECT OB69-JM GULF UNIVERSITIES RESEARCH CONSORTIUM OFFSHORE ECOLOGY INVESTIGATIONS.

/FN8/ 8. KRITZLER, H. (1974), "OIL PRODUCTION AND POLYCHAETOUS ANNELIDS IN A LOUISIANA ESTUARY," PROJECT OB 56 HJM, GULF UNIVERSITIES RESEARCH CONSORTIUM OFFSHORE ECOLOGY INVESTIGATIONS.

/FN9/ 9. EL-SAYED, S.Z. (1974), "EFFECTS OF OIL PRODUCTION ON THE ECOLOGY OF PHYTOPLANKTUN OFF THE LOUISIANA COAST," PROJECT OB 66 JHM, GULF UNIVERSITIES RESEARCH CONSORTIUM OFFSHORE ECOLOGY INVESTIGATIONS.

/10/ 10. MARUM, J.P. (1974), "EFFECTS OF LONG TERM DRILLING AND PRODUCTION ON THE ZOOPLANKTON OF LOUISIANA COASTAL WATERS," PROJECT OB SS HJM, GULF UNIVERSITIES RESEARCH CONSORTIUM OFFSHORE ECOLOGY INVESTIGATIONS.

/11/ 11. FISH, A.G., MASSEY, L.L., INABINET, J.R. AND LEWIS, P.L. (1974), " A STUDY OF THE EFFECTS OF ENVIRONMENTAL FACTORS UPON THE DISTRIBUTION OF THE SELECTED SANDY BEACH ORGANISMS OF TIMBALIER BAY, LOUISIANA." PROJECT OB 64 HJM GULF UNIVERSITIES RESEARCH CONSORTIUM OFFSHORE ECOLOGY INVESTIGATIONS.

III. RESULTS OF MARINE STUDIES IN AREAS SUBJECTED.

TO LONG TERM OIL PRODUCTION

SOUTH TIMBALIER AREA, LOUISIANA. EXTENSIVE STUDIES HAVE BEEN MADE OF THE SOUTH TIMBALIER AREA IN THE GULF OF MEXICO AND IN TIMBALIER BAY, LOUISIANA BY A NUMBER OF INVESTIGATORS IN THE OFFSHORE ECOLOGY INVESTIGATION UNDER MANAGEMENT OF THE GULF UNIVERSITIES RESEARCH CONSORTIUM (GURC). /6/ THE STUDY AREA CONSISTED OF SOMEWHAT OVER 500 SQUARE MILES AND COMPRISED BOTH OFFSHORE AND COASTAL WATERS AND THE ADJACENT BEACHES. THE AREA IN TIMBALIER BAY WAS SELECTED BECAUSE IT HAS BEEN SUBJECTED TO INTENSIVE OIL AND GAS DRILLING AND PRODUCTION FOR OVER 40 YEARS. BIOLOGICAL STUDIES WERE UNABLE TO DOCUMENT ANY ADVERSE EFFECT OF PETROLEUM OPERATIONS SURROUNDING TYPICAL PLATFORMS IN THE CONTINENTAL SHELF AREA. THREE PLATFORMS WERE STUDIES IN THE OFFSHORE AREA AND TWO IN COASTAL WATERS. THERE WAS NO MEASURABLE EFFECT ON THE BENTHIC ORGANISM, /7/ OR UPON THE PHYTOPLANKTON /8/ SURROUNDING THE PETROLEUM OPERATIONS. IN FACT, PROFESSOR EL-SAYER /9/ FOUND THAT THE AREA OF THE OFFSHORE ECOLOGY INVESTIGATION WAS ONE OF THE MOST PRODUCTIVE IN THE GULF OF MEXICO. THERE WAS NO EVIDENCE THAT THE PETROLEUM OPERATIONS HAD ANY DELETERIOUS EFFECT ON THE PHYTOPLANKTON COMMUNITIES OFF THE LOUISIANA COAST. IN A PARALLEL STUDY, MARUM /10/ FOUND NO EVIDENCE TO INDICATE THAT OIL DRILLING AND PRODUCTION HAS CHANGED THE COPEPOD FAUNA OVER THE PAST 20 YEARS. FISH, MASSEY, INABINET, AND LEWIS /11/ STUDIES SEVERAL INTERTIDAL BEACH SPECIES IN SHALLOW WATER AREAS SINCE THEY EXPECTED THESE SPECIES TO BE GOOD INDICATORS OF ENVIRONMENTAL DISTURBANCE IN THE COASTAL AREA. THEY CONCLUDED THAT NATURAL FACTORS, SUCH AS SALINITY AND SEDIMENT SIZES, HAD THE PRINCIPAL INFLUENCE ON THE MARINE SPECIES THEY EXAMINED. THEY FOUND NO PERMANENT EFFECTS DUE TO OIL PRODUCTION OPERATIONS. THE OBSERVATIONS FROM THE GURC STUDIES CONCLUDE THAT NATURAL PHENOMENA SUCH AS SEASONALITY, FLODS, UPWELLINGS, AND THE CHANGES IN CONTRIBUTIONS OF LOW SALINITY WATER SILT, AND NUTRIENTS FROM THE RIVER SYSTEMS HAVE A MUCH GREATER IMPACE UPON THE ECO SYSTEM THAN DO PETROLEUM DRILLING AND PRODUCTION ACTIVITIES. THE LOW LEVEL DISCHARGE OF HYDROCARBONS AND INORGANIC SALTS WHICH CAN BE THE RESULT OF PETROLEUM PRODUCING OPERATIONS DOES NOT HAVE A DETRIMENTAL AFFECT ON THE MARINE ENVIRONMENT AND THE MARINE LIFE IN THAT AREA.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 391 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101224

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

/6/ GULF UNIVERSITIES RESEARCH CONSORTIUM (1974), "FINAL PROJECT PLANNING COUNCIL CONSENSUS REPORT," OFFSHORE ECOLOGY INVESTIGATION, REPORT NO. 138, SEPTEMBER 20.

/12/ MACKIN, J.G. (1971), "A STUDY OF THE EFFECT OF OIL FIELD BRINE EFFLUENTS ON BIOTIC COMMUNITIES IN TEXAS ESTUARIES," TEXAS A&M RESEARCH FOUNDATION PROJECT 735 REPORT, PAGE 72, NOVEMBER.

/13/ REFERENCE 5 PAGE III-24.

TEXAS BAYS AND ESTUARIES. IN ADDITION TO THE SHALLOW WATER STUDIES IN TIMBALIER BAY BY GURC, /6/ THERE HAS ALSO BEEN REPORTED A DETAILED INVESTIGATION ON THE EFFECTS OF OIL FIELD PRODICED WATERS IN TEXAS BAYS AND ESTUARIES BY MACKIN. /12/ LOW -TIDE WATER DEPTHS IN THE LOCATION HE STUDIED VARIED FROM 2.5 TO AROUND 9 FEET. CURRENT FLOWS WERE GENERALLY SMALL. HIS RESULTS SHOWED THAT THE DISCHARGES AFFECTED ONLY THE BOTTOM ORGANISMS AND THAT THIS EFFECT WAS LOCALIZED. THE HALO OF DEPRESSED BOTTOM FAUNA EXTENDED RADIALLY FOR APPROXIMATELY 400 FEET. AT DISTANCES GREATER THAN 500 FEET THE DIVERSITY AND NUMBER OF INDIVIDUALS WERE MORMAL FOR THE BAY. THE RATE OF DILUTION,EVEN IN VERY SHALLOW AREAS STUDIED BY MACKIN, WAS SUFFICIENT TO REDUCE THE TOXIC EFFECTS OF THE DISCHARGES TO A SMALL AREA. THUS, THE MINIMAL EFFECT OF DISCHARGES IN SHALLOW WATERS PROBABLY DOES NOT EXITS IN DEEPER WATERS. IN REFRENCE TO THE WORK OF MACKIN IT WAS SUGGESTED IN A RECENT DRAFT ENVIRONMENTAL STATEMENT /13/ THAT "BRINE DISCHARGES, UNDER CONDITIONS SUCH AS OCCUR IN DEEP WATER PROBABLY WOULD BE FOUND TO BE INEFFECTIVE, ALL OTHER THINGS BEING EGUAL, IN THE REDUCTION OF BOTTOM COMMUNITIES. FOR EXAMPLE, BRINE DISCHARGES IN 30 TO 150 FEET OF WATER RATHER THAN 8 FEET STUDIED BY MACKIN, WOULD BE SUBJECT TO ENORMOUSLY GREATER DILUTION, WITH PROBABLY GREATER BACTERIAL ACTION IN DESTRUCTION OF THE OIL CONTENT OF THE BRINE."

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 392 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101225

SERIAL NO. 96-H6

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TRANSCRIPT

SENATE

/FN14/ 14. NATIONAL ACADEMY OF SCIENCES (1975), OCEAN AFFAIRS BOARD WORKSHOP, "PETROLEUM IN THE MARINE ENVIRONMENT," REPORT OF THE WORKSHOP ON INPUTS, FATES, AND EFFECTS OF PETROLEUM IN THE MARINE ENVIRONMENT HELD AT AIRLIE, VIRGINIA, WASHINGTON, D.C.

/15/ 15. BATES, C.C. AND PEARSON, E. (1975), "INFLUX OF PETROLEUM HYDROCARBONS INTO THE OCEAN," OFFSHORE TECHNOLOGY CONFERENCE PAPER OTC 2390, HOUSTON,T EXAS.

/FN16/ 16. WILSON, R.D., MONAGHAN, P.H., OSANIK, A., PRICE, L.C. AND ROGERS, M.A. (1974), "NATURAL MARINE OIL SEEPAGES," SCIENCE 184, PP. 857-865.

/FN17/ 17. MCCOWN, B.H., BROWN, J. AND BARSDATE, R.J. (1972), "NATURAL OIL SEEPS AT CAPE SIMPSON, ALASKA; LOCATED INFLUENCE ON TERRESTRIAL HABITAT," IN "PROCEEDING OF THE SYMPOSIUM ON THE IMPACT OF OIL RESOURCE DEVELOPMENT IN NORTHERN PLANT COMMUNITIES," 23 AAAS ALASKA SCIENCE CONFERENCE, UNIVERSITY OF ALASKA, FAIRBANKS, PAGES 86-90.

/FN18/ 18. BARSDATE, R.J', ALEXANDER, V', AND BENOIT, R.E. (1972), "NATURAL OIL SEEPS AT CAPE SIMPSON, ALASKA; AQUATIC EFFECTS," IBID., PAGES 91-95.

/FN19/ 19. GERARDE, H.W. AND GERARDE, D.F. (1962), "THE UBIQUITOUS HYDROCARBONS," ASSOCIATION OF FOOD AND DRUG OFFICIALS OF THE UNITED STATES, VOLUMES XXV AND XXVI, 1971 AND 1972, PAGES 1-47.

/FN20/ 20. BLUMER, M., GILLARD, R.R.L. AND CHASE,T. (1971) "HYDROCARBONS OF MARINE PHYTOPLANKTON," MARINE BIOLOGY 8, PAGES 183-189.

/FN21/ 21. BLUMER, M. (1967), "HYDROCARBONS IN DIGESTIVE TRACT AND LIVER OF A BASKING SHARK," SCIENCE 156, PAGES 390-391.

/FN22/ 22. CLARK, R.C., JR. (1966), "SATURATED HYDROCARBONS IN MARINE PLANTS AND SEDIMENTS," M.S. THESIS, DEPARTMENT OF GEOLOGY AND GEOPHYSICS, MASSACHUSETTS INSTITUTE OF TECHNOLOGY.

/FN23/ 23. BENDORAITIES, J.G., BROWN, B.L. AND HEPNER, L.S. (1963), PROCEEDINGS SIXTH WORLD PETROLEUM CONGRESS, SECTION V, PAGE 13.

/FN24/ 24. YOUNGBLOOD, W.W., BLUMER, M., GUILLARD, R.L. FIORE, F. (1971), "SATURATED AND UNSATURATED HYDROCARBONS IN MARINE BENTHIC ALGAE," MARINE BIOLOGY 8, PAGES 190-201.

/FN25/ 25. KOONS, C.B., JAMIESON, G.W. AND CIERESZKO, L.S. (1965), "NORMAN ALKANE DISTRIBUTION IN MARINE ORGANISMS: POSSIBLE SIGNIFICANCE TO PETROLEUM ORIGIN," BULLETIN OF THE AMERICAN ASSOCIATION OF PETROLEUM GEOLOGIST 49, PAGES 301-304.

IV. INPUTS AND FATES OF HYDROCARBONS

THE NATIONAL ACADEMY OF SCIENCES REPORT /14/ ON "PETROLEUM IN THE MARINE ENVIRONMENT REVIEWED THE INPUT OF PETROLEUM HYDROCARBONS TO THE MARINE ENVIRONMENT FROM VARIOUS SOURCES. THIS STUDY ESTIMATES THAT THE WORLDWIDE INPUT OF OIL TO THE OCEANS FROM OFFSHORE DRILLING AND PRODUCTION IS 0.08 MILLION TONS PER YEAR. THE LARGER PORTION OF THIS LOSS (0.06 MILLION TONS PER YEAR) IS ACCOUNTED FOR BY MAJOR ACCIDENTS AND SPILLS RESULTING FROM LINE RUPTURES AND SIMILAR MECHANICAL FAILURES. THE REMAINING 0.02 MILLION TONS PER YEAR IS ATTRIBUTED TO MINOR SPILLS (50 BARRELS OR LESS PLUS DISCHARGES OF OIL FIELD PRODUCED WATERS DURING NORMAL DRILLING AND PRODUCING OPERATIONS. THIS INPUT SHOULD BE COMPARED WITH OTHER SOURCES AS SHOWN IN TABLE II. A PARTICULARLY IMPORTANT COMPARISON IS WITH THE MUCH HIGHER CONTINUOUS DISCHARGE OF PETROLEUM HYDROCARBONS FROM SUBMARINE SEEPS WHICH ARE ESTIMATED TO CURRENTLY TOTAL 0.6 MILLION METRIC TONS PER YEAR. /15,16/ /17, 18/ HYDROCARBONS FROM SEEPS HAVE BEEN CONTINUALLY DISCHARGED. SEEPS, LIKE MOST OTHER GEOLOGIC PHENOMENA, INVOLVE TIME SCALES MEASURED IN MILLIONS OF YEARS.

HYDROCARBONS HAVE ALSO BEEN CONTINUOUSLY ADDED TO THE MARINE ENVIRONMENT BY EROSION AND DISCHARGE OF UPLIFTED SEDIMENTARY ROCKS CONTAINING PETROLEUM HYDROCARBONS THAT HAVE BEEN GENERATED DURING THE BURIAL OF THESE SEDIMENTARY ROCKS.

IT IS CLEAR FROM THESE DATA THAT HYDROCARBONS HAVE BEEN CONTINUOUSLY DISCHARGED TO THE MARINE ENVIRONMENT. THE FRACTION OF HYDROCARBONS CONTRIBUTED BY OIL FIELD PRODUCTED WATERS IS SMALL AND DISPROVES THE CONTENTION THAT THERE MAY BE A DETRIMENTAL EFFECT FROM THE CONTINUOUS, LOW LEVEL DISCHARGE OF HYDROCARBONS FROM OFFSHORE PETROLEUM OPERATIONS. PETROLEUM HYDROCARBONS ARE NOT A FOREIGH SUBSTANCE TO THE MARINE ENVIRONMENT /19,20,21,21,23,24,25 / AND THERE IS NO DOCUMENTED ADVERSE EFFECT FROM THE CONTINUOUS DISCHARGE OF THESE HYDROCARBONS.

OFFSHORE HYDROCARBON DISCHARGES. PRODUCED WATER DISCHARGE FROM OFFSHORE OPERATIONS IS DILUTED WITH LARGE VOLUMES OF MOVING WATER. BECAUSE OF THE LARGE VOLUME OF WATER, THE DISCHARGED HYDROCARBONS ARE RAPIDLY DISPERSED. ONCE DISPERSION BEGINS, THE OIL IMMEDIATELY BEGINS TO UNDERGO CHANGES BOTH IN CONCENTRATION AND COMPOSITION THROUGH DILUTION, EVAPORATION, SOLUTION, SPREADING, EMULSIFICATION, AIR SEA INTERCHANGE, AND BIOLOGICAL DEGRADATION AS REVIEWED IN THE REPORT OF THE NATIONAL ACADEMY OF SCIENCE. /14/

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 393 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101226

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

/FNA A) FROM THE REPORT OF THE NATIONAL ACADEMY OF SCIENCES (REFERENCE 14).

TABLE II

INPUT OF PETROLEUM HYDROCARBONS INTO THE OCEAN. /A/

TABLE OMITTED

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 394 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101227

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

/FN26/ 26. ALPINE GEOPHYSICAL ASSOCIATES, INC. (1971), "OIL POLLUTION INCIDENT, PLATFORM CHARLIE, MAIN PASS BLOCK 41 FIELD, LOUISIANA, "PROJECT 15080 FTU 05/75, FOR THE WATER QUALITY OFFICE, ENVIRONMENTAL PROTECTION AGENCY, MAY, PP.6-7.

/FN27/ 27. MCAULIFFE, C.D., SMALLEY, A.E., GROVER, R.D., WELSH, W.M., PICKLE, W.S. AND JONES, G.E. (1975) "THE CHEVRON MAIN PASS BLOCK 41 OIL SPILL CHEMICAL AND BIOLOGICAL INVESTIGATOINS," PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL POLLUTION, SAN FRANCISCO, PP. 555-566.

/FN28/ 28. BROWN, R.A., SEARL, T.D., ELLIOTT, J.J., PHILLIPS, B.G., BRANDON, D.E. AND MONAGHAN, P.H. (1973), "DISTRIBUTION OF HEAVY HYDROCARBONS IN SOME ATLANTIC OCEAN WATERS," PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL SPILLS, PP. 505-519.

/FN29/ 29. MONAGHAN, PH, BRANDON, D.E., BROWN, R.A., SEARL, T.D. AND ELLIOTT, J.J.(1974), "MEASUREMENT AND INTERPRETATION OF NONVOLATILE HYDROCARBONS IN THE OCEAN, PART I. MEASUREMENTS IN ATLANTIC, MEDITERRANEAN, GULF OF MEXICO AND PERSIAN GULF AID. INJB.74. PREPARED FOR US. DEPARTMENT OF COMMERCE, MARITIME ADMINISTRATION BY EXXON PRODUCTION RESEARCH COMPANY, AND EXXON RESEARCH AND ENGINEERING COMPANY.

/FN30/ 30. KOONS,C.B. AND BRANDON,D.E. (1975), "HYDROCARBONS IN WATER AND SEDIMENT SAMPLES FROM COAL OIL POINT AREA OFFSHORE CALIFORNIA," OFFSHORE TECHNOLOGY CONFERENCE, PAPER OTC-2387, HOUSTON,T EXAS.

/FN31/ 31. KREIDER, R.E. (1971), "IDENTIFICATION OF OIL LEEKS AND SPILLS," PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL SPILLS," PP. 119-124, WASHINGTON, D.C.

/FN32/ 32. TEMPLETON, W.L. (1974), "SUMMARY REPORT ON EFFECTS OF OIL DISCHARGE DOMESTIC AND INDUSTRIAL WASTEWATERS ON THE FISHERIES OF LAKE MARACAIBO, VENEZUELA," BATTELLE NORTH WEST LABORATORY, REPORT TO CREOLE PETROLEUM CORPORATION, CARACAS, VENEZUELA.

IT IS IMPORTANT TO NOTE THAT, AS THE RESULT OF THESE NATURAL PROCESSES WHICH ACT TO DISPERSE AND DEGRADE OIL, THE ACTUAL MEASURED CONCENTRATIONS OF HYDROCARBONS IN OFFSHORE AND COASTAL WATERS IS LOW. THE EXTENT OF HYDROCARBON DISPERSION WAS THOROUGHLY STUDIED IN THE CASE OF THE MAIN PASS BLOCK 41 OIL SPILL, /26,27/ DETAILED STUDIES OF THIS OIL SPILL /27/ FOUND THAT DISSOLVED HYDROCARBONS WERE 200 PARTS PER BILLION AT THE PLATFORM BUT ONLY 1 PART PER BILLION ONE MILE AWAY. BROWN, MONAGHAN, AND THEIR CO WORKERS /28,29/ HAVE PUBLISHED RESULTS SHOWING THAT THE TANKER ROUTES IN THE ATLANTIC OCEAN AND GULF OF MEXICO CONTAINED AN AVERAGE OF 9 PERTS PER BILLION AT 10 METERS DEPTH. THEIR RESULTS SHOW THAT EXTRACTABLE ORGANICS, WHICH INCLUDES NATURAL LIPIDS AND OTHER ORGANIC COMPOUNDS, ARE PRESENT IN A SOMEWHAT HIGHER CONCENTRATION ESPECIALLY AS THE TANKER LANES APPROACHED LARGE CITIES. RECENTLY, KOONS AND BRANDON /30/ HAVE EXAMINED THE WATER COLUMN IN THE AREA OF NATURAL SEEPS OFF COAL OIL POINT NEAR SANTA BARBARA, CALIFORNIA, AND FOUND EXTRACTABLE HYDROCARBON LEVELS OF FROM 0.3 TO 16 PARTS PER BILLION. DESPITE THE CONTINUED INPUT OF HYDROCARBON IN THIS AREA FROM THESE NATURAL SEEPS, HIGH CONCENTRATIONS OF HYDROCARBONS HAVE NOT DEVELOPED.

FORM OF DISCHARGED HYDROCARBONS. HYDROCARBONS DISCHARGED WITH COPRODUCED WATERS FROM OIL AND GAS EXTRACTION ARE PRESENT IN THE WATER FOLLOWING REMOVAL OF THE MAJOR PORTIONS OF THE OIL IN SEPARATION AND TREATMENT FACILITIES. THE REMAINING HYDROCARBONS ARE PRESENT EITHER AS SMALL DROPLETS OR DISSOLVED HYDROCARBONS. THE CONCENTRATION OF THE DISSOLVED HYDROCARBONS MAY VARY UP TO ABOUT 50 PPM. BECAUSE THE HYDROCARBONS ARE DISSOLVED OR DISPERSED IN FINE DROPLET FORM, UPON DISCHARGE THEY RAPIDLY DISPERSE BY PHYSICAL PROCESSES AND ALSO THROUGH BIODEGRADATION AND PHOTOOXIDATION.

THE RATE OF EVAPORATION OF THE LOWER MOLECULAR WEIGHT FRACTIONS FROM A CRUDE OIL IS QUITE RAPID. FOR INSTANCE, KREIDER /31/ CONDUCTED SIMULATED WEATHERING EXPERIMENTS AND FOUND THAT A CRUDE OIL LOST ESSENTIALLY ALL COMPONENTS WHICH BOIL BELOW C12 IN 24 HOURS TIME. THE PROCESS OF EVAPORATION CAN REMOVE MUCH OF THE VOLATILE MATERIAL FROM AN OIL MASS.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 395 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101228

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

/FN33/ 33. KOONS, C.B. AND MONAGHAN, P.H. (1973), "PETROLEUM DERIVED HYDROCARBONS IN GULF OF MEXICO WATERS" IN TRANSACTIONS - GULF COAST ASSOCIATION OF GEOLOGICAL SOCIETIES 23, PP. 170-181.

/FN34/ 34. WEISS, F.T. (1975), "FATE OF SPILLED OILS, " MARINE ENVIRONMENTAL IMPLICATIONS OF OFFSHORE OIL AND GAS DEVELOPMENT IN THE BALTIMORE CANYON REGION OF THE MID ATLANTIC COAST ESTUARINE RESEARCH FEDERATION REPORT ERF 71-1, PAGES 185 TO 197.

/FN35/ 35. MERTENS,E.W. AND HAXBY, L.P. (1975), "RECENT ADVANCES IN UNDERSTANDING THE EFFECTS OF OIL IN THE MARINE ENVIRONMENT," WORLD PETROLEUM CONGRESS, PANEL DISCUSSION 25(3), PAGES 1-9 TOKYO.

/FN36/ 36. ZOBELL, C.E. (1969), "MICROBIAL MODIFICATIONS OF CRUDE OIL IN THE SEA," PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL SPILLS, PP. 317-326, NEW YORK.

/FN37/ 37. COLWELL, R.R., WALKER, J.D. AND NELSON, J.D., JR. (1973), "MICROBIAL ECOLOGY AND THE PROBLEM OF PETROLEUM DEGRADATION IN CHESAPEAKE BAY," IN MICROBIAL DEGRADATION OF OIL POLLUTANTS, LOUISIANA STATE UNIVERSITY, PUBLICATION NO. LSU-SG-73-01.

/FN38/ 38. MIGET, R.J., OPPENHEIMER, C.H., KATOR, H.I. AND LAROCK, P.A. (1969), "MICROBIAL DEGRADATION OF NORMAL PARAFFIN HYDROCARBONS IN CRUDE OIL," PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL SPILLS, PP. 327 TO 331, NEW YORK.

/FN39/ 39. WALKER, J.B., COLWELL, R.R. AND PETRAKIS, L. (1975), "A STUDY OF THE BIODEGRADATION OF LOUISIANA CRUDE OIL EMPLOYING COMPUTERIZED MASS SPECTROMETRY," PROCEEDINGS OF CONFERENCE ON PREVENTION AND CONTROL OF OIL POLLUTION, SAN FRANCISCO, CALIFORNIA, PP. 601-605.

/FN40/ 40. ROBERTSON, B., ARTHELGER, S., KINNEY, P.J. AND BUTTON, D.K. (1973), "HYDROCARBON BIODEGRADATION IN ALASKA WATERS." IN MICROBIAL DEGRADATION OF OIL POLLUTIONS, LOUISIANA STATE UNIVERSITY, NO. LSU-SG-73-01, PP. 171-184.

/FN41/ 41. AGOSTI, J.M' AND AGOSTI, T.E. (1972), "THE OXIDATION OF CERTAIN PRUDHOE BAY HYDROCARBONS OF MICRO ORGANISMS INDIGENOUS TO A NATURAL OIL SEEP AT UMIAT, ALASKA," IN "PROCEEDINGS OF THE SYMPOSIUM ON THE IMPACT OF OIL RESOURCE DEVELOPMENT IN NORTHERN PLANT COMMUNITIES," 23RD AAAS ALASKA SCIENCE CONFERENCE, UNIVERSITY OF ALASKA, FAIRBANKS. ALASKA, PP. 80-85.

/FN42/ 42. BARSDATE, R.J. AND ALEXANDER, V. (1970), "PHOTOSYNTHETIC ORGANISMS IN SUBARCTIC LAKE ICE," ARTIC, VOLUME 23, PAGE 301.

THIS IS IMPORTANT BECAUSE OF THE RELATIVELY HIGHER TOXICITY OF SOME OF THE VOLATILE FRACTIONS. THE BATTELLE NORTHWEST LABORATORIES, IN A PROJECT CARRIED OUT FOR CREOLE PETROLEUM IN VENEZUELA /32/ OBSERVED THAT THE TOXICITY OF CRUDE OIL WAS GREATLY REDUCED EVEN BY SHORT WEATHERING. ON RELATIVELY SHORT EXPOSURE OF THIN FILMS OF OIL ON WATER TO THE ATMOSPHERE, THEY FOUND A LARGE LOSS OF LIGHT AROMATICS BOTH FROM THE OIL AND FROM THE WATER COLUMN. IT IS ESTIMATED THAT EVAPORATIVE LOSSES IN THE MAIN PASS OIL SPILL IN THE GULF OF MEXICO MAY HAVE BEEN FROM 25 TO 30 PERCENT IN THE FIRST 24 HOURS. /26,27/ DISSOLVED HYDROCARBONS IN PRODUCED WATERS WHICH INCLUDE THOSE WITH LESS THAN 10 CARBON ATOMS IN THE MOLECULE EVAPORATE RAPIDLY INTO THE ATMOSPHERE AS WELL AS BIODEGRADE. FOR EXAMPLE, MEASUREMENT IN THE WATER COLUMN OF VOLATILE C3-C8 HYDROCARBONS IN THE VICINITY OF PRODUCING PLATFORMS IN THE GULF OF MEXICO SHOW TOTAL CONTENTS OF THESE HYDROCARBONS OF LESS THAN ONE PART PER BILLION. /33/

MICROBIAL DEGRADATION. IT IS IMPORTANT TO POINT OUT THAT HYDROCARBON OXIDIZING BACTERIA HAVE BEEN FOUND IN ALL WATERS STUDIES /14,34,35,36,37,38,39/. THESE BACTERIA, WHICH USE HYDROCARBONS FOR AN ENERGY SOURCE, ARE EFFECTIVE IN CONVERTING HYDROCARBONS TO CARBON DIOXIDE AND WATER. PROBABLY ONE OF THE MAJOR WAYS IN WHICH HYDROCARBONS ARE REMOVED IN ESTUARIES AND COASTAL AREAS IS BY MICROBIOLOGICAL DEGRADATION' FOR EXAMPLE, ZOBELL /36/ STATES THAT IN COASTAL AREAS BACTERIA CAN OXIDIZE FROM 0.02 TO 2 GRAMS OF HYDROCARBON PER SQUARE METER PER DAY DEPENDING ON SEVERAL FACTORS INCLUDING RATE OF THE ORDER OF A PART PER MILLION OF HYDROCARBON PER DAY. HYDROCARBON-OXIDIZING BACTERIA HAVE BEEN OBSERVED IN WARM WATERS, IN COLD WATERS SUCH AS THE COOK INLET /40/ AND THEIR PRESENCE HAS BEEN DOCUMENTED IN THE ARTICLE /17,18 41/ INCLUDING ASSOCIATION WITH ICE /42/. THE PRESENCE OF THESE BACTERIA IS AN INDICATION OF THE CONTINUAL INPUT OF HYDROCARBONS TO THE MARINE ENVIRONMENT, WHETHER THESE HYDRO CARBONS ARE FROM PETROLEUM OR BIOGENIC ORIGIN.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 396 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

101229

SERIAL NO. 96-H6

HEARINGS

TRANSCRIPT

SENATE

"HYDROCARBON POLLUTION OF EDIBLE SHELLFISH BY AN OIL SPILL," MARINE BIOASSAY 5, PP. 195-202.

/FN44/ 44. BLUMER, M., SASS, J., SOUZA, G., SANDERS, H.L., GRASSLE, J.F. AND HAMPSON, G.R. (1970), "THE WEST FALMOUTH OIL SPILL," WOODS HOLE OCEANOGRAPHIC INSTITUTION, WOODS HOLE, MASSACHUSETTES.

/FN45/ 45. BLUMER, M. AND SASS, J. (1972), "WEST FALMOUTH OIL SPILL, " DATA AVAILABLE IN NOVEMBER 1971, II., CHEMISTRY, WHOI 72-19 WOODS HOLE OCEANOGRAPHIC INSTITUTION, WOODS HOLE, MASSACHUSETTS, APRIL.

/FN46/ 46. LEE, R.F., SAUERHERBER, R., AND DOBBS, G.H. (1972) "UPTAKE, METABOLISMS AND DISCHARGE OF POLYCYCLIC AROMATIC HYDROCARBONS BY MARINE FISH," MARINE BIOLOGY 17, PP. 334-346.

/FN47/ 47. LEE, R.F., SAUERHEBER, R., AND DOBBS, G.H. (1972) "UPTAKE METABOLISM AND DISCHARGE OF POLYCYCLIC AROMATIC HYDROCARBONS BY MARINE FISH," MARINE BIOLOGY 17, PP. 201-208.

/FN48/ 48. LEE, R.F. (1975), "FATE OF PETROLEUM HYDROCARBONS

IN MARINE ZOOPLANKTON," PROCEEDINGS OF JOINT CONFERENCE ON

PREVENTION AND CONTROL OF OIL POLLUTION. SAN FRANCISCO, PP

201-208.

/FN49/ 49. ANDERSON, J.W., NEFF, J.M., COX, B.A., TATEM, H.E., AND HIGHTOWER, G.M.(9174), "THE EFFECTS OF OIL ON ESTUARINE ANIMALS; TOXICITY, UPTAKE AND DEPURATIONS, RESPIRATION," IN SYMPOSIUM: POLLUTION AND THE PHYSIOLOGICAL ECOLOGY AND ESTUARINE AND COASTAL WATER ORGANISMS, SPONSORED BY THE ENVIRONMENTAL PROTECTION AGENCY AND THE BELLE W. BARUCH COASTAL RESEARCH INSTITUTE OF THE UNIV OF SOUTH CAROLINA.

/FN50/ 50. VAUGHAN, B.E. (1973), "EFFECTS OF OIL AND CHEMICALLY DISPERSED OIL ON SELECTED MARINE BIOTA LABORATORY STUDY," BATTELLE NORTHWEST LABORATORIES, API PUBLICATION, NO.4191, NOV.

/FN51/ 51. TEAL, J.M. AND STEGEMAN, J.J. (1973), :ACCUMULATION, RELEASE AND RETENTION OF PETROLEUM HYDROCARBONS BY THE OYSTER, CRASSOSTREA VIRGINICA, " MARINE BIOLOGY 22, PP. 37-44.

V. EFFECTS OF HYDROCARBONS

IMPORTANT QUESTIONS REGARDING THE EFFECTS OF HYDROCARBONS IN THE MARINE ENVIRONMENT CONCERN WHETHER OR NOT HYDROCARBONS CAN BE TAKEN INTO MARINE ANIMAL TISSUES AND WHETHER THEY WILL ENTER THE FOOD WEB. THESE IMPORTANT QUESTIONS HAVE NOW BEEN THOROUGHLY EXAMINED AND IT HAS BEEN CONCLUDED THAT THERE IS NO EVIDENCE FOR A FOOD WEB MAGNIFICATION OF HYDROCARBONS IN MARINE ORGANISMS.

THIS CONCERN WAS INITIALLY PUT INTO FORM BY SOME WORK OF BLUMER OF THE WOODS HOLE OCEANOGRAPHIC INSTITION. BLUMER'S WORK WAS INITIATED FOLLOWING A SPILL OF FUEL OIL NEAR WEST FALMOUTH, MASSACHUSETTES IN SEPTEMBER, 1969. BLUMER /43, 44,45/ ANALYZED OYSTERS, SCALLOPS, AND OTHER MARINE ORGANISMS AND FOUND THAT THEY HAD TAKEN UP OIL FRACTIONS. HE KEPT THREE OYSTERS IN FLOWING SEAWATER IN HIS LABORATORY. ONE OYSTER WAS ANALYZED AFTER IT HAS BEEN KEPT IN FLOWING SEAWATER FOR 72 DAYS AND THE OTHER TWO AFTER 180 DAYS. HIS PUBLICATION IN 1970 /44/ STATED THAT NONE OF THESE THREE OYSTERS HAD PURGED THEMSELVES OF THE OIL THEY CONTAINED PRIOR TO THE BEGINNING OF THE EXPERIMENT. HE CONCLUDED, THUS, ONCE CONTAMINATED, SHELLFISH, CANNOT CLEANSE THEMSELVES OF OIL POLLUTION.

A NUMBER OF SCIENTISTS HAVE REINVESTIGATED THIS MATTER AND HAVE REFUTTED BLUMER'S STATEMENT. /14,49,50,51/ EXPERIMENTS HAVE BEEN DONE WITH, LITERALLY, THOUSANDS OF MARINE ANIMALS. THE TEST ORGANISM INCLUDE VARIOUS SPECIES OF OYSTERS, SHRIMP, CRABS, AND COPEPODS, AS WELL AS SEVERAL KINGS OF FISH. THESE EXPERIMENTS HAVE TAKEN PLACE IN A NUMBER OF LABORATORIES IN THE UNITED STATES. THE TIME OF EXPOSURE HAS VARIED FROM A MATTER OF HOURS TO SEVERAL WEEKS. INEVERY INSTANCE, RELEASE OF HYDROCARBONS OCCURRED. DATA NOW IN HAND CLEARLY SHOW THAT MARINE ANIMALS DO TAKE UP HYDROCARBONS BY MARINE MUSSELS, FISH AND BY COPEPODS. THEY FOUND THAT THESE COMPONDS DID INDEED FIND THEIR WAY FROM SEAWATER INTO THE MARINE ANIMAL TISSUES, BUT THAT WHEN THE ANIMALS WERE PLACED IN CLEAN WATER, THE HYDROCARBONS WERE LOST' THE MUSSELS PURGED THE HYDRO CARBONS UNCHANGED WHEREAS THE FISH AND COPEPODS METABOLIZED THESE HYDROCARBONS. ANDERSON /49/ CARRIED OUT EXPOSURE TESTS ON OYSTERS AND CLAMS EXPOSED TO CRUDE OILS AND PETROLEUM PRODUCTS. THE ANIMALS WERE THEN PLACED IN CLEAN SEAWATER.

/FN43/ 43. BLUMER, M., SOUZA,G., SASS, J. (1970),

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HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 397 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

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/FN50/ 50. VAUGHAN, B.E. (1973), "EFFECTS OF OIL AND CHEMICALLY DISPERSED OIL ON SELECTED MARINE BIOTA LABORATORY STUDY, BATTELLE NORTHWEST LABORATORIES, API PUBLICATION, NO.4191, NOVEMBER.

/FN51/ 51. TEAL, J'M. AND STEGEMAN, J.J. (1973), "ACCUMULATION, RELEASE AND RETENTION OF PETROLEUM HYDROCARBONS BY THE OYSTER CRASSOSTREA VIRGINIA," MARINE BIOLOGY 22, PP. 37-44.

FN14

/FN14/ 14. NATIONAL ACADEMY OF SCIENCES (1975), OCEAN AFFAIRS BOARD WORKSHOP, "PETROLEUM IN THE MARINE ENVIRONMENT," REPORT OF THE WORKSHOP ON INPUTS, FATES, QND EFFECTS OF PETROLEUM IN THE MARINE ENVIRONMENT HELD AT AIRLIE, VIEGINIA, WASHINGTON,DC.

/FN52/ 52. ANDERSON, J.W., NEFF, J.M., COX, B.A., TATEM,H.E. AND HIGHTOWER, G.M. (1974), "CHARACTERISTICS OF DISPERSIONS AND WATER SOLUBLE EXTRACTS OF CRUDE AND REFINED OILS AND THEIR TOXICITY TO ESTUARINE CRUSTACEANS AND FISH," MARINE BIOLOGY PP. 75,88.

SPECIFIC ANALYSES FOR INDIVIDUAL HYDROCARBONS WERE MADE WITH METHODS ABLE TO DETECT CONCENTRATIONS OF HYDROCARBON 0.1 PPM AND GREATER. PURGING WAS FOUND TO THE LEVEL OF ANALYTICAL SENSITIVITY. VERY SIMILAR DATA HAVE NOW BEEN FOUND IN STUDIES AT OTHER LOCATIONS IN THE UNITED STATES INCLUDING BATTELLE NORTHWEST IN THE STATE OF WASHINGTON /50/ AND MORE RECENT DATA FROM WOODS HOLE /51/ USING, IN EACH CASE, LOCAL ANIMALS. IN EVERY CASE EXAMINED, ESSENTIALLY COMPLETE PURGING WAS FOUND TO OCCUR.

THE NATIONAL ACADEMY OF SCIENCE REPORT /14/ STATES: "ORGANISMS SUCH AS MUSSELS AND OYSTERS HAVE BEEN SHOWN TO ELIMINATE MOST ABSORBED PETROLEUM HYDROCARBONS WHEN PLACED IN CLEAN WATER."

ACCUMULATION IN THE FOOD WEB. THE ADDITIONAL QUESTION OF ACCUMULATION OF PETROLEUM HYDROCARBONS IN THE FOOD SHOWN TO BE CONSIDERED. LEE'S RESULTS/46,47,48/ SHOW A RAPID METABOLISM OF CERTAIN AROMATIC HYDROCARBONS IN FISH AND COPEPODS. DATA FROM ANDERSON AND OTHERS SHOW RELATIVELY RAPID PURGING OF HYDROCARBONS FROM ANIMALS PLACED IN A CLEAN ENVIRONMENT. ONCE AN OIL SPILL EPISODE HAS PASSED, ANY AFFECTED ORGANISMS CLEANSE THEMSELVES QUICKLY OF WHATEVER OIL CONTAMINATION THAT THEY MAY HAVE INCURRED. THEREFORE, IT IS NOT POSSIBLE FOR SUCH CONTAMINATION TO BECOME CONCENTRATED BY TRANSFER FROM ONE TROPHIC LEVEL TO THE NEXT THROUGH THE FOOD CHAIN. THE NATIONAL ACADEMY REPORT /14/ STATES "THERE IS NO EVIDENCE FOR FOOD WEB MAGNIFICATION OF PETROLEUM HYDROCARBONS IN MARINE ORGANISMS."

CONSEQUENTLY, THE NATIONAL ACADEMY REPORT /14/ CONCLUDES THAT THE EFFECT OF OIL CONTAMINATION ON HUMAN HEALTH APPEARS NOT TO BE CAUSED FOR ALARM.

TOXICITY OF HYDROCARBONS. TO DISTINGUISH THE TOXICITY OF CRUDE OILS FROM PROCESSED OILS, BIOASSAY DATA HAVE BEEN OBTAINED ON A NUMBER OF MARINE SPECIES. DATA OBTAINED BOTH FROM BATTELLE NORTHWEST AND FROM TEXAS A&M /52/ SHOW THAT PROCESSED OILS ARE CONSIDERABLY AND CONSISTENTLY MORE TOXIC THAN THE CRUDE OILS. SOME OF THESE DATA, SHOWN IN TABLE III CLEARLY POINT OUT THAT THE MEDIAN TOLERANCE LIMIT TLM IS HIGHER WITH TYPICAL CRUDES THAN WITH PROCESSED OILS IN BIO ASSAYS CONDUCTED WITH ANUMBER OF MARINE SPECIES. THIS AGREES WITH THE EXPERIENCE THAT OIL SPILLS RESULTING FROM CRUDE OIL LOSSES OR PRODUCING ACCIDENTS ARE LESS SEVERE THAN FROM PRODUCT SPILLS. THE DATA IN TABLE III ARE EXPRESSED AS THE MEDIAN TOLERANCE LIMIT (TLM) IN PARTS PER MILLION. THUS, A TLM OF 1 PPM INDICATES A MATERIAL MORE TOXIC THAN A TLM OF 10 PPM.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 398 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

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/FN27/ 27. MCAULIFFE, C.D., SMALLEY, A.E., GROVER, R.D., WELSH, W.M. PICKLE, W.S. AND JONES, G.E. (1975), "THE CHEVRON MAIN PASS BLOCK 41 OIL SPILL CHEMICAL AND BIOLOGICAL INVESTIGATIONS. PROCEEDINGS OF JOINT CONFERENCE ON PREVENTION AND CONTROL OF OIL POLLUTION, SAN FRANCISCO, PP.555-566.

/FN53/ 53. GORDON, D.C., JR. AND PROUSE, N.J. (1973). "THE EFFECTS OF THREE DIFFERENT OILS ON MARINE PHYTOPLANKTON PHOTOSYNTHESIS," BEDFORD INSTITUTE OF OCEANOGRAPHY, DARTMOUTH, NOVA SCOTIA.

/FN54/ 54. STRAUGHAN, D. (1975), REPORT IN PREPARATION FOR THE AMERICAN PETROLEUM INSTITUTE.

EACH SET OF THE MARINE ANIMALS WAS EXPOSED TO THE DILUTED WATER SOLUBLE FRACTIONS PREPARED IN THE LABORATORY FROM EACH OF THE INDICATED OILS. THE HYDROCARBON VALUES LISTED WERE DETERMINED ON THE AMBIENT, TEST WATER PREPARED AT THE INITIAL LABORATORY TESTINT TIME. FOR MORE DETAILS ON THE TEST PROCEDURES, SEE REFERENCE 52. THESE WATER SOLUBLE HYDROCARBON CONCENTRATIONS CORRESPOND TO VERY MUCH HIGHER CONCENTRATIONS OF WHOLE OIL. FOR EXAMPLE, THE EQUILIBRIUM CONCENTRATION OF DISSOLVED HYDROCARBONS FOR THE OILS TESTED VARIED FROM 1.3 TO 24 PPM. IF THE OILS WERE DISCHARGED TO A WATER SURFACE IN A FIELD SITUATION, THE DISOLVED HYDROCARBON CONCENTRATIONS WOULD BE LOW AS WAS OBSERVED DURING THE MAIN PASS BLOCK 41 OIL SPILL. /27/

THE LEVELS OF HYDROCARBONS REQUIRED TO SHOW TOXICITY ARE OF THE ORDER OF PARTS PER MILLION AS CAN BE SEEN FROM TABLE III. AS DISCUSSED ABOVE, HYDROCARBON LEVELS FOUND EVEN IN EXPOSED AREAS RANGE FROM 1 TO 20 PARTS PER BILLION. IN THE FIELD, LOSSES OR DISPERSION OF HYDROCARBONS OCCUR RAPIDLY AND GO BELOW TOXIC LEVELS. THE FIELD STUDIES, DISCUSSED EARLIER, SHOW THAT LOW LEVEL DISCHARGE OF HYDROCARBONS PRESENT IN SEAWATER IN CONCENTRATIONS LESS THAN 30 PARTS PER BILLION ACTUALLY STIMULATED PHYTOPLANKTON GROWTH IN LABORATORY EXPERIMENTS. IF HIGHER CONCENTRATIONS WERE PRESENT, THERE WAS AN INHIBITION OF PHOTOSYTHESIS BELOW CONTROL LEVELS.

IN HER INVESTIGATION, NOW IN ITS THIRD YEAR, DR. DALE STRAUGHAN /54/ OF THE UNIVERSITY OF SOUTHERN CALIFORNIA FINDS THAT THE NATURAL MARINE OIL SEEPS NEAR SANTA BARBARA DO NOT AFFECT THE GROWTH RATE OF MARINE ANIMALS IN THE INTERTIDAL AND OFFSHORE AREA. HER GROUP CONDUCTED A STUDY TO SAMPLE THE BIOTA IN THE IMMEDIATE VICINITY OF THE NATURAL OIL SEEPS AND COMPARED THEM WITH THE SAME SPECIES WHICH LIVED AT NEARBY CATALINA ISLAND WHERE THERE IS NO SIGNIFICANT EXPOSURE TO PETROLEUM. MARINE LIFE FLOURISHED IN THE SEEP AREA. THE RESULTS OF STUDIES IN THE SEEP AREA OFF COAL OIL POINT HAVE PRODUCED NO EVIDENCE OF ABNORMALITITES OR USUAL DISEASES.

REAUTHORIZATION OF THE RCRA

HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 399 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

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TABLE II

OIL BIOASSAYS ON SEVERAL MARINE ANIMALS

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STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

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MUSKIE E S

GRAVEL M

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BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

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/FN1/ 1. COLLINS, A.G. (1974), "SALINE GROUNDWATERS PRODUCED WITH OIL AND GAS," PROJECT 16060 EQQ. PREPARED FOR OFFICE OF RESEARCH AND MONITORING U.S. ENVIRONMENTAL PROTECTION AGENCY, U.S. DEPARTMENT OF INTERIOR, BUREAU OF MINES, BARTLESVILLE, OK74003.

/FN2 2. COLLINS, A.G. (1974), "GEOCHEMISTRY OF LIQUIDS, GASES AND ROCKS FROM THE SMACKOVER FORMATION," REPORT OF INVESTIGATIONS 7897, U.S. DEPARTMENT OF THE INTERIOR, BARTLESVILLE ENERGY RESEARCH CENTER, BARTLESVILLE, OK74003.

/FN3/ 3. COLLINS, A.G. (1974), "GEOCHEMISTRY OF OIL FIELD WATERS," AMERICAN ELSEVIER SCIENTIFIC PUBLISHING CO, INC.NY.

/FN4/ 4. RITTENHOUSE, G., FULTON, R.B.III, GRABOWSKI, R.J. AND BERNARD, J.L. (1969) "MINOR ELEMENTS IN OIL FIELD WATERS," CHEMICAL GEOLOGY 4, PAGES 189-209.

/FN56/ 56. KETCHUM, B.H. (1973), "SYMPOSIUM ON OCEAN POLLUTION," STATEMENT MADE BEFORE SENATE COMMERCE COMMITTEE, SUBCOMMITTEE ON OCEANS AND ATMOSPHERE, JUNE 12.

VI. EFFECTS OF INORGANIC COMPONENTS

THE EXTENSIVE PUBLISHED SURVEYS OF THE COMPOSITION OF OIL FIELD PRODUCED WATERS /1,2,3,4/ SHOW THAT THE PREDOMINANT CATIONS IN ORDER OF DECREASING CONCENTRATION ARE SODIUM, CALCIUM, AND MAGNESIUM. RITTENHOUSE AND HIS CO WORKERS /4/ CONCLUDED THAT THE COMPONENTS IN OIL FIELD WATERS ARE TYPICALLY PRESENT IN THE RANGES OF CONCENTRATIONS INDICATED IN TABLE IV. COLLINS /1/ PROVIDES EXTENSIVE DATA ON PRODUCED WATERS FROM MANY LOCATIONS. TYPICAL SODIUM CONCENTRATIONS RANGE FROM 23,000 TO 57,000 MG PER LITER. TYPICAL CALCIUM CONCENTRATIONS ARE BETWEEN 2,500 TO 25,800 MG PER LITER AND THOSE FOR MAGNESIUM ARE FROM 100 TO 5,000 MG PER LITER. THERE ARE OCCASIONAL WATERS IN WHICH VALUES EITHER MUCH HIGHER OR LOWER THAN THE AVERAGES ARE OBSERVED.

IT IS IMPORTANT TO NOTE THAT THE METAL IONS PRESENT IN HIGHEST CONCENTRATIONS ARE THOSE WHICH ARE COMMON EITHER TO SEAWATER OR MANY TERRESTRIAL DEPOSITS AND ARE NOT CONSIDERED HAZARDOUS. THOSE METALS GENERALLY CONSIDERED AS TOXIC ARE PRESENT AT VERY LOW CONCENTRATIONS, OFTEN BELOW THE LEVEL OF DETECTION OF EVEN THE SENSITIVE METHODS USED. THE METALS WHICH WOULD BE OF GREATEST CONCERN IN THE ENVIRONMENT ARE THOSE WHICH ARE TOXIC IN CONCENTRATIONS OF PARTS PER MILLION OR LESS. TO CONSIDER ANY POSSIBLE HAZARDS IN DISCHARGING PRODUCED WATERS CONTAINING TOXIC METALS INTO THE MARINE ENVIRONMENT, IT IS NECESSARY TO CONSIDER THE FOLLOWING THREE FACTORS:

(1) CONCENTRATION OF TRACE METALS IN PRODUCED WATERS (SEE

TABLE V)

(2) CONCENTRATION OF TRACE METALS IN NORMAL SEAWATER (SEE

TABLE VI)

(3) TOXICITY LEVELS OF TOXIC METALS (SEE TABLE VII).

EXCELLENT DATA COVERNING THESE THREE POINTS ARE AVAILABLE WHICH CLEARLY SHOW THE LACK OF SIGNIFICANT HAZARD FROM DISCHARGE OF TRACE METALS INTO A MARINE ENVIRONMENT. TABLE V, TAKEN FROM THE PUBLICATION OF RITTENHOUSE, FULTON, GRABOWSKI, AND BERNARD /4/ GIVES DATA ON THE MEDIAN CONCENTRATION OF ELEMENTS IN PRODUCED WATERS FROM MANY LOCATIONS. SOME DATA ARE ALSO GIVEN FOR THESE CONSTITUENTS IN SEAWATER AND AN ESTIMATE GIVEN FOR DETECTION LIMIT OF THE SENSITIVE ANALYTICAL TECHNIQUES EMPLOYED. ANOTHER AND MORE COMPLETE SET OF DATA ON THE COMPOSITION OF SEAWATER IS GIVEN IN TABLE VI WHICH IS TAKEN FROM A RECENT PUBLICATION OF THE NATIONAL ACADEMY OF SCIENCES. /55/ WITH THE EXCEPTION OF CU, CR, MN, AND SR, THE (WORD ILLEGIBLE) OF TRACE METALS IN PRODUCED WATERS IS NOT MUCH DIFFERENT FROM (WORD ILLEGIBLE).

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HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

SERIAL NO. 96-H6

PART 401 OF 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

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TABLE IV

TYPICAL CONCENTRATION RANGES OF INORGANIC COMPONENTS IN PRODUCED WATERS

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HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

U.S. SENATE

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TABLE V

MEDIAN CONCENTRATIONS OF TRACE METALS IN PRODUCED WATERS /A

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FOOTNOTES TO TABLE OMITTED

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HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

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TABLE VI

COMPOSITION OF SEAWATER

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STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

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MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

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HEARINGS BEFORE THE SUBCOMMITTEE ON RESOURCE PROTECTION OF THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED

STATES SENATE NINETY SIXTH CONGRESS FIRST SESSION, 790322 AND 790323

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HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

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PRESSLER L

YAGO J W STAFF DIRECTOR

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TABLE VII

TOXIC ELEMENTS OF CRITICAL IMPORTANCE IN MARINE POLLUTION B ON POTENTIAL SUPPLY & TOXICITY LISTED IN ORDER OF DECREA TOXICITY

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AND HEARINGS RECOVERY BEFORE ACT THE

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AND STATES FOREIGN SENATE COMMERCE NINETY

SIXTH HOUSE CONGRESS OF FIRST REPRESENTATIVES SESSION, NINETY-FIFTH 790322 CONGRESS AND SECOND 790323 SESSION

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STAFFORD R T

BAKER H H

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/FN58/ 58. COUNCIL ON ENVIRONMENTAL QUALITY (1972), "THE THIRD ANNUAL REPORT OF THE COUNCIL ON ENVIRONMENTAL QUALITY U.S. GOVERNMENT PRINTING OFFICE, WASHINGTON.D.C. 20402, AUGUST.

/FN59/ 59. NATIONAL ACADEMY OF SCIENCES (1974), "WATER QUALITY CRITERIA," U.S. GOVERNMENT PRINTING OFFICE, WASHINGTON D.C.

/FN60/ 60. KETCHUM, B.H' (1975), "ASSESSING POTENTIAL OCEAN POLLUTANTS, "NATIONAL ACADEMY OF SCIENCES, WASHINGTON,D.C. PG 301.

/FN61/ 61. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (1974), "DRAFT DEVELOPMENT DOCUMENT FOR EFFLUENT LIMITATIONS GUIDELINES AND NEW SOURCE PERFORMANCE STANDARDS FOR THE OIL AND GAS EXTRACTION POINT SOURCE CATEGORY," PAGE V-4 OCTOBER.

/FN69/ 69. LERMAN, A'& CHILDS, C.W. (1973), "METAL ORGANIC COMPLEXES IN NATURAL WATERS: CONTROL OF DISTRIBUTION BY THERMODYANAMIC, KINETIC AND PHYSICAL FACTORS," IN "TRACE METALS AND METAL ORGANIC INTERACTIONS IN NATURAL WATERS." EDITED BY SINGER, P.C., ANN ARBOR PUBL.,INC. ANN ARBOR MICHIGAN.

/FN70/ 70. MOREL, F., MCDUFF R.E. AND MORGAN J.J.(1973), "INTERACTIONS AND CHEMOSTASIS IN AQUATIC CHEMICAL SYSTEMS; ROLE OF PH, PE, SOLUBILITY AND COMPLEXATION, IN "TRACE METALS AND METAL ORGANIC INTERACTIONS IN NATURAL WATERS." EDITED BY SINGER, P.C., ANN ARBOR PUBL., INC., ANN ARBOR.MICHIGAN.

/FN71/ 71. WILSON, R.C.H. (1972), "PREDICTION OF COPPER TOXICITY IN RECEIVING WATERS. J. FISH. RES. BD.CANADA, 29, PAGES 1500-1502.

TITLE PAGE OMITTED

TABLE VII PRESENTS A LISTING OF TOXIC ELEMENTS CONSIDERED TO BE OF CRITICAL IMPORTANCE TO MARINE POLLUTION. THIS TABLE IS TAKEN FROM A PRESENTATION MADE BY DR. B.H. KETCHUM OF WOODS HOLE TO THE SENATE COMMERCE COMMITTEE. /56/ A NUMBER OF IMPORTANT POINTS COME FROM THIS TABLE. FIRST CONSIDERATION SHOULD BE GIVEN TO THE TOP TIER OF THE SIX MOST TOXIC ELEMENTS (HG, CD, AG, NI, SE, PB). PRODUCED WATERS DO NOT NORMALLY CONTAIN CONCENTRATIONS OF THESE SIX ELEMENTS GREATER THAN THOSE FOUND IN SEAWATER. RECENTLY, ATTENTION HAS BEEN PAID TO THE DETERMINATION OF THE TWO MOST TOXIC ELEMENTS (HG AND CD) IN EFFLUENTS FROM A NUMBER OF CRUDE OIL OFFSHORE PRODUCTION UNITS BY THE ROBERT S. KERR ENVIRONMENTAL RESEARCH LABORATORY /58/ IN ESSENTIALLY ALL SAMPLES EXAMINED, VALUES WERE BELOW THE LEVELS OF DETECTION WHICH WERE (SYMBOL OMITTED) 50 PARTS PER BILLION CD AND (SYMBOL OMITTED) 0.5 PART PER BILLION FOR HG.

OF THE LOWER TIER OF TOXICITY (CU, CR, AS, AZ, MN) THERE SEEMS NOT TO BE ANY REAL CAUSE FOR DAMAGE BECAUSE OF THE LOW LEVELS AT WHICH THESE TRACE ELEMENTS ARE PRESENT IN PRODUCED WATERS.

THERE IS AN INCREASING BODY OF EVIDENCE INDICATING THAT THERE ARE NATURAL PROCESSES OPERATING TO REDUCE BOTH THE CONCENTRATION AND TOXICITY OF TRACE METALS DISSOLVED IN WATER. IN ORDER FOR A HEAVY METAL TO BE TOXIC IT APPARENTLY MUST BE IN THE IONIC STATE, /69, 70, 71/ IN MOST NATURAL WATERS MUCH OF THE FREE METAL IONS WOULD PROBABLY BE BOUND TO ORGANIC SUBSTANCES. NATURALLY PRESENT IN THE WATER, DECREASING THE RELATIVE PERCENTAGE OF THE IONIC SPECIES. THERE IS INDIRECT EVIDENCE THAT ORGANICALLY CHELATED HEAVY METALS IN AQUEOUS SOLUTIONS DO NOT HAVE AS GREAT AN EFFECT UPON ORGANISMS AS DO SOLUTIONS OF THE METAL SALTS. /71/ THIS COULD BE DUE EITHER TO THE FACT THAT THE ORGANO METALLIC COMPLEX IS TOO BULKY TO ENTER A BIOLOGICAL SYSTEM OR IT COULD BE DUE TO THE LACK OF AVAILABILITY OF THE METAL FOR REACTION WITH ENZYMES WITHIN THE CELLS.

ANOTHER SIGNIFICANT CONSIDERATION IS THE REALATIVE CONTRIBUTION OF TRACE ELEMENTS FROM MAN MADE SOURCES AND FROM NATURAL RIVER FLOW. WHERE THE NATURAL CONTRIBUTION IS A LARGE PORTION OF THE POTENTIAL SUPPLY, CONTROL OF INDIVIDUAL MAN MADE SOURCE WOULD HAVE LITTLE EFFECT ON WATER QUALITY. THEREFORE, IT WOULD NOT BE PRACTICAL TO EMPHASIZE LIMITED CONTROL EXCEPT IN ISOLATED LOCATIONS, SUCH AS IN URBAN OR INDUSTRIAL AREAS, WHERE INDIVIDUAL CONTRIBUTIONS CAN BE APPRECIABLE.

THE CONCEPT OF RELATIVE CRITICAL INDEX IN THE FINAL COLUMNS OF TABLE VII IS DERIVED BY KETCHUM /60/ BY DIVIDING THE ANNUAL AMOUNT OF A SUBSTANCE MOBILIZED BY EITHER HUMAN OR NATURAL ACTIVITIES BY THE TOXICITY LEVEL. THE REALATIVE CRITICAL INDEX HELPS TO IDENTIFY ELEMENTS AS POLLUTANTS AND ASSISTS PUTTING A PRIORITY ON SOURCES.

OVERSIGHT REAUTHORIZATION OF -- THE RESOURCE RCRA CONSERVATION AND

HEARINGS RECOVERY ACT BEFORE THE

HEARING SUBCOMMITTEE ON BEFORE THE RESOURCE PROTECTION SUBCOMMITTEE OF ON THE OVERSIGHT COMMITTEE AND INVESTIGATIONS ON ENVIRONMENT OF AND THE PUBLIC COMMITTEE WORKS ON INTERSTATE UNITED

AND FOREIGN STATES COMMERCE SENATE NINETY

SIXTH HOUSE CONGRESS OF REPRESENTATIVES FIRST SESSION, NINETY-FIFTH CONGRESS 790322 AND SECOND SESSION 790323

SERIAL NO. SERIAL NO. 95-183 96-H6 4781030

PART PART 407 002 OF OF 487 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

HOUSE OF REPRESENTATIVES SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

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/FN61/ 61. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (1974), "DRAFT DEVELOPMENT DOCUMENT FOR EFFLUENT LIMITATIONS GUIDELINES AND NEW SOURCE PERFORMANCE STANDARDS FOR THE OIL AND GAS EXTRACTION POINT SOURCE CATEGORY," PAGE V-4 OCTOBER.

/FN62/ 62. MACKIN, J.G. (1973), "A REVIEW OF SIGNIFICANT PAPERS ON EFFECTS OF OIL SPILLS AND OIL FIELD BRINE DISCHARGE ON MARINE BIOTIC COMMUNITIES," TEXAS A&M RESEARCH FOUNDATION PROJECT 737 REPORT, PP.4-8, FEBRUARY.

/FN12/ 12. MACKIN, J.G. (1971), "A STUDY OF THE EFFECT OF OIL FIELD BRINE EFFLUENTS ON BIOTIC COMMUNITIES IN TEXAS ESTUARIES," TEXAS A&M RESEARCH FOUNDATION PROJECT 735 REPORT PAGE 72, NOVEMBER.

/FN6/ 6. GULF UNIVERSITIES RESEARCH CONSORTIUM (1974), "FINAL PROJECT PLANNING COUNCIL CONSENSUS REPORT." OFFSHORE ECOLOGY INVESTIGATION, REPORT NO. 138, SEPTEMBER 20.

/FN64/ 64. CASTENHOLZ,R.W. (1967), "STABILITY AND STRESSES IN INTERTIDAL POPULATION" IN "POLLUTION AND MARINE ECOLOGY," EDITED BY T.A. OLSON AND F.J. BURGESS, INTERSCIENCE PUBLISHERS, NEW YORK, 1967, P. 15.

TITLE PAGE OMITTED

VII. ENVIRONMENTAL ASPECTS OF OTHER PARAMETERS.

IN ADDITION TO THE POSSIBLE ENVIRONMENTAL EFFECTS OF PETROLEUM HYDROCARBONS AND TRACE ELEMENTS IN OFFSHORE PRODUCED WATERS, DESCRIBED IN THE PREVIOUS SECTIONS, THERE ARE SOME ADDITIONAL COMPONENTS AND PROPERTIES OF PRODUCED WATERS WHICH HAVE POTENTIAL FOR MINOR ENVIRONMENTAL EFFECTS THERE ARE SALINITY, DISSOLVED OXYGEN, ORGANIC COMPOUNDS OTHER THAN HYDROCARBONS, AND TEMPERATURE.

SALINITY - MANY OFFSHORE PRODUCED WATERS HAVE HIGHER CONCENTRATIONS OF DISSOLVED SOLIDS THAN THE WATERS SURROUNDING THE PLATFORMS. THE AVERAGE TOTAL DISSOLVED SOLIDS CONTENT FOR PRODUCED FORMATION WATERS FROM OFFSHORE LOUISIANA PRODUCTION FACILITIES IS APPROXIMATELY 110,000 MG/ LITER (PPM) /61/ COMPARED WITH 35,000 MG/LITER FOR NORMAL SEAWATER. SINCE WE ARE DEALING WITH DISSOLVED COMPONENTS, DILUTION OCCURS QUITE RAPIDLY WHEN THE PRODUCED WATERS ARE DISCHARGED INTO THE WATERS SURROUNDING THE PLATFORM. /12,62/ ANY ENVIRONMENTAL EFFECTS WILL BE EXTREMELY LOCALIZED NEAR THE POINT OF DISCHARGE MACKIN STATES, "THIS DILUTION IN LARGE WATER BODIES AND COMPARATIVELY DEEP WATER IS ALMOST INSTANTANEOUS, AND DILUTIONS OF 1000 PARTS OF SEAWATER TO ONE OF BRINE CAN BE AFFECTED IN EVEN COMPARATIVELY SHALLOW WATER IN DISTANCES OF FROM 8 TO 50 FEET. IN OFFSHORE WATERS IN THE GULF OR ELSEWHERE, THERE IS NO BRINE PROBLEM FOR THAT REASON."

IN OFFSHORE WATERS, NATURAL PROCESSES SUCH AS TIDES, FLOODS, CURRENTS, OR DROUGHTS WOULD CAUSE MUCH GREATER VARIATION IN SALINITY THAN THE DISCHARGE OF PLATFORM PRODUCTION WATERS. NEARSHORE CONTINENTAL WATERS ARE NEITHER TYPICALLY MARINE NOR ESTUARINE, BUT RATHER TRANSITIONAL. CONSEQUENTLY, ORGANISMS LIVING IN THESE WATERS AND UNDERLYING SEDIMENTS MUST BE TOLERANT TO LARGE SCALE VARIATIONS (E.G., SALINITY) IN THE ENVIRONMENT. FOR EXAMPLE, CASTENHOLZ /64/ NOTED THAT THE INTERTIDAL REGION OF THE NEARSHORE ENVIRONMENT EXHIBITS CHANGES IN ENVIRONMENTAL CONDITIONS EQUIVALENT TO HUNDREDS OF MILES IN SOME TERRESTRIAL AREAS AND YET THE TOTAL SPAN OF THE INTERTIDAL REGION MAY ONLY BE SEVERAL VERTICAL FEET.

SALINITY MEASUREMENTS WERE MADE AT 180 DIFFERENT SAMPLING STATIONS OFFSHORE AND IN TIMBALIER BAY (LOUISIANA) IN THE OFFSHORE ECOLOGY INVESTIGATION, /6/ CONDUCTED IN THE NORTHERN GULF OF MEXICO BY GULF UNIVERSITIES RESEARCH CONSORTIUM. VARIATIONS WERE CORRELATABLE WITH SEASON AND GEOGRAPHY OF SAMPLING SITES AND ALL VARIATIONS WERE WITHIN THE RANGES REPORTED BY SEASON.

REAUTHORIZATION OVERSIGHT OF -- THE RESOURCE CONSERVATION RCRA AND

HEARINGS RECOVERY BEFORE ACT THE

HEARING SUBCOMMITTEE ON BEFORE RESOURCE THE SUBCOMMITTEE PROTECTION OF ON OVERSIGHT THE COMMITTEE AND INVESTIGATIONS ON ENVIRONMENT OF THE AND PUBLIC COMMITTEE ON WORKS UNITED INTERSTATE

AND STATES FOREIGN COMMERCE SENATE NINETY

HOUSE SIXTH OF CONGRESS REPRESENTATIVES FIRST NINETY-FIFTH SESSION, 790322 CONGRESS SECOND AND 790323 SESSION SERIAL

SERIAL NO. NO. 95-183 4781030 96-H6

PART PART 003 408 OF OF 487 415

RANDOLPH J CHAIRMAN

MUSKIE E S

GRAVEL M

BENTSEN L M

BURDICK Q N

CULVER J C CHAIRMAN

HART G

MOYNIHAN D P

STAFFORD R T

BAKER H H

DOMENICI P V

CHAFEE J H

SIMPSON A K

PRESSLER L

YAGO J W STAFF DIRECTOR

GUARD B MINORITY STAFF DIRECTOR

HOUSE OF REPRESENTATIVES SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

U.S. SENATE

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS

SUBCOMMITTEE ON RESOURCE PROTECTION

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/FN66/ 66. GULF UNIVERSITIES RESEARCH CONSORTIUM (1973) "ORGANIC CARBON, INORGANIC CARBON AND BOD VARIATIONS IN IN OEI," PRELIMINARY REPORT, AUTHORED BY C.R. BRENT, PP. 1-11, NOVEMBER 1-2.

/FN67/ 67. TURNER, C.H., CARLISLE, J.E., JR. AND EBERT, E.E. (1962), "OFFSHORE OIL DRILLING ITS EFFECT UPON THE MARINE ENVIRONMENT," INCLUDED IN THE DOCUMENT, "INSTALLATION OF PLATFORMS 'C" AND "HENRY" ON FEDERAL OIL AND GAS LEASES OCS P 0241 AND 0240 ISSUED UNDER THE OUTER CONTINENTAL SHELF LANDS ACT, SANTA BARBARA CHANNEL AREA OFF THE COAST OF CALIF (EIS)," PREPARED BY THE U.S. GEOLOGICAL SURVEY, WASHINGTON D.C., AUGUST 26, 1971. NATIONAL TECHNICAL INFORMATION SERVICE IDENTIFICATION NO: PB-198-970-F.

/FN6/ 6. GULF UNIVERSITES RESEARCH CONSORTIUM (1974), "FINAL PROJECT PLANNING COUNCIL CONSENSUS REPORT," OFFSHORE ECOLOGY INVESTIGATION, REPORT NO. 138, SEPTEMBER 20.

LIST OMITTED

IN AN M.I.T. STUDY /65/ IT WAS STATED THAT THE CONTINUOUS DISCHARGE OF PRODUCTION WATERS FROM PLATFORMS DOES NOT APPEAR TO BE A SERIOUS THREAT TO THE ENVIRONMENT. NO ADVERSE EFFECTS OF DISCHARGES HAVE BEEN NOTED IN THE GULF OF MEXICO. IT IS AN ESTABLISHED FACT THAT THE AREA UNDER THE PLATFORMS SUPPORTS UNUSUALLY DENSE POPULATIONS, AS HAS BEEN MEASURED IN THE SANTA BARBARA CAHANNEL UNDER PLATFORMS HILDA AND HAZEL. /67/

DISSOLVED OXYGEN - SINCE OXYGEN IS ALSO A DISSOLVED MOLECULAR SPECIES, THE ABOVE COMMENTS ABOUT DILUTION CERTAINLY APPLY HERE AS WELL. ALSO, THE OFFSHORE ECOLOGY INVESTIGATION /66/ FOUND THAT NATURAL PROCESSES (TIDES, FLOODS, DROUGHTS, ETC.) COMPLETELY OVERSHADOWED ANY CHANGES IN DISSOLVED OXYGEN CONTENT WHICH MIGHT HAVE BEEN CAUSED BY THE DISCHARGE OF PRODUCTION WATERS. NO SIGNIFICANT DEPLETION OF OXYGEN WAS OBSERVED AT PLATFORM SITES AND WHAT SMALL REDUCTION WAS NOTED COULD BE EXPLAINED BY THE GENERALLY RICH BIOTA LIVING ON THE PLATFORM LEGS.

ORGANIC COMPOUNDS,OTHER THAN HYDROCARBONS - OTHER ORGANICS FOUND IN PLATFORM PRODUCTION WATERS WILL USUALLY BE PRESENT IN EVEN LOWER CONCENTRATIONS THAN THE PETROLEUM HYDROCARBONS ASSOCIATED WITH THESE WATERS. THESE OTHER ORGANICS WOULD LIKELY BE IN THE FEW PPM RANGE AND DILUTION WOULD RAPIDLY DISPERSE THEM BELOW THE LIMITS OF ANY ADVERSE ENVIRONMENTAL EFFECTS.

IN THE OFFSHORE ECOLOGY INVESTIGATION /66/ MEASUREMENTS WERE MADE OF THE ORGANIC CARBON CONTENT IN THE WATERS AROUND TWO PRODUCING PLATFORMS AND A CONTROL AREA SOME SIX MILES AWAY. TYPICAL ORGANIC CARBON CONTENTS MEASURED AROUND THE PLATFORMS WERE 5.8 AND 5.0 MG/LITER (PPM), RESPECTIVELY, AND 5.1 MG/LITER (PPM) FOR THE CONTROL AREA. SINCE THESE VALUES ARE ALL WITHIN THE SAMPLING VARIABILITY, IT WAS INDICATED THAT THERE WAS NO SIGNIFICANT BUILD UP OF ORGANIC COMPOUNDS IN THE VICINITY OF THE PRODUCING PLATFORMS.

TEMPERATURE - PRODUCTION WATERS TEND TO BE SOMEWHAT WARMER THAN THE WATER SURROUNDING THE PLATFORMS, BUT HERE AGAIN, THE DIFFERENCES ARE NOT LIKELY GREAT. AS WITH DISSOLVED SPECIES, DILUTION WOULD ALMOST INSTANTANEOUSLY DIMINISH ANY TEMPERATURE GRADIENTS. IN THE OFFSHORE ECOLOGY INVESTIGATION /6/ TEMPERATURE MEASUREMENTS WERE ALSO MADE AT SOME 180 DIFFERENT SAMPLING STATIONS OFFSHORE AND IN TIMBALIER BAY. AS WAS FOUND WITH SALINITY, THE TEMPERATURE VARIATIONS CORRELATED WITH SEASON AND NEARNESS TO SHORE, AND NO IMPACT OF THE PLATFORMS AND THEIR DISCHARGES ON (WORDS OMITTED).

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

HOUSE OF REPRESENTATIVES NINETY-FIFTH CONGRESS SECOND SESSION SERIAL NO. 95-183 4781030

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HOUSE OF REPRESENTATIVES NINETY-FIFTH CONGRESS SECOND SESSION SERIAL NO. 95-183 4781030

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OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

HOUSE OF REPRESENTATIVES NINETY-FIFTH CONGRESS SECOND SESSION SERIAL NO. 95-183 4781030

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OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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THE SUBCOMMITTEE MET, PURSUANT TO NOTICE AT 9:30 A.M., IN ROOM 2123, RAYBURN HOUSE OFFICE BUILDING, HON. ALBERT GORE, JR., PRESIDING (HON. JOHN E MOSS, CHAIRMAN).

MR. GORE. THE SUBCOMMITTEE WILL COME TO ORDER.

IN AMERICA LAST YEAR, AN ESTIMATED 92 BILLION POUNDS OF HAZARDOUS WASTES WERE DUMPED IN THE GROUND. THIS AMOUNT INCREASED BY 8 PERCENT EACH YEAR. OF DEEPEST CONCERN TO ME AND TO THIS SUBCOMMITTEE ARE ESTIMATES THAT AT LEAST 90 PERCENT OF HTESE HAZARDOUS WASTES ARE DISPOSED OF IMPROPERLY, UNSAFELY, AND IRRESPONSIBLY. MANY OF THESE DANGEROUS SUBSTANCES END UP IN OUR AIR, OUR FOOD, AND OUR DRINKING WATER.

HAZARDOUS WASTE MAY BE THE SINGLE MOST SIGNIFICANT ENVIRONMENTAL HEALTH ISSUE OF THIS DECADE. MANY AMERICANS ARE JUSTLY CONCERNED ABOUT THE PROBLEMS OF DISPOSING OF NUCLEAR WASTE. YET TOTAL NUCLEAR WASTES PRODUCED TO DATE ARE ESTIMATED TO BE WELL UNDER 100 MILLION POUNDS. BY CONTRAST, 92 BILLION POUNDS OF NONNUCLEAR WASTE ARE GENERATED EACH AND EVERY YEAR; AND THESE WASTES ARE DISPOSED OF CAVALIERLY.

AMERICA HAS BEEN POCKMARKED WITH THOUSANDS OF CANCER CESSPOOLS -- AND EPA DRAGS ITS FEET TO AVOID FACING THE MAGNITUTDE OF THIS THREAT. RUSTING AND BUSTED 55-GALLON DRUMS ARE NOT A SENSIBLE FINAL RESTING PLACE FOR POWERFUL POINSONS AND CARCINOGENIC INDUSTRIAL CHEMICALS. ALREADY, MANY SITES HAVE CAUSED TRAGEDY, LEAKING TOXIC SUBSTANCES INTO OUR ENVIRONMENT AND WATER SUPPLIES; WE ARE REMINDED OF LOVE CANAL, N.Y.; TOONE, TENN.; LOUISVILLE, KY.; DEERFIELD, OHIO; ALEXANDRIA, VA.; AND DOVER TOWNSHIP, N.J. THE LIST IS LOND, EVEN THOUGH INCOMPLETE.

RECOGNIZING THE SERIOUSNESS OF THE PROBLEM, CONGRESS PASSED THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976. THIS LEGISLATION CALLED FOR THE DEVELOPMENT OF REGULATIONS TO IDENTIFY AND MANAGE THIS HAZARDOUS WASTE PROBLEM. THE RESOURCE CONSERVATION AND RECOVERY ACT IS A STRONG LAW WITH A CLEAR MANDATE DIRECTING THE U.S. ENVIRONMENTAL PROTECTION AGENCY TO BRING THIS PROBLEM UNDER CONTROL.

EPA WAS GIVEN 18 MONTHS TO PROMULGATE REGULATIONS WHICH WOULD BRING THIS HEALTH-THREATENING ENVIONRMENTAL PROBLEM TO AN END.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

HOUSE OF REPRESENTATIVES NINETY-FIFTH CONGRESS SECOND SESSION SERIAL NO. 95-183 4781030

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IN MARCH OF THIS YEAR, JUST 1 MONTH BEFORE THE DEADLINE FOR THESE REGULATIONS, AN EPA OFFICIAL, DEPUTY ADMINISTRATOR BARBARA BLUM TESTIFIED BEFORE A HOUSE APPROPRIATIONS SUBCOMMITTEE THAT EPA WAS ON SCHEDULE. WHEN ASKED "ARE YOU ON TARGET AND DO YOU PLAN TO HVE THE REGULATIONS ISSUED . . . BY THE STATUTORY DATE?", DEPUTY ADMINISTRATOR BLUM REPLIED, "YES". BUT THE REGULATIONS WERE NOT ISSUED IN APRIL 1978. WE NOW LEARN THAT THE REGULATIONS WILL NOT BE PROMULGATED UNTIL JANUARY 1980 AT THE EARLIEST.

DELAYS ARE COSTLY. EACH MONTH THE COSTS OF HANDLING WASTES

RISE DRAMATICALLY. FOR EACH MONTH EPA DELAYS IN ISSUING THE

REGULATION, NEARLY 8 BILLION POUNDS OF HAZARDOUS WASTE ARE

GENERATED -- MUCH OF IT, IF NOT MOST, WILL BE DISPOSED OF

IMPROPERLY. BY THE TIME EPA EXPECTS THE REGULATIONS TO BE

IN PLACE, AND ESTIMATED 160 BILLION ADDITIONAL POUNDS OF

HAZARDOUS WASTE WILL HAVE BEEN PRODUCED AND DISPOSED OF IN AN

AD HOC FASHION.

THE CLEANUP COSTS OF IMPROPERLY DISPOSED OF MATERIAL ARE ASTRONOMICAL. OF SIGNIFICANCE TO THE PUBLIC AND THIS SUBCOMMITTEE IS THE FACT THAT CLEANUP COSTS, WHICH OFTEN RANGE IN THE MILLIONS OF DOLLARS, FAR EXCEED THE COSTS OF PROPER DISPOSAL. FOR EXAMPLE, ONE EPA STUDY HAS ESTIMATED THAT THE COST OF PROPERLY DISPOSING OF WASTES IN DOVER TOWNSHIP, N.J., WOULD HAVE BEEN ONLY ONE THIRD OF THE PARTIAL CLEANUP COSTS. WE CANNOT AFFORD TO WAIT MUCH LONGER FOR TOUGH, COMPREHENSIVE RULES WHICH WILL ELIMINATE THE FLOW OF HAZARDOUS SUBSTANCES INTO OUR ENVIRONMENT.

AT TODAY'S HEARING WE WILL: EXPLORE THE REASONS FOR EPA'S DELAY IN PROMULGATING RCRA REGULATIONS; TRY TO DETERMINE WHETHER EPA'S CURRENT PROJECTED DEADLING FOR THESE REGULATIONS OF JANUARY 1980 IS APPROPRIATE; ASCERTAIN WHAT PROGRESS EPA HAS MADE IN DRAFTING RIGOROUS REGULATIONS; AND EXPLORE WHAT STEPS EPA HAS TAKEN TO INVENTORY, MONITOR, AND TAKE ACTION ON POTENTIALLY DANGEROUS WASTE SITES.

TO ADDRESS THESE ISSUES, WE WILL HEAR INITIALLY FROM TWO MEMBERS OF CONGRESS, HON. HENRY J. NOWAK AND HON JOHN J. LAFALCE, BOTH FROM NEW YORK STATE, WHO HAVE BEEN PARTICULARLY CONCERNED ABOUT THE DANGERS OF HAZARDOUS WASTE BECAUSE OF THE EVENTS AT LOVE CANAL, N.Y., WHERE HUNDREDS OF FAMILIES HAD TO BE RELOCATED BECAUSE A CLOSED DUMP BEGAN TO LEAK A VARIETY OF TOXIC CHEMICALS. MR. NOWAK'S CONCERNS ABOUT THIS ISSUE TRIGGERED TODAY'S HEARING. WE WILL ALSO HEAR FROM CHRISTINE AND WOODROW STERLING FROM TOONE, TENN., WHOSE WATER SUPPLY HAS BEEN CONTAMINATED BY PESTICIDE WASTE.

MR. HUGH KAUFMAN, MANAGER OF THE ASSESSMENT PROGRAM,

HAZARDOUS WASTE MANAGEMENT DIVISION OF THE ENVIRONMENTAL

PROTECTION AGENCY, WILL BE ASKED TO DESCRIBE HOW EPA HAS BEEN

RESPONDING TO SITUATIONS LIKE TOONE, TENN. PANELISTS INCLUDE

MR. LESLIE DACH OF THE ENVIRONMENTAL DEFENSE FUND, MR. GEORGE

WOLFF OF THE ILLINOIS ATTORNEY GENERAL'S OFFICE AND DR. DANA

DAVOLI OF CITIZENS FOR A BETTERN ENVIRONMENT, WHO WILL DISCUSS

PUBLIC AND STATE GOVERNMENT CONCERNS ABOUT EPA'S DELAYS.

THEY WILL ALSO DISCUSS THIR CONCERNS ABOUT THE QUALITY OF THE

MOST RECENT DRAFT REGULATIONS. AND FINALLY, WE WILL CALL UPON

EPA OFFICIALS, THOMAS C. JORLING, ASSISTANT ADMINISTRATOR FOR

THE OFFICE OF WATER AND WASTE MANAGEMENT; STEFFAN W. PLEHN,

DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE; AND JOHN P.

LEHMAN, DIRECTOR OF THE HAZARDOUS WASTE MANAGEMENT DIVISION OF

THE OFFICE OF SOLID WASTE, WHO HAVE THE RESPONSIBILITY FOR

IMPLEMENTING THE RCRA LAW.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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WE WILL ASK THEM TO EXPLAIN WHY THEY HAVE FAILED TO PROMULGATE THE REGULATIONS, WHY THEY HAVE FAILED TO IDENTIFY POTENTIALLY HAZARDOUS SITES AND WHY THEY HAVE FAILED TO USE THEIR AUTHORITY TO VIGOROUSLY ENFORCE THE LAW.

THE THREAT POSED BY HAZARDOUS WASTES MAY BE THE ENVIRONMENTAL SLEEPING GIANT OF THIS DECADE. HUNDREDS OF BILLIONS OF POUNDS OF THESE TOXIC WASTES ARE NOT POLLUTING OUR ENVIRONMENT AND JEOPARDIZING PUBLIC HEALTH. EPA HAS BEEN CHARGED WITH THE RESPONSIBILITY TO SOLVE THIS PROBLEM. AND YET, WE LEARN -- FROM SENATOR PROXMIRE -- THAT EPA HAS SPENT CLOSE TO $40,000 IN A 2-YEAR STUDY TO FIND OUT THAT RUNOFF FROM OPEN STACKS OF COW MANURE ON VERMONT FARMS CAUSES THE POLLUTION OF THE WATER IN NEARBY SMALL STREAMS AND PONDS. WHAT ARE EPA'S PRIORITIES? WHAT HAS EPA BEEN DOING SINCE THE RCRA WAS ENACTED? HOW SOON CAN WE BE ASSURED THAT EPA IS ON THE RIGHT TRACK AND HAS MADE PROGRESS IN VIGOROUSLY ATTACKING THIS PROBLEM?

OUR FIRST WITNESS TODAY IS THE HONORABLE HENRY J NOWAK OF NEW YORK.

STATEMENT OF HON. HENRY J NOWAK, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF NEW YORK

MR NOWAK. MR. CHAIRMAN, THANK YOU VERY MUCH. FIRST I WOULD LIKE TO COMMEND YOU AND THE SUBCOMMITTEE FOR YOUR SPECIAL CONSIDERATION OF MY REQUEST TO CONDUCT THIS HEARING AND REFOCUS NATIONAL ATTENTION ON THIS COMPLEX AND CRITICAL PROBLEM OF HAZARDOUS WASTE DISPOSAL. I AM SURE YOU SHARE MY HOPE THAT TODAY'S HEARING -- AND FUTURE CONGRESSIONAL OVERSIGHT IN THIS AREA -- WILL ACCELERATE THE COOPERATIVE EFFORT BY THE PUBLIC AND PRIVATE SECTORS NEEDED TO DEAL WITH THIS SINISTER, MULTIFACETED PROBLEM.

SECOND, I WOULD RESPECTFULLY REQUEST PERMISSION FOR INCLUSION IN THIS HEARING RECORD OF THE COMPLETE TEXT OF THE ARTICLES ON HAZARDOUS WASTE DISPOSAL THAT APPEARED IN THE DITIONS OF THE BUFFALO COURIER-EXPRESS BETWEEN SEPTEMBER 16 AND SEPTEMBER 26, 1978.

MR. GORE. WITHOUT OBJECTION, IT IS SO ORDER (SEE P. 6.)

MR. NOWAK. AS A RESULT OF THE LOVE CANAL EMERGENCY, THE COURIER-EXPRESS DETAILED REPORTER MICHAEL DESMOND ON AN ASSISGNMENT TO TRACE THE NATIONAL SCOPE OF THIS PROBLEM. SEVERAL WEEKS AND SEVERAL THOUSAND MILES LATER, MR. DESMOND COMPLETED A SERIES OF ARTICLES THAT CHILLINGLY DESCRIBE THE BREADTH AND DEPTH OF THE HAZARDOUS WASTE CRISIS. BOTH HE AND THE COURIER-EXPRESS ARE TO BE COMMENDED FOR THIER PURLIC SERVICE IN DRAWING ATTENTION TO THE GRAVITY OF THE PROBLEM CONFRONTING US.

THE CONGRESS CLEARLY RECOGNIZED THE SEVERITY OF THE HAZARDOUS WASTE PROBLEM IN 1976 WHEN IT PASSED THE RESOURCE CONSERVATION AND RECOVERY ACT. WHAT THE COURIER-EXPRESS SERIES POINTED OUT, HOWEVER, WAS THAT THE ENVIRONMENTAL PROTECTION AGENCY HAS BEEN INTOLERABLY SLOW IN IMPLEMENTING THIS VITAL PROGRAM. WORSE, EPA'S PROJECTED TIMETABLE ENVISIONS CONTINUING ITS SNAIL'S PACE APPROACH TO THIS PROBLEM.

THIS NATION CANNOT AFFORD TO WAIT UNTIL MID-1980 TO BEING A COORDINATED, COMPREHENSIVE ATTACK ON THIS PROBLEM. THE MISHANDLING AND IMPROPER DISPOSAL OF TOXIC WASTES THAT PROMPTED THE 1976 LEGISLATION CONTINUES TODAY. THIS CONTINUES TO THREATEN OUR ENVIRONMENT AND OUR HEALTH AND IS COUNTERPRODUCTIVE TO OUR EFFORTS TO EXPEND BILLIONS OF DOLLARS TO CLEAN UP OUR AIR AND WATER.

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I REQUESTED THAT THIS HEARING BE CONVENED TO GET ANSWERS FROM EPA TO SEVERAL QUESTIONS AND TO DETERMINE WHAT CAN BE DONE TO EXPEDITE ITS ISSUANCE OF ALL THE REQUIRED RCRA REGULATIONS. THE NATION WOULD LIKE TO KNOW WHY EPA IS MORE THAN 6 MONTHS LATE IN ISSUING THESE REGULATIONS AND WHAT EPA CAN DO TO ACCELERATE THIS ALREADY DELAYED PROCESS.

WHILE THE RCRA REGULATIONS WOULD DEAL PRINCIPALLY WITH CURRENT AND PROSPECTIVE HANDLING AND DISPOSAL PROCEDURES INVOLVING TOXIC WASTES, THE LOVE CANAL EMERGENCY HAS FOCUSED ATTENTION ON ANOTHER DEADLY ASPECT OF THIS PROBLEM . . . THE HUNDREDS, PERHAPS THOUSANDS, OF INACTIVE AND ABANDONED HAZARDOUS WASTE DISPOSAL SITES THAT POCKMARK OUR NATION.

ANOTHER MAJOR QUESTION FOR EPA, THEREFORE, IS TO DETAIL WHAT IT IS AND IS NOT DOING ABOUT THE INACTIVE SITE PROBLEM. DOES EPA ALREADY HAVE ADEQUATE LEGAL AUTHORITY TO FASHION AN EFFECTIVE PROGRAM OF DEALING WITH INACTIVE SITES? IS FURTHER FEDERAL LEGISLATION REQUIRED? IF SO, WHAT IS BEING DONE BY THE AGENCY TO PROPOSE SUCH LEGISLATION?

THE LOVE CANAL EMERGENCY RAISES SOME SERIOUS QUESTIONS ABOUT HOW WELL EQUIPPED THE FEDERAL GOVERNMENT IS TO PARTICIPATE WITH THE STATES AND LOCAL AGENCIES IN DEALING WITH THE DEADLY SERIOUS PROBLEMS THAT CAN ARISE IN CONNECTION WITH INACTIVE SITES.

THE FACT THAT THE CONGRESS HAD TO APPROVE A SPECIAL APPROPRIATION TO PROVIDE $4 MILLION TO SUPPORT THE EMERGENCY CLEANUP IN THE LOVE CANAL AREA CLEARLY SUGGESTS THAT ADEQUATE AUTHORITY AND ADVANCED PREPARATION ARE AREAS OF FEDERAL PARTICIPATION THAT MAY NEED IMPROVEMENT. THE FEDERAL GOVERNMENT, THROUGH EPA, MUST DEVELOP A CAPABILITY -- A RESERVE OF TECHNICAL AND FINANCIAL RESOURCES -- THAT CAN BE MADE AVAILABLE QUICKLY TO DEAL WITH FUTURE LOVE CANALS.

MR. CHAIRMAN, THESE HEARINGS SHOULD KINDLE A GREATER SENSE OF URGENCY ABOUT COPING WITH THE HAZARDOUS WASTE CRISIS. THIS IS A CLASSIC EXAMPLE OF THE MAXIM: "AN OUNCE OF PREVENTION IS WORTH A POUND OF CURE." THE SOONER THIS NEW REGULATORY PROGRAM IS IN PLACE, THE SOONER WE CAN PUT A CAP ON WHAT HAS BEEN A HAPHAZARD, OFTEN INDISCRIMINATE FLOW OF POISON INTO OUR ENVIRONMENT. EXPENDING OUR ENERGIES NOW, AS QUICKLY AS POSSIBLE, WILL UNDOUBTEDLY SAVE MILLIONS OF DOLLARS IN LONG-TERM REMEDIAL WORK AND ELIMINATE COUNTLESS THREATS TO HEALTH AND SAFETY.

SIMULTANEOUSLY, WE MUST ALSO BE CONCERNED ABOUT THE IMPACT THIS FEDERAL REGULATORY DELAY IS HAVING ON EFFORTS BY THE STATES TO DEAL COMPREHENSIVELY WITH THIS PROBLEM. MY HOME STATE OF NEW YORK, FOR EXAMPLE, THIS YEAR ENACTED THE INDUSTRIAL HAZARDOUS WASTE MANAGEMENT ACT, WHOSE IMPLEMENTATION IS TRIGGERED BY THE FEDERAL REGULATIONS. THE BUFFALO EVENING NEWS, THE OTHER MAJOR DAILY NEWSPAPER IN BUFFALO, NOTED IN A SEPTEMBER 25, 1978, EDITORIAL:

OBVIOUSLY, HOWEVER, NEW YORK'S RULES MUST COMPLY WITH WHATEVER STANDARDS EPA EVENTUALLY ESTABLISHES. MEANWHILE, STATE ENVIRONMENTAL OFFICIALS SAY THEY ARE HAMPERED IN CONTRACTING WITH FIRMS FOR IMPLEMENTING SAFEGUARDS BECAUSE THE LATTER ARE RELUCTANT TO UNDERTAKE DISPOSAL PROGRAMS SO LONG AS THE EVENTUAL FEDERAL RULES REMAIN UNCERTAIN.

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IF WE EXPECT A MAJOR STATE AND LOCAL EFFORT IN THIS AREA, THE FEDERAL GOVERNMENT MUST EXERT MORE ACTIVE LEADERSHIP ON THIS CRITICAL ISSUE.

MR. CHAIRMAN, UNQUESTIONABLY WE ALL RECOGNIZE THE SEVERITY OF THE HAZARDOUS WASTE PROBLEM, A DEADLY LEGACY OF OUR INDSTRIALIZED CIVILIZATION.

I LOOK FORWARD TO WORKING WITH YOU, THE SUBCOMMITTEE AND EPA IN HASTENING OUR SEARCH FOR SOLUTIONS. THIS WILL BE AN EXPENSIVE, LONG-TERM PROCESS AND I HOPE TODAY'S HEARING MARKS A NEW ERA IN STIMULATING AND SUSTAINING IT.

I WOULD JUST LIKE, WHILE I HAVE THIS OPPORTUNITY, TO COMPLIMENT MY COLLEAGUE JOHN LAFALCE, IN WHOSE AREA THE LOVE CANAL EXISTS. HIS WORK AND HIS LEADERSHIP HAVE REALLY STIMULATED THE FEDERAL GOVERNMENT AND THE STATE TO TAKE THE ACTIONS THEY HAVE TAKEN ON BEHALF OF THOSE PEOPLE WHO HAVE SUFFERED HEALTH AND NOW RELOCATION PROBLEMS. I THINK HE HAS DONE A WONDERFUL JOB AND SHOULD BE COMPLIMENTED FOR IT AS THE LEADER IN THIS EFFORT.

(TESTIMONY RESUMES ON P. 65.)

(THE ARTICLES FROM THE BUFFALO COURIER-EXPRESS, REFERRED TO, FOLLOW).

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C-E REPORTER TRAVELS U.S. FOR STORY

MICHAEL DESMONS, A REPORTER FOR THE COURIER-EXPRESS HAS TRAVELED 5,200 MILES CRISS-CROSSING THE COUNTRY IN THE LAST SEVERAL WEEKS TO FIND OUT HOW AND WHERE THE MOUNTAINS AND RIVERS OF HAZARDOUS CHEMICALS WASTES ARE BEING STORED.

WHAT HE LEARNED WAS THAT THE NATION IS SITTING ON COUNTLESS CHEMICAL TIME BOMBS THAT COULD GO OFF WITHOUT WARNING FOR GENERATIONS TO COME. AT STAKE, AMONG OTHERS AS YET UNKNOWN, ARE CANCER, MISCARRIAGES, GENETIC DEFECTS, DEATH.

"I'M APPALLED AT THE LOCK OF KNOWLEDGE ON THE PART OF GOVERNMENT AGENCIES AS TO WHAT IS GOING ON," DESMOND SAID, ADDING:

"TOO MANY AGENCIES OF STATE GOVERNMENT SEEM TO BE FINANCED FOR SHOW, RATHER THAN FOR EFFECT IN THE FIELD. AS FOR THE FEDERAL GOVERNMENT, THE ENVRIONMENTAL PROTECTION AGENCY IS SO SNARLED IN ITS OWN BUREAUCRACY THAT IT IS VIRTUALLY POWERLESS."

VETERAN REPORTER

DESMOND HAS BEEN WITH THE COURIER-EXPRESS SINCE 1969, EXCEPT FOR A STINT AS DEPUTY PRESS SECRETARY TO NEW YORK ASSEMBLY SPEAKER STANLEY STEINGUT, D-BROOKLYN.

AT PRESENT, HE IS A MEMBER OF THE NEWSPAPER'S SPECIAL PROJECTS TEAM. PREVIOUSLY, HE HELD VARIOUS OTHER EDITORIAL PSOTS, INCLUDING THAT OF ALBANY CORRESPONDENT.

A BUFFALO NATIVE, HE IS A GRADUATE OF CANISIUS HIGH SCHOOL AND HOLY CROSS COLLEGE IN WORCESTER, MASS. HE ALSO ATTENDED THE UNIVERSITY OF BUFFALO LAW SCHOOL AND DID GRADUATE WORK AT BUFFALO STATE COLLEGE.

WON AWARDS

OUTSIDE OF BUFFALO, HE HAS WORKED FOR NEWSPAPERS IN LOCKPORT AND UTICA. HE HAS WON AWARDS FOR NEW WRITING FROM THE STATE ASSOCIATED PRESS ASSOCIATION AND THE BUFFALO NEWSPAPER GUILD.

MICHAEL DESMOND . . . COURIER-EXPRESS REPORTER.

PHOTOGRAPH OMITTED.

TO DATE, DESMOND'S PURUIST OF THE SCANDALOUS HAZARDOUS WASTE STODY HAS TAKEN HIM TO WASHINGTON, D.C., CLEVELAND AND AKRON, OHIO, WASHINGTON AND CHARLESTON, W. VA., BATON ROUGE AND NEW ORLEANS, LA., HOUSTON, TEXAS, CHICAGO AND WILSONVILLE, ILL., MUSKEGON, MONTAGUE AND GRAND RAPIDS, MICH., BRIDGEPORT, TRENTON, NEWARK AND ELIZABETH, N.J., NIAGARA FALLS AND NEW YORK CITY, ATLANTA, ST. LOUIS, BALTIMORE, PHILADELPHIA, PITTSBURGH, AND ROANOKE, VA.

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THE JOURNEY OF A COURIER-EXPRESS REPORTER . . . 5,2000 MILES IN PURSUITE OF THE TOXIC WASTE STORY.

MAP OMITTED.

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LOVE CANAL HAZARD IS SMALL PART OF NATIONAL PROBLEM

BY MICHAEL DESMOND 1978 BUFFALO COURIER-EXPRESS, INC.

THERE IS A SEA OF HAZARDOUS CHEMICALS WASHING ACROSS THIS NATION, A SEA WHICH PROVIDES A HUGH THREAT TO THE HEALTH OF PRESENT AND FUTURE GENERATIONS, AN EXTENSIVE INVESTIGATION BY THE COURIER-EXPRESS HAS DISCOVERED.

THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) ESTIMATES 5.6 BILLION POUNDS OF HAZARDOUS WASTE IS PROPERLY DISPOSED OF EACH YEAR. THAT IS ONLY SIX PERCENT OF THE ESTIMATED 92 BILLION POUNDS OF HAZARDOUS WASTE ACTUALLY GENERATED EACH YEAR.

THAT LEAVES 86.4 BILLION POUNDS TO PERIL THE NATION'S POPULACE.

DESPITE THE CLEAR NUMBERS THEY ARE REALLY GUESSES: NO ONE KNOWS WHAT THE REAL FIGURES ARE.

THE EPA ESTIMATES THERE ARE 20,000 DUMP SITES FOR HAZARDOUS MATERIALS OPERATING NOW, BUT HAS NO IDEA HOW MANY OTHER THOUSANDS HAVE BEEN USED AND CLOSED. THE FORMER DUMPS MAY BE AT LEAST AS DANGEROUS AS THE PRESENT ONES. AND NO ONE KNOWS HOW LONG A "SECURE" DUMP SITE WILL REMAIN SAFE -- A YEAR, A DECADE, A GENERATION.

NEW CHEMICALS

NO ONE KNOWS WHAT TO DO ABOUT THE NEW CHEMICALS PRODUCED BY INDUSTRY EACH YEAR.

THERE ARE THOUGHT TO BE 1,000 NEW CHEMICALS BORN EACH YEAR,

ON TOP OF THE 70,000 WHICH ALREADY EXIST, AND NO PERSON OR

AGENCY KNOWS HOW TO DISPOSE OF MANY OF THEM SAFELY AND

PERMANENTLY.

IN THE MIDDLE AGES, ALCHEMISTS TRIED TO TURN BASE MATERIALS INTO GOLD. IN A RELIGIOUS AND SUPERSTITIOUS AGE, THE ALCHEMISTS WERE FEARED BECAUSE THEY WERE PLAYING IN A FIELD RESERVED TO GOD.

TODAY, SCIENTISTS ARE ALSO ALCHEMISTS. THEY TAKE OIL AND GAS AND WATER AND SALT AND TURN THEM INTO PROFITABLE CHEMICALS AND PALSTICS AND TEXTILES.

LEGACY OF POISON

BUT, BEHIND THEM, THEY ARE LEAVING A LEGACY FOR UNTOLD GENERATIONS. THE WASTE MATERIALS OF AN INDUSTRIAL AGE ARE SEEPING INTO THE AIR WE BREATHE, THE WATER WE DRINK AND THE LAND ON WHICH WE GROW OUR FOOD.

ONCE, PEOPLE COULD FLEE A FLOOD BY GOING TO THE NEAREST HIGH GROUNDS AND WATCH THE FURIOUS WATERS SIMPLY LASH UNAVAILINGLY AT THEM. IN THE INDUSTRIAL AGE, THERE IS NO HIGH GROUND: WITNESS:

IN AN INDUSTRIAL AREA OUTSIDE THE SMALL TOWN OF WASHINGTON W. VA., WORKERSAT THE L.B. FOSTER METAL PIPE MANUFACTURING PLANT WERE SHOCKED TO DISCOVER THE GROUND EXPLODED IF THEY TRIED TO DIG INTO IT. NO ONE WAS INJURED. RESEARCH DISCLOSED THE TRACT HAD BEEN USED IN 1959 BY CARBORUNDUM METAL AND RADIOACTIVE ORE FROM A ZIRCONIMUM TUBE MANUFACTURING PLANT. WHEN FOSTER BOUGHT THE SITE TWOYEARS AGO, IT WAS A CORNFIELD

- AT A ROAD INTERSECTION IN THE FARM COUNTRY OF CENTRAL OHIO, NEAR ADRON, A VISIT BY THE COURIER-EXPRESS FOUND THOUSANDS OF DRUMS AND TANKS OF CHEMICALS SITTING ON A FORMER STRIP COAL MINE. THEY CONTAIN EVERYTHING FROM PAINT THINNER TO A COMPLICATED CHEMICALS USED TO MAKE THE DEADLY PESTICIDES MIREX AND KEPONE. THE SITE ISN'T EVEN FENCED.

- IN THE AGING INDUSTRIAL CITY OF LOWELL, MASS., WASTE FROM A MISMANACED WASTE TREATMENT SITE IS CONTAMINATING A RIVER USED DOWNSTREAM FOR DRINKING WATER. CHEMICALS FOUND IN THE MERRIMACK RIVER INCLUDE TWO CHEMICALS WHICH CAUSE CANCER IN LABORATORY ANIMALS, CHLOROFORM AND TRICHLOROETHYLENE.

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- IN BAYOU SORRELL, LA., A FEW WEEKS AGO, A 19-YEAR OLD BOY WAS KILLED WHEN CAUSTIC CHEMICALS HE WAS DUMPING FROM A TANK TRUCK INTO A LAKE OF CHEMICALS REACTED TOGETHER PRODUCING A DEADLY GAS. HE DIED ALMOST IMMEDIATELY. GOVERNMENT INVESTIGATORS WERE INITIALLY DENIED ADMISSION TO INVESTIGATE BY THE OPERATOR OF THE LAGOON.

- NOT FAR FROM FAYOU SORREL, A 100-SQUARE-MILE AREA AROUND DARROW AND GEISMAR WAS CONTAMINATED WITH THE TOXIC CHEMICAL HEXACHLOROBENZENE SEVERAL YEARS AGO. THE MATERIAL WAS DUMPED ON THE LAND AND CATTLE WERE CONTAMINATED AFTER THEY GRAZED IN GRASS GROWING OUT OF THE SOIL.

- WASTE FROM THE ROCKY MOUNTAIN NATIONAL ARSENAL NEAR DENVER HAS CONTAMINATED 30 SQUARE MILES OF UNDERGROUND WATER, DAMAGED 6.5 SQUARE MILES OF FARMLAND AND MAY HAVE CAUSED EARTHQUAKES. THE DEFENSE DEPARTMENT RECENTLY ESTIMATED IT WILL COST $78 MILLION TO CLEAN UP THE MESS.

- IN MUSKEGON, MICH., A CHEMICAL COMPNAY WENT BROKE. A SUBSEQUENT SITE EXAMINATION BY A PURCHASER AND THE STATE DEPARTMENT OF NATURAL RESOURCES TURNED UP THOUSANDS OF DRUMS OF CHEMICALS STASHED INTE WOODS BEHIND THE PLANT.

- IN THE DESERT OF SOUTHWESTERN IDAHO, NEAR BOISE, WESCON, INC. HAS TAKEN OVER A TITAN MISSILE SILO AND TURNED IT INTO A GIANT MAUSOLEUM FOR DANGEROUS WASTES. ALREADY, GIANT BLAST DOORS INTENDED TO PROTECT MISSILES AGAINST ATOMIC BLASTS HAVE BEEN CLOSED OVER SEVERAL SILOS OF WAST CHEMICALS LEAVING THEM FOR THE FUTURE.

- A "MIDNIGHT HAULER" DUMPED TOXIC CHEMICALS CALLED PCBS ALONG 250 MILES OF ROAD NEAR RALEIGH, N.C. IN EARLY AUGUST.

- IN THE GULF OF MEXICO, ALONG THE GULF COAST OF LOUISIANA AND TEXAS, DRUMS APPARENTLY CONTAINING METALLIC SODIUM WASTE, HAVE TURNED UP IN FISHING NETS. SOME HAVE EXPLODED, WRECKING NETS AND KILLING AT LEAST ONE FISHERMAN.

- IN THE CHEMICAL INDUSTRY CENTER OF NIAGARA FALLS, AN ABANDONED CHEMICAL WASTE DUMP IN THE CITY'S LOVE CANAL NEIGHBORHOOD BEGAN TO LEAK CANCER-CAUSING CHEMICALS LESS THAN 25 YEARS AFTER THE BEST TECHNOLOGY OF THE DAY WAS USED TO SEAL IT. THIS IS WHAT PROMPTED THE EXTENSIVE LOOK BY THE COURIER-EXPRESS INTO THE ENTIRE HAZARDOUS WASTE SITUATION.

WIDESPREAD HAZARD

"I'M SURE ALL THE STATE ARE GOING TO BE FACING THESE KINDS OF PROBLEMS," COMMENTED TOM COOK, HAZARDOUS WASTE SECTION CHIEF FOR THE WASHINGTON STATE DEPARTMENT OF ECOLOGY.

HAZARDOUS MATERIALS CAN TURN UP ANYWHERE. A ONCE THRIVING FISHING INDUSTRYIN VIRGINIA'S JAMES RIVER AND IN PARTS OF CHESAPEAKE BAY HAS BEEN CRIPPLED BY THE INTENSELY DANGEROUS PESTICIDE KEPONE. THIS MATERIAL LEAKED OUT OF TWO MANUFACTURING PLANTS IN HOPEWELL, VA. SOME OF IT WAS SIMPLY DUMPED DOWN THE DRAIN.

SUBSEQUENTLY, AN EAP REPORT CITED LIFE SCIENCE PRODUCTS CO. FOR ITS "CARELESS MANUFACTURING AND DISPOSAL PRACTICES" WHICH LED TO "DELETERIOUS HEALTH EFFECTS ON THE PRODUCTION WORKERS" OF THE HOPEWELL SEWAGE TREATMENT PLANT.

SHAKING PALSY

MANY WORKERS AT THE LIFE SCIENCE AND THE SEMI-WORKS PLANT OF THE ALLIED CHEMICAL CORP., NEARBY, MAY NEVER RECOVER FROM A SHAKING PALSY OR THE INTERNAL DAMAGE BROUGHT ON IN MAKING THE PESTICIDE.

THE PESTICIDE MIREX HAS BEEN FOUND IN SIGNIFICANT QUANTITIES IN LAKE ONTARIO. MIREX AND THE VIRGINIA PESTICIDE WERE DUMPED FROM THE NIAGARA FALLS PLANT OF THE HOOKER CHEMICALS AND PLASTICS CORP. IN ADDITION, SOME SCIENTISTS SUSPECT NATURAL ACTION IN THE LAKE IS TURNING SOME OF THE MIREX INTO KEPONEX.

BOTH ARE MADE FROM A CHEMICAL HOOKER CALLS "C-56."

AT A HOOKER PLANT IN MONTAGUE, MICH., A FEW MILES NORTH OF MUSKEGON, WASTE MATERIAL FROM THE MANUFACTURE OF C-56 WAS DUMPED ON A SITE INSIDE THE PLANT NOT FAR FROM WHITE LAKE, A LOCAL SOURCE OF WATER AND RECREATION.

FOUND IN WELLS

THE C-56 HAS TURNED UP IN WELLS IN THE IMMEDIATE PLANT AREA AND STATE OFFICIALS SAY IT IS "MIGRATING" TOWARD WHITE LAKE.

BRUCE DAVIS, EXECUTIVE VICE PRESIDENT OF THE INDUSTRIAL CHEMICALS GROUP FOR HOOKER, TOLD THE COURIER-EXPRESS MIREX WAS NEVER MADE, STORED OR HANDLED IN MONTAGUE. BUT MIREX HAS BEEN FOUND IN THE DUMP SITE THERE.

THERE IS SPECULATION THAT SOMEHOW THE C-56 MOLECULES IN THE DUMP REACTED TOGETHER TO FORM THE DANGEROUS MIREX.

MORE THAN TWO DECADES AGO, THE PESTICIDE 2,4-D MYSTERIOUSLY TURNED UP IN GROUND WATER AT ROCKY MOUNTAIN ARESENAL. THE 2,4-D APPARENTLY WAS PRODUCED DEEP IN THE EARTH FROM A VARIETY OF PESTICIDE AND CHEMICAL WARFARE WASTES DUMPED INTO LAGOONS ON ARSENAL GROUNDS.

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DEEP WELL

AFTER THE LAGOONS WERE FOUND TO BE DEFECTIVE BECAUSE THEY LEAKED, THE ARSENAL DRILLED A WELL MORE THAN TWO MILES INTO THE GROUND AND OVER A THREE YEAR PERIOD PUMPED 165 MILLION GALLONS OF THE WASTES INTO THE GROUND.

A SERIES OF EARTHQUAKES IN THE AREA BEGAN SHORTLY AFTER THE WASTE BEGAN TO BE PUMPED DOWN THE WELL. SOME SCIENTISTS THINK THE MATERIAL IN SOME WAY LUBRICATED ROCK AND CAUSED THE QUAKES.

THIS IS THE SUBJECT OF WIDE DISPUTE. HOWEVER, EPA NOTED IN A REPORT ON THE WASTE PROBLEM AT ROCKY MOUNTAIN ARESENAL, "CORRELATION OF THE INJECTION OF LARGE VOLUMES OF LIQUID INTO THE WELL WITH EARTHQUAKES IN THE DENVER AREA CAUSED THIS OPERATION TO CEASE IN 1966."

PAYS PIPER

AN INDUSTTIAL SOCIETY IS NOW PAYING THEPIPER FOR THE CHEMICAL WONDERS WHICH SURROUND US. ALMOST EVERY CHEMICAL PROCESS LEAVES A WASTE IN THE AIR, THE WATER OR THE LAND WHOSE ABILITY TO ACCEPT WHAT HAS BEEN DUMPED HAS BEEN OVERLOOKED.

THE ABILITY OR THE DESIRE OF TOO MANY GOVERNMENTS TO DO ANYTHING ABOUT WHAT IS GOING ON IS DOUBTFUL. WITHOUT ADEQUATE FEDERAL REGULATION, STATES CAN ATTRACT INDUSTRY BY NOT CHECKING TOO CLOSELY WHAT INDUSTRIES ARE DOING WITH THEIR WASTE.

SOME UNSCRUPULOUS PERSONS OR COMPANIES PROCLAIM THEMSELVES TO BE WASTE TREATERS OR HAULERS AND HAUL THE WASTE OFF INTO THE NIGHT, TO DISPOSE OF THE MATERIAL BY THE SIDE OF THE ROAD, INTO REGULAR GARBAGE DUMPS OR INTO SCENIE AREAS LIKE THE SANDY FORESTS OF THE PINE BARRENS OF SOUTHERN NEW JERSEY.

AS LONG AS INDUSTRIAL WASTE IS PRODUCED, IT HAS TO GO SOMEWHERE.

PERHAPS THE MOST TRUTHFUL RESPONSE TO WHAT HAPPENS THEN CAME FROM BURKE LOKEY, A PUBLIC HEALTH ENGINEER WITH THE RADIATION AND HAZARDOUS WASTE CONTAMINATION DIVISION OF THE COLORADO HEALTH DEPARTMENT.

HE SAID, "WE DON'T CARE AS LONG AS THEY TAKE IT OUT OF STATE."

SUNDAY: EPA AND GOVERNMENT INACTION.

FACTORY WASTES HEAVIEST IN DIXIE

EPA ESTIMATES THE 14 LARGEST WASTE-PRODUCING INDUSTRIES POUR OUT 28 MILLION TONS PER YEAR. ON A REGIONAL BASIS, THE WASTE IS DISTRIBUTED THIS WAY, IN MILLIONS OF TONS AND PERCENTAGES;

TABLE OMITTED.

THE INDUSTRIES ARE BATTERY MAKING; ORGANIC CHEMICALS, PESTICIDES AND EXPLOSIVES, INORGANIC CHEMICALS; PETROLEUM REFINING; PAINT AND ALLEID PRODUCTS; TEXTILES; RUBBER AND PLASTICS; PRIMARY METALS; METAL MINING; PETROLEUM RE-REFINING; PHARMACEUTICALS; LETHER; TANNING AND FINISHING; SPECIAL MACHINERY; AND ELECTROPLATING.

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RULES ON WASTES DUE IN 1980-EPA

WASHINGTON -- NEW REGULATIONS GOVERNING THE MANAGEMENT TRANSPORTATION AND DISPOSAL OF HAZARDOUS WASTES WILL NOT BE ISSUED UNTIL JANUARY, 1980, THE ENVIRONMENTAL PROTECTION AGENCY ANNOUNCED FRIDAY.

STAFFEN PLEHN, DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE, TOLD A PACKED PUBLIC METTING THAT ALTHOUGH THE LAW REQUIRED THEM TO BE PROMULGATED LAST APRIL, THE NEW REGULATIONS WOULD BE DELAYED FOR MORE THAN A YEAR.

"IF IT WERE WITHIN OUR POWER WE WOULD WANT TO HAVE AN OPERATIONAL HAZARDOUS AND SOLID WASTE REGULATORY PROGRAM IN PLACE IMMEDIATELY," PLEHN SAID. "HOWEVER, THAT IS NOT POSSIBLE."

DIFFICULT ISSUES INVOLVED

WHEN ASKED WHAT THE AGENCY HAD BEEN DOING FOR THE PAST 18 MONTHS, PLEHN REPLIED THAT IT WAS DELAING WITH THE "VERY DIFFICULT TECHNICAL, FINANCIAL, LEGAL AND ENVIRONMENTAL ISSUES" THAT THE LAW PROVIDES.

HE REFUSED TO ANSWER ANY SUBSTANTIVE QUESTIONS DEALING WITH THE PROPOSED RULES THEMSELVES, RESTRICTING QUESTIONING TO THE LIMITED ISSUE OF THE TIMETABLE.

CONGRESS PASSED THE RESOURCE CONSERVATION AND RECOVERY ACT TO DEAL WITH HAZARDOUS WASTES. THE LAW STIPULATED THAT THE REGULATIONS SHOULD BE PROMULGATED "NO LATER THAN 18 MONTHS" AFTER ENACEMENT. THE LAW WAS PASSED IN OCTOBER, 1976.

MORE SUITS THREATENED

THE STATE OF ILLINOIS AND TWO ECOLOGY ORGANIZATIONS, ENVIRONMENTAL DEFENSE FUND AND ENVIRONMENTAL ACTION, HAVE BROUGHT SEPARATE SUITES AGAINST EPA FOR FAILING TO ENACT THE REGULATIONS.

OTHER GROUPS, SUCH AS THE NATIONAL SOLID WASTE MANAGEMENT ASSOCIATION, HAVE PUT EPA ON NOTICE THAT THEY ALSO WILL SUE IF THE RULES ARE NOT ISSUED SOON.

THE NEW TIMETABLE IS A LENGTHY LIST OF MEETINGS, HEARINGS, REVIEWS, AND ASSESSMENTS. EPA OFFICIALS SAID ALL THE ACTIONS WERE NEEDED TO INSURE "FULL PUBLIC PARTICIPATION."

"THESE ARE THE BEST PROCEDURES WE'VE BEEN ABLE TO DEVISE AS AN AGENCY," PLEHN SAID.

PLEHN ALSO SAID THAT THE PROCEDURE COULD BE SHORTENED OR LENGTHENED, DEPENDING ON WHAT THE AGENCY'S REVIEW OF PUBLIC COMMENTS SHOWS.

INDUSTRIES BACK EPA

AT FRIDAY'S MEETING, REPRESENTATIVES FROM INDUSTRIES WHO DEAL IN HAZARDOUS WASTES STOOD FULLY BEHIND THE EXPANDED TIMETABLE.

"THE PROMULGAITON DATE WAS SET BY CONGRESS WITHOUT UNDERSTANDING THE DIFFICULTY," SAID ROBERT HARNESS OF MONSANTO. "CONTRARY TO POPULAR BELIEF, THE EXTENDED SCHEDULE WILL NOT MEAN OPEN SEASON FOR HAZARDOUS WASTES."

OTHER INDUSTRY REPRESENTATIVES ECHOED HARNESS, SAYING THEY THOUGHT THE TIMETABLE WAS "REALISTIC."

THEY ALSO COMPLAINED, HOWEVER, THAT THE NEW REGULATIONS COULD END UP BEING TOO BROAD. HARNESS SAID THAT "RELATIVELY INOCUOUS WASTES" WOULD BE INCLUDED UNDER THESE RULES.

SOME EPA SOURCES SAID THAT THE NEW TIMETABLE WAS DRAWN UP BECAUSE THEY WERE AFRAID TO ENACT TOUGHER RULES IN THE EMOTIONAL WAKE OF LOVE CANAL AND SIMILAR SITUATIONS ELSEWHERE. THEY SAID THEY WOULD PREFER TO TAKE THEIR TIME AND WAIT UNTIL THE CLAMOR HAD DIED DOWN.

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CHEMICAL GLOSSARY

MIREX -- A PESTICIDE USED AGAINST FIRS ANTS. IT IS THOUGHT TO CAUSE LIVER DAMAGE AND SOME ANIMAL BIRTH DEFECTS.

KEPONE -- A PESTICIDE USED AGAINST ANTS AND ROACHES. IT IS SUSPECTED AS A CHEMICAL WHICH CAUSES CANCER IN HUMANS. IT IS KNOWN TO CAUSE NERVE DISORDERS AND LIVER DAMAGE IN HUMANS.

CHLOROFORM -- A CHEMICAL USED AT ONE TIME AS AN ANESTHETIC. IT IS A CAUSE OF ANIMAL CANCER.

TRICHLOROETHYLENE -- AN INDUSTRIAL SOLVENT. IT CAUSES CANCER IN LABORATORY ANIMALS.

HEXACHLOROBENZENE -- A BYPRODUCT OF THE MANUFACTURE OF INDUSTRIAL SOLVENTS. IT CAN EVENTUALLY CAUSE LIVER DAMAGE.

PCB -- THE TERM USED TO DESCRIBE ABOUT 200 CHEMICALS KNOWN AS POLYCHLORINATED BIPHENYLS. THEY ARE USED IN THE ELECTRICAL INDSUTRY AND IN PLASTICS. MANUFACTURE IS NOW BANNED. THEY CAUSE LIVER DAMAGE TO HUMANS AND HAVE A VARIETY OF BAD EFFECTS ON FISH AND WILDLIFE.

SODIUM -- A METAL WHICH EXPLODES ON CONTACT WITH AIR. IT IS USUALLY STORED SO IT WILL NOT BE SO EXPOSED.

C-56 -- THE TRADE NAME OF THE HOOKER CHEMICALS & PLASTICS CORP. FOR HEXACHLOROCYCLOPENTADIENE. VERY LITTLE IS KNOWN ABOUT ITS EFFECTS ON HUMANS BUT IN INDUSTRIAL USE VERY LOW EXPOSURE IS RECOMMENDED.

2,4-D -- A HERBICIDE SOMETIMES USED TO KEEP DOWN WEEDS IN ROADSIDE DITCHES. IT IS KNOWN AS 2,4-D BECAUSE THE FULL NAME IS 2,4-DICHLOROPHENOXYACETIC ACID.

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EPA SLOW IN FIGHTING WASTE PERIL BEHIND SCHEDULE IN WRITING RULES BURY NOW, PAY LATER

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE SECOND IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH THE INEPTITUDE OF THE FEDERAL AGENCY WHICH SHOULD BE ATTACKING THE PROBLEM, BUT WHICH APPARENTLY IS NOT EVEN AWARE OF ITS SERIOUSNESS.

THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY IS SO SNARLRED IN ITS OWN BUREAUCRACY THAT IT APPARENTLY HAS NOT YET REALIZED IT IS AT WAR WITH A DEADLY ENEMY: THE MOUNTAINS AND RIVERS OF TOXIC WASTES THAT ARE THREATENING THE NATION'S HEALTH AND SAFETY.

THERE IS NOT OTHER WAY TO EXPLAIN WHY FEWER THAN 200 OF EPA'S NEARLY 11,000 EMPLOYEES HAVE BEEN MUSTERED TO FIGHT THE CHEMICAL FOE.

THE BUILDING IN WHICH THE EPA IS LOCATED IN WASHINGTON, D.C., IS A PERFECT MATCH FOR THE AGENCY -- ALMOST TOTALLY CONFUSING.

THE STRUCTURE, CALLED THE WATERSIDE MALL, IS A MISTURE OF TWO TOWERS WITH A LOW SLUNG OFFICE AND SHOPPING SECTION CONNECTING THEM. VISITORS ARE ISSUED MAPS TO TRY TO HELP THEM AROUND THE COMPLEX AND EPA WORKERS ADMIT THEY FREQUENTLY GET LOST THEMSELVES.

EPA IS A YOUNG AGENCY WITH BURGEONING RESPONSIBILITIES. IT IS SUPPOSED TO DO EVERYTHING FROM CHECKING GAS MILEAGE ON CARS TO CONTROLLING THE DUMPING OF HAZARDOUS CHEMICALS INTO THE ENVIRONMENTAL.

UNDER ATTACK

NEARLY EVERYTHING THE AGENCY DOES IS CONTROVERSIAL. INDUSTRY ATTACKS EPA BECAUSE PROPOSALS ARE TOO EXPENSIVE. ENVIRONMENTALISTS ATTACK EPA BECAUSE THE AGENCY ISN'T MOVING FAST ENOUGH. CITIZENS ATTACK EPA FOR NOT DOING SOMETHING ABOUT MYRIAD PROBLEMS.

AND, EVEN IN AN ERA OF BIG GOVERNMENT, EPA IS BIG GOVERNMENT.

DOUGLAS M. COSTLE HAS BEEN ADMINISTRATOR OF EPA SINCE MARCH 5, 1977.

IN THE FEDERAL FISCAL YEAR WHICH STARTS OCT. 1, EPA WILL SPEND $1.2 BILLION. THERE ARE 10.946 BUDGET EPA EMPLOYEES. YET, ONLY $25.2 MILLION WILL BE FOR HAZARDOUS WASTES, AND ONLY 161 WORKERS -- IN HEADQUARTERS AND IN THE 10 REGIONAL OFFICES -- ARE WORKING ON THE PROBLEM. OF THE $25.2 MILLION, $15 MILLION IS GOING TO THE STATES TO HELP THEM LOOK INTO THE PROBLEM.

ENVIRONMENTAL GROUPS HAVE SUED EPA FOR ADMINISTRATIVE SLOTH. ON APRIL 21, THE AGENCY WAS SUPPOSED TO RELEASE REGULATIONS TO PUT THE RESOURCE CONSERVATION RECOVERY ACT (RCRA) INTO EFFECT. THIS WAS 18 MONTHS AFTER PRESIDENT GERALD R FORD SIGNED THE LEGISLATION INTO LAW. BUT EPA IS 21 MONTHS BEHIND SCHEDULE.

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RCRA HAS THREE MAIN GOALS. THEY ARE THE ENCOURAGEMENT OF CONSERVING RESOURCES RATHER THAN DISPOSING OF THEM; IMPROVING THE DISPOSAL OF ALL SOLID WASTES TO PROTECT PUBLIC HEALTH AND ENVIORNMENTAL QUALITY; AND, REGULATING HAZARDOUS WASTES FROM GENERATION TO DISPOSAL. THE LAWS ENCOURAGE STATES TO ACT ON THEIR OWN. BUT, IF THEY DON'T EPA WILL ENFORCE THE ACT.

TARGET DATE

GARY DIETRICH, ASSOCIATE DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE FOR EPA, TOLD THE COURIER-EXPRESS IN HIS WASHINGTON OFFICE THE CURRENT TARGET FOR "PROMULGATION" OF THE REGULATIONS IS JANUARY 1980. HE CALLED THAT SCHEDULE "PRETTY DAMN TIGHT" AT THE PRESENT RATE OF PROGRESS.

NEITHER THE STATE OF ILLINOIS NOR THE DUAL GROUP OF THE ENVIRONMENTAL DEFENSE FUND (EDF) AND ENVIRONMENTAL ACTION (EA) HAVE MUCH SYMPATHY FOR EPA.

ILLINOIS ATTORNEY GENERAL WILLIAM J. SCOTT SUED EPA ON SEPT. 7 OVER ITS FAILURE TO PRODUCE THE REGULATION. HE SAID:

"WE'VE GOT TO PROVIDE SAFE MEANS FOR STORAGE AND DISPOSAL OF TOXIC WASTES IN ORDER TO BOTH SERVE OUR INDUSTRY AND TO PROTECT THE HEALTH OF CITIZENS. WE CAN DO IT, THE LAW IS ON THE BOOKS, AND NOW IS THE TIME FOR THE FEDERAL GOVERNMENT AND ITS EMPLOYEES TO LIVE UP TO THE LAW AND ACT." "THE THREAT TO HEALTH POSED BY HAZARDOUS WASTE IS CLEAR," SAID EDF SCIENCE ASSOCIATE LESLIE DACH.

"UNLESS PROPERLY TAKEN CARE OF, TI WILL COME BACK TO HAUNT US AND OUR CHILDREN," THE EDF OFFICIAL CONTINUED.

MAJOR PROBLEM

A. BLAKEMAN EARLY, A LEGISLATIVE REPRESENTATIVE FOR EA, NOTED, "ONE MAJOR PROBLEM IS THAT THOSE DISPOSAL SITE OPERATORS WHO KNOW THEY CAN NOT MEET EPA'S REGULATIONS ARE LOADING TOXIC, POISONOUS WASTES INTO THEIR SITES AS FAST AS POSSIBLE BEFORE THESE REGULATIONS ARE ISSUED. THE LONGER EPA WAITS TO ISSUE REGULATIONS, THE MORE THE TOXIC DISPOSAL PROBLEM GROWS."

DACH OF EDF ASKED, "EPA ACTS AS IF THE LAW WERE A MEANINGLESS SCRAP OF PAPER. THEY SIT AROUND WHILE NEARLY TWO BILLION MORE POUNDS OF POISONS ARE UNSAFELY DISPOSED OF EVERY WEEK. HOW MANY MORE LOVE CANALS DO WE NEED TO GET SOME ACTION?"

"THE "LOVE CANAL" REFERS TO A FORMER CHEMICAL WASTE DUMP IN NIAGARA FALLS. IN 1976, FOR REASONS WHICH ARE NOT YET CLEAR, THE DUMP BEGAN TO LEAK HIGH CONCENTRATIONS OF CHEMICALS, SOME OF WHICH CAUSE CANCER IN HUMANS AND LABORATORY ANIMALS. NEW YORK STATE IS COMMITTED TO MOVING 237 FAMILIES AWAY FROM THE AREA AND CLEANING IT UP.

A NUMBER OF OTHER GROUPS ARE EXPECTED TO SUE EPA OVER ITS FAILURE TO ISSUE NEW, TOUGH REGULATIONS.

LAW'S DELAY

COMPANIES IN THE WASTE DISPOSAL FIELD ARE RELUCTANT TO INVEST IN NEW FACILITIES TO HANDLE HAZARDOUS WASTE BECAUSE THEY DON'T KNOW IF THE FACILITIES WILL MEET THE EPA REGULATIONS TOBE ISSUED IN 1980. EARLIER PROPOSED REGULATIONS HAVE ALREADY BEEN DRASTICALLY CHANGED AND THERE WILL BE MORE CHANGES.

THE MONEY TO GO INTO HAZARDOUS WASTE MANAGEMENT CAN BE SIGNIFICANT. EDWARD R. SHUSTER, VICE PRESIDENT MARKETING SALES FOR NEWCO CHEMICAL WASTE SYSTEMS INC., IN NIAGARA FALLS, TOLD THE COURIER-EXPRESS IT MIGHT COST $20 MILLION TO JUST BUILD ONE INCINERATOR WHICH COULD PROPERLY HANDLE THE

CARL GOSLIN, ASSISTANT TECHNICAL DIRECTOR OF THE MANUFACTURING CHEMISTS ASSOCIATION (MCA) IN WASHINGTON, COMMENTED, "IT TAKES $10 MILLION TO BUILD A PROPERLY DESIGNED PLANT -- AT AN OFF HAND ESTIMATE". THE MCA IS THE TRADE GROUP FOR THE GREAT CHEMICAL COMPANIES.

THERE IS NO GREAT RUSH INTO A FIELD WHICH REMAINS SO UNCERTAIN WITHOUT THE FINAL RULES AND REGULATION.

MUCH OF THE EPA EFFORT HAS BEEN FIRE FIGHTING. AGENCY OFFICIALS AND WORKERS ARE CONSTANTLY BEING SENT INTO AREAS WHERE CHEMICAL SITUATIONS HAVE GONE HAYWIRE.

IN THE OLD TEXTIEL TOWN OF LOWELL, MASS., A BANKRUPT CHEMICAL STORAGE AND TREATMENT COMPANY SITE IS LEAKING TOXIC CHEMICALS INTO A NEARBY RIVER WHICH PROVIDES WATER FOR LAWRENCE, MASS. DOWNSTREAM. THERE ARE ESTIMATED TO BE 15,000 DRUMS OF A WIDE VARIETY OF CHEMICALS ON THE SITE AND HUNDREDS OF THOUSANDS OF GALLONS OF CHEMICALS IN STORAGE TANKS.

BIDS ASKED

VARIOUS CHEMICAL WASTE TREATMENT COMPANIES HAVE BEEN ASKED FOR BIDS ON COST OF REMOVAL OF THE MATERIALS AND CLEANUP OF THE SITE.

EVEN WITHOUT THE LONG-DELAYED REGULATIONS, EPA IS STUMBLING INTO ACTION. IN THE FISCAL YEAR WHICH ENDS SEPT. 30, THE AGENCY HAS GIVEN $3.8 MILLION TO STATES TO SURVEY CHEMICAL WASTES AND THEIR ULTIMATE DISPOSAL. IN THE FISCAL YEAR WHICH STARTS OCT. 1, THAT WILL RISE TO $15 MILLION.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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ACCORDING TO DIETRICH, EPA HAS TO DO THIS. "THE STATUTE IS SILENT ON INACTIVE SITES. IT SEEMS TO DEAL WITH PROSPECTIVE PROBLEMS," HE NOTED. SO, EPA IS DOING NOTHING ITSELF ABOUT CLOSED SITES.

THE VIEW DRAWS FIRE. EARLY, OF ENVIRONMENTAL ACTION, SCOFFS, "IT'S A REACTION TO A REALIZATION THAT THERE ARE MORE WASTES OUT THERE THAN EPA CAN HANDLE," HE SAID. THIS GROUP IS PART OF THE COALITION WHICH SUED EPA ON WEDNESDAY.

SOME OF THE SAME GROUPS SUED EPA EARLIER OVER ITS FAILURE TO ISSUE REGULATIONS UNDER THE SAFE DRINKING WATER ACT OF 1974. UNDER A CONSENT DECREE, THE AGENCY IS STILL WORKING TO STUDY LIST OF 129 POLLUTANTS.

CONTROL METHODS

EPA HAD BEEN REQUIRED TO ESTABLISH METHODS FOR CONTROL AND ANALYSIS OF TOXIC SUBSTNACES IN WASTE WATER. WHEN THE AGENCY FAILED TO DO IT, IT WAS SUED. ON JUNE 7, 1976, EPA SIGNED THE CONSENT DECREE AGREEING TO DO WHAT IT WAS SUPPOSED TO DO.

OF THE 129 CHEMICALS, IT HAS FINALLY REACHED A DECISION ON HOW IT WILL ANALYZE ALL OF THEM. NOW, IT PLANS TO START MEASURING THEM AT VARIOUS PLACES AROUND THE COUNTRY. THEN, BASED ON THE RESULTS, RULES AND REGULATIONS WILL BE WRITTEN.

SINCE EPA CAN'T MEET VARIOUS DEADLINES IN THE CONSENT DECREE, EARLY COMMENTED TO THE COURIER-EXPRESS, "IT RAISES THE QUESTION OF WHAT CAN BE DONE WITH A LAWSUIT." HE NOTED THE AGENCY IS 18 MONTHS LATE ON THE CONSENT DECREE.

MUCH OF THE PROBLEM IS THAT MANY OF THESE CHEMICALS HAVE BEEN USED FOR YEARS, WITHOUT ANYBODY KNOWKING VERY MUCH ABOUT THEM. NOW SOPHISTICATED PROCEDURES HAVE TO BE USED TO SET LIMITS ON THEM IN WATER.

EPA IS ALSO FACING SOME INTERNAL PROBLEMS. ENVIRONMENTALISTS CLAIM SOME OF ITS REGIONS ARE NOT VERY ACTIVE IN DEALING WITH THE PROBLEMS OF HAZARDOUS CHEMICALS.

ONE REGION OFTEN CITED IS THAT HEADQUARTERED IN DALLAS WHICH COVERS TEXAS, OKLAHOMA, NEW MEXICO, LOUISIANA AND ARKANSAS. THIS IS THE HEATLAND OF AMERICA'S PETRO-CHEMICAL INDUSTRY.

DIETRICH NOTED A RECENT TELEPHONE CONFERENCE AMONG ALL REGIONAL DIRECTORS TO DISCUSS THE HAZARDOUS WASTE SITUATION AND A PLANNED MEETING THIS MONTH IN WASHINGTON. HE WANTS ALL REGIONS ACTIVE ON THE PROBLEM.

BUT, THE REGIONAL STRUCTURAL WEAKNESSES OF EPA WERE CLEAR WHEN HE COMMENTED, "WE AT EPA HEADQUARTERS DON'T KNOW HOW MANY HAZARDOUS WASTE SITES THERE ARE OUT THERE." HE SAID IT WAS UP TO THE STATES AND THE REGIONAL OFFICES TO KNOW, BUT MOST OF THE DON'T KNOW EITHER.

IN AN ADMISSION THAT CUTS TO THE HEART OF THE ENTIRE PROBLEM, DIETRICH SAID, "WE DON'T KNOW VERY MUCH ABOUT WHERE PEOPLE ARE TOSSING HAZARDOUS WASTES."

MONDAY: ILLEGAL DUMPING OF TOXIC WASTES.

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ILLEGAL WASTE HAULERS CREATE U.S. TIME BOMB BURY NOW, PAY LATER

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE THIRD IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH TOXIC WASTE DUMPING PRACTICES, LEGAL AND ILLEGAL.

THERE ARE TWO WAYS TO DISPOSE OF HAZARDOUS CHEMICAL WASTES -- LEGALLY AND ILLEGALLY. AND THE ILLEGAL WAY IS BY FAR THE MOST COMMON.

"MIDNIGHT HAULERS," AS ILLEGAL WASTE-DUMPERS ARE KNOWN, ARE FAMILIAR FIGURES IN THE CHEMICAL INDUSTRY. THEY ARE ESPECIALLY FAMILIAR AMONG SMALLER CHEMICALLY-ORIENTED COMPANIES WHICH CANNOT AFFORD THE HIGH COSTS OF LEGAL WASTE TREATMENT OR DISPOSAL.

HOW EXPENSIVE IS LEGAL WASTE TREATMENT? ONE OPERATOR OF A WELL-KNOWN CHEMICAL WASTE TREATMENT PLANT CITED THIS EXAMPLE TO THE COURIER-EXPRESS: TO TURN ONE TYPE OF CHEMICAL INTO HARMLESS MATERIAL COSTS $5 A GALLON. THE CHEMICAL COMES IN 55-GALLON DRUMS. THE COST, THEN, IS $275 PER DRUM. MULTIPLIED BY THE THOUSANDS OF DRUMS WHICH MUST BE DISPOSED OF, AND THE COSTS WOULD BE ASTRONOMICAL.

DUPONT COSTS

E.I. DUPONT DENEMOURS & CO. INC., FOR EXAMPLE, WILL SPEND $35 MILLION THIS YEAR TO OPERATE ITS DISPOSAL SYSTEM FOR CHEMICAL WASTES FROM ITS OWN VAST COMPLEX OF PLANTS ACROSS THE NATION. THE FIRM SAID IT EXPECTS TO SPEND EVEN MORE NEXT YEAR.

C. EDWARD ASHBY JR. IS WELL AWARE OF THE "MIDNIGHT HAULER" PROBLEM. HE IS VICE PRESIDENT-EASTERN REGION FOR ROLLINS ENVIRONMENTAL SERVICES INC. IN BRIDGEPORT, N.J., A DISPOSAL FIRM LOCATED NOT FAR FROM THE STATE'S RUSTIC PINE BARRENS. HE GRIMACES WHEN "MIDNIGHT HAULING" IS MENTIONED AS AN ALTERNATIVE TO PROPER DISPOSAL, BUT ADMITS IT IS COMMON.

NEW JERSEY IS A CHEMIST'S DREAM. FROM THE INDUSTRIAL COMPLEX ACROSS THE DELAWARE RIVER FROM PHILADELPHIA TO THE MILES OF INDUSTRY ACROSS THE HUDSON RIVER FROM NEW YORK CITY, THE STATE IS A GIANT TEST TUBE.

BIG WASTE PRODUCER

CURRENTLY, THE STATE PRODUCES 350,000 TONS OF CHEMICAL WASTE A YEAR AND 1.2 BILLION GALLONS MORE WHICH IS DUMPED INTO THE OCEAN, ACCORDING TO DR. RONALD BUCHANAN, CHIEF OF THE BUREAU OF HAZARDOUS AND CHEMICAL WASTES IN THE STAT'S DEPARMENT OF ENVIRONMENTAL PROTECTION IN TRENTON.

BUT, HE IS WELL AWARE OF THE PINE BARRENS AND ITS COUNTERPART IN NORTH JERSEY, THE MEADOWLANDS, WHERE ILLEGAL DUMPING IS COMMON.

MANY STATES HAVE EQUIVALENT ILLEGAL DUMPING AREAS. KENNETH WEISS, A RESEARCH ENGINEER FOR THE DELAWARE DEPARTMENT OF NATURAL RESOURCES AND ENVIRONMENTAL CONTROL IN DOVER, NOTED, "FROM WHAT WE HAVE LEARNED FROM OUR WASTE INVESTIGATION, MOST OT IT IS GOING OUT OF STATE."

HOWEVER, THE DEPARTMENT MAKES NO ATTEMPT TO VERIFY RECORDS SHOWING AN OUT OF STATE DESTINATION, HE ADMITTED.

MANY STATES HAVE LAWS OR RULES ON THE BOOKS TO TAKE CARE OF HAZARDOUS WASTES. BUT, HERE IS LITTLE OR NO STAFF TO ENFORCE THE LAWS, SO THEY ARE LARGELY JUST FOR SHOW.

TIP OF ICEBERG

"WE DON'T HAVE THE ABILITY WITH OUR CURRENT STAFFING TO DO MORE THAN BREAK THE TIP OF THE ICEBERG," WAS THE COMMENT OF JAMES SNYDER, CHIEF OF THE OPERATIONS AND COMPLIANCE SECTION OF THE SOLID WASTE MANAGEMENT DIVISION OF THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES.

THIS ISN'T A PROBLEM CONFINED TO THE LARGE INDUSTRIAL STATES. "WE'RE CERTAIN THERE ARE THINGS THAT ARE GOING ON WE DON'T KNOW ABOUT," COMMENTED DENNIS DALLEY, ASSOCIATED DEPUTY DIRECTOR OF HEALTH IN THE ENVIRONMENTAL HEALTH SERVICES BRANCH IN THE DIVISION OF HEALTH IN THE UTAH DEPARTMENT OF SOCIAL SERVICES. HE IS ONE OF THREE STATE EMPLOYEES IN THE HAZARDOUS WASTE FIELD.

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NEW JERSEY . . . "GIANT TEST TUBE."

DRAWING OMITTED

LOUISVILLE, KY. FOUND OUT ABOUT ILLEGAL DUMPING IN THE SPRING OF 1977. A SERIES OF TOXIC CHEMICALS USED TO MAKE PESTICIDES WERE DUMPED DOWN A SEWER. THE CHEMICALS CONTAMINATED THE SEWER SYSTEM AND SENT 35 SEWER PLANT WORKERS FOR MEDICAL TREATMENT.

SEWAGE DUMPED

FOR NEARLY THREE MONTHS, 100 MILLION GALLONS OF RAW SEWAGE A DAY WAS PUT INTO THE OHIO RIVER BECAUSE THE MORRIS FOREMAN TREATMENT PLANT COULD NOT BE USED.

FINAL CLEANUP OF SEWER LINES TOOK MORE THAN A YEAR, WHILE MUCH RAW SEWAGE CONTINUED TO FLOW INTO A MAJOR RIVER. A GROUP OF EMPLOYEES AND OFFICIALS OF AN INDIANA CHEMICAL FIRM WERE INDICTED IN FEDERAL COURT FOR VIOLATING THE FEDERAL WATER POLLUTION CONTROL ACT.

RECENTLY, MIDNIGHT DUMPERS POURED TOXIC PCB ALONG 210 MILES OF ROAD OUTSIDE RALEIGH, N.C.

"THERE ARE STATES, MINNESOTA IS ONE, UNLIKE NEW YORK WHO HAVE PUT THEIR HEAD IN THE SANDS," COMMENTED DR. CHARLES A. JOHNSON, TECHNICAL DIRECTOR OF THE NATIONAL SOLID WASTES MANAGEMENT ASSOCIATION IN WASHINGTON, D.C. HE ADDED:

"AS LONG AS WE CONTINUE TO BE AN INDUSTRIAL SOCIETY WE ARE GOING TO HAVE INDUSTRIAL WASTES."

HIS GROUP LOBBIED HARD FOR THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA). AT THE SAME TIME, THE ASSOCIATION DOESN'T THINK THE LAW PROVIDES ENOUGH PROTECTION INTO THE DISTANT FUTURE.

AND, THE FUTURE IS THE PROBLEM.

LOVE CANAL

WHEN THE HOOKER CHEMICALS & PLASTICS CORP. BURIED ITS WASTE IN THE INDUSTRIAL DREAM THAT WAS THE LOVE CANAL AREA OF NIAGARA FALLS, IT WAS USING THE STANDARD APPROACH OF THE TIME. THE CHEMICALS TURNED INTO A NIGHTMARE WHICH HAUNTS THE QUIET NEIGHBORHOOD AND MAY HAUNT ITS RESIDENTS FOR A GENERATION OR MORE.

SO, AS THE HORRIBLE EXAMPLE OF THE LOVE CANAL INDICATES, THERE ARE EVEN PROBLEMS WITH LEGAL DUMPS.

THE LOVE CANAL WAS A CHEMICAL WASTE DUMP WHICH WENT WRONG. THE BAD DUMPS AROUND THE COUNTRY -- AND THERE ARE PROBABLY MANY THOUSANDS OF THEM -- ARE TICKING TIME BOMBS. IN THE LOVE CANAL, THE BOMB HAS GONE OFF. CHEMICALS FROM THE LEAKING SITE ARE THOUGHT TO HAVE CAUSED BIRTH DEFECTS AND MISCARRIAGES, AND HAVE FORCED EVACUATION OF A SECTION OF NIAGARA FALLS.

WHAT FORMER DUMP SITE WILL GO OFF NEXT? THERE IS NO WAY TO TELL. THE U.S. ENVIRONMENTAL PROTECTION AGENCY, THE GOVERNMENT UNIT RESPONSIBLE FOR PROTECTING THE NATION'S HEALTH FROM SUCH CALAMITIES, ADMIST IT DOES NOT EVEN KNOW WHERE THE SITES ARE.

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SOME WASTE IS SUPPOSED TO BE BURNED, FEDERAL REGULATIONS REQUIRE THAT PCBS BE BURNED IN SPECIAL INCINERATORS AT 2,100 DEGREES. BUT, THERE IS NO PUBLIC INCINERATOR IN THE COUNTRY LICENSED TO BURN LIQUID PCBS. SO, THEY HAVE TO BE STORED UNTIL EPA CAN LICENSE INCINERATORS.

WASTE FUEL

SOME CHEMICALS ARE CLEANED AND MIXED AND USED A FUELS IN INDUSTRIAL PROCESSES. SINCE THE OIL EMBARGO OF FIVE YEARS AGO, INDUSTRY IS MUCH MORE AWARE OF THIS SOURCE OF HEAT, ONE LARGE TREATMENT PLANT USES ABOUT 10 PERCENT OF THE WASTES IT HANDLES AS A FUEL SUPPLEMENT.

SOME CHEMICALS CAN BE TREATED AND CLEANED AND REUSED. THIS IS ESPECIALLY TRUE OF INDUSTRIAL SOLVENTS. ONE PLANT RECYCLES 10 PERCENT ON THE AVERAGE.

SOME LIQUID WASTE CAN BE TREATED TO PRECIPITATE OUT THE CONTAMINANT IN THE FORM OF A SLUDGE. THE WATER IS THEN CLEANED AND DISCHARGED. USUALLY THE SLUDGE IS BURIED. BUT, SOME METALS CAN BE RECLAIMED IF CONCENTRATED ENOUGH.

SOMETIMES WASTE ITSELF CAN BE EXCHANGED WITH OTHER COMPANIES AND USED AS A SOURCE MATERIAL BY THE SECOND COMPANY. CURRENTLY, LITTLE OF THIS IS BEING DONE.

THERE ARE THREE LAST RESORTS. DUMPING IN A SECURE LAND FILL IS ONE. PUMPING MATERIAL SEVERAL MILES INTO THE GROUND IN A DEEP WELL IS A SECOND. AND, HAULING THE MATERIAL OUT INTO THE OCEAN OR GULF OF MEXICO IS THE THIRD.

REDUCE WASTES

OF COURSE, THERE IS AN ALTERNATIVE COMPANIES HAVE BEEN RELUCTANT TO USE AS LONG AS DISPOSAL, AT PRESENT, IS CHEAPER: REDUCING THE AMOUNT OF WASTE TO BE DISPOSED OF. THIS CAN BE DONE BY MAKING PRODUCTING MORE EFFICIENT OR BY CHANGING THE BASIC PROCESSES.

JAMES REILLY, CORPORATE DIRECTOR OF ENVIRONMENTAL AFFAIRS FOR DUPONT IN WILMINGTON, DEL., COMMENTED ON EFFICIENCY: "THAT GETS TO BE THE TOPIC OF ANY MANUFACTURING DISCUSSION."

BRUCE DAVIS, EXECUTIVE VICE PRESIDENT FOR HOOKER'S INDSUTRIAL CHEMICALS GROUP, NOTED HIS FIRM HAS SPENT $5 MILLION IN NIAGARA FALLS ON ONE OF ITS INDUSTRIAL PROCESSES. IT RESULTED IN "A HELL OF A LOT MORE EFFICIENCY AND ONE OF THE SAVINGS IS LESS DISPOSAL RESIDUE."

IN ANOTHER PROCESS IN NIAGARA FALLS, HE SAID, "WE'VE ESSENTIALLY ELIMINATED ANY MATERIAL GOING TO LANDFILL OR SEWER SYSTEM."

DAVIS SAID THE TECHNOLOGY INVOLVED IN THIS CHANGE WILL BE SOLD TO OTHER COMPANIES IN THE FIELD BY HOOKER. "WE ARE ONE OF THE LEADING PURVEYORS OF CHLORALKALI TECHNOLOGY IN THE WORLD," HE NOTED. THIS INVOLVES TURNING SALT AND WATER INTO COMMERCIAL CHEMICALS.

SIMPLY TRYING TO THROW AWAY THE WASTES ISN'T THE ANSWER BECAUSE IT DOESN'T WORK.

OCEAN DUMPING WILL BE STOPPED, BY LAW AFTER DEC. 31, 1981. IT HAS BEEN THE SUBJECT OF FIERCE ATTACK.

TEXAS PROTECT

ON AUG. 23, SHRIMP FISHERMEN FROM FREEPORT, TEXAS ATTACKED AN EPA PROPOSAL TO PTERMIT THE FEDERAL ENERGY DEPARTMENT TO DUMP SALT BRINE INTO A FISH SPAWNING GROUND. THE BRINE IS BEING PUMPED OUT OF AN UNDERGROUND SALT FORMATION TO MAKE ROOM FOR OIL STORAGE THROUGH THE GOVERNMENT'S STRATEGIC PETROLEUM RESERVE PROGRAM.

THE OIL IS EING STORED TO BE USED IN THE EVENT OF ANOTHER OIL EMBARGO. THE BRINE IS SO MUCH SALTIER THAN THE OCEAN THAT IT COULD POLLUTE THE SPAWNING GROUNDS.

LONNIE VANDERGRIFFT IS PRESIDENT OF THE FREEPORT SHRIMP ASSOCIATION AND A DIRECTOR OF GULF COAST FISHERMAN'S DEFENSE FUND. BOTH GROUPS ARE CONSIDERING A FEDERAL COURT SUIT AGAINST THE PROPOSAL. VADERGRIFFT SAID: "THE EPA IS SUPPOSED TO BE AGAINST OCEAN DUMPING. BUT, THIS WILL BE JUST LIKE A SEWER LINE INTO THE GULF."

DUMPING SUPERVISED

CURRENTLY, THE EPA IS SUPERVISING THE ANNUAL DUMPING OF 1.5 MILLION TONS OF WASTE OFF THE NEW JERSEY SHORE, DR. PETER ANDERSON, CHIEF OF THE MARINE PROTECTION BRANCH FOR EPA'S REGION 2 IN NEW YORK CITY, TOLD THE COURIER-EXPRESS.

MOST OF THE WASTE IS EITHER CHEMICALLY BASIC, AS IS THE OCEAN, OR ACIDIC WHICH IS NEUTRALIZED INTO A SALT BY THE OCEAN. SOME TOXIC PESTICIDE WASTES AND PESTICIDES ARE ALSO DUMPED. ANDERSON CLAIMED THEY DETERIORATE IN THE OCEAN. GARBAGE AND SEWAGE ARE ALSO DUMPED AND HAVE WASHED BACK ON SHORE.

REP. BOB ECKHARDT, D-TEXAS WAS INFLUENTIAL IN PUSHING FOR THE NOW REQUIRED END TO MOST DUMPING. HE POINTED OUT TO THE COURIER-EXPRESS THAT ONE STEEL COMPANY USED TO DUMP 1,000 POUNDS OF CYNIDE INTO THE HOUSTON SHIP CAHNNEL EACH DAY. EVENTUALLY, FORMER TEXAS GOVERNOR JOHN CONNALLY WAS CALLED IN BY THE COMPANY TO GET EPA OFF ITS BACK ABOUT THE WASTE.

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OCEAN OFF N.Y. IS DUMPING SITE

THE NEW YORK BIGHT IS A GIANT BLOT IN THE ATLANTIC OCEAN OFF LONG ISLAND AND THE SHORE OF NEW JERSEY.

THE BIGHT IS FORMED BY MONTAUK POINT, CAPE MAY, N.J., AND THE EDGE OF THE OUTER CONTINENTAL SHELF. INTO THIS AREA, UNDER EPA SUPERVISION, 1.5 MILLION TONS OF MUNICIPAL SLUDGE ACID WASTE, CONSTRUCTION DEBRIS AND CHEMICAL WASTE WERE DUMPED LAST YEAR.

THERE ARE FOUR SPECIFIC AREAS FOR DUMPING INSIDE THE BIGHT.

A NUMBER OF SCIENTIFIC INVESTIGATIONS HAVE DOCUMENTED

SEVERAL ADVERSE ENVIRONMENTAL IMPACTS FROM THE DUMPING.

EIGHTY-SIX PERCENT OF ALL OCEAN DUMPING ALLOWED BY EPA IS IN THE NEW YORK BIGHT. OTHER DUMPING PLACES ARE OFF THE COAST OF PUERTO RICO AND THE PACIFIC COAST.

"CONNALLY WENT UP TO WASHINGTON AND HAD SOME CONVERSATIONS WITH THE DEPARTMENT OF JUSTICE. IT WAS OUT OF EPA'S HANDS," ECKHARDT TOLD THE COURIER-EXPRESS.

CASE REOPENED

ECKHARDT SAID A LETTER TURNED UP WHICH SHOWED EPA WAS ORDERED TO REOPEN THE CASE. CONNALLY, WHO WAS ALSO FORMALLY TREASURY SECRETARY, WAS LATER PUBLICLY PRAISED BY THE PRESIDENT OF THE STEEL COMPANY.

FINALLY, TIGHTER CONTROLS WERE PUT ON BY CONGRESS.

ECKHARDT HAS BEEN PUSHING ON THE DUMPING SITUATION, EVEN THOUGH HE ADMITS, "I REALLY DO HAVE MORE OF THE CHEMICAL INDUSTRY IN MY DISTRICT THAN ANY OTHER CONGRESSMAN."

TOUCHY ISSUE

THE ISSUE REMAINS TOUCHY:

ON AUG. 23, THE ETHYL CORP. WITHDREW A NEW APPLICATION FOR OCEAN DUMPING IN THE GULF OF MEXICO WHEN EPA RULED THAT BOTH HOUSTON NEWSPAPERS COULD USE THE FREEDOM OF INFORMATION ACT TO FIND OUT WHAT THE COMPANY WAS DUMPING. ETHYL WAS THE LAST COMPANY TO HAVE A FEDERAL PERMIT TO DUMP IN THE GULF.

WHEN EPA BEGAN TO REGULATE GULF DUMPING IN 1973, THERE WERE SEVEN COMPANIES DUMPING. BEFORE THAT, THE PRACTICE WAS LOOKSELY REGULATED BY THE ARMY CORPS OF ENGINEERS.

IT ISN'T KNOWN EAXCTLY WHAT ETHYL WANTED TO DUMP, ALTHOUGH

IN THE PAST THE FIRM HAS DUMPED CALCIUM AND SODIUM SLUDGE

IN AN AREA 50 MILES OFF THE MISSISSIPPI DELTA. INSTEAD, THE

COMPANY SAID, IT WILL INCINERATE ITS WASTE.

WASTE BURIED

SOME OTHER COMPANIES NO LONGER DUMPING IN THE GULF ARE NOW BURYING THEIR WASTE.

AT ONE TIME, THE GULF WAS CLOSE TO BEING A MAIN DUMPING GROUND FOR MIDDLE AMERICA. REP. ECKHARDT NOTED:

"I STARTED COMPLAINING A LONG TIME AGO. PEOPLE WERE SHIPPING DRUMS DOWN THE OHIO RIVER TO DUMP IN THE GULF OF MEXICO."

TUESDAY: EPA DELAY STALLS TREATMENT.

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PUBLIC FRETS OVER EPA 'LAXITY' ON DUMP SITES BURY NOW, PAY LATER

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE FOURTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION.

THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY IS DELAYING MORE AND BETTER TREATMENT OF CHEMICAL WASTES BECAUSE OF ITS TARDINESS IN SETTING GROUND RULES FOR THE INDUSTRY.

THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) OF 1976 WAS DESIGNED TO MANAGE HAZARDOUS AND CHEMICAL WASTE. BUT EPA, HEADED BY ADMINISTRATOR DOUGLAS M. COSTLE, HAS NOT YET TOLD POTENTIAL INVESTORS WHAT RULES AND REGULATIONS WILL BE ON WASTE HANDLING. THE ACT REQUIRED THE REGULATIONS TO BE WRITTEN BY APRIL 1978. BUT EPA SIAD IT WILL NOT COMPLETE THE WORK UNTIL 1980.

SOPHISTICATED WASTE TREATMCNT IS A SMALL BUT GROWING FIELD, FACING GROWING OPPOSITION BY NEIGHBORS OF TREATMENT PLANT SITES.

CITIZENS ARE WORRIED THAT THE WASTE TREATMENT PLANT SET UP IN THEIR NEIGHBORHOOD WILL GO BROKE AND LEAVE BEHIND LAKES OF CHEMICALS AND DRUMS OF UNKNOWN MATERIALS TO POSE A HEALTH THREAT.

THERE IS REASON FOR THAT KIND OF WORRYING:

- MICHIGAN RECENTLY SPENT $700,000 IN PONTIAC CLEANING UP 20,000 DRUMS O- TOXIC WASTES AFTER ANKERSON RESOURCE RECOVERY SYSTEMS WENT BROKE.

- THE COAST GUARD HAS JUST SPENT $1.9 MILLION IN OSWEGO, CLEANING UP LIQUID WASTES AFTER POLLUTION ABATEMENT SERVICES (PAS) WENT OUT OF BUSINESS.

NEW YORK STATE'S PROPOSED SUPPLEMENTAL BUDGET INCLUDES $750,000 TO BE USED TO FIND OUT WHAT IS IN THE PAS DRUMS AND HOW MUCH IT WILL COST TO PROCESS THE WASTES. THE DRUMS ARE SPLIT BETWEEN OSWEGO AND A WAREHOUSE IN NEARBY MEXICO, N.Y.

MAKE CLAIM

COMPANIES IN THE WASTE TREATMENT FIELD CLAIM THAT WASTES CAN BE "PROPERLY" DISPOSED OF. BUT, NONE SAY IT'S EASY. AND NO ONE CAN SAY "PERMANENTLY."

THERE IS CONSIDERABLE SKEPTICISM IN THE INDUSTRY ABOUT BURIED WASTES. NO MATTER HOW WELL DESIGNED AND HOW WELL BUILT THE WASTE BURIAL VAULTS ARE, NO ONE IS REALLY CERTAIN HOW LONG THEY WILL LAST.

WHAT BURYING THE WASTE REALLY DOES IS LEAVE TODAY'S PROBLEMS FOR FUTURE GENERATIONS.

"WHEN YOU GET IN THAT BUSINESS, YOU HAVE TO BE IN THE BUSINESS OF RUNNING A CHEMICAL PLANT," ACCORDING TO CARL GOSLIN, ASSISTANT TECHNICAL DIRECTOR OF THE MANUFACTURING CHEMISTS ASSOCIATION (MCA). THE MCA IS A TRADE GROUP FOR CHEMICAL PRODUCERS IN WASHINGTON, D.C.

GOSLIN ONCE RAN A WASTE TREATMENT SITE IN DELAWARE. SINCE CHEMICALS ARE GOING IN AND CHEMICALS ARE GOINT OUT, A TREATMENT PLANT MUST BE OPERATED AS IF IT WERE AN INITIAL MAKER OF CHEMICALS.

PROPER DISPOSAL OF CHEMICALS AND WASTE WHICH CANNOT BE

TURNED TO ANOTHER USE FILL COST A LOT OF MONEY.

"WE ARE GOING TO HAVE THE COSTS OF DISPOSAL BUILT INTO THE COST OF THE ITEM," REMARKED DR. CHARLES A. JOHNSON, TECHNICAL DIRECTOR OF THE NATIONAL SOLID WASTE MANAGEMENT ASSOCIATION. BUT ONE THING IS FOR SURE: THE CONSUMER WILL FOOT THE BILL.

NO ONE CAN TELL WHAT THE EXTRA COST WILL BE.

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LOBBYING GROUP

JOHNSON'S ASSOCIATION IS A LOBBYING GROUP IN WASHINGTON FOR THE ENTIRE SOLID WASTE INDUSTRY. A SMALL SEGMENT OF THE GROUP HANDLES HAZARDOUS AND CHEMICAL WASTES.

JOHNSON ADMITS THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT COULD BE A REAL BOON TO HIS GROUP'S MEMBERS IN THE CHEMICAL FIELD. THAT IS, IF THE EPA EVER GETS THE REGULATIONS OUT TO IMPLEMENT THE LAW. EPA ANNOUNCED ON FRIDAY THAT IT WILL ISSUE ITS REGULATIONS IN JAN. 1980 -- 21 MONTHS LATE.

THE REGULATIONS WERE DUE IN APRIL, 18 MONTHS AFTER THE RCRA BECAME LAW.

ON SEPT. 7, ILLINOIS ATTORNEY GENERAL WILLIAM J. SCOTT FILED SUIT AGAINST THE EPA FOR ITS FAILURE TO PUT THE REGULATIONS INTO EFFECT. LAST WEDNESDAY, ALSO IN FEDERAL DISTRICT COURT IN WASHINGTON, TWO ACTIVIST GROUPS, ENVIRONMENTAL ACTION AND THE ENVIRONMENTAL DEFENSE FUND, ALSO SUED EPA FOR THE LACK OF REGULATIONS.

WITHOUT THE RULES, COMPANIES ARE RELUCTANT TO INVEST IN THE TREATMENT FIELD BECAUSE THE INVESTMENTS MIGHT WIND UP IN VIOLATION OF THE FINAL RULES.

AT THE SAME TIME, THE RULES WILL GUARANTEE THE EXISTENCE OF THE WASTE TREATMENT INDUSTRY. BASIC TO RCRA IS THE IDEA THAT THE COMPANY WHICH GENERATES WASTE IS RESPONSIBLE FOR WHATEVER HAPPENS TO IT. UNDER THE LAW, THE COMPANY MUST PROVE ITS WASTE WAS PROPERLY DISPOSED OF IN AN APPROVED SITE.

THERE WILL BE MUCH LESS OPPORTUNITY FOR "MIDNIGHT HAULERS,"

THE CLANDESTINE OPERATORS WHO SPILL WASTES INTO SEWERS,

ROADSIDE DITCHES, DRINKING WATER SOURCES OR WHATEVER.

CAN COP OUT

NOW, CHEMICAL WASTEPRODUCERS CAN SIMPLY COP OUT BY SAYING TO FEDERAL OR STATE INVESTIGATORS THEY HAD HIRED A REPUTABLE HAULER. THE PRODUCERS CAN CLAIM TO HAVE NO RESPONSIBILITY FOR LATER ILLEGAL DISPOSAL.

JIM HUNT, WHO OVERSEES LICENSING OF WASTE HAULERS FOR THE INDIANA BOARD OF HEALTH, NOTED:

"WE DON'T HAVE THE CONTROLS OF MANPOWER TO GET TOTALLY ON TOP OF TE PROBLEM. WHILE THIS STATE HAS A LIQUID INDUSTRIAL WASTES CONTROL PROGRAM, THERE IS STILL MUCH ILLICIT TRAFFIC. IT IS WIDESPREAD, WITH A LOT OF INTERSTARE MOVEMENT, AND DIFFICULT TO TRACE."

BASIC TO THE WHOLE PROBLEM IS THAT NO ONE REALLY KNOWS HOW MUCH HAZARDOUS WASTE IS GENERATED, EXACTLY WHERE IT GOES OR EVEN EXACTLY HOW TO DEFINE HAZARDOUS WASTE.

ONLY 6 PCT.

EPA THROWS AROUND ESTIMATES OF 96 BILLION POUNDS A YEAR, WITH 80 PERCENT GOING INTO ON-PREMISES FACTORY SITES AND THE OTHER 20 PERCENT GOING INTO THE 20,000 PRIVATE DUMP SITES. ONLY 5.6 BILLION POUNDS ARE PROPERLY DISPOSED OF, EPA ADMITS. THAT'S ONLY 6 PERCENT.

HAZARDOUS WASTE OBVIOUSLY INCLUDE WASTE WHICH CAN CAUSE CANCER, CAN CAUSE BIRTH DEFECTS, AND CAUSE GENETIC DEFECTS OR AN EVEN CAUSE IMMEDIATE DEATH. BUT, THERE IS ALSO WASTE WHICH CAN EXPLODE OR WASTE WHICH IS DANGEROUS ONLY IN VERY HIGH CONCENTRATIONS.

REPUTABLE WASTE TREATMENT OPERATORS OFFER A VARIETY OF SERVICES.

PICK IT UP

INITIALLY, THEY TEST TO SEE EXACTLY WHAT IT IS A WASTE GENERATOR WANTS HANDLED. IF IT IS SOMETHING THE TREATMENT FIRM CAN HANDLE, THE PLANT CAN EVEN PICK IT UP. WHEN THE MATERIAL ARRIVES, IT IS CHECKED AGAIN TO MAKE CERTAIN IT IS WAHT IT IS SUPPOSED TO BE.

PROPER ANALYSIS SHOULD CLEAR ANY OBSCURITIES CAUSED BY THE USE OF CHEMICAL TRADE NAMES WHICH DO NOT INDICATE THE ACTUAL CHEMICAL.

WASTE TREATMENT FIRMS MAINTAIN ELABORATE FACILITIES FOR ELECTRONIC, MECHANICAL AND CHEMICAL TESTS OF WASTE TO MAKE CERTAIN THE FIRM KNOWS WHAT THE STUFF IS.

SOME WASTE MUST SIMPLY BE BURNED. THE FEDERAL GOVERNMENT REQUIRES THAT LIQUIDS OF THE HIGHLY TOXIC PCB FAMILY BE BURNED IN INCINERATORS WHICH CAN MAINTAIN A TEMPERATURE OF 2,100 DEGREES FAHRENHEIT FOR LONG PERIODS.

PILING UP

SINCE NOT A SINGLE PUBLIC INCINERATOR INTHE COUNTRY IS LICENSED TO DO THAT, PCB IS PILING UP ALL OVER THE COUNTRY. OR, IT IS BEING ILLEGALLY DUMPED.

EPA ESTIMATES THAT ONE MILLION GALLONS A YEAR OF LIQUID PCB WASTE WILL BE PRODUCED FOR THE NEXT 25 YEARS. DISPOSAL FIRMS ARE UNWILLING TO INVEST IN BUILDING INCINERATORS UNTIL THE EPA ISSUES ITS LONG-DELAYED REGULATIONS.

SOME MATERIALS MUST BE BURIED IN "SECURE LANDFILLS." THESE AREN'T JUST DUMPS ANY MORE, AS THE LOVE CANAL IN NIAGARA FALLS REALLY WAS. ELECTRICAL MATERIALS MADE WITH PCB IN SOLID FORM CAN BE BURIED IN SECURE LANDFILLS.

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CAN BURN WASTE

LIQUID WASTES ARE HANDLED DIFFERENTLY. TREATMENT DEPENDS ON EXACTLY WHAT THEY ARE. C. EDWARD ASHBY, VICE PRESIDENT EASTERN REGION FOR ROLLINS ENVIRONMENT ENVIRONMENTAL SERVICES, INC., BRIDGEPORT, N.J., SAID HIS DISPOSAL FIRM CAN BURN WASTE WHICH IS 99 PERCENT WATER. BECAUSE OF THE POSSIBILITY OF A PATENT APPLICATION, ASHBY WON'T SAY HOW. BUT APPARENTLY IT INVOLVES USING HEAT FROM THE INCINERATOR PROCESS TO BOIL OFF MOST OF THE WATER IN THE INCOMING WASTE.

RIGHT NOT, HOWEVER, ROLLINS CAN'T USE THE BRIDGEPORT INCINERATOR: LAST DECEMBER, AN ON SITE EXPLOSION OF DISPUTED CAUSE KILLED SIX PERSONS AND KNOCKED IT OUT OF SERVICE.

SOME LIQUID WASTES ARE MOSTLY SOLVENTS, CHEMICALS USED TO DISSOLVE OTHERCHEMICALS. THROUGH CHEMICAL TREATMENT, SOME OF THESE SOLVENTS CAN ACTUALLY BE CLEANED AND PUT BACK INTO USE. SOME SOLVENTS ARE CLEANED AND THEN SIMPLY USED AS FUEL BECAUSE IT IS NOT ECONOMICALLY ATTRACTIVE TO REUSE THEM AS SOLVENTS.

DIRTY WATER

MANY WASTES HAVE A LOT OF WATER IN THEM. SOMETIMES A "FLOCCULANT" CAN BE ADDED WHICH TURNS THE CONTAMINANT INTO RESIDUE, LEAVING DIRTY WATER. THE RESIDUE IS LEFT TO DRY AND THEN BURIED IN A LANDFILL. SOMETIMES VARIOUS FORMS OF BACTERIA CAN BE PUT INTO THE WATER WHICH WILL LITERALLY EAT THE WASTE MATERIAL.

WHATEVER LIQUID WASTE TREATMENT PROCESS IS INVOLVED, LARGE AMOUNTS OF WATER ARE PRODUCED WHICH ALSO MUST BE CLEANED. THE WATER IS PUMPED THROUGH GIANT TANKS OF ACTIVATED CARBON TO REMOVE ORGANIC WASTES. THEN, IT IS AERATED TO PROVIDE OXYGEN FOR BACTERIA AND CLEANING. FINALLY, THE CLEAN WATER IS RELEASED.

FEARS ABOUND

BUT, PEOPLE ARE AFRAID OF PLACES WHERE SOLID HAZARDOUS WASTE IS ACTUALLY BURIED. THEIR FEARS ARE NOT WITHOUT REASON, THE COURIER-EXPRESS HAS FOUND.

THE LITTLE TOWN OF WILSONVILLE, ILL., FOUGHT AND WON A BATTLE TO GET RID OF A CHEMICAL WASTE DUMP IN AN ABANDONED COAL MINE THERE. MRS. GWEN MOLINAR, A VILLAGE TRUSTEE, EXPLAINED TO THE COURIER-EXPRESS:

"WE'VE GOT A GOOD WATER SUPPLY OUT THERE. THERE'S NO CONTAMINATION YET. YOU KNOW HOW YOU GET THE IT'S-ALL-RIGHT . . . NOW . . . FEELING."

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CHEMICAL WASTE HAUNTS LOUISIANA SWAMP BURY NOW, PAY LATER

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE FIFTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION.

EARLY ONE MORNING IN LATE JULY, KIRTLEY MAURICE JACKSON, 19, OF PLAQUEMINE, LA., DROVE OUT TO A CHEMICAL WASTE LAGOON IN ASWAMP AREA OF THAT STATE, PERHAPS ENJOYING THE HOT WINDLESS DAY.

JACKSON WAS DRIVING A TANK TRUCK WHICH BELONGED TO A COMPANY OWNED BY HIS FATHER, STANLEY H. "JACKIE" JACKSON, THE CHIEF DEPUTY SHERIFF IN CHARGE OF INVESTIGATION FOR IBERVILLE PARISH, A PARISH THAT IS ESSENTIALLY A SWAMP BETWEEN BATON ROUGE AND NEW ORLEANS.

IBERVILLE IS A THROWBACK PARISH IN WHAT IS A HEAVILY INDUSTRIALIZED STATE. FOR MANY YEARS, IT WAS RUN BY SHERIFF JESSEL OURSO. WHEN THE SHERIFF DIED TWO WEEKS AGO, AFTER A PROLONGED ILLNESS, THERE WAS EVEN A BLACK STALLION WITH REVERSED BOOTS TO HELP CARRY HIM TO HIS GRAVE, IN AN OLD MILITARY TRADITION.

OUT IN THE SWAMP, CLEAN LAND, AIR AND WATER CORP. (CLAW) OPERATED A DEEP WELL WHERE VARIOUS CHEMICAL WASTES WERE PUMPED TWO MILES INTO THE GROUND. A REPORT PREPARED BY THE STATE OFFICE OF CONSERVATION INDICATES 39 DIFFERENT COMPANIES USED THE WELL TO BURY EVERYTHING FROM TOULENE WASTE WATER TO RECYCLED SYTRENE.

KIRTLEY JACKSON WAS DRIVING THE SHJ INC. TRUCK TO THE LAGOON WHICH ALSO WAS OPERATED BY HIS FATHER'S COMPANY. WHAT WAS IN THE LAGOON ISN'T QUITE CLEAR, BECAUSE THE RECORDS SHOWING WHAT WAS DUMPED IN IT ARE MISSING.

ACIDIC SAMPLES

PARISH CORONER DR. C. E. BLUNCK JR. SAID SAMPLES TAKEN LATER INDICATED THERE WAS SULFURIC ACID, ALCOHOL AND SLUDGE FROM AN OIL REFINERY CATALYTIC CRACKER. ALL WERE ACIDIC.

WHAT WAS IN JACKSON'S TRUCK? "IT WAS A COMTINATION OF CORROSIVE MATERIALS, MANY OF WHICH SHOULD HAVE GONE INTO A DEEP WELL," THE CORONER TOLD THE COURIER-EXPRESS.

WHEN JACKSON BEGAN TO EMPTY HIS TANK TRUCK, THERE WAS A "DEAD CALM," AN UNUSUAL SITUATION IN THE SOUTHERN AREAS OF LOUISIANA. THE AIR AND GASES FROM THE LAGOON WERE SIMPLY SITTING THERE.

BUT THE WASTE FROM THE TRUCK TURNED ON THE YOUTH. THE REACTION OF THE ALKALINE WASTE FROM THE TRUCK AND THE ACIDIC LAGOON GENERATED MASSIVE AMOUNTS OF DEADLY HYDROGEN SULFIDE GAS.

APPARENTLY, JACKSON WENT TO THE CAB OF THE TRUCK AND TRIED TO DRIVE AWAY.

"BY THE TIME ANYONE GOT TO HIM, HE WAS DEAD," DR. BLUNCK SAID. "HE HAD ABSORBED ABOUT SIX TIMES THE LETHAL DOSE." IT TOOK MORE THAN SIX WEEKS OF INVESTIGATION TO PRECISELY DETERMINE THE CAUSE OF DEATH. THE CORONER SAID THE BODY OF THE YOUTH WAS CHECKED FOR ALL FORMS OF DRUGS AND ALCOHOL TO SEE IF HIS REACTIONS MIGHT HAVE BEEN SLOWED BY THEM. NOTHING WAS FOUND.

TANGLING THE INVESTIGATION, THE CORONER SAID, WAS HIS INABILITY TO GET THE "TRUE SEQUENCE OF WHAT WAS DISPOSED OF INTO THAT PIT IN THE PRECEDING 48 HOURS."

IN A STATE WIHT LIMITED ENVIRONMENTAL INTEREST, THE CASE CAUSED AN UPROAR.

LOUISIANA MAY HAVE THE IMAGE OF A SLEEPY SOUTHERN STATE. IN SOME WAYS, IT IS. BUT, IT IS ALSO HIGHLY INDUSTRIALIZED, WITH AN INDUSTRY BUILT ON OIL AND GAS AND THE SALT FROM FAR UNDER THE GROUND.

A VISITOR TO THE STATE CAPITAL IN BATON ROUGE TRAVESL TO A TOWERING CAPITOL BY HUEY LONG, ONE THE STATE'S GOVERNOR AND U.S. SENATOR.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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FROMTHE AIRPORT, THE VISITOR PASSES WHAT MAY BE THE LARGEST SINGLE CHEMICAL AND INDUSTRIAL COMPLES IN THE WORLD. ON A CLOUDY DAY, IT REQUIRES NO VISION TO DETECT IT, ONLY A NOSE.

DRAWING OMITTED

VISIBLE FROMTHE CAPITOL, BETWEEN THE COMPLEX AND THE RIVER, IS A CHEMICAL WASTE DUMP.

IT'S THE SORT OF STATE WHERE ATTORNEY GENERAL WILLIAM J. GUSTE HAS ONE ASSISTANT WORKING ON ENVIRONMENTAL MATTERS. BEFORE A BUDGET CUT, HE HAD TWO. AT THE SAME TIME HE DOES HAVE THE FORMER EXECUTIVE DIRECTOR OF THE LOUISIANA WILDLIFE FEDERATION INC. STASHED AWAY ON HIS PAYROLL AS A RESEARCH ASSISTANT.

MORATORIUM DECLARED

ABOUT ONE MONTH AFTER JACKSON'S DEATH, THE WASTE DISPOSAL PROBLEM HEATED UP TO THE POINT THAT GOV. EDWIN EDWARDS TOOK ACTION. HE DECLARED A MORATORIUM ON NEW HAZARDOUS WASTE PERMITS.

"I AM TAKING THIS ACTION TO INSURE THE HEALTH AND SAFETY OF OUR CITIZENS. PROPER REGULATION OF THE TRANSPORTATION, STORAGE AND DISPOSAL OF HAZARDOUS WASTES IS ESSENTIAL IF WE ARE TO PROTECT THE PUBLIC AND THE PROPERTY OF OUR STATE," HE NOTED IN A STATEMENT.

THIS ACTION BY GOV. EDWARDS SEEMS TO HAVE GIVEN HIM SOME POLITICAL COURAGE TO DO A LITTLE MORE. LAST THRUSDAY, HE SAID, "WHEN OPTING FOR INDUSTRY OR THE RISK, I WILL TAKE A POSITION AGAINST INDUSTRY."

"THERE IS NO NEED FOR A MULTIPLICITY OF INDUSTRY IF IT DESTROYS THE VERY REASON FOR OUR BEING," HE TOLD THE LOUISIANA ENVIRONMENTAL PROTECTION AGENCY.

FIVE YEARS AGO, HE TOLD ENVIRONMENTALISTS HE DIDN'T WANT TO HEAR THEIR CONCERNS OR LISTEN TO THEIR ADVICE. NOW, HE PLANS TO GO TO THE STATE LEGISLATURE IN APRIL FOR STRONGER CONTROLS ON WASTE.

THIS MAY ALSO PARTLY HAVE BEEN CAUSED BY THE STATE HEALTH DEPARTMENT BANNING FISHING IN LAKE PROVIDENCE, A PROMINENT FISHING SPOT, ON SEPT. 12 BECAUSE OF CONTAMINATION OF A DEADLY PESTICIDE.

AT THE SAME TIME, THIS CONCERN HAS NOT BEEN EXTENDED TO THE STATE OFFICE OF SCIENCE, TECHNOLOGY AND THE ENVIRONMENT. THE OFFICE IS PREPARING THE STATE RULES UNDER THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) OF 1976. THE RULES GO OUT TO THE PUBLIC FOR 15 DAYS FOR COMMENT, OFFICIALLY STARTING THURSDAY. NO COPIES ARE AVAILABLE YET.

THE OFFICE HAS TWO PEOPLE WORKING ON THE FEDERAL LAW.

RCRA IS THE CONGRESSIONAL ANSWER TO THE WHOLE PROBLEM OF GENERATION, SHIPMENT AND PROCESSING OF HAZARDOUS WASTE. BUT THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY HAS NEVER ISSUED THE RULES TO PUT IT INTO EFFECT.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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DELAY UNTIL 1980

THE EPA RULES WERE DUE IN APRIL. BUT EPA, HEADED BY ADMINISTRATOR DOUGLAS M. COSTLE, NOW SAYS IT WON'T ISSUE THE RULES UNTIL 1980.

LOUISIANA HAS A NEW LAW TO REGULATE HAZARDOUS WASTES. BUT, IN A REPLAY OF THE PROBLEMS OF THE EPA, REGULATIONS TO IMPLEMENT THE LAW HAVEN'T BEEN WRITTEN.

LOUISIANA IS ONE FO THE MANY STATES THAT HAVE SERIOUS CHEMICAL

WASTE PROBLEMS.

ONE TEST OF THIS IS THE WIDESPREAD CONTAMINATING CHEMICAL FAMILY OF PCBS. A 1977 STUDY OF WATER AND SEDIMENT SAMPLES BY THE EPA IN LOUISIANA WATERS FOUND WIDESPREAD PCBS, BUT ADMITTED TESTING METHODS WERE NOT ADEQUATE.

IN RELEASING THE FIGURES, EPA NOTED THE METHOD USED TO LOOK FOR PCBS ISN'T VERY GOOD. AS A RESULT THERE COULD BE PCBS PRESENT, JUST NOT MEASURED.

WATER POLLUTION IN LOUISIANA IS UNDER THE JURISDICTION OF THE STREAM CONTROL COMMISSION. BUT, THE COMMISSION IS SOMETHING OF A BUREAUCRATIC FICTION. IT IS MADE UP OF THE HEADS OF A NUBMER OF STATE AGENCIES AND HAS NO STAFF OF ITS OWN. UNDER THE LAW, JURISDICTION WILL PASS TO THE DEPARTMENT OF NATURAL RESOURCES.

'NO APPRORPIATION'

THE COMMISSION HAS "NO APPROPRIATION AND NO BUDGET," ACCORDING TO DALE GIVENS, ITS ASSISTANT DIRECTOR. GIVENS SUGGESTED THE PCBS ARE COMING DOWN FROM THE AIR IN RAIN.

HE DOESN'T THINK THERE IS ANY PARTICULAR PROBLEM WITH THE STATE'S VAST WATER SUPPLIES, BUT ADMITS NO ONE IS REALLY LOOKING. THE STANDARD STATE TESTS OF WATER ARE FOR BIOLOGICAL OSYGEN, SUSPENDED SOLIDS AND THE "PH" OF THE WATER. THE CURRENT EXPANDED PROGRAM IS MORE FOR HEAVY METALS AND SOME PESTICIDES.

"WHICH REALLY DON'T TELL YOU A HILL OF BEANS ABOUT WHETHER THER EIS A LOW LEVEL OF SOMETHING, THAT MIGHT CAUSE CANCER," HE NOTED.

IN A FEW AREAS, PCBS ARE SO HIGH IN WATER THAT THEY CAN BE MEASURED. THIS INDICATES THEY ARE HUNDREDS OF TIMES ABOVE THE SAFE LEVEL SET BY THE FEDERAL FOOD AND DRUG ADMINISTRATION.

GOVERNMENT ACTION ON THE STATE LEVEL IS SLOW, BUT THE CITIZENS OF NEW ORLEANS SEEM TO HAVE AN UNCONSCIOUS REACTION. THE OLD CITY IS A HEAVY USER OF BOTTLED DRINKING WATER.

REGULATIONS URGED.

DR. ROBERT H. HARRIS OF THE ENVRIONMENTAL DEFENSE FUND IN WASHINGTON, D.C., RECENTLY ATTACKED PROPOSALS TO DELAY EPA DRINKING-WATER REGULATIONS. HE TOLD AN EPA HEARING IN NEW ORLEANS:

"FURTHERMORE, EPA SHOULD BE REMINDED THAT A LARGE SEGMENT OF THE PUBLIC IN NEW ORELANS, AS WELL AS ELSEWHERE, HAS LOST CONFIDENCE IN THE SAFETY OF LOCAN WATER SUPPLIES. BY SEEKING EXPENSIVE ALTERNATIVES, SUCH AS BOTTLED WATER AND HOME WATER TREATMENT DEVICES, THEY ARE PAYING MANY TIMES TH E RATE INCREASE THE EPA REGULATIONS WILL REQUIRE."

A 1974 EPA STUDY FOUND 20 CHEMICALS IN THE NEW ORLEANS DRINKING WATER WHICH HAVE THE CAPACITY TO CAUSE CANCER. SOME ARE PESTICIDES. BUT OTHERS ARE INDUSTRIAL WASTES, SUCH AS BENZENE AND HEXACHLOROBENZENE.

HARRIS ESTIMATED THERE WOULD BE 250 EXTRA CANCER DEATHS A YEAR IN NEW ORLEANS CAUSED BY THE LOCAL DRINKING WATER.

CITIZENS ARE SUSPICIOUS BECAUSE THEY KNOW THE BAYOU SORREL LAGOON WHERE JACKSON DIED IS AN AREA WHERE HIGH WATER WOULD FLUSH IT OUT ONCE OR TWICE A YEAR, PUTTING THE WASTES INTO THE LOCAL WATER.

THE STATE PRODUCES VAST AMOUNTS OF WASTES A YEAR. MUCH OF IT IS DUMPED DOWN DEEP WELLS. MUCH OF IT PROBABLY JUST DISAPPEARS. GIVENS COMMENTED:

"I WOULD SAFELY SAY THERE IS NO REPORT, OR ONE POINT, WHERE YOU COULD GO TO FIND OUT ABOUT WASTE."

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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EPA ON SPOT IN WASTE GLUT

OF THE ESTIMATED 92 BILLION POUNDS OF HAZARDOUS CHEMICAL WASTE GENERATED IN THE U.S. EACH YEAR, ONLY 5.6 BILLION POUNDS (ABOUT 6 PERCENT) ARE "PROPERLY DISPOSED OF", BY THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY'S OWN ESTIMATE. THESE ARE THE STARTLINE FIGURES DEVELOPED IN AN INVESTIGATION OF THE PROBLEM BY THE COURIER-EXPRESS' MICHAEL DESMOND AND REPORTED IN A CONTINUING SERIES OF COPYRIGHTED STORIES.

OBVIOUSLY, THE FEDERAL GOVERNMENT NEEDS TO DO MORE TO MAKE A DENT IN THIS SEA OF TOXIC WASTES THAT IS THREATENING THE NATION'S HEALTH AND SAFETY. YET ITS ACTIONS ARE AGONIZINGLY SLOW.

THE RESOURCE CONSERVATION AND RECOVERY ACT WAS PASSED BY CONGRESS IN OCTOBER, 1976. IT STIPULATED THAT REGULATIONS TO CONTROL HAZARDOUS WASTES BE PROMULGATED "NO LATER THAN 18 MONTHS" AFTER ENACTMENT. DESPITE THREATS AND LAWSUITE, THE EPA HAS NOT ISSUED THE REGULATIONS. AT LAST REPORT, IT SAID THEY WILL NOT BE ISSUED UNTIL 1980, BLAMING THE "VERY DIFFICULT TECHNICAL, FINANCIAL, LEGLA AND ENVIRONMENTAL ISSUES" INVOLVED.

DUE TO THIS GOVERNMENT INACTION, MANY PROBLEMS HAVE ARISEN. A NUMBER OF COMPANIES HAVE BEEN TRYING TO INCREASE THE AMOUNT OF DUMPING BEFORE IMPLEMENTATION. COMPANIES IN THE WASTE-DISPOSAL FIELD ARE RELUCTANT TO INVEST IN NEW FACILITIES BECAUSE THEY DON'T KNOW IF THEY WILL MEET THE 1980 EPA REGULATIONS. STATES WITH TOUGHER WASTE-DISPOSAL LAWS ARE, IN A WAY, HURTING THEMSELVES, SINCE INDUSTRIES IN OTHER STATES, WHERE RULES ARE WEAK OR NONEXISTENT, MAY BE CONTINUING TO DUMP WITH IMPUNITY, THUS INVITING MORE "RUNAWAY" PLANTS.

CLEARLY, THE EPA OUGHT TO ISSUE ITS REGULATIONS TO CUT OFF FURTHER DUMPING AT ONCE, AND IRON OUT THE TECHNICAL DETAILS LATER. THIS LAW, SPELLING OUT THE WILL OF THE PEOPLE, HAS BEEN ON THE BOOKS FOR NEARLY TWO YEARS WHILE THE BUREAUCRATS HAVE FAILED TO TAKE EVEN THE FIRST STEPS TOWARD ENFORCING IT. IT IS MANDATORY THAT THE ENFORCEMENT PICTURE BE EVENED OUT AMONG THE STATES, AS CONGRESS INTENDED, SO THAT WASTE DISPOSAL COSTS TO INDUSTRY CAN BE SPREAD MORE FAIRLY. IT SEEMS TO USE ESSENTIAL THAT THE EPA EMBARK ON A CRASH PROGRAM TO GET THIS DONE.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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TOXICS RATTLE NEW ENGLANDERS, TOO BURY NOW, PAY LATER

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE SIXTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH THE PRACTICE OF THE NEW ENGLAND STATES TO SHIP THEIR HAZARDOUS WASTES ELSEWHERE.

THE NEW ENGLAND STATES SOLVE THE HAZARDOUS WASTE PROBLEM BY SHIPPING THEIR DANGEROUS MATERIALS TO OTHER PARTS OF THE COUNTRY.

THE NORTHEAST CORNER OF THE NATION HAS NO GOOD WASTE DISPOSAL SITE. BUT, AS WOULD BE EXPECTED IN A HEAVILY INDUSTRIALIZED AREA, THERE ARE INDUSTRIAL AND HAZARDOUS WASTES.

BAY STATE MESS

MASSACHUSETTS IS THE POSSESSOR OF ONE OF THE GREAT CHEMICAL MESSES OF OUR TIME: THE SILRESIM CHEMICAL CORP. IN LOWELL FIRM WENT BROKE, LEAVING BEHIND 15,000 DRUMS -- 55 GALLONS EACH -- OF VARIOUS CHEMICALS AND HUNDREDS OF THOUSANDS OF GALLONS OF ALL KINDS OF LIQUIDS IN TANKS.

THE CITIZENS OF METHUEN AND LAWRENCE, MASS. GET THEIR DRINKING WATER FROM AN INTAKE DOWNSTREAM FROM WHERE CHEMICALS FROM SILRESIM ARE LEACHING INTO THE MERRIMACK RIVER.

IN RHODE ISLAND, THE RESIDENTS ARE STARTING TO WORRY ABOUT CHEMICALS LEACHING INTO THE PAWTUXET RIVER FROM A LAND FILL.

IN CONNECTICUT, JOHN HOUSEMAN, PRINCIPAL ENVIRONMENTAL PROTECTION, ADMITS THERE ARE PROBLEMS. ASKED IF THE STATES WASTES ARE BEING PROPERLY DISPOSED OF, HE COULD ONLY SAY, "RIGHT NOW, I HAVE NO WAY OF KNOWING."

VILE ODOR

IN MAINE, THE LITTLE TOWN OF GRAY FOUND OUT ONE DAY THAT THE VILE ODOR AND STRANGE COLOR WHICH TURNED UP IN THEIR DRINKING WATER IN 1975 CAME FROM CHEMICALS DUMPED AT A SITE OUTSIDE OF TOWN. EVENTUALLY, THE SITE WAS CLOSED DOWN.

GRAY TOWN COUNCIL CHAIRMAN MICHALE GIBBS PUT HIS FINGER ON THE ISSUE:

"WE DISCOVERED OUR PROBLEM PRETTY MUCH BY ACCIDENT. I SHUDDER TO THINK WHAT SOME OTHER TOWNS MIGHT BE DRINKING IN THEIR WATER."

IT'S A SERIOUS POINT:

DATA LISTED

THE NEW ENGLAND REGIONAL COUNCIL RECENTLY ATTEMPTED JUST TO GET A HANDLE ON HOW MUCH WASTE THERE WAS IN THE SIX STATES. IT CAME UP WITH FIGURES OF 18.4 MILLION GALLONS OF RECLAIMABLE WASTES, THAT IS WASTE OIL AND SOLVENTS; 5.6 MILLION GALLONS OF TREATABLE WASTES; 5.9 MILLION GALLONS OF WASTE THAT HAS TO BE INCINERATED; AND 17.9 MILLION GALLONS OF WASTE THAT HAS TO BE LANDFILLED.

HOW ACCURATE THE FIGURES ARE IS ANYBODY'S GUESS. HOUSEMAN WOULD ONLY TERM THEM "ROUGHT ESTIMATES".

THER ARE UNUSUAL INDUSTRIED IN THE AREA. PROVIDENCES HAS A LARGE JEWELRY INDUSTRY WITH HIGHLY ACIDIC WASTE. MUCH OF THAT GOES INTO CITY SEWERS, ACCORDING TO FRANK STEVENSON, A SENIOR SANITARY ENGINEER WITH THE DIVISION OF LAND RESOURCE OF THE DEPARTMENT OF ENVIRONMENTAL MANAGEMENT.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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STACKED SILRESIM WASTE DRUMS MONUMENT TO GOVERNMENT INACTION . . . SOME WASTE WENT INTO DRINKING WATER.

PHOTOGRAPH OMITTED.

LOSING TRACK

"WE ARE ALSO LOSING TRACK OF THE SEWAGE DISCHARGE," HE NOTED. THE CITY IS GETTING A SYSTEM TO PRE-TREAT JEWELRY WASTE BEFORE IT GOES INTO THE REGULAR SYSTEM.

VERMONT AND NEW HAMPSHIRE ARE BELIEVED TO PRODUCE MINIMAL AMOUNTS OF HAZARDOUS WASTES.

CONNECTICUT HAS A SIMILAR WATER CASE INTHE TOWN OF PLAINFIELD WHERE CHEMICALS WERE DUMPED INTO A REGULAR LANDFILL. THE STATE HAS ALREADY SPENT $600,000 THERE, INCLUDING AN $80,000 STUDY OF UNDERGROUND WATER. THERE ARE A NUMBER OF DRINKING WATER WELLS NEARBY AND WILLIAM HEGNER, A PRINCIPAL ENGINEER WITH THE OIL AND CHEMICAL SECTION OF THE WATER COMPLIANCE BUREAU, AGREES THE CHEMICALS COULD TURN OP IN THE WATER.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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"THERE IS A POTENTIAL FOR THAT," HE ADMITTED.

BRIDGEPORT PROBLEM

THE STATE ALSO HAD A CLEANUP PROBLEM IN BRIDGEPORT, WHERE CHEMICALS WERE DUMPED INTO A GRAVEL AREA. THE CONTAMINATED GRAVEL HAD TO BE DUG UP AND HAULED AWAY. MUCH OF IT WENT TO THE SCA CHEMICAL WASTE SERVICES, INC., FORMERLY CHEMTROL, IN NIAGARA COUNTY, N.Y.

BUT, THE BIGGEST CHEMICAL WASTE PROBLEM IN NEW ENGLAND IS SILRESIM. THE STATE LEGISLATURE HAS BEEN ASKED TO PUT UP $1.5 MILLION FOR A CLEANUP BASED ON A REPORT FROM FRED C. HART ASSOCIATES, IN AN ENVIRONMENTAL RESEARCH FIRM IN NEW YORK CITY. THE HART REPORT SAID:

"RESULTS OF STUDIES CONDUCTED FOR THIS CONTRACT INDICATED SIGNIFICANT ON-SITE CONTAMINATION OF SOILS AND GROUND WATER AND THE POTENTIAL FOR CONTAMINATION OF SURFACE WATER BODIES AFTER THE SPRING THAW. HIGH CONCENTRATIONS OF TOLUENE AND TRICHLOROETHYLENE WERE DETECTED IN SOIL AND GROUND WATER SAMPLED AT THE FACILITY. HIGH CONCENTRATIONS OF TOTAL ORGANIC CARBON WERE ALSO DETECTED IN ON-SITE WELLS AND LOCAL SEWERS."

CAUSES DEPRESSION

TOULENE CAUSES DEPRESSION OF THE CENTRAL NERVOUS SYTEMS, ADDICTION, MUSCULAR FATIGUE AND CAN KILL IN HIGH CONCENTRATIONS.

THERE ARE TWO FORMS OF TRICHLOROETHYLENE. HIGH EXPOSURE TO EITHER CAN KILL. EITHER MAY ALSO CAUSE KIDNEY OR LIVER DAMAGE.

AIR TANKS

THE SITUATION IS SO BAD THAT THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) HAS ORDERED ANY OF ITS EMPLOYEES VISITING THE SCENE TO WEAR AIR TANKS, RATHER THAN FILTERING MASKS.

THE SITE HAS BEEN A PROBLEM ALMOST SINCE IT OPENED IN 9173. IT BEGAN AS MORE OF A STORAGE SITE THAN ANYTHING ELSE. BUT GRADUALLY ITS OWNER, DR. JOHN MISERLIS, BEGAN TO TRY TO TURN IT INTO A CHEMICAL WASTE RE-PROCESSING PLANT.

IN JULY 1975, THE STATE DIVISION OF WATER POLLUTION CONTROL (DWPC) THREATENED TO REVOKE ITS LICENSE UNLESS CHANGES WERE MADE.

WHEN THE 1976 LICENSE LIMITED WHAT COULD BE HANDLED ON SITE, THE CORPORATION TOOK THE STATE TO COURT AND THE JUDGE REMOVED THE RESTRICTIONS. SOME NEW ONES WERE SET IN THE COURT ORDER BUT WERE APPARENTLY NEVER ADHERED TO.

BY BANK

IN OCTOBER 1976, THE SITE WAS TAKEN OVER BY THE BANK WHICH HELD THE MORTGAGE. THE BANK STUDIED THE SITUATION AND REOPENED THE SITE. LAST YEAR, THE FIRM WENT INTO BANKRUPTCY, EVEN THOUGH THE SITE ITSELF WAS STILL IN OPERATION.

A YEAR AGO, LOWELL CITY WORKERS WERE OVERCOME BY TOLUENE FUMES IN THE SEWER. APPARENTLY AT THAT POINT THE CITY AND CITIZENS BECAME AWARE OF HOW BAD THE SITUATION HAD BECOME.

THE COURT ORDER HAD REQUIRED THE REMOVAL OF 500 BARRELS A MONTH TO CUT DOWN THE ACCUMULATION. THE HART REPORT INDICATES THE MATERIALS IN THE DETERIORATING DRUMS WERE SIMPLY DUMPED INTO SOME OF THE LARGE TANKS ON THE SITE.

NOW THE STATE AND THE FEDERAL GOVERNMENT ARE ASKING COMPANIES TO COME IN AND MAKE BIDS ONRHE CLEANUP. THE HART REPORT INDICATES PART OF THE CLEANUP WILL INCLUDE SEALING THE UNDERGROUND WATER AND PUTTING SOME SORT OF CAP ON THE SURFACE TO CONTROL RUNOFF AND AIR POLLUTION.

"WE GENERALLY KNOW WHAT'S THERE," COMMENTED HANS BONNE OF THE STATE DWPC.

AT ONE POINT, DR. MISERLIS USED AN AERIAL PHOTO OF THE SITE TO TAKE A VARIETY OF GOVERNMENT AGENCIES ON A TOUR OF CHEMISTRY. FOR EXAMPLE, HE COULD TELL THEM AREA 27 CONTAINED CHLORINATED BENZENE FROM SOLVENT CHEMICAL CO. INC. OF NIAGARA FALLS, N.Y. OR, HE COULD TELL THEM HE HAD NO IDEA WHAT WAS IN AREA 23. AREA 14 HAD SIX STORAGE TANKS WITH A COMBINED CAPACITY OF 80,000 GALLONS CONTAINING HEXANE, TOULENE, METHYLENE CHLORIDE, WATER ACETONE AND WHAT WAS DESCRIBED BY HIM AS "MISCELLANEOUS HYDROCARBONS."

STORAGE TANK

THERE IS EVEN ONE 100,000 GALLON STORAGE TANK FILLED TO THE TOP. IN WARM WEATHER, THE HART REPORT SAID, "DUE TO A DECREASE IN DENSITY UPON WARMING, THE MATERIALS STORED IN THE 100,000 GALLON STORAGE TANK WILL LIKELY OVERFLOR AS SOON AS WARM WEATHER ARRIVES SINCE THE TANK IS FULL TO THE TOP."

THE MATERIAL INSIDE IS IN THREE PARTS. THERE IS A ONE-FOOT RESIDUE LAYER ON THE BOTTOM. ABOVE THAT IS 50,000 GALLONS OF WATER WITH A VARIETY OF DISSOLVED HYDROCARBONS. ON TOP IS 50,000 GALLONS OF SUCH THINGS AS TOULENE, CANCER CUASING BENZENE AND MINERAL SPIRITS.

RIGHT NOW, IT'S ALL STILL THERE.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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DR. CHARLES A JOHNSON IS TECHNICAL DIRECTOR OF THE NATIONAL SOLID WASTE MANAGEMENT ASSOCIATION, A TRADE GROUP IN WASHINGTON, D.C. HE CALLED SILRESIM A "CLASSIC EXAMPLE" OF COMMERCIAL PLANS TO RECYCLE CHEMICAL AND HAZARDOUS WASTES.

"HE COULDN'T MAKE IT PAY," WAS THE VERDICT.

21 MONTHS LATE

DESPITE PROBLEMS ENCOUNTERED AT TILRESIM AND AND ELSEWHERE, THE EPA HAS JUST ANNOUNCED IT WOULD BE AT LEAST 21 MONTHS LATE ISSUING REGULATIONS THAT COULD CONTROL IMPROPER WASTE DISPOSAL. EPA IS HEADED BY DOUGLAS M. COSTLE, AN APOINTEE OF PRESIDENT JIMMY CARTER.

THE REGULATIONS WERE REQUIRED TO BE ISSUED LAST APRIL, 18 MONTHS ARE THE 1976 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) BECAME LAW. BUT THOSE 18 MONTHS PROVED NOT TO BE SUFFICIENT FOR EPA TO COME UP WITH THE REGULATIONS NECESSARY TO INSTITUTE THE RCRA. LAST FRIDAY, EPA SAID IT WOULD BE UNABLE TO COME UP WITH THE RULES UNTIL JANUARY 1980.

THAT MEANS THE AGENCY WILL HAVE TAKEN 39 MONTHS TO COMPLETE WORK ON THE REGULATIONS. DESPITE THE DELAY, EPA HAS ONLY 161 OF ITS NEARLY 11,000 EMPLOYEES NATIONWIDE WOKRING IN THE AREA OF HAZARDOUS WASTES.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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NOWAK, KEMP PRESSING FOR TOXIC WASTE ACTION

WASHINGTON -- REP. HENRY J NOWAK, D-BUFALLO, ON THURSDAY URGED THE ADMINISTRATOR OF THE ENVIRONMENTAL PROTECTION AGENCY (EPA) TO SPEED UP THE ISSUANCE OF TOXIC WASTE DISPOSAL REGULATIONS AS DECREED BY THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA).

AT THE SAME TIME, REP. JACK F. KEMP, R-HAMBURG, ALERTED HIS COLLEAGUES TO THE NATIONAL THREAT POSED BY UNREGULATED CHEMICAL WASTE DISPOSAL.

BOTH BUFFALO AREA CONGRESSMAN SAID THEY WERE REACTING TO AN ON-GOING SERIES OF ARTICLES IN THE COURIER-EXPRESS ON THE HAZARDOUS WASTE PROBLEMS THROUGHOUT THE NATION.

'DEEPLY CONCERNED'

IN A LETTER TO EPA HEAD DOUGLAS M. COSTLE, NOWAK SAID HE IS "DEEPLY CONCERNED WITH THE EPA'S FAILURE TO COMPLY WITH THE REQUIREMENTS OF THE RCRA AND PROMULGATE THE REGULATIONS WITHIN 18 MONTHS."

I AM EVER MORE CONCERNED BY INDICATIONS THAT THE FINAL RULES FOR THIS VITAL PROGRAM ARE NOT EXPECTED BEFORE JANUARY, 1980," NOWAK ADDED.

THE ACT WAS PASSED BY CONGRESS IN 1976 TO CONTROL THE GENERATION, TREATMENT, TRANSPORTATION, STORAGE AND DISPOSAL OF HAZARDOUS OR TOXIC WASTES.

THE STATE OF ILLINOIS AND TWO ENVIRONMENTAL GROUPS HAVE SUED EPA FOR ITS FAILURE TO ISSUE THE RULES THAT WERE DUE LAST APRIL.

NOWAK SAID HE REALIZED THE COMPLEX PROBLEMS EPA FACES IN MAKING THESE RULES, BUT "YOUR PROJECTED 1980 ISSUANCE OF THE FINAL REGULATIONS PRESENTS AN INTOLERABLE DELAY IN WHAT HAS BEEN CLEARLY IDENTIFIED AS A CRITICAL PROBLEM FOR YEARS."

HIS LETTER WENT ON TO SAY "THE COURIER-EXPRESS SERIES ILLUSTRATES THE SCOPE OF THE NATIONAL PROBLEM. HE ALSO SENT COSTLE A COMPLETE SET OF THE ARTICLES FOR HIS REVIEW AND COMMENTS.

IN REMAKRS PREPARED FORINSERTION IN THE CONGRESSIONAL RECORD, KEMP SAID HE, HIS STAFF AND SCIENTIFIC AND LEGAL ADVISERS AND STUDYING THE ENTIRE QUESTION OF HAZARDOUS WASTE DISPOSAL TO PREPARE TO INTRODUCTION LEGISLATION EARLY NEXT FALL.

"A SIGNIFICANT CONTRIBUTION TO HIS HAS BEEN MADE BY THE COURIER-EXPRESS IN A SERIES OF COPYWRITED ARTICLES BY MICHAEL DESMOND, A STAFF WRITER FOR THE PAPER WHO TRAVELED EXTENSIVELY AROUND THE COUNTRY IN DETERMINING THE EXTENT OF THE PROBLEM, THE STATUS OF INCIDENTS, THE RESPONSES OF THE ENVIORNMENTAL PROTECTION AGENCIES, ET CETERA," KEMP SAID. "THIS SERIES HAS SHOWN CONVINCINGLY THAT THIS IS A NATIONAL PROBLEM, ONE REQUIRING A NATIONAL SOLUTION, IF NOT A FEDERAL ONE."

KEMP SAID HE MEANT THEPROBLEM REQUIRES A JOINT SOLUTION FROM ALL LEVELS OF GOVERNMENTS IN THE NATION, RATHER THAN LEAVING IT ALL TO THE FEDRRAL GOVERNMENT.

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EPA UNIT ADMITS UNABLE TO FIX SITES $1.5 BILLION NEEDED FOR CLEANUP JOB

BY DAVID E. LYNCH

WASHINGTON -- THE ENVIRONMENTAL PROTECTION AGENCY ADMITTED ON THRUSDAY THAT IT KNOWS OF 300 CHEMICAL WASTE DUMPS THAT ARE AN IMMEDIATE THREAT TO THE NATION'S HEALTH AND SAFETY, BUT THAT THE AGENCY IS POWERLESS TO DO ANYTHING ABOUT THEM.

TOP EPA OFFICIALS TOLD THE COURIER-EXPRESS THAT IT WOULD COST $1.5 BILLION TO CLEAN UP THE 300 HAZARDOUS DUMPS, BUT THAT THERE IS NOT MONEY AVAILABLE FOR THAT PURPOSE.

FURTHER, THE EPA SAID, THERE IS NO LAW GIVING THE AGENCY -- OR ANY OTHER AGENCY, FOR THAT MATTER -- AUTHORITY TO DEAL WITH THE PROBLEM OF CLEANING UP THE 300 DUMPS.

"TIP OF ICEBERG"

THE EPA SAID THE 300 KNOWN DUMP SITES ARE JUST THE TIP OF THE CIEBURG BECAUSE, IT SAID, HUNDREDS IF NOT THOUSANDS OF HAZARDOUS DUMPS COULD COME TO THE SURFACE OVER THE NEXT FEW YEARS.

BESIDES, ONE TOP OFFICIAL CONCEDED, THE EPA IS MORE CONCERNED WITH PREVENTING THE FORMATION OF HAZARDOUS DUMP IN THE FUTURE THAN IT IS IN ATTACKING THE IMMEDIATE PROBLEM.

THAT EPA OFFICIAL IS GARY DIETRICH, ASSOCIATE DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE.

ASKED IFTHE EPA IS TAKING THIS PROBLEM AS SERIOUSLY AS IT SHOULD, DIETRICH SAID:

STRESS PREVENTION PROGRAM

"THAT'S IN THE EYE OF THE BEHOLDER. WE'RE PUTTING ALL OUR ENERGIES IN A PREVENTION PROGRAM RIGHT NOW. IF WE STOPPED TO LOOK AT THE READIOACTIVE PROBLEM, WE WOULD HAVE TO DIVIDE OUR RESOURCES, AND THE PREVENTION PROGRAM WOULD BE SLOWED DOWN."

THE PREVENTION PROGRAM IS KNOWN AS THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) WHICH WAS ENACTED IN 1976 TO CONTROL THE GENERATION, TREATMENT, TRANSPORTATION, STORAGE AND DISPOSAL OF HAZARDOUS OR TOXIC WASTES.

BUT EPA SAID THE LONG-DELAYED RCRA WILL NOT GIVE THE AGENCY A ROLE IN THE DEALING WITH RETROACTIVE HAZARDOUS WASTE EMERGENCIES.

"OFF THE TOP FO MY HEAD I KNOW OF 300 SITUATIONS LIKE THE LOVE CANAL (NIAGARA FALLS) PROBLEM THAT STICK OUT LIKE SORE THUMBS" DIETRICH SAID.

HE SAID IT WOULD COST $50,000 TO ASSESS THE PROBLEM AT EACH OF THE 300 SITES, AND IT WOULDPROBABLY COST ABOUT $5 MILLION TO REMEDY THE PROBLEM AT EACH SITE.

$1.5 BILLION TOTAL COST

"THAT ADDS UP TO $1.5 BILLION," HE SAID, "AND THAT DOESN'T GO INTO $10 MILLION."

HE WAS REFERRING TO THE FEDERAL WATER POLLUTION ACT WHICH AUTHORIZES A $10 MILLION EMERGENCY POLLUTION FUND THAT WOULD PROVIDE THAT ROLE.

BUT THE CARTER ADMINISTRATION FIRMLY OPPOSES THE APPROPRIATION OF MONIES FOR THAT FUND. SO IT'S A FUNDLESS FUND HAT DIETRICH SAYS WOULDN'T NEAR TO PROVIDING THE MONEY NECESSARY TO CLEAN UP THE ABANDONED BUT DEADLY HAZARDOUS WASTE SITES.

HOW DOES THE EPA FEEL ABOUT THE ADMINISTRATION, PRINCIPALLY THE OFFICE OF MANAGEMENT AND BUDGET (OMB), KILLING THIS FUND?

"THE PRESIDENT'S THE BOSS. WE JUST WORK FOR HIM," DIETRICH SAID WITH A SMILE. "ACTUALLY, EPA ISN'T AS OPPOSED AS OMB. WE RECOGNIZE IT WILL OEPN THE BARN DOOR TO STATE AND LOCAL GOVERNMENTS THAT WANT TO USE IT FOR ANY POLLUTION PROBLEM, BUT WE ALSO RECOGNIZE IT HAS TO BE OPENED TO SOME DEGREE. IT JUST HAS TO BE LIMITED."

$10 MILLION NOT ENOUGH

IN ANY EVENT, DIETRICH SAYS THE $10 MILLION WOULDN'T EVEN SCRATCH THE SURFACE OF THE PROBLEM.

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UPON ENACTMENT OF RCRA, CONGRESS MANDATED THAT THE EPA DRAW UP REGULATIONS FOR THE IMPLEMENTATION OF THIS LAW WITHIN 18 MONTHS. THAT DEADLINE PASSED IN APRIL, AND EPA ADMINISTRATOR DOUGLAS M. COSTLE LAST WEEK ANNOUNCED THAT THE REGULATIONS WON'T BE READY NOW UNTIL JANUARY OF 1980.

THE EPA WILL SPEND $1.2 BILLION THIS FISCAL YEAR. THERE ARE 10,946 EPA EMPLOYEES. OF THIS BUDGET ONLY $25.2 MILLION WILL BE FOR HAZARDOUS WASTES,AD ONLY 161 WORKERS -- IN WASHINGTON AND IN THE 10 REGIONAL OFFICES -- ARE WORKING ON THE PROBLEM. OF THE $25.2 MILLION, $15 MILLION IS GOING TO THE STATE'S TO HELP THEM LOOK INTO THE PROBLEM.

ASKED IF 161 PEOPLE ARE ENOUGH TO COMBAT THE CHEMICAL WASTE PROBLEM, DIETRICH SAID:

"OF COURSE NOT, BUT WE'VE GOT 500 PEOPLE PLUGGING THEIR THUMBS INTO INDUSTRIAL DISCHARGES; 500 MORE WORKING ON INDUSTRIAL AIR POLLUTION; 500 WORKING ON THE TOXIC SUBSTANCES ACT AND 1,000 PEOPLE IN RESEARCH.

"THOSE AREN'T EXACT NUMBERS, BUT IT'S NOT AS THOUGH THE OTHER 10,000 PEOPLE IN EPA ARE SITTING AROUND ON THEIR THUMBS."

ALL THIS OVERLOOKS ANOTHER PROBLEM THE EPA SAYS MONEY WON'T SOLVE -- WHAT TO DO WITH THE WASTE. "LOVE CANAL HAS CAUSED A BACKLASH," DIETRICH SAID. "NO ONE WANTS TO LIVE NEAR THESE DUMPS NOW, AND WHILE EVERYONE WANTS THEM MOVED, THEY DON'T WANT THEM MOVED NEAR THEM.?"

THE SOLID WASTE EXECUTIVE WAYS THE GOVERNMENT IS CAPABLE OF HANDLING THE POBLEM. "WE'VE ALWAYS BEEN ABLE TO FIND AN ANSWER TO OUR PROBLEMS THROUGHOUT HISTORY."

OPTIMISTIC OVER FUTURE

HE PREDICTED THE GROWING PUBLIC AWARENESS OF THIS PROBLEM WILL EVENTUALLY LEAD TO PUBLIC POLICY AND LAW THAT WILL GIVE EPA THE AUTHORITY TO CLEAN UP THE MESS.

HE SAID THE BOTTOM LINE IS FOUND IN RCRA THAT WILL EVENTUALLY "MAKE THE COST OF DISPOSAL PRODUCT PART OF THE PURCHASE PRICE."

UNTIL THAT HAPPENS HE SAID, THE MOUNTAINS AND RIVERS OF TOXIC WASTES THREATENING THIS NATION'S HEALTH AND SAFETY WILL HAVE TO BE DEALT WITH ONE DAY AT A TIME.

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LOVE CANAL TOPS LIST OF DISASTERS

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE SEVENTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH HOW NEW YORK STATE HAS REACTED TO SEVERAL ENVIRONMENTAL DISASTERS.

NEW YORK STATE AHS A PROMINENT PLACE AMONG CENTERS OF INDUSTRY.

BUT, IT IS ALSO THE LOCATION OF AT LEAST FIVE MAJOR ENVIRONMENTAL DISASTERS INVOLVING HAZARDOUS CHEMICAL WASTES. THEY ARE:

1. THE LOVE CANAL AREA IN NIAGARA FALLS, WHERE A CLOSED WASTE DUMP HAS BEGUN TO LEAK A VARIETY OF DANGEROUS CHEMICALS, AT LEAST ONE OF WHICH CAUSE HUMAN CANCER, FORCING THE EVACUATION OF HUNDREDS OF FAMILIES.

2. EXTENSIVE CONTAMINATION OF THE HUDSON RIVER AND ITS FISH WITH THE TOXIC PCB CHEMICAL FAMILY.

3. CONTAMINATION OF DRINKING WATER WELLS ON LONG ISLAND WITH CHEMICALS, INCLUDING THE CANCER-CAUSING VINYL CHLORIDE.

4. SPILLS INTO LAKE ONTARIO FROM A BANKRUPT CHEMICAL WASTE PROCESSING PLANT IN OSWEGO AND AN EXPENSIVE PROGRAM TO CLEAN UP WASTE LEFT BEHIND BY THE COMPANY.

5. CONTAMINATION OF LAKE ONTARIO AND ITS FISH BY THE DANGEROUS PESTICIDE MIREX, A CONTAMINATION SO BAD THAT AT ONE POINT THE STATE BANNED CATCHING FISH FROM THE LAKE.

LOVE CANAL DUMP

THE LOVE CANAL, A CHEMICAL WASTE DUMP IN NIAGARA FALLS, WAS CLOSED IN 1953. ABOUT TWO YEARS AGO, THE DUMP BEGAN TO LEAK DANGEROUS CHEMICALS, AT LEAST ONE OF WHICH IS KNOWN TO CAUSE CANCER IN HUMANS. THE LEAKING CHEMICALS ARE FORCING THE EVACUATION OF HUNDREDS OF FAMILIES. IT ISN'T KNOWN IF THEY WILL EVER BE ALLOWED TO RETURN.

AS A RESULT OF THE HUDSON RIVER PCB SPILL AND THE LAKE ONTARIO MIREX SITUATION, NEW YORK IS PROBABLY FAR AHEAD 1OF OTHER STATES IN ITS PROGRAM TO SYSTEMATICALLY SAMPLE AND LOOK FOR CHEMICAL CONTAMINATION.

YET THE STATE STILL IS IN THE EARLY STAGES OF FINDING OUT HOW SERIOUS ITS TOXIC WASTE PROBLEM REALLY IS.

THREE DAYS AGO THE STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION SAID IT HAS ASKED REGIONAL OFFICIALS TO FIND OUT WHERE THE HAZARDOUS WASTE DUMP SITES ARE THROUGHOUT THE STATE.

THE LIST IS EXPECTED TO BE COMPLETED BY THE END OF NEXT WEEK.

HEAD START FOR STATE

SO, DESPITE THE HEAD START AFFORDED NEW YORK STATE BY ITS SERIES OF ENVIRONMENTAL DISASTERS, THE STATE OBVIOUSLY IS FAR FROM GAINING THE UPPER HAND ON ITS CHEMICAL WASTE MESS.

CHARLES GODDARD IS CHIEF OF THE HAZARDOUS WASTE MANAGEMENT SECTION OF THE DIVISION OF SOLID WASTE MANAGEMENT OF THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION. HE RECENTLY DECLARED:

"IN NEW YORK STATE, INDUSTRY GENERATES APPROXIMATELY ONE MILLION METRIC TONS OF HAZARDOUS WASTE PER YEAR. IN MORE DESCRIPTIVE TERMS THIS QUANTITY WOULD COVER A SQUARE MILE TO A DEPTH OF SLIGHTLY GREATER THAN ONE FOOT."

NEW YORK MUST CONTROL THIS WASTE CAREFULLY, NOT ONLY BECASUE THE MATERIAL CAN BE DANGEROUS BUT ALSO BECAUSE THE STATE HAS 5.2 MILLION PERSONS WHO OBTAIN THEIR WATER SUPPLY FROM GROUND WATER.

THE MOST EXTREME EXAMPLE OF THIS IS ON LONG ISLAND. IN THE HEAVILY POPULATED COUNTIES OF NASSAU AND SUFFOLK, ALL 2.5 MILLION PEOPLE DRINK WATER WHICH COMES FROM WELLS. TO PROTECT THIS AREA THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY ESTABLISHED SPECIAL REGULATIONS WENT INTO EFFECT SEPT. 1.

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FEDERAL INVESTIGATOR WILLIAM WILCOX STRIKES AN ELOQUENT POSE . . . DURING HIS RECENT VISIT TO LOVE CANAL AREA.

PHOTOGRAPH OMITTED.

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SPECIAL LIMITS

LIMITS ON DISSOLVED SOLIDS WERE ESTABLISHED BECAUSE THE UNDERGROUND WATER TABLE IS THE PRINCIPAL SOURCE OF DRINKING WATER; IF THE WATER TABLE WERE CONTAMINATED, IT WOULD CREATE A SIGNIFICANT HAZARD TO PUBLIC HEALTH.

LONG ISLAND BECAME AWARE OF DRINKING WATER PROBLEMS IN

1972, WHEN TASTE AND ODOR PROBLEMS WERE REPORTED AT WELLS

SERVING THE 20,000 WORKERS OF THE GURMMAN AEROSPACE CORP.

IN BETHPAGE IN NASSAU COUNTY.

IT WAS NOT UNTIL MARCH, 1974, THAT AN INDUSTRIAL WASTE DUMP AT GRUMMAN WAS FOUND TO CONTAIN THE HUMAN CANCER CAUSING CHEMICAL VINYL CHLORIDE AND CHEMICAL SOLVENTS.

A NEARBY NASSAU COUNTY PLANT OF THE HOOKER CHEMICALS & PLASTICS CORP. THAT WAS MAKING POLYVINYL CHLORIDE AND CHEMICAL, SOLVENTS IN ITS WELLS. IN COT. 1975, TWO GRUMMAN WELLS WERE FOUND TO CONTAIN THE KNOWN ANIMAL CANCER-CAUSING SOLVENT TRICHLOROETHYLENE ALONG WITH TETRACHLOROETHYLENE.

VINYL CHLORIDE FOUND

VINYL CHLORIDE WAS FOUND IN ONE WELL. BOTH WERE IMMEDIATELY SHUT DOWN. FURTHER TESTING OF WELLS ACCROSS NASSAU COUNTY SHOWED A WIDE VARIETY OF CARBON TETRACHLORIDE, TWO OTHER CHEMICALS THAT CAN CAUSE CANCER IN ANIMALS.

THE COUNTY HEALTH DEPARTMENT HAS LIMITED USE OF A NUMBER OF WELLS. MUCH OF THE CONTAMINANTS APPARENTLY COME FROM HOUSEHOLD AND COMMERCIAL ACTIVITY THAT ENTERED THE GROUND WATER AFTER BEING DUMPED DOWN DRAINS. THE STATE AND COUNTY ARE TRYING TO REMOVE MANY PRODUCTS FROM USE AND TO LIMIT CASUAL COMMERCIAL DUMPING.

NEW YORK'S REACTION TO THIS IS COMPLICATED BY ITS KNOWLEDGE THAT MORE THAN 200 LAKES IN THE ADIRONDACK STATE PARK ARE TOO ACIDIC FOR FISH, APPARENTLY BECAUSE AIRBORNE CHEMICALS ARE WASHED FROM THE SKY BY RAIN.

THE EMPIRE STATE HAS VAST RECREATIONAL PROGRAMS, EXPECIALLY IN FISHING. IN TWO AREAS, CHEMICAL WASTE HAS CRIPPLED THOSE PROGRAMS:

1. SEVERAL YEARS AGO, IT WAS LEARNED THAT THE GENERAL ELECTRIC CO. HAD DUMPED SIGNIFICANT AMOUNTS OF PCBS FROM TWO PLANTS NEAR ALBANY.

BURNING PERMIT FOR PCBS

NOW, GE HAS THE ONLY PERMIT IN THE COUNTRY TO BURN PCB IN A SPECIAL INCINERATOR FOR ITS OWN USE. IT IS NOT LICENSED TO HANDLE PCB FOR ANY ONE ELSE.

BUT, THE PCBS HAVE RUINED FISHING IN MOST OF THE HUDSON BECAUSE LEVELS ARE SO HIGH. APPARENTLY, THE ACTUAL BOTTOM OF THE RIVER WILL HAVE TO BE DREDGED IN VARIOUS PLACES, AND THE MATERIAL CARRIED AWAY SOME PLACE TO BE BURIED.

2. MIREX IS A DIFFERENT SIUTATION. CANADIAN SCIENTISTS FOUND THIS STRONG PESTICIDE, USED AGAINST FIRE ANTS IN THE SOUTH, IN LAKE ONTARIO FISH. IT IS CLOSELY RELATED TO THE PESTICIDE KEPONE WHICH CONTAMINATED VIRGINIA'S JAMES RIVER AND PART OF CHESAPEAKE BAY, SHUTTING THEIR FISHING INDUSTRY.

HOOKER HAS LONG SINCE STOPPED MAKING OR PROCESSING MIREX IN ITS NIAGARA FALLS PLANT. BUT, IT HAS SENT 153 TONS OF IT TO THE SCA POLLUTION CONTROL SERVICES CORP. PLANT IN THE NIAGARA COUNTY TOWN OF PORTER FOR STORAGE.

FISHING BAN

INITIALLY, NEW YORK BANNED THE TAKING OF FISH FROM LAKE ONTARIO. LATER, THE BAN WAS MODIFIED TO ADVICE TO EAT ONLY A LIMITED AMOUNT OF LAKE ONTARIO FISH. PREGNANT WOMEN WERE ADVISED BY THE STATE TO EAT NONE OF IT. THE STATE ALSO HAS A PROGRAM FOR WOMEN FROM LAKE ONTARIO AREAS TO CHECK MOTHER'S MILK FOR MIREX. THE CHEMICAL IS THOUGHT TO CAUSE LIVER DAMAGE IN HUMANS AND IS KNOWN TO CAUSE BIRTH DEFECTS IN ANIMALS.

EXACTLY WHAT CAN BE DONE ABOUT THE CHEMICAL ISN'T REALLY KNOWN.

IRONICALLY, NEW RESEARCH INDICATES THE FIRE ANT MIGHT NOT BE SUCH A BAD THING AFTER ALL. IT APPARENTLY IS THE MORTAL ENEMY OF BOLL WEEVILS, THE CURSE OF COTTON GROWERS BECAUSE THEY DAMAGE COTTON CROPS.

THE PRIORITY CONCERN IN NEW YORK RIGHT NOW IS POLLUTION ABATEMENT SERVICES, THE BANKRUPT CHEMICAL WASTE PROCESSING PLANT ON THE SHORE OF LAKE ONTARIO IN OSWEGO. THE COAST GUARD HAS SPENT $1.9 MILLION TO TRY CLEANING UP THE CHEMICAL MESS.

SEEKING INFORMATION

"RIGHT NOW, WE ARE NEGOTIATING TO FIND OUT WHAT IS THERE. THE COMPANY HAS NO RECORDS," GODDARD SAID OF THE 15,000 DRUMS OF MATERIAL LEFT BEHIND BY THE COMPANY.

THE STATE'S PROPOSED SUPPLEMENTAL BUDGET CONTAIN $750,000 TO PAY FOR TESTING TO FIND OUT WHAT IS IN THE DRUMS. THEN, THE STATE WILL APPARENTLY HAVE TO PICK UP THE TAB FOR TREATING THE CHEMICALS AND DISPOSING OF THE DRUMS.

CHEMICAL WASTE DRUMS CAN BE CLEANED AND REUSED. BUT, USUALLY, THE MOST DECREPIT DRUMS ARE USED TO SHIP THE MATERIALS TO WASTE TREATMENT SITES.

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GODDARD CLAIMS NEW YORK NOW HAS ITS WASTE PROBLEMS PRETTY WELL UNDER CONTROL, SAYING: "MOST OF IT NOW GOES TO PROPER DISPOSAL SITES."

CHEMICAL GLOSSARY

1. CARBON TETRACHLORIDE -- A CHEMICAL USED AT ONE TIME AS A COMMON HOUSEHOLD CLEANER. IT CAUSES ANIMAL CANCERS.

2. CHLOROFORM -- A CHEMICAL USED AT ONE TIME AS AN ANESTHETIC. IT IS A CAUSE OF ANIMAL CANCER.

3. KEPONE -- A PESTICIDE USED AGAINST ANTS AND ROACHES. IT IS SUSPECTED AS A CHEMICAL WHICH CAUSES CANCER IN HUMANS. IT IS KNOWN TO CAUSE NERVE DISORDERS AND LIVER DAMAGE IN HUMANS.

4. MIREX -- A PESTICIDE USED AGAINST FIRE ANTS. IT IS THOUGHT TO CAUSE LIVER DAMAGE AND SOME ANIMAL BIRTH DEFECTS.

5. PCB -- THE TERM USED TO DESCRIBE ABOUT 200 CHEMICALS KNOWN AS POLYCHLORINATED BIPHENYLS. THEY ARE USED IN THE ELECTRICAL INDUSTRY AND IN PLASTICS. MANUFACTURE IS NOW BANNED. THEY CAN CAUSE LIVER DAMAGE TO HUMANS AND HAVE A VARIETY OF BAD EFFECTS ON FISH AND WILDLIFE.

6. POLYVINYL CHLORIDE -- FREQUENTLY REFERRED TO AS PVC. IT IS A PLASTIC USED IN SUCH PRODUCTS AS HOUSEHOLD PIPE.

7. TETRACHLOROETHYLENE -- A CHEMICAL SOLVENT ALSO USED IN SOME SOAPS.

8. TRICHLOROETHYLENE -- AN INDUSTRIAL SOLVENT. IT CAUSES CANCER IN LABORATORY ANIMALS.

9. VINYL CHLORIDE -- A CHEMICAL USED TO MAKE PLASTICS, ESPECIALLY POLYVINYL CHLORIDE. VINYL CHLORIDE CAN CAUSE HUMAN CANCER.

TWO DISPOSAL OPERATIONS

THE STATE BENEFITS FROM HAVING TWO OF THE BEST KNOWN COMPANIES IN THE DISPOSAL FIELD WITHIN ITS BOUNDARIES, SGA IN THE TOWN OF PORTER AND NEWCO CHEMICAL WASTE SYSTEMS INC. IN NIAGARA FALLS.

IN ADDITION, THE STATE COOPERATES WITH OTHER STATES TO KEEP TRACK OF WASTES SHIPPED FROM ONE STATE TO ANOTHER. WITHOUT THE RULES UNDER THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA), THERE IS NO SYSTEM TO KEEP TRACK OF WASTES SHIPPED ACROSS STATE LINES.

FOR EXAMPLE, A COMPANY SEEKING TO DISPOSE OF WASTES COULD GIVE NEW JERSEY A FORM SHOWING THE MATERIAL WAS SENT TO NEW YORK. BUT, WITHOUT COOPERATION AMONG THE STATES, THERE WOULD BE NO GUARANTEE IT ACTUALLY WENT.

GODDARD IS ANNOYED AT FEDERAL EPA FOR ITS DELAYS IN GETTING OUT THE RCRA RULES.

"MORE DISCOURAGED"

"I'M GETTING MORE AND MORE DISCOURAGED AT WHAT I'M SEEING OF THEIR TIME SCHEDULE," HE SAID.

EPA WAS SUPPOSED TO HAVE THE RULES LAST APRIL, 18 MONTHS AFTER THE ACT BECAME LAW. NOW EPA, HEADED BY DOUGLAS M. COSTLE, ADMINISTRATOR, SAYS IT WILL NOT ISSUE THE RULES UNTIL JANUARY 1980, 39 MONTHS AFTER ENACEMENT.

PART OF GODDARD'S UNHAPPINESS INVOLVES HIS STATE'S INDUSTRIAL MANAGEMENT ACT.

REGULATIONS DELAYED

AS A RESULT OF BARGAINING WITH ASSOCIATED INDUSTRIES OF NEW YORK, AN INDUSTRIAL LOBBYING GROUP, THE STATE LAW WILL NOT TAKE EFFECT UNTIL THE EPA RULES ARE ISSUED.

CURRENTLY, NEW YORK HAS INCREASINGLY TIGHTER CONTROLS ON INDUSTRIAL WASTE, INCLUDING TRANSPORTATION AND DESIGN RULES FOR HAZARDOUS WASTE TREATMENT FACILITIES AND SECURE DUMPS.

GODDARD NOTED, "IN THE LAST FEW YEARS AND ESPECIALLY IN RECENT MONTHS, INDUSTRY HAS BECOME ACUTELY CONSCIOUS OF THE PROBLEM."

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TEXAS COAST ATTEMPTING COMEBACK AFTER YEARS OF TOXIC WASTE NEGLECT

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE EIGHTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH TOXIC WASTE PROBLEMS IN TEXAS.

WORKING INLAND FROM THE GULF OF MEXICO ALONG THE HOUSTON SHIP CHANNEL IN TEXAS IS ONE OF THE NATIONS GREATEST INDUSTRIAL COMPLEXES, A COMPLEX TRADITIONALLY NOT FETTERED BY ANY GOVERNMENT RULES ON POLLUTION CONTROLS.

THEN A TROPICAL STORM OR A HURRICANE WOULD SWEEP IN FROM THE GULF EVERY ONCE IN A WHILE AND FLUSH THE CHANNEL CLEAN FOR A NEW SEASON OF DUMPING.

IN 1971, THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) SAID THE SHIP CHANNEL EACH DAY WAS RECEIVING 55,000 POUNDS OF OIL AND GREASE, 7,900 POUNDS OF ZINC, 5,000 POUNDS OF CADMIUM, 1,600 POUNDS OF LEAD, 1,000 POUNDS OF CYANIDE, 400 POUNDS OF PHENOL AND 200 POUNDS OF CHROMIUM.

THE ONLY SURPRISING THING IS THAT ONE DAY THE CHEMICALS DIDN'T MIX AND TURN THE WHOLE THING SOLID.

AFTER THE EPA ESTIMATE, IT CALLED FOR A LIMIT ON DUMPING IN THE CHANNEL. "THE TEXAS WATER QUALITY BOARD SCOFFED AT THIS," NOTED KEITH OZMORE, ENVIRONMENTAL ASSISTANT TO REP. BOB ECKHARDT, D-TEXAS, TO THE COURIER-EXPRESS.

HE ADDED, "THE WATER QUALITY BAORD DID NOT DO VERY MUCH ABOUT REDUCTIONS FROM INDUSTRY ALONG THE CHANNEL."

NEW DEPARTMENT SET UP

AT THE SAME TIME, COUPLE OF ENVIRONMENTAL MESSES HAVE ATTRACTED SOME ATTENTION.

THE HOUSTON SHIP CHANNEL WAS ONE, ALTHOUGH IT HAS BEEN PARTIALLY CLEANED UP. ANOTHER INVOLVED FRENCH LTD. OF HOUSTON INC., A WASTE DISPOSAL FIRM, WITH A DUMP IN CROSBY, NEAR HOUSTON.

"THE ODOR WOULD GAG A MAGGOT," A NEIGHBOR TOLD A COURIER EXPRESS REPORTER WHEN THE DUMP WAS OPERATING.

IN DISCUSSING WHAT HAPPENED THERE, EPA PUT IT RATHER SUCCINCTLY: "ENVIRONMENTAL DAMAGE -- CONTAMINATION OF GROUND AND SURFACE WATERS. AIR POLLUTION FROM OCCASIONAL FIRES. DESTRUCTION OF LOCAL VEGETATION."

WASTES GO IN RIVER

OVER A PERIOD OF ABOUT SIX YEARS AT FRENCH LTD., 70 MILLION GALLONS OF WASTE WERE DUMPED INTO AN UNLINED SAND PIT NEAR A TRUCK STOP. THEN, ON JUNE 15, 1973, A HEAVY FLOOD FLUSHED THE DISPOSAL SITE, REMOVING MOST WASTES INTO THE SAN JACINTO RIVER. LATER, A $5,000 FINE BY A STATE COURT WAS ORDERED PAID TO HARRIS COUNTY. THE SITE WAS TURNED OVER TO THE STATE INSTEAD OF PAYING A SEPARATE STATE FINE.

THIS MAY ALL BE IN THE PAST, AT LEAST ACCORDING TO J. C. NEWELL, DIRECTOR OF PERMITS FOR THE WASTE WATERS DIVISION OF TEXAS WATER RESOURCES DEPARTMENT.

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TEXAS NOW REQUIRES PERMITS FOR DUMPING SOLID INDUSTRIAL WASTE, MONITORS THE WATE AND REQUIRES A MANIFEST SYSTEM TO INDICATE WHERE IT GOES. THE DUMP SITE PERMITS ALSO INCLUDE THE REQUIREMENTS FOR CLOSING A SITE.

HE CITED THE SHIP CHANNEL AS AN EXAMPLE, "IT'S NOT SUITABLE FOR SWIMMING. BUT, CONSIDERABLE PROGRESS HAS BEEN MADE."

ECKHARDT AGREES. THE DEER PARK DEMOCRAT MUST BALANCE BETWEEN THE ENVIRONMENT AND A DISTRICT OF WHICH HE ADMITS, "I REALLY DO HAVE MORE OF THE CHEMICAL INDUSTRY IN MY DISTRICT THAN ANY OTHER CONGRESSMAN."

SPONSORED CONTROL ACT

HE HAS BEEN A LEADER AGAINST DUMPING OF CHEMICALS IN THE GULF OF MEXICO AND WAS THE KEY SPONSOR OF THE TOXIC SUBSTANCES CONTROL ACT (TOSCA), ONE OF THE GREATEST FORWARD STEPS EVER BY GOVERNMENT IN ATTEMPTING TO GET A CONTROL ON THE ALCHEMISTS OF INDUSTRY.

TOSCA GIVES EPA THE AUTHORITY TO REGULATE THE PRODUCTION AND USE OF ALL CHEMICALS HARMFUL TO PUBLIC HEALTH OR TO THE ENVIRONMENT. THE LAW REQUIRES EPA TO LIST ALL SUCH CHEMICALS NOW ON THE MARKET, TO LIMIT THE USE OF THOSE FOUND TO BE HARMFUL AND IF NECESSARY TO BAN THEIR PRODUCTION.

THIS LAW ALSO BANNED THE MANUFACTURE OF PCB.

THE EPA HAS BEEN SLOW IN IMPLEMENTING TOSCA.

IT ALSO HAS BEEN SLOW IN DRAWING UP THE REGULATIONS TO IMPLEMENT THE RESOURCES CONSERVATION AND RECOVERY ACT (RCRA) SIGNED INTO LAW IN 1976.

EPA SLOW TO START

THAT LAW GAVE EPA 18 MONTHS -- UNTIL APRIL, 1977 -- TO DRAFT THE IMPLEMENTING REGULATIONS. THE DEADLINE HAS PASSED. NOW, EPA -- HEADED BY ADMINISTRATOR DOUGLAS M. COSTLE, AN APPOINTEE OF PRESIDENT JIMMY CARTER -- HAS ANNOUNCED IT WILL NOT HAVE THE REGULATIONS READY UNTIL JANAURY, 1980. THAT WOULD BE 39 MONTHS AFTER ENACTMENT OF RCRA AND 21 MONTHS AFTER THE DEADLINE ESTABLISHED BY CONGRESS.

MEANWHILE, EPA ADMITS IT DOESN'T HAVE A HANDLE ON THE PROBLEM OF HAZARDOUS CHEMICAL WASTES WHICH THE REGULATIONS WOULD HELP TO CONTROL.

TOSCA WAS WRITTEN AFTER SCIENTISTS MADE PUBLIC THAT VINYL CHLORIDE, A COMMON INDUSTRIAL CHEMICAL, CAUSED A RARE AND INVARIABLY FATAL FORM OF LIVER CANCER IN CHEMICAL WORKERS.

THERE HAD ALREADY BEEN SEVERAL PREVIOUS CASES OF

COMMON INDUSTRIAL CHEMICALS OR MATERIALS TURNING OUT TO BE

CANCER CAUSING. THESE INCLUDE ASBESTOS AND A SERIES OF COAL

TAR DIES.

TOSCA COMPLEMENTS RCRA

IRONICALLY, THE FEDERAL GOVERNMENT HAS JUST DISCOVERED THE EPA OFFICES IN NEW YORK CITY ARE LOCATED IN A BUILDING FILLED WITH ASBESTOS USED IN CONSTRUCTION.

TOSCA AMOUNTS TO A COMPANION TO RCRA. TOSCA WILL CONTROL WHAT CHEMICALS ARE ALLOWED INTO INDUSTRY AND WHICH SHOULD BE REMOVED; RCRA WILL REGULATE THE DISPOSAL OF INDUSTRIAL CHEMICALS.

"OF COURSE THE TOXIC SUBSTANCES ACT IS RELATIVELY NEW AND IT HAS A VERY SMALL BUDGET," ECKHARDT NOTED. HE HINTED WHY IT MAY HAVE A SMALL BUDGET. "PERHAPS INDUSTRY IS WILLING TO GO ALONG AND THEY FEEL THEY COULD KILL IT BY NOT PUTTING UP MONEY."

ONE AREA IN WHICH ECKHARDT FEELS HE HAS BEEN SUCCESSFUL IS OCEAN DUMPING OF CHEMICAL WASTES. IT'S A LONG STANDING PRACTICE TO DUMP DRUMS OF WASTE IN THE GULF OF MEXICO. MANY CONTAIN SODIUM SLUDGE AND WILL EXPLODE IF EXPOSED TO WATER. THE IDEA IS TO PUT HOLES IN THE DRUM AND THEN IT IS SUPPOSED TO EXPLODE UNDER WATER. BUT, SOME HAVE BLOWN UP IN FISHERMEN'S NETS OR, IN ONE CASE, ON THE BOAT ITSELF.

IT WAS OPEN SEASON FOR CHEMISTRY. SAID ECKHARDT: "I STARTED TO COMPLAIN A LONG TIME AGO. PEOPLE WERE SHIPPING DRUMS DOWN THE OHIO RIVER TO DUMP IN THE BULF OF MEXICO."

THERE IS AN UNDERWATER CORAL REEF NOT FAR FROM HOUSTON IN A DUMP -REA, THE CONGRESSMAN NOTED.

"LORD KNOWS WHAT DAMAGE THEY MAY HAVE DONE IN TERMS OF THE MARINE LIFE AND BEAUTY OF THE AREA," HE SAID.

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HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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20,000 DUMPS ARE HAZARD IN U.S.: EPA AGENCY HAS

NO WAY TO COUNTER PERIL

BY DAVID E. LYNCH

WASHINGTON -- THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) NOW ESTIMATES THERE ARE AS MANY AS 20,000 INACTIVE HAZARDOUS WASTE DUMPS THROUGHOUT THE COUNTRY.

BUT A TOP EPA OFFICIAL ADMITTED TO THE COURIER-EXPRESS, THE AGENCY DOES NOT EVEN HAVE AN ACCURATE INVENTORY OF THE 300 DUMPS IT SAYS ARE AN IMMEDIATE HEALTH AND SAFETY HAZARD.

IN FACT, GARY DIETRICH, ASSOCIATE DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE FOR EPA, SAID HE IS JUST NOW PREPARING A MEMO ORDERING HIS REGIONAL STAFF TO PREPARE AN INVENTORY OF THESE, THE MOST DANGEROUS, SITES.

30 DAYS

HE SAID THIS INVENTORY WILL TAKE UP TO 30 DAYS.

IN AN INTERVIEW EARLIER THIS WEEK, DIETRICH TOLD THE COURIER-EXPRESS THAT HIS AGENCY HAS NEITHER THE LAW NOR THE MONEY TO REMEDY THE HEALTH AND SAFETY HAZARDS POSED BY THESE INACTIVE CHEMICAL DUMPS.

AT THAT TIME, DIETRICH ACKNOWLEDGED THE 300 KNOWN DANGEROUS DUMP SITES AND ADDED THERE MIGHT BE HUNDREDS OR THOUSANDS MORE ACROSS THE COUNTRY. AT THAT TIME, HE GAVE NO INDICATION THAT THE FIGURE MIGHT REACH 20,000.

BUT, HE SAID, THE EPA IS MORE CONCERNED WITH PREVENTING THE FORMATION OF THESE DANGEROUS DISPOSAL SITES IN THE FUTURE THAN WITH ATTACKING THE IMMEDIATE PROBLEM.

DISPOSAL DISASTERS

HE SAID HE HAD HIS 10 REGIONAL STAFF MEMBERS IN FOR A MEETING A FEW WEEKS AGO, AND HE ASKED EACH OF THEM TO GIVE HIM EXAMPLES OF CHEMICAL DISPOSAL DISASTERS ON THE MAGNITUDE OF THE LOVE CANAL, NIAGARA FALLS, CONTAMINATION.

"EACH OF THEM HAD THREE TO FIVE EXAMPLES," DIETRICH SAID, AND VIRTUALLY EVERY ONE OF THESE CASES WERE GENERALLY KNOWN ABOUT FOR TWO OR THREE -- AND SOME CASES UP TO 10 -- YEARS. AND NOTHING-S BEEN DONE ABOUT THEM."

HE SAID HE EXPECTS THE 10-MEMBER REGIONAL STAFF, THE ONLY EPA EMPLOYEES WORKING ON THE HAZARDOUS WASTE PROBLEM OUTSIDE OF HEADQUARTERS, TO COME UP WITH A COMPLETE INVENTORY ON ANYWHERE FROM 100 TO 300 SUCH SITES.

OF THE 11,000 EPA EMPLOYEES, ONLY161 ARE INVOLVED IN THE HAZARDOUS WASTE AREA.

LOCATIONS UNKNOWN

DIETRICH, AS EVERYONE ELSE AT EPA, ADMITS THE AGENCY DOES NOT KNOW WHERE THESE DEATH TRAPS ARE. HE ESTIMATES THERE ARE SOME 300 OF THE LOVE CANAL "TIME BOMB" NATURE, AND AGENCY ESTIMATES OF THE TOTAL NUMBER OF INACTIVE HAZARDOUS WASTE DUMPS RANGE UP TO 20,000 THROUGHOUT THE COUNTRY.

THE ASSOCIATE DEPUTY SAYS THERE WAS NO FEDERAL LAW TO

DEAL WITH CHEMICAL WASTE UNTIL 1976 WHEN CONGRESS ENACTED THE

RESOURCE CONSERVATION AND RECOVERY ACT (RCRA). THE ACT

REQUIRED EPA TO COME UP WITH REGULATIONS TO IMPLEMENT IT BY

APRIL, 1978.

THIS LEGISLATION PROMISES "CRADLE TO GRAVE" REGULATION OF CHEMICALS AND OTHER HAZARDOUS SUBSTANCES, BUT EPA DELAY IN DRAFTING THE REGULATIONS NOW MAKES IMPLEMENTATION OF THIS LAW IMPOSSIBLE BEFORE 1980.

INVESTIGATION ASKED

ON FRIDAY, REP. HENRY J. NOWAK, D-BUFFALO, CALLED FOR A CONGRESSIONAL INVESTIGATION OF THE EPA DELAY. HE MADE THE CALL IN A LETTER TO REP. JOHN E. MOSS, D-CALIF., CHAIRMAN OF THE HOUSE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS. THAT SUBCOMMITTEE DEALS WITH ENFORCEMENT OF CONGRESSIONAL ACTS.

DIETRICH SAID THE CHEMICAL INDUSTRY HAS BEEN EXPANDING IN LEAPS AND BOUNDS SINCE THE EARLY PART OF THIS CENTURY, BUT IT WASN'T UNTIL THE 1960S THAT THE STATES BEGAN PROGRAMS TO REGULATE THE DISPOSAL OF CHEMICAL WASTES.

AND HE IS CRITICAL OF THE STATE PROGRAM SAYING "THEY'RE STILL NOT VERY GOOD."

FOR THE MOMENT, EPA IS LEAVING THE PROBLEM IN THE HANDS OF THE STATES, "AND PUTTING ALL OUR ENERGEIS INTO THE PREVENTION PROGRAM (RCRA)," DIETRICH SAID, ADDING:

"IF WE STOPPED TO LOOK AT THE RETROACTIVE PROBLEM, WE WOULD HAVE TO DIVIDE OUR RESOURCES, AND THE PREVENTION PROGRAM WOULD BE SLOWED DOWN."

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NOW USED FOR HAZARDOUS WASTES IDAHO LAUNCHING SITES FOR MISSILES

CHEMICAL WASTE DUMPS -- PAST AND PRESENT -- ARE THREATENING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN -- PRESENT AND FUTURE. THIS IS THE NINTH IN A COURIER-EXPRESS SERIES OF ARTICLES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH THE PRACTICES OF WESTERN STATES IN COPING WITH HAZARDOUS WASTES.

TWO $55 MILLION RELICS OF THE MISSLE AGE HAVE BECOME ONE OF THE MORE INGENIOUS METHODS OF DISPOSING OF THE HAZARDOUS WASTES OF THE INDUSTRIAL AGE.

WES-CON INC. OF TWIN FALLS, IDAHO, OWNS TWO COMPLEXES EACH BUILT TO LAUNCH THREE TITAN MISSILES. THE SILOES ARE 160 FEET DEEP AND 50 FEET ACROSS. THE CONCRETE IS 16 FEET THICK AT THE BOTTOM AND 11 FEET THICK ON THE SIDES. THE SITES WERE FUILT ABOUT 20 YEARS AGO AND WERE CLOSED IN 1964.

THE FIRM HAS ALREADY FILLED TWO OF THE THREE SILOS AT A NEAR-DESERT SITE NEAR GRAND VIEW, IDAHO, AND IS WELL ON THE WAY TO FILLING THE THIRD. A SECON DSITE ABOUT 40 MILES AWAY IN BRUNEAU, IS BEING PREPARED TO TAKE WASTE IN ITS THREE SILOS.

PERHAPS 300 MILES AWAY, IN AN EQUALLY DRY AREA OF EASTERN OREGON, CHEM-NUCLEAR SYSTEMS INC. OF BELLEVUE, WASH., OPERATES A DISPOSAL SITE BASED ON THE ABILITY OF DRY DESERT AIR TO DRY OUT WET WASTE. CHEMICAL WASTES ARE SIMPLY PUT OUT IN 400,000 GALLON PONDS AND LEFT TO DRY IN THE SUN.

CALIFORNIA A LEADER

CALIFORNIA HAS SOME HAZARDOUS WASTE TREATMENT SITES WHICH USE THE SAME APPROACH. THAT STATE MAY ALSO HAVE THE NATION'S BEST SYSTEM OF RULES AND REGULATIONS GOVERNING DISPOSAL OF HAZARDOUS CHEMICALS. CALIFORNIA ALSO HAS MORE GOOD DISPOSAL SITES THAN ANY OTHER STATE, ACCORDING TO JAMES STAHLER, ENVIRONMENTAL ENGINEER IN THE SAN FRANCISCO REGIONAL OFFICE OF THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY COVERING CALIFORNIA, ARIZONA, HAWAII AND NEVADA.

"IT'S ONE FO THE MOST AGRESSIVE, PROGRESSIVE STATES IN THE UNION," STAHLER SAID OF THE STATE'S HAZARDOUS WASTE PROGRAM.

HE SHOULD KNOW. STAHLER WAS LOANED BY EPA TO CALIFORNIA IN 1973 TO WRITE THE STATE REGULATIONS GOVERNING SOLID AND HAZARDOUS WASTES. THAT WAS THREE YEARS BEFORE CONGRESS PASSED THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA) WHICH IS SUPPOSED TO HANDLE THE PROBLEM ON A NATIONAL BASIS.

"BEFORE RCRA WAS A DREAM," HE COMMENTED, CALIFORNIA WAS WORKING ON ITS LAW.

BUT, EPA IS YEARS AWAY FROM PUTTING THE REGULATIONS TO IMPLEMENT RCRA INTO EFFECT.

CALIFORNIA HAS TO WATCH THE CHEMICAL DISPOSAL PROBLEM: THE STATE HAS AN ESTIMATED 10 PERCENT OF THE NATIONAL TOTAL OF 92 BILLION POUNDS OF HAZARDOUS WASTE.

THE GOLDEN STATE NOW HAS NINE HAZARDOUS WASTE SITES LICENSED TO HANDLE HAZARDOUS WASTES. WHEN THE LAW TOOK EFFECT ON JULY 1, 9173, THERE WERE 18. THE STEADY EXPANSION OF THE STATE -- "URBAN ENCROACHMENT" -- HAS CUT INTO THE TOTAL.

RECENTLY A SITE NEAR SAN DIEGO WAS CLOSED BECAUSE THE OPERATOR DECIDED RESIDENTIAL AREAS WERE CLOSING IN ON THE LOCATION. A CLOSED SITE LIKE THIS IN A RESIDENTIAL AREA OPENS UP THE POSSIBILITY OF A SITUATION SIMILAR TO THAT OF THE LOVE CANAL IN NIAGARA FALLS. THERE, A HAZARDOUS WASTE DUMP WENT BAD FORCING THE EVACUATION OF THE NEIGHBORHOOD.

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HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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AN IDAHO TITAN SILO SIMILAR TO THIS IS NOW USED AS TOMB FOR CHEMICAL WASTE . . . MISSILE AGE RECYCLING.

PHOTOGRAPH OMITTED.

THERE IS PLENTY OF NEED FOR MORE SITES IN CALIFORNIA.

"I CANNOT THINK OF ANYTHING THAT THIS STATE DOESN'T PRODUCE OR USE OR THROW AWAY," HE COMMENTED ON THE STATE'S INDUSTRIES.

UNTIL RECENTLY, STAHLER NOTED, "PERHAPS 50 PERCENT" OF HAZARDOUS WASTE DISPOSAL OR TREATMENT "LEFT SOMETHING TO BE DESIRED."

THERE ARE BAD PAST SITES. PERHAPS THE WORST IS IN RIVERSIDE, CALIF., JUST OUTSIDE LOS ANGELES. A QUARRY COMPANY OPERATED A DUMP SITE THERE FOR SEVERAL YEARS, MOSTLY TAKING HEAVY METAL SLUDTE AND ACIDS. THE WASTES WERE DUMPED IN A SERIES OF PITS RUNNING DOWN A HILLSIDE ON THE EDGE OF RESIDENTIAL PYRITE CANYON.

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"WHEN THE STUFF WAS DRIED UP, THEY WOULD DIG OUT THE MIDDLE OF THE PIT AND DUMP IT ON THE SIDE," EXPLAINED STEPHEN HERRERA, STAFF ENGINEER WITH THE SANTA ANA REGIONAL WATER QUALITY BOARD.

THE SITE HAS BEEN CLOSED FOR FIVE YEARS AND THE PREVIOUS OWNERS "JUST WALKED AWAY," HE SAID.

BUT, LAST YEAR, HEAVY RAINS WASHED INTO THE PITS, THREATENING TO WASH THE ENTIRE COMPLES AND EVERYTHING IT CONTAINED DOWN THE HILL AND INTO A RESIDENTAIL AREA. SO, PERHAPS A MILLION GALLONS OF WATER AND WASTE WERE PUMPED OUT INTO A NEARBY STREAM. THE STREAM THEN OVERFLOWED ONTO ADJACENT LAND.

THE POLLUTION ALSO SOMEHOW SEEPED INTO THE WELL OF AN ELEMENTARY SCHOOL 7,000 FEET AWAY, ACCORDING TO MRS. RUTH KIRKBY, SECRETARY OF A CITIZENS GROUP AGITATING FOR A CLEANUP OF THE ENTIRE SITE.

IT ISN'T COMPLETELY CLEAR WHAT WENT INTO THE SITE. BUT, IT IS KNOWN TO HAVE RECEIVED A VARIETY OF ACIDS AND A LOT OF METAL SLUDGES, ESPECIALLY FROM METAL PLATING OPERATIONS. MRS. KIRKBY HAS BEEN SO INVOLVED IN TRYING TO GET THE SITE CLEANED UP SH HAS EVEN TALKED TO DR. ROGER HERDMAN, NEW YORK STATE DIRECTOR OF PUBLIC HEALTH. SHE SAID SHE TALKED TO DR. HERDMAN BECAUSE OF THE LOVE CANAL SITUATION IN NIAGARA FALLS.

SHE EXPLAINED THAT SHE WAS WORRIED THAT THE AIR AND WATER POLLUTION INTE AREA OF THE PYRITE CANYON MIGHT CREATE THE S-ME SORT OF ENVIRONMENTAL DISASTER THAT OCCURRED IN NIAGARA FALLS, WHERE DANGEROUS CHEMICALS SEEPING FROM A CLOSED DUMP HAVE FORCED EVACUATION OF A WHOLE NEIGHBORHOOD.

CALIFORNIA HAS APPROPRIATED $375,000 TO CLEAN UP THEPYRITE CANYON SCENE. STAHLER HAS SOME DOUBTS THAT THE MONEY IS ANYWHERE NEAR ENOUGH.

"LIKE LOVE CANAL, THEY WERE FIRST TALKING $4 MILLION, THEN $8 MILLION," HE SAID. "NOW THEY'RE TALKING $10 MILLION."

SAID MRS. KIRKBY:

"WE JUST WISH WE KNEW WHAT TO DO ABOUT THIS. IT'S A TERRIBLE THING."

BOTH THE CHEM-NUCLEAR OREGON SITE AND THE TWO WES-CON IDAHO SITES ARE ATTEMPTS TO GET AROUND THE LOCATION PROBLEM. THAT IS ALSO TRUE OF A SITE IN BEATTY, NEV. ALL FOUR SITES ARE LOCATED IN EXTREMELY ISOLATED, NEARLY DESERT AREAS.

THE SITES ARE LOCATED IN FAR, OUT OF THE WAY PLACES, WITH ESSENTIALLY NO NEIGHBORS. IN ADDITION, THE SOIL ON THE SITE WILL NOT CARRY WASTE MATERIALS FAR AWAY. GROUND WATER IS SO FAR BELOW THE SITE, IT IS NOT LIKELY TOFLUSH WASTE AWAY TO THREATEN NEIGHBORS.

FOR EXAMPLE, AT THE CHEM-NUCLEAR OREGON SITE, IF A POND WERE FILLED WITH 53 INCHES OF WATER ON JAN. 1 OF AN AVERAGE YEAR, IT WOULD BE DRY ON DEC. 31 OF THE SAME YEAR BECAUSE OF EVAPORATION. THERE IS NEGATIVE PRECIPITATION THERE.

TIGHT STATE RULES

THE SITE OPERATES UNDER RIGID CONTROLS BY THE STATE OF OREGON. THE STATE MUST APPROVE EVERY WASTE MATERIAL WHICH GOES INTO THE SITE.

"OUR POLICY IS THAT IF A CHEMICAL CAN BE RECYCLED, WE REQUIRE IT," EDUARDO G. CHIONG, AN ENGINEER IN THE HAZARDOUS WASTE SECTION OF THE OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY, TOLD THE COURIER-EXPRESS.

IRONICALLY, THE MAN WHO SET UP THE OREGON SYSTEM AS A STATE CHEMICAL ENGINEER IS NOW ON THE OTHER SIDE OF THE FENCE. PATRICK H. WICKS IS NOW MANAGER OF CHEMICAL DISPOSAL AND TREATMENT FOR CHEM-NUCLEAR.

OREGON AGENTS MAKE FREQUENT VISITS TO THE SITE. THE COMPANY RELIES ON THE PRODUCER OF THE WASTE FOR ANALYSIS OF THE CONTENTS.

"WE DON'T DO ANY TESTING. THAT'S DONE BEFORE IT'S SHIPPED. IT WOULD BE PROHIBITIVE. IT'S UP TO THE INTEGRITY OF THE MANUFACTURER," SAID FRANK DEMENT, SITE MANAGER.

"BATHTUB RINGS"

CHEM-NUCLEAR HAS FIVE WORK AREAS. TWO ARE ESSENTIALLY WASTE LAKES. THESE ARE 400,000 GALLON AREAS. ONE CONTAINS ACIDS AND THE OTHER CONTAINS BASIC WASTES. THE BASIC WASTE LAKE HAS RINGS OF COLOR AROUND IT FROM THE DIFFERENT WASTES, LIKE RINGS ON A BATHTUB.

ANOTHER PIT STARTED OUT AS 500 FEET LONG AND 30 FEET DEEP. IT IS GRADUALLY BEING FILLED FROM ONE END WITH A VARIETY OF SOLID WASTES. IN ITS BOTTOM IS A VAST, SEALED CONCRETE BOX. IT CONTAINS ROAD AND ROADSIDE MATERIALS WHICH WERE CONTAMINATED WHEN A TANK TRUCK LOAD OF PURE CYANIDE WAS WRECKED AND SPILLED ONTO THE HIGHWAY.

A WRECKED TRUCK IS ALSO BURIED AT CHEM-NUCLEAR. IT WAS CONTAMINATED IN A HIGHWAY WRECK AND SIMPLY BURIED BECAUSE IT WASN'T WORTH CLEANING AND FIXING.

THE OREGON AREA HAS TWO LARGE PITS FOR LIQUID WASTE, OTHER THAN THE ACID AND BASIC TANKS. HERE ALSO, THE DRY AIR IS USED TO SIMPLY DRY OUT THE WASTE. AS WITH MUCH CHEMICAL WASTE, THERE IS A LOT OF WATER IN IT.

DIRT CAP APPLIED

THE FIRM HAS PILED UP TO 11 FEET OF SLUDGE IN THE BOTTOM OF TWO OTHER PITS USED FOR OTHER LIQUID IN 30 MONTHS OF OPERATION.

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WHEN 27 FEET THICK, THE DUMPING WILL BE STOPPED AND THE MATERIAL ALLOWED TO DRY. THEN A THREE FOOT THICK DIRT CAP WILL BE PUT ON IT.

AT THE GRAND VIEW IDAHO SITE, WES-CON HAS A LITTLE DIFFERENT APPROACH. THE SITE IN USE NOW IS LOCATED IN THE MIDDLE OF A VAST NATURAL DEPOSIT OF THE SPECIAL "BENTONITE" CLAY USED TO SEAL HAZARDOUS WASTES. SO, A MACHINE JUST DIGS THE CLAY OUT AND PILES IT UP TO BE USED AS BACK FILL.

THE DRUMS OF WASTE ARE PUT INTO THE HOLE WITH A SPECIAL BUCKET AND COVERED OVER WITH CLAY. ORIGINALLY, DRUMS OF CHEMICAL WASTES WERE JUST DROPPED INTO THE HOLE. BUT, THERE WERE FIRES AND EXPLOSIONS AND GOVERNMENT OBJECTIONS. SO, THE PROCEDURE WAS CHANGED.

MOST OF THE MATERIAL GOING INTO THE SILOS COMES FROM AGRICULTURE, ACCORDING TO GENE REINBOLD, THE COMPANY PRESIDENT. THIS COVERS PESTICIDES, WASTES FROM MAKING PESTICIDES AND RELATED MATERIALS AND PESTICIDE CONTAINERS. A SMALL UNDERGROUND ROOM IS USED FOR DISPOSAL OF AEROSOL CONTAINERS, MANY OF THEM FULL OF VARYING TYPES OF CHEMICALS.

VALUABLE COPPER STORED

THERE ARE ABOUT 3,000 CARDBOARD DRUMS OF COPPER SLUDGE STORED AROUND THE IDAHO STIES. REINBOLD SAID THE MATERIAL IS ABOUT 30 PERDENT COPPER.

"WE'RE NOW TRYING TO GET AN ENGINEER TO GET THE COPPER OUT," HE SAID. "THERE'S A MILLION DOLLARS WORTH OF COPPER OUT THERE."

THE WES-CON SITE IN BRUNEAU IS NOW DIFFERENT. IN ABOUT SIX MONTHS, REINBOLD SAID, DUMPING WILL START IN THE THREE SILOS THERE. NOW, IN A SITE TOUR CONDUCTED FOR THE COURIER-EXPRESS IT CAN BE SEEN WHERE THE $55 MILLION WNET WHEN THE AIR FORCE BUILT THIS MISSILE SITE.

BOTH THE GRAND VIEW AND BRUNEAU SITES ARE LOCATED NOT FAR FROM MOUNTAIN HOME (IDAHO) AIR FORCE BASE, WHICH IS STILL OPERATING.

ONE VAST, VAULTED UNDERGROUND ROOM HELD A COMPLETE POWER PLANT TO OPERATE THE ENTIRE COMPLEX WITHOUT OUTSIDE POWER. ANOTHER THREE STODY AREA HELD THE LIVING QUARTERS AND THE CONTROL CENTER. SEEMINGLY ENDLESS TUNNELS LINK THE SECTIONS.

DEEP WATER TABLE

IN BOTH GRAND VIEW AND BRUNEAU, THE WATER TABLE IS 2,000 FEET DOWN BELOW THE SITE. (AT CHEM-NUCLEAR IN OREGON, THE WATER IS ONLY 800 FEET DOWN, BUT THERE ARE TWO LAYERS OF HARD ROCK IN BETWEEN.)

WES-CON IS LICENSED TO TAKE SOLID MATERIALS CONTAMINATED WITH PCB, BUT IT CAN'T TAKE LIQUID PCB.

REINBOLD SAID HE PLANS TO USE UNDERGROUND AREAS IN ADDITION AREAS BESIDE THE SIX SILOS FOR SPECIAL STORAGE.

"WE HAVEN'T DECIDED YET. IT DEPENDS ON WHAT WE GET. WE WANT TO USE IT FOR LONG TERM HEATED STORAGE OF SOME MATERIALS WHICH CAN BE RECYCLED FOUR OR FIVE YEARS DOWN THE LINE," REINBOLD SAID.

MATERIALS FOR THE SITE COME FROM ALL OVER HE SAID. SOME COME FROM AS FAR EAST AS NEW JERSEY, HE TOLD THE COURIER EXPRESS.

VARIOUS WASTES, ALSO ESPECIALLY PCB, COMEIN FROM CANADA.

ROGER FUENTES, A CHEMICAL ENGINEER WTIH THE EPA REGIONAL OFFICE IN SEATTLE, WAS UNABLE TO SAY HOW MUCH CHEMICAL WASTE COMES FROM CANADA, HOWEVER, HE SAID:

"WE DON'T HAVE THE INFORMATION AS FAR AS MOVEMENT OF HAZARDOUS WASTE. WE DON'T HAVE THE FACILITIES TO KEEP TRACK FO THAT WITHOUT RCRA."

LAW NOT IMPLEMENTED

RCRA IS A FEDERAL LAW WHICH PROVIDES FOR "CRADLE TO GRAVE" HANDLING OF HAZARDOUS WASTE. BUT, EPA HAS NOT YET BEEN ABLE TO PROVIDE THE REGULATIONS TO IMPLEMENT THE LAW IN THE ALMOST TWO YEARS SINCE IT BECAME LAW.

AS A RESULT, THE LAW IS ESSENTIALLY A DEAD LETTER.

THERE DOESN'T SEEM TO BE MUCH URGENCY ABOUT THE HAZARDOUS CHEMICAL WASTE SITUATION IN SOME WESTERN STATES.

WASHINGTON, FOR EXAMPLE, HAS NO HAZARDOUS WASTE DISPOSAL SITE YET. BUT IT DOES HAVE AN ALABORATE SET OF RULES WHICH TOOK EFFECT AUG. 1 TO DEFINE WHAT IS AN "EXTREMELY HAZARDOUS" WASTE. THE STATE ESTIMATED THERE ARE SOMEHWERE BETWEEN 20,000 AND 60,000 TONS GENERATED EACH YEAR OF EXTREMELY HAZARDOUS WASTE.

THEY ARE CURRENTLY VERY SOFT NUMBERS," ACCORDING TO TOM COOK, HEAD OF THE HAZARDOUS WASTE SECTION OF THE DEPARTMENT OF ECOLOGY IN OLYMPIA, WASH., MEANING THE ESTIMATES ARE VERY ROUGH.

COOK SAID FIRMS IN HIS STATE CAN TREAT THE WASTE, STORE IT ON SITE OR SEND IT OUT OF STATE. THAT SENT OUT OF STATE USUALLY GOES TO WES-CON IN IDAHO OR CHEM-NUCLEAR IN OREGON.

SMALL CHEMICAL INDUSTRY

THE STATE OF IDAHO KEEPS AN EYE ON WES-CON. THE FIRM TAKES CARE OF ONE OF THE STATE'S PROBLEMS, THE DISPOSAL OF EMPTY PESTICIDE DRUMS.

JEROME JANKOWSKI, SENIOR ENVIRONMENTAL QUALITY SPECIALIST IN THE SOLID WASTE SECTION IN THE IDAHO DEPARTMENT OF HEALTH AND WELFARE, NOTED, "WE DON'T HAVE MUCH IN THE WAY OF A CHEMICAL INDUSTRY."

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PERHAPS THE LONGEST SHIPMENTS ARE FROM HAWAII. EPA'S STAHLER SAID THERE ARE NOT CHEMICAL WASTE REGULATIONS IN HAWAII. ALL HAWAIIAN WASTE OSTENSIBLY IS SHIPPED TO THE U.S. MAINLAND. HOWEVER, THERE IS SOME EVIDENCE OF IMPROPER DUMPING OF CHEMICAL WASTES IN THE ALOHA STATE.

ARIZONA IS NOW COMPETING ITS HAZARDOUS WASTE REGULATIONS, WITH A TARGET DATE OF NOV. 1 FOR EFFECTIVENESS. STAHLER SAID THEY ARE BASED ON THE CALIFORNIA RULES. THE STATE WILL LEASE A TREATMENT AND DUMP SITE TO A PRIVATE OPERATOR FOR HAZARDOUS WASTE AFTER THE REGULATIONS ARE COMPLETED.

AN ISOLATED SITE IS BEING CONSIDERED.

STAHLER PUT HIS FINGER ON ONE FO THE KEY ISSUES WHEN HE TOLD THE COURIER-EXPRESS:

"NOBODY WANTS A GARBAGE DUMP IN THEIR BACKYARD. BUT, GOD KNOWS THE STUFF HAS TO GO SOMEWHERE."

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GET BUSY ON WASTE CLEANUP . . .

THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) POSES AN INTOLERABLE PROBLEM WHEN IT CLAIMS THAT IT IS POWERLESS TO DO ANYTHING ABOUT CHEMICAL WASTE DUMPS WHICH IT ADMITS ARE AN IMMEDIATE THREAT TO THE NATION'S HEALTH AND SAFETY. THERE ARE 300 SUCH HAZARDOUS DUMPS, ACCORDING TO EPA, AND IT WOULD COST $1.5-BILLION TO CLEAN THEM UP.

THE EPA, ACCORDING TO GARY DIETRICH, THE AGENCY'S ASSOCIATE DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE, IS CONCENTRATING ON "PREVENTION" THROUGH THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) ENACTED IN 1976 TO CONTROL THE GENERATION, TREATMENT, TRANSPORTATION, STORAGE AND DISPOSAL OF HAZARDOUS OR TOXIC WASTES. THE AGENCY IS ALREADY MONTHS BEHIND SCHEDULE IN ISSUING IMPLEMENTING REGULATIONS FOR THE ACT, AND DOES NOT EXPECT TO RELEASE SUCH RULES UNTIL JANUARY, 1980. REP. HENRY J. NOWAK, D-BUFFALO, HAS CALLED FOR A HOUSE PROBE OF THE DELAY AND FOR LEGISLATIVE HEARINGS ON THE WASTE PROBLEM.

WHILE THE PREVENTION ASPECT IS IMPORTANT, IT SHOULD NOT PRECLUDE DOING SOMETHING ABOUT THE PRESENT CRITICAL SITUATION. EPA SAYS THAT IT DOESN'T HAVE THE NECESSARY AUTHORITY -- BUT WE FIND THAT HARD TO BELIEVE. WHAT APPARENTLY IS TRUE, HOWEVER, IS THAT OUT OF A $1.2-BILLION BUDGET AND ALMOST 11,000 EMPLOYEES, THE AGENCY IS UTILIZING ONLY 161 WORKERS AND SPENDING ONLY ABOUT $25 MILLION TO DEAL WITH THE PROBLEM OF HAZARDOUS WASTES. INCREDIBLE:

EPA SAYS IT DOESN'T HAVE THE MONEY OR THE AUTHORITY TO DEAL WITH WHAT AMOUNTS TO 300 LOVE CANAL SITUATIONS. IT'S TIME EPA GOT BOTH. IT'S HARD TO IMAGINE THAT THE FUNDS SHOULD BE ANY INSOLUBLE PROBLEM. IN A $500-BILLION FEDERAL BUDGET, SURELY $1.5-BILLION, OR AT LEAST A START ON THAT AMOUNT, CAN BE FOUND TO REMEDY EXISTING TOXIC THREATS TO THE AMERICAN PUBLIC'S HEALTH. COME ON, MR. PRESIDENT, HOW ABOUT TAKING SOME MONEY FROM THE $7.1-BILLION TO $9.2-BILLION BEING CONSIDERED FOR FOREIGH AID -- SOME OF IT DESTINED FOR SUCH COMMUNIST-LED COUNTRIES AS YUGOSLAVIA, APPARENTLY -- IN CURRENT LEGISLATION IN CONGRESS?

. . . MORE ACTION ON CANAL FUNDING

MEANWHILE, WE WERE PLEASED BY THE HOUSE OF REPRESENTATIVES' ACTION LAST TUESDAY APPROVING AN APPROPRIATION BILL WHICH INCLUDES $4-MILLION OF THE SCHEDULED CLEANUP EFFORTS IN THE LOVE CANAL AREA OF NIAGARA FALLS. THE FUNDS ARE PART OF AN OMNIBUS APPROPRIATION FOR THE DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AND OTHER SUCH INDEPENDENT GOVERNMENT AGENCIES.

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IN THE SENATE, WHERE SENS. DANIEL P. MOYNIHAN AND JACOB JAVITS EARLIER ATTEMPTED -- UNSUCCESSFULLY -- TO TAP A $10-MILLION EMERGENCY POLLUTION CONTROL FUND AUTHORIZED UNDER THE WATER POLLUTION CONTROL ACT, WE HOPE THERE WILLBE PROMPT ACTION ON THE AGENCIES' APPROPRIATION BILL CONTAINING THE LOVE CANAL CLEANUP MONEY. FRANKLY, IT'S HARD TO UNDERSTAND THE REPORTED WHITE HOUSE OBJECTIONS TO APPROPRIATION OF THE EMERGENCY POLLUTION CONTROL FUNDS. IN A WAY, IT TIES IN WITH THE PICTURE, SHARPLY ETCHED IN THE COURIER-EXPRESS' CONTINUING SERIES ON WASTE-DISPOSAL PROBLEMS, OF A GENERAL FOOT-DRAGGING.

SHOULDN'T THE PRESIDENT BE ORDERING THE ENVIRONMENTAL PROTECTION AGENCY TO BOLSTER ITS FORCES IN THE TOXIC WASTE CLEANUP FIELD? WHAT SENSE OF PRIORITY IS BEING USED IN THIS MATTER? IF THE EPA, ON THE OTHER HAND, IS NOT FOLLOWING THE ACTUAL PRESIDENTIAL WISHES WITH REGARD TO IT REDIRECTING ITS RESOURCES, AS HAS BEEN SUGGESTED BY AT LEAST ONE CONGRESSMAN, THEN CERTAINLY SOMEONE AT EPA SHOULD BE CALLED TO AN ACCOUNTING.

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EPA LAGS BADLY

ON WASTE CURBS

BY DAVID E. LYNCH

WASHINGTON -- BACK IN 1976, THE SPONSORS OF THE RESOURCE CONSERVATION AND RECOVERY ACT CALLED THE VEXING SOLID WASTE PROBLEM "THE STEPCHILD OF THE ENVIRONMENTAL MOVEMENT."

BUT CONGRESS RESPONDED WITH SURPRISING SPEED AND UNANIMITY AS THE SOLID-WASTE MEASURE SAILED THROUGH, SUPPOSEDLY MAKING RESOURCE CONSERVATION AND RECOVERY A LEGITIMATE MEMBER OF FAMILY.

THAT WAS ON OCT. 21, 1976, ALMOST TWO YEARS AGO, AND THE ENVIRONMENTAL GROUPS ARE NOW SAYING THE ENVIRONMENTAL PROTECTION AGENCY, (EPA) IS STILL TREATING THE PROBLEM LIKE A STEPCHILD.

THE LAW THAT WAS ENACTED ON OCT. 21 "REQUIRED" THE EPA TO ISSUE REGULATIONS NEEDED TO IMPLEMENT THE HAZARDOUS WASTE SECTION OF THE STATUTE WITHIN 18 MONTHS.

THE EPA NOW SAYS THOSE REGULATIONS WON'T BE READY UNTIL JANUARY OF 1980. THE ENVIRONMENTALISTS WHO ARE SUING TO SPEED UP THIS PROCESS SAY THEY PROBABLY WON'T BE READY BY THEN.

HERE'S WHAT THE LAW REQUIRED EPA TO DO CONCERNING HAZARDOUS WASTES:

-- ISSUE REGULATIONS WITHIN 18 MONTHS DEFINING THE WORD ILLEGIBLE HAZARDOUS WASTES AND LISTING SPECIFIC HAZARDOUS WASTES.

THAT WON'T BE COMPLETED UNTIL 1980, ACCORDING TO DOUGLAS M. COSTLE, ADMINISTRATOR OFTHE EPA.

-- ISSUE REGULATIONS WITHIN 18 MONTHS REQUIRING PERMITS TO OPERATE HAZARDOUS WASTE TREATMENTS, STORAGE OR DISPOSAL FACILITIES.

THAT WON'T BE COMPLETED UNTIL 1980, ACCORDING TO THE EPA.

ESTABLISH A CIVIL PENALTY OF UP TO $25,000 A DAY FOR HAZARDOUS WASTE VIOLATIONS THAT TAKE PLACE AFTER STATE OR FEDERAL COMPLIANCE DEADLINES; SET A CRIMINAL PENALTY OF UP TO $25,000 A DAY AND/OR ONE YEAR IN PRISON FOR KNOWING VIOLATIONS.

BECAUSE THE REGULATIONS ARE NOT IN PLACE, THERE ARE NO COMPLIANCE DEADLINES TO VIOLATE AND, THEREFORE, NO PENALTIES UNDER THE LAW.

THOSE WHO HAVE BEEN HIGHLY CRITICAL OF THE EPA'S DELAY SAY IT IS CONTRIBUTING TO THE DEADLY CHEMICAL WASTE PROBLEM THAT IT IS SUPPOSED TO BE SOLVING.

FIRMS PRODUCING CHEMICALS WASTES ARE LOADING TOXIC, POISONOUS WASTES INTO THEIR LESS THAN TOTALLY SAFE SITES AS FAST AS POSSIBLE BEFORE THESE REGULATIONS ARE ISSUED.

AND THE "MIDNIGHT HAULERS," THE ILLEGAL WASTE DUMPERS WHO OPERATE UNDER THE CLOAK OF DARKNESS, HAVE ONE LESS FEDERAL PENALTY TO WORRY ABOUT WHILE EPA STRUGGLES WITH THE REGULATION.

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CONGRESS HAS BEEN ATTEMPTING TO COME UP WITH AN EFFICIENT NATIONAL POLICY ON SOLID WASTE SINCE 1965, WHEN IT PASSED THE SOLID WASTE DISPOSAL ACT. THE RESOURCE CONSERVATION AND RECOVERY ACT ACTUALLY AMENDED THAT STATUTE, WHICH WAS STRENGTHENED IN 1970 BY THE RESOURCE RECOVERY ACT.

THE 1976 BILL AUTHORIZED $365.9 MILLION FOR SOLID-WASTE PROGRAMS IN FISCAL YEARS 1978-79. THAT INCLUDED $80 MILLION FOR EPA'S GENERAL USE, AND $70 MILLION TO FINANCE STATE PROGRAMS, $50 MILLION FOR STATE HAZARDOUS-WASTE PROGRAMS AND $35 MILLION TO HELP FINANCE DEMONSTRATION PROJECTS.

THE FILL ALSO REQUIRED STATES RECEIVING FEDERAL GRANTS

TO BAN ALL OPEN DUMPING WITHIN FIVE YEARS OF ENACTMENT.

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EPA EXPECTS MORE SUITS ONCE RULES ON HAZARDOUS WASTES ARE ON BOOKS

BY MICHAEL DESMOND

SAN FRANCISCO -- PUFFING AWAY ON A PIPE, STEFFEN W. PLEHN HAD A LOOK OF CASUAL SUPERIORITY AS HE SAT ON A PLATFORM OVER A ROOM FULL OF PEOPLE WHO ARE IN THE GARBAGE AND HAZARDOUS WASTE BUSINESS.

PLEHN IS THE ENVIRONMENTAL PROTECTION AGENCY'S DEPUTY ASSISTANT ADMINISTRATOR FOR SOLID WASTE. IN THAT POST, HE IS IN CHARGE OF THE FEDERAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA). THIS IS THE FEDERAL LAW SUPPOSED TO BE THE SOLUTION TO ALL PROBLEMS IN THE FIELD OF SOLID AND CHEMICAL WASTE.

IT IS ALSO NOT IN EFFECT.

REGULATIONS GOVERNING THE APPLICATION OF GHE LAW ARE NOW NOT DUE UNTIL JANUARY 1980, DESPITE THE MANDATE, IN THE LAW PASSED BY CONGRESS IN 1976, TO HAVE THEM COMPLETED APRIL 21.

PLEHAN WAS HERE TO ADDRESS THE SEVENTH NATIONAL CONGRESS ON WASTE MANAGEMENT TECHNOLOGY AND RESOURCE AND ENERGY RECOVERY, SPOONSORED BY THE NATIONAL SOLID WASTE MANAGEMENT ASSOCIATION.

IRONICALLY, THE ASSOCIATION HAS NOTIFIED EPA IT WILL BE SUING THE AGENCY FOR ITS FAILURE TO PRODUCE THE RCRA RULES. EPA ALREADY HAS SUITS BY THE STATE OF ILLINOIS AND TWO ACTIVIST GROUPS, THE ENVIRONMENTAL DEFENSE FUND AND ENVIRONMENTAL ACTION, PENDING AGAINST FOR THE SAME REASON.

OTHER SUITS ARE EXPECTED.

ONCE THE RULES ARE FINALLY READY TO GO, HE SAID, "WE'LL PROBABLY BE SUED TO A LOT OF PEOPLE."

STEFFEN W. PLEHN . . . EXPECTS LITIGATION.

PHOTOGRAPH OMITTED.

THE GOVERNMENT OFFICIAL SAID THE RULES ARE LATE BECAUSE OF THE COMPLICATED PROCEDURES FOR PUTTING THEM OUT. THEN, SPEAKING TO THE COURIER-EXPRESS, THE TOOK A SHOT AT CONGRESS:

"IT'S ONLY IN THE ENVIRONMENTAL AREA THAT CONGRESS SETS DEADLINES FOR REGULATIONS. IN ALMOST ALL CASES, THE DEADLINES SET BY CONGRESS ARE MORE AMBITIOUS THAN THE AGENCY IS CAPABLE OF ACHIEVING."

AT THE SAME TIME, HE DOEN'T THINK ANY MORE MONEY WOULD SPEED UP THE RULES. "THE CONGRESS HAS GIVEN US ALL THE RESOURCES REQUESTED IN THE BUDGET," PLEHN SAID.

THE SOLID WASTE CHIEF IS A PROFESSIONAL BUREAUCRAT. HE IS A GRADUATE OF HARVARD COLLEGE, WHERE HE ALSO RECEIVED A MASTER'S DEGREE IN PUBLIC ADMINISTRATION.

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FROM 1972 UNTIL 1975, HE WORKED FOR THE U.S. COUNCIL ON ENVIRONMENTAL QUALITY, THEN SWITCHED OVER TO BE EXECUTIVE ASSISTANT TO THEN EPA ADMINISTRATOR RUSSELL TRAIN. WHEN DOUGLAS M. COSTLE WAS NAMED TO HEAD THE AGENCY BY PRESIDENT JIMMY CARTER IN MARCH 1977, PLEHN STAYED ON AS EXECUTIVE ASSISTANT. HE WAS NAMED TO HIS PRESENT POST BY COSTLE 10 MONTHS AGO.

THE OFFICIAL IS NEITHER A LAWYER NOR A TECHNICIAN IN THE SOLID AND HAZARDOUS WASTE FIELD. IN PERSON, HE LOOKS MORE LIKE AN IVY LEAGUE COLLEGE PROFESSOR, WITH IMPECCABLE SUIT AND WING TIP SHOES.

PLEHN CLAIMS THE GAENCY IS SLOW ON THE RULES BECAUSE OF LEGAL WORRIES.

"OUR CONCERN IS THAT OUR REGULATIONS BE TECHNICALLY SOUND AND FULLY DEFENSIBLE LEGALLY. NOTHING WOULD BE GAINED BY PUTTING OUT REGULATIONS THAT WOULD NOT HOLD UP IN COURT," HE SAID.

HE DENIED MORE RESOURCES WOULD HELP:

"ANY AGENCY CAN USE MORE RESOURCES. BUT, I DON'T THINK THAT'S THE PRIMARY CONSTRAINT IN ACHIEVING THE REGULATIONS."

PLEHN SAID GOVERNMENT IS SIMPLY SLOW TO PUT OUT REGULATIONS.

AMONG THE RED TAPE, HE CITED REQUIREMENTS FOR ENVIRONMENTAL IMPACT STATEMENTS, ECONOMIC IMPACT ANALYSES, PUBLIC COMMENT PERIODS AND COMPLICATED REVIEWS INSIDE EACH AGENCY ISSUING RULES.

PLEHN IS COUNTING ON THE INDIVIDUAL STATES TO DO MUCH OF THE FUTURE WORK IN THE HAZARDOUS WASTE FIELD. RCRA WILL ALLOW STATES TO ADMINISTER THEIR OWN PROGRAMS, WITH FEDERAL GRANTS TO PAY FOR THEM. IF THE STATES CAN'T OR WON'T DO IT, HE SAID, IT WILL COST THE FEDERAL GOVERNMENT A LOT OF MONEY.

IN THE FISCAL YEAR WHICH STARTS OCT. 1, EPA IS PUTTING UP $15 MILLION TO HELP STATES LOCATE HAZARDOUS WASTES AND START THEIR OWN CLEANUP PROGRAMS. LAST YEAR, EPA PUT NO MONEY INTO SUCH ACTIVITIES. THIS YEAR, THE AGENCY PUT UP $4.7 MILLION.

"THAT'S A FAIRLY SIGNIFICANT RATE OF INCREASE," PLEHN SAID.

EPA IS HANDLING THINGS THAT WAY BECAUSE THE AGENCY CLAIMS

IT HAS NO MONEY OR LEGAL AUTHORITY TO LOOK INTO PAST AND

CLOSED DUMPSITES. IN FACT, THE AGENCY CLAIMS TI CAN'T DO

ANYTHING ABOUT DUMP SITES NOW OPEN BUT TO BE CLOSED BY THE

TIME THE REGULATIONS TAKE EFFECT.

EVEN WHEN THE RULES ARE IN EFFECT, THEY WON'T DO ANYTHING ABOUT SITUATIONS SUCH AS THE CHEMICALLY DEVASTATED LOVE CANAL AREA OF NIAGARA FALLS, FOR EXAMPLE.

EPA ADMITTED TO THE COURIER-EXPRESS THURSDAY THAT 300 CLOSED CHEMICAL WASTE DUMPS AROUND THE NATION ARE AN IMMEDIATE THREAT TO THE NATION'S HEALTH AND SAFETY.

"OFF THE TOP OF MY HEAD, I KNOW OF 300 SITUATIONS LIKE THE LOVE CANAL PROBLEM THAT STICK OUT LIKE SORE THUMBS," ACCORDING TO GARY DIETRICH, ASSOCIATE DEPUTY ADMINISTRATOR FOR SOLID WASTE. HE SAID THERE ARE HUNDREDS OF THOUSANDS MORE THAT THE EPA DOES NOT KNOW ABOUT.

THE AGENCY HAS ESTIMATED IT WOULD COST $1.5 BILLION TO CLEAN UP JUST THE 300 KNOWN DUMPS.

EPA SAID PRESIDENT CARTER WOULD NOT RELEASE EVEN THE $10 MILLION THAT COULD BE USED TOWARD CLEANING UP SOME OF THESE SITES.

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$6 MILLION VANISHES IN HUDSON PCBS, $25 MILLION MORE SOUGHT

BY MICHAEL A. HITZIK

AFTER SPENDING $6 MILLION IN THE LAST TWO YEARS STUDYING HOW TO RID THE HUDSON RIVER OF TOXIC PCBS AND DISPOSE OF THE CHEMICALS, NEW YORK STATE STILL DOESN'T HAVE MUCH OF AN ANSWER.

FURTHERMORE, ENVIRONMENTAL CONSERVATION COMMISSIONER PETER A. A. BERLE IS SEEKING $25 MILLION FROM THE FEDERAL GOVERNMENT TO COMPLETE THE CHORE.

PCBS (POLYCHLORINATED BIPHENYLS) WERE MANUFACTURED UNTIL JULY, 1977, BY THE GENERAL ELECTRIC CORP. FOR USE AS FIRE RETARDANTS AND COOLANTS IN ELECTRICAL TRANSFORMERS.

AFTER GATHERING EVIDENCE THAT THE COMPOUNDS COULD CAUSE

NERVOUS DISORDERS AND OTHER AILMENTS, THE FEDERAL GOVERNMENT

BANNED THEIR MANUFACTURE LAST SPRING. EXISTING PCBS, HOWEVER,

MAY BE RECYCLED FOR USE UNTIL 1983.

STATE HEARING

IT WAS GENERAL ELECTRIC'S PLANTS IN FORT EDWARD AND OTHER HUDSON RIVER COMMUNITIES THAT DUMPED PCBS INTO THE RIVER, CONTAMINATING IT SO THOROUGHLY THAT COMMERCIAL FISHING IS NOW BANNED FROM FORT EDWARD TO NEW YORK CITY.

GENERAL ELECTRIC HAD DUMPED MORE THAN 600,000 POUNDS OF PCBS INTO THE RIVER BASIN BETWEEN 1950 AND 1976. ALTHOUGH IT HAD OBTAINED STATE AND FEDERAL DISCHARGE PERMITS, A STATE HEARING OFFICER FOUND THE COMPANY GUILTY IN 1976 OF VIOLATING WATER QUALITY STANDARDS.

THE OFFICIAL PLACED FULL BLAME FOR THE CONTAMINATION OF THE RIVER, HOWEVER, ON A COMBINATION OF "INDUSTRIAL ABUSE AND REGULATORY FAILURE," ACCORDING TO DR. LEO HETLING, RESEARCH DIRECTOR FOR THE STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION.

ACCORDINGLY, THE STATE AND GE REACHED AN AGREEMENT IN SEPTEMBER, 1976, CALLING FOR A JOINT $7 MILLION RESEARCH AND CLEANUP FUND. GE WAS TO PROVIDE $3 MILLION FOR A CLEANUP STUDY AND $1 MILLION FOR CHEMICAL RESEARCH, AND THE STATE WAS TO CONTRIBUTE THE REST.

"VARIOUS ALTERNATIVES"

ALL BUT $1 MILLION HAS BEEN SPENT, SAID DR. HETLING, MOSTLY FOR A COMPREHENSIVE STUDY OF THE EXTENT OF CONTAMINATION AND OF PROPOSED SOLUTIONS.

"THE REPORT LOOKED AT VARIOUS ALTERNATIVES," HE SAID "RANGING FROM DOING NOTHING AT ALL TO DREDGING THE ENTIRE RIVER."

THE FAVORED APPROACH, APPROVED BY AN INDEPENDENT PCB ADVISORY COMMITTEE OF STATE AND FEDERAL OFFICIALS AND MEDICAL AND CHEMICAL AUTHORITIES, WAS TO DREDGE JUST THOSE "HOT SPOTS" WHERE CONTAMINATION OF THE RIVER SEDIMENT WAS HEAVIEST, REMOVING 300,000 POUNDS OF PCBS.

UNDER THE AGREEMENT, GE BEGAN DEVELOPING AN ENVIRONMENTALLY SAFE SUBSTITUTE FOR PCBS, WHICH IT CALIMS TO HAVE FOUND AND PLACED INTO PRODUCTION.

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THE COMPANY'S EFFORT TO FIND A MEANS OF DISPOSAL OR DECONTAMINATION OF THE PCB-LADEN RIVER SEDIMENT HAS BEEN LESS PRODUCTIVE, HOWEVER.

GE INVESTIGATED THREE METHODS: PYROLYSIS OR "COOKING" THE SEDIMENT TO DEGRADE THE PCBS; INCINERATION, AND FINDING WHETHER BACTERIA EXIST NATURALLY TO DESTROY THE CHEMICALS.

EXPENSIVE BURNING

IT ACQUIRED A SPECIAL PERMIT TO SEND 40 DRUMS OF SEDIMENT TO A NEW JERSEY LABORATORY FOR INCINERATION AND FOUND THAT TEMPERATURES OF 1,000 DEGREES FAHRENHEIT AND HIGHER DESTROY THE COMPOUNDS.

"BUT TO REACH THOSE TEMPERATURES," SAID DR. MANUEL AVEN, MANAGER OF GE'S PHYSICAL CHEMISTRY LABORATORY IN SCHENECTADY, "YOU HAVE TO BURN AN AWFUL LOT OF OIL TO RUN THE FURNACE."

FIGURES DEVELOPED BY THE STATE SHOW THAT THE COST OF INCINERATING THE 1.6 MILLION CUBIC YARDS OF RIVER BOTTOM PRODUCED BY "HOT SPOT" DREDGING WOULD COME TO $16 MILLION IN FUEL ALONE, ADDED TO $21 MILLION IN DREDGING COSTS AND UNDETERMINED TRANSPORT CHARGES.

AVEN'S CONCLUSION WAS THAT INCINERATION IS "RATHER PROHIBITIVE ECONOMICALLY," ALTHOUGH GE WILL LEAVE TO THE STATE THE DECISION ON WHETHER THE METHOD IS WORTHWHILE.

MATTER OF EVOLUTION?

PYROLYSIS, IN ESSENCE ANOTHER FORM OF INCINERATION, WAS SIMILARLY DEEMED OVERLY COSTLY.

GE SCIENTISTS, HOWEVER, DID DISCOVER THAT BACTERIA EXIST IN THE ENVIRONMENT WITH AN APPETITE FOR PCBS, BREAKING THEM DOWN INTO WATER, CARBON DIOXIDE, AND CARBON-BASED ACIDS. THE ORGANISMS, APPARENTLY EVOLVED PRECISELY BECAUSE PCBS WERE AVAILABLE FOR THEM TO FEAST ON.

"BUT IT'S PREMATURE TO DISCUSS PRACTICAL APPLICATIONS OF THE FINDING," SAID DR. RONALD BROOKS, MANAGER OF THE SCHENECTADY LABORATORY'S ENVIRONMENTAL UNIT.

HE SAID GE'S GOAL IS TO DETERMINE THE CONDITIONS UNDER WHICH THE BACTERIA WORK BEST AND MOST RAPIDLY TO CONSUME PCBS, "CONDITIONS WE ARE QUITE FAR FROM PREDICTING IN THE LAB."

TEMPORARY SOLUTION?

AVEN SAID THAT, ALTHOUGH GE'S OBLIGATION TO CONTINUE ITS STUDY HAS EXPIRED UNDER THE TERMS OF THE AGREEMENT, INVESTIGATION OF BACTERIAL DISPOSAL WILL CONTINUE AS PART OF THE COMPANY'S GENERAL MICROBIOLOGY PROGRAM.

IN THE MEANTIME, THE STATE'S EFFORT TO CLEAN THE RIVER WILL BE LIMITED, MONEY PERMITTING, TO DREDGING THE HOT SPOTS AND DEPOSITING THE SEDIMENT INDEFINITELY IN CAREFULLY CONSTRUCTED LANDFILLS.

"THE PROBLEM THERE IS MAINTENANCE," COMMENTED DR. HETLING.

NO SURE WAY HAS BEEN FOUND TO GUARANTEE THAT A TOXIC LANDFILL WILL BE PROPERLY MAINTAINED THROUGH WHAT COULD BE DECADES OF RESEARCH.

NEVERTHELESS, THE DEPARTMENT HAS COMBED ALL LAND WITHIN THREE MILES OF THE HUDSON SEEKING ADEQUATE LANDFILL SITES, AWAY FROM RESIDENTIAL AREAS, WETLANDS, PINE FORESTS, HISTORICAL SITES AND OTHER IMPORTANT REGIONS.

FORTY ACRES IN THE UPPER HUDSON BASIN MEET THE DEPARTMENT'S "STRICTLY TECHNICAL CRITERIA," SAID DR. HETLING, BUT STILL FACE PUBLIC AND POLITICAL RESISTANCE AND EXTENSIVE ENVIRONMENTAL STUDIES.

DREDGING THE WORST

THE REMAINING $1 MILLION FROM THE GE-STATE AGREEMENT IS BEING USED TO DREDGE A SECTION OF THE HUDSON JUST SOUTH OF FORT EDWARD WHERE CONTAMINATION HAS WORST AND WAS COMPOUNDED BY THE DEMOLITION OF AN UNUSED NIAGARA MOHAWK CORP. POWER DAM IN 1975.

THE DEMOLITION SENT PCB-LADEN SEDIMENT THAT HAD ACCUMULATED BEHIND IT DOWNSTREAM. THE SEDIMENT IS BEING REMOVED AND THE LOCAL SHORELINE COVERED WITH "RIP-RAP," OR CRUSHED STONE, TO END THE INFILTRATION. THE SEDIMENT IS DEPOSITED IN A CLAY-LINED LANDFILL IN THE TOWN OF MOREAU, ACROSS THE RIVER FROM FORT EDWARD AND ABOUT 40 MILES NORTH OF ALBANY.

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CRITICS SEE EPA HEAD AS TOO CAUTIOUS TO ACT

BY DAVID E. LYNCH

WASHINGTON -- DOUGLAS M. COSTLE, 38, THE ADMINISTRATOR OF THE ENVRIONMENTAL PROTECTION AGENCY IS A CAUTIOUS MAN, A MAN WHO SAYS HIS AGENCY "SHOULD DO ITS HOMEWORK" BEFORE TAKING ANY ACTION.

HE SAID THAT EARLY IN HIS ADMINISTRATION WHEN NATIONAL ENVIROMENTAL GROUPS HAILED HIS APPOINTMENT AS A SIGNAL THAT PRESIDENT CARTER WOULD GIVE A HIGH NATIONAL PRIORITY TO PRESERVING AND ENHANCING THE ENVIRONMENT.

THE ENVIRONMENTAL GROUPS THAT HAVE BEEN WAITING ALMOST TWO YEARS TO COSTLE TO ISSUE REGULATIONS ON HAZARDOUS WASTE DISPOSAL NOW SAY HE IS TOO CAUTIOUS, THAT HE IS OVER DOING HIS HOMEWORK WHILE THE HEALTH AND SAFETY OF THE AMERICAN PEOPLE ARE IMPERILED BY ALMOST DAILY DISCOVERIES OF HAZARDOUS WASTE DUMPS.

THE ENVIRONMENTAL DEFENSE FUND AND ENVIRONMENTAL ACTION AS WELL AS THE STATE OF ILLINOIS EARLIER THIS YEAR LOST THEIR PATIENCE. THEY SUED THE EPA FOR FAILING TO ISSUE REGULATIONS ON THE RESOURCE CONSERVATION RECOVERY ACT (RCRA).

THE LAW THAT REGULATES SOLID WASTES FROM "CRADLE TO THE GRAVE" WAS ENACTED BY CONGRESS IN 1976 WITH INSTRUCTIONS TO EPA THAT THE REGULATIONS WERE TO BE ISSUED WITHIN 18 MONTHS. THAT DEADLINE WAS UP LAST APRIL, AND COSTLE NOW SAYS THE REGULATIONS NECESSARY TO IMPLEMENT THE LAW WON'T BE READY UNTIL JANUARY OF 1980.

LESLIE DACH, THE SCIENCE ASSOCIATE AT THE ENVRIONMENTAL DEFENSE FUND, DOUBTS THAT THEY WILL BE READY BY THEN.

DOUGLAS M. COSTLE . . . A CAUTIOUS MAN.

PHOTOGRAPH OMITTED.

TOP PRIORITY

DACH AND OTHER ENVIRONMENTAL LEADERS MET WITH COSTLE ABOUT THREE WEEKS AGO TO DISCUSS THE DELAY. DACH SAID THE ADMINISTRATOR ASSURED THEM THAT THE RCRA RETULATIONS WERE HIS TOP PRIORITY. BUT HE IS BEING ESPECIALLY CAUTIOUS IN AN EFFORT TO MAKE SURE THE RULES STAND UP TO THE INEVITABLE COURT SUIT THAT WILL FOLLOW THEIR ISSUANCE.

"I DON'T THINK COSTLE IS PURPOSELY DELAYING THE REGULATIONS," DACH SAID. BUT DACH IS HIGHLY CRITICAL OF COSTLE'S APPROACH TO THE JOB.

HE SAID THE EPA HAS ALL THE DATA IT NEEDS TO START WRITING THE RULES. "IT'S JUST THAT THEY'RE AFRAID TO BITE THE BULLET ON TOUGH POLICY ISSUES SUCH AS HOW BROAD AND STRINGENT THE RULES SHOULD BE."

FAULTS COSTLY

HE FAULTS COSTLE FOR NOT STEPPING IN AND PUTTING DOWN THE "QUIET WARFARE" BETWEEN THE EPA DEPARTMENTS THAT HAS ARISEN THROUGH THE RULE MAKING PROCESS.

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DACH SAYS RCRA HAS THE POTENTIAL TO VIRTUALLY CONTROL AIR AND WATER STANDARDS, AND THE PEOPLE WORKING IN THOSE DEPARTMENTS AND OTHERS IN THE AGENCY ARE AFRAID RCRA WILL TAKE AWAY SOME OF THEIR AUTHORITY.

HE SAYS COSTLE'S SCHEDULE FOR ISSUING THE REGULATIONS IS "FILLED WITH FAT," CALLING FOR A SIX-MONTH POLICY REVIEW PERIOD AFTER THE PUBLIC HAS HAD 180 DAYS TO COMMENT ON THE PROPOSAL.

REVIEW PERIOD

THE ACTUAL RULES ARE EXPECTED TO BE READY THIS COMING JANUARY. A YEAR-LONG REIVEW COMMENT PERIOD IS TO FOLLOW. DACH AND THIS ASSOCIATES SAY THIS CAN BE CUT IN HALF.

HE SAYS THE POLICY QUESTIONS SHOULD BE ANSWERED BY NOW, NEVER MIND NEXT YEAR. "COSTLE IS BEING TOO CAUTIOUS."

THIS CAUTIOUS COSTLE HAS CAUSED MANY IN THE ENVRIONMENTAL MOVEMENT TO TAKE ANOTHER LOOK AT THE MAN THEY THOUGHT WOULD GIVE THEM THE "GET TOUGH" ADMINISTRATION THEY WERE LOOKING FOR.

THEY SAY HE LET THE CARTER ADMINISTRATION GET AWAY WITH TOO MUCH IN ITS ENERGY AND ANTI-INFLATION PROGRAMS.

CLEAN AIR

ENERGY DEPARTMENT HEAD JAMES R. SCHLESINGER HAS PUBLICALLY OPPOSED COSTLE'S ENFORCEMENT OF CLEAN AIR STANDARDS, SAYING IT RUNS COUNTER TO THE ADMINISTRATION'S PUSH FOR THE INCREASED USE OF LOW SULFUR COAL FROM THE WEST.

ROBERT S. STRAUSS, THE FORMER DEMOCRATIC PARTY CHIEF, WHO HEADS CARTER'S ANTI-INFLATION EFFORTS, HAS CALLED ON COSTLE TO EASE OFF ON ENVRIONMENTAL REGULATIONS TO HELP BUSINESSES HOLD THE LINE ON PROCES.

DACH AND OTHERS INTHE ENVIRONMENTAL MOVEMENT SAY COSTLE WAS AT FIRST COWED BY STRAUSS AND SCHLESINGER, WHO WERE PRESSING THEIR POINTS IN SPEECHES THROUGHOUT THE COUNTRY.

OPPORTUNITY MISSED

DACH SAID COSTLE MISSED THE OPPORTUNITY TO "GET OUT OF THE PUBLIC ARENA" AND FIGHT FOR HIS PROGRAMS AGAINST SCHLESINGER AND STRAUSS.

THE SCIENCE ASSOCIATE SAYS THE EPA ADMINISTRATOR SEEMS TO BE FLEXING HIS MUSCLES A BIT NOW. HE IS FIGHTING AGAINST THE PRESSURE COMING FROM SCHLESINGER AND STRAUSS, BUT HE LOST SOME IMPORTANT EARLY TIME.

ASKED TO RATE COSTLE'S PERFORMANCE TO DATE, DACH GIVES HIM A "B", SAYING THE ADMINISTRATOR HAS "DONE A LOT BETTER THAN HIS PREDECESSORS."

COSTLE WAS VIEWED AS A NATURAL FOR THE JOB WHEN HE WAS FIRST APPOINTED BY PRESIDENT CARTER IN 1977.

IN CARTER MOLD

HE WAS A RELATIVELY YOUNG 37, A LIBERAL TO MODERATE DEMOCRAT IN THE CARTER MOLD, A MEMBER OF THE FEDERAL COMMISSION THAT RECOMMENDED THE CREATION OF THE EPA IN 1970. A FORMER JUSTICE DEPARTMENT LAWYER, HE WAS COMMISSIONER OF THE CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION.

HIS WORK IN CONNECTICUT EARNED HIM THE RESPECT OF BOTH THE ENVIRONMENTAL GROUPS AND INDUSTRY.

HE ALSO CAME INTO AN ADMINISTRATION THAT PROMISED TO GIVE ITS EPA MORE SUPPORT THAN THE ADMINISTRATORS UNDER FORMER PRESIDENTS NIXON AND FORD HAD.

INCURRED RATH

COSTLE HAS HAD IT RELATIVELY EASY UP TO THIS POINT. LIKE EVERY EPA ADMINISTRATOR BEFORE HIM, HE HAS AT ONE TIME OR ANOTHER INCURRED THE RATH OF INDUSTRY AND THE ENVIRONMENTALISTS. IT COMES WITH THE TERRITORY.

BUT THAT HAS BEEN A "PIECE OF CAKE" COMPARED WITH WHAT HE FACES NOW. HIE DELAY ON THE RCRA REGULATIONS HAS ANGERED THE ENVIRONMENTALISTS.

THE ACTUAL RULES ARE SURE TO DISAPPOINT BOTH THE ENVIRONMENTALISTS AND THE INDUSTRIALISTS, WITH THE ENVIRONMENTALISTS SEEING THE RULES AS TOO NARROW AND THE INDUSTRIALISTS AS TOO BROAD.

AND THE PEOPLE LIVING AROUND THE ESTIMATED 20,000 CHEMICAL DUMPS LOCATED THROUGHOUT THIS COUNTRY MIGHT COMPLAIN THAT THE REGULATIONS ARE NEITHER TOO TOUGH OR TOO WEAK, THEY'RE TOO LATE.

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JAILED JERSEYITES HAUNTED BY WASTE

BY MICHAEL DESMOND

WILLIAM J. CARRACINO, PRESIDENT OF THE CHEMICAL CONTROL CORP. OF ELIZABETH, N.J., WILL HAVE TIME IN THE NEXT COUPLE OF YEARS TO THINK ABOUT ILEGAL DUMPING OF CHEMICAL WASTE.

ON SEPT. 8, CARRACINO WAS GIVEN A TWO- TO THREE-YEAR SENTENCE IN A NEW JERSEY STATE PRISON AFTER HE WAS CONVICTED ON A SERIES OF CHARGES INVOLVING ILLEGAL DISPOSAL OF CHEMICAL WASTES. HE ALSO WAS FINED $22,000 IN ESSEX COUNTY, N.J., SUPERIOR COURT.

HE WAS NOT ALONE. CONVICTED WITH HIM WAS A GROUP OF HIS EMPLOYEES, ON THE SAME CHARGES. ONE WAS GIVEN THE SAME JAIL SENTENCE AND FINED $20,000. ANOTHER WAS GIVEN ONE YEAR IN THE COUNTY JAIL. AN EMPLOYEE WHO TESTIFIED FOR THE PROSECUTION RECEIVED 30 DAYS IN THE COUNTY JAIL.

THE CORPORATION WAS FINED $75,000. IT HAS NEW OWNERSHIP, NEW JERSEY OFFICIALS SAID.

THE FIRM OPERATES FROM A WATERFRONT SITE IN ELIZABETH. THERE IS NO FENCE AND WASTE DRUMS ARE PILED UP RIGHT TO THE CURB LINE, A VISIT FROM THE COURIER-EXPRESS FOUND. A STENCH HANGS OVER THE AREA.

RHODE ISLAND SUIT

CHEMICAL CONTROL HAS BEEN A WELL-KNOWN PROBLEM FIRM IN THE WASTE DISPOSAL FIELD. A SUIT IS PENDING AGAINST IT IN RHODE ISLAND OVER A SITE IN SMITHFIELD, R.I., WHERE MANY DIFFERENT CHEMICALS WERE DUMPED.

THE ELIZABETH FIRM IS A SMALL ONE. BUT LARGE CORPORATIONS CAN HAVE PROBLEMS IN WASTE DISPOSAL, TOO.

THE HOOKER CHEMICALS & PLASTICS CORP. HAS RECEIVED A GREAT DEAL OF ATTENTION RECENTLY AS THE COMPANY WHICH ONCE OPERATED A DUMP SITE IN THE LOVE CANAL SECTION OF NIAGARA FALLS.

A VARIETY OF POTENTIALLY DEADLY CHEMICALS HAVE SEEPED FROM THE SITE, FORCING OFFICIALS TO DEVELOP CONTINGENCY PLANS FOR THE EVACUATION OF HUNDREDS OF FAMILIES, PERHAPS PERMANENTLY, IF NECESSARY.

BUT HOOKER ALSO IS WELL KNOWN TO OFFICIALS IN OHIO AND MICHIGAN BECAUSE OF THE DISPOSAL OF CHEMICAL WASTE FROM THE FIRM'S PLANT IN MONTAGUE, MICH.

TENNESSEE INCIDENT

STATE AND LOCAL OFFICIALS ON LONG ISLAND ARE FAMILIAR WITH THE FIRM, SINCE VINYL CHLORIDE FORMERLY MADE IN A HOOKER PLANT TURNED UP SEVERAL YEARS AGO IN WELLS AT THE GRUMMAN AEROSPACE CORP. IN BETHPAGE.

ANGLERS IN THE NIAGARA FRONTIER ARCA ARE FAMILIAR WITH HOOKER BECAUSE OF DISCHARGES OF MIREX FROM ITS NIAGARA FALLS PLANT FOUND IN FISH IN LAKE ONTARIO.

CHEMICAL WASTE DUMPS-- PAST AND PRESENT-- ARE THREATCNING THE HEALTH OF THE NATION'S MEN, WOMEN AND CHILDREN-- PRESENT AND FUTURE. THIS IS THE TENTH IN A COURIER-EXPRESS SERIES OF ARTICULES ABOUT THE INCREDIBLE SITUATION. IT DEALS WITH THE CASE HISTORIES OF SEVERAL DISPOSAL INCIDENTS.

THE LOVE CANAL SITUATION HAS MADE MANY AVERAGE CITIZENS MORE LIKELY TO SPOT SIMILAR ACTIVITIES.

BUTY IN TOONE, TENN., LAST WINTER, IT TOOK ONLY THE SUDDEN ADDITION OF COLOR TO LOCAL DRINKING WATER TO MAKE LOCAL RESIDENTS WONDER WHAT WAS GOING ON. THE WATER DEVELOPED A STRANGE ODOR, LIKE THAT OF AN INSECTICIDE, AND A RASH OF STOMACH CRAMPS AND DIZZY SPELLS HIT.

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VELSICOL CHEMICAL CORP. OF CHICAGO HAS DUMPED 350,000 55-GALLON DRUMS OF WASTE FROM ITS MEMPHIS PLANT IN A FIELD OUTSIDE TOONE. THE WASTE INCLUDED TOLUENE, HETACLOROBENZENE AND TETRACHLOROETHYLENE.

CHEMICAL GLOSSARY

CHLORDANE - A PESTICIDE WHOSE USE IS NOW BANNED.

C-56 - THE TRADE NAME OF THE HOOKER CHEMICALS & PLASTICS CORP. FOR HEXACHLOROCYCLOPENTADIENE. VERY LITTLE IS KNOWN ABOUT ITS EFFECTS ON HUMANS, BUT IN INDUSTRIAL USE VERY LOW EXPOSURE IS RECOMMENDED.

HEPTACHLOR - ANOTHER NOW BANNED PESTICIDE CLOSELY RELATED TO CHLORDANE.

KEPONE - A PESTICIDE USED AGAINST ANTS AND ROACHES. IT IS KNOWN TO CAUSE NERVE DISORDERS AND LIVER DAMAGE IN HUMANS.

MIREX - A PESTICIDE USED AGAINST FIRE ANTS. IT IS THOUGHT TO CAUSE LIVER DAMAGE AND SOME ANIMAL BIRTH DEFECTS.

PHOSVEL - A PESTICIDE WHICH CAUSES SEVERE NERVE DAMAGE TO HUMANS AND KILLS IN RELATIVELY LOW DOSES. IT WAS MADE IN THIS COUNTRY BUT WAS NEVER FORMALLY LICENSED FOR USE HERE.

TRIS-BP - A FLAME RETARDANT USED IN CHILDREN'S SLEEPWEAR. IT WAS BANNED WHEN RESEARCH INDICATED IT MAY CAUSE HUMAN CANCER AND THAT DID CAUSE GENETIC DAMAGE IN LABORATORY TESTS.

VINYL CHLORIDE - A CHEMICAL USED TO MAKE PLASTICS, ESPECIALLY POLYVINYL CHLORIDE. VINYL CHLORIDE CAN CAUSE HUMAN CANCER.

COMPANY DENIAL

BUT THE COMPANY DENIES THAT, JUST BECAUSE MANY OF THE SAME CHEMICALS ARE IN THE WATERAND IN THE WELLS, THE TWO ARE CONNECTED.

"WE DON'T BELIEVE THERE IS ANY EVIDENCE OR REASON TO BELIEVE UP TO THIS TIME THAT ANY UNDERGROUND CONTAMINATION COULD HAVE TAKEN PLACE," ACCORDING TO RICHARD BLEWITT, VELSICOL DIRECTOR OF PUBLIC AFFAIRS.

"ONE OR MORE CHEMICALS FOUND IN THOSE WELLS COULD NOT HAVE COME FROM OUR FORMER SITE," HE TOLD THE COURIER-EXPRESS.

THE FIRM OPERATED THE SITE FROM 1965 TO 1972.

VELSICOL AND TENNESEE ARE NOW DOING A STUDY TO TRY TO DETERMINE EXACTLY WHAT DID HAPPEN IN THAT RURAL AREA OF SOUTHWEST TENNESEE.

THE INDUSTRY JOURNAL "CHEMICAL WEEK" SAID IN ITS AUG. 23 ISSUE OF COMPANY DIFFICULTY:

"NO CHEMICAL COMPANY HAS PROBABLY FACED A GREATER ONE: SURVIVAL AFTER A SERIES OF ENVIRONMENTAL CALAMITIES ANDPERHAPS JUST PLAIN BAD LUCK. FOR AFTER A RELATIVELY UNEVENTFUL FIRST 40 YEARS OR SO OF EXISTENCE, VELSICOL IN THE PAST FOUR YEARS HAS SHOT INTO PROMINENCE AS AN 'ENVIRONMENTAL BAD GUY,' THE BUTT OF SNIDE REMARKS EVEN WITHIN THE INDUSTRY."

SEWAGE PLANT

IN ADDITION TO TOONE, TENN., THE COMPANY IS KNOWN FOR ITS MANUFACTURE OF THE PESTICIDE PHOSVEL WHICH ALLEGEDLY CAUSED NERVE DAMAGE IN PRODUCTION WORKERS; ITS MANUFACTURE OF THE NOW BANNED PESTICIDES CHLORDANE AND HEPTACHLOR; MANUFACTURER OF THE FIRE RETARDANT TRIS-- INVESTIGATED AS A SUSPECTED CAUSE OF CANCER-- USED IN CHILDREN'S SLEEPWEAR, AND AN INCIDENT OF ALLEGEDLY ILLEGAL WASTE DUMPING.

ON MARCH 29, 1977, A TOTAL OF 35 EMPLOYEES OF THE MORRIS FORMAN SEWAGE TREATMENT PLANT IN LOUISVILLE, KY., WERE TAKEN TO A HOSPITAL FOR CARE OF BLISTERS, SORE THROATS AND CHEST PAINS.

FOR THE NEXT TWO MONTHS, 100 MILLION GALLONS OF SEWAGE PER DAY WAS DIVERTED STRAIGHT INTO THE OHIO RIVER. THE PLANT AND SEWER LINES WERE FOUND TO BE CONTAMINATED WITH THREE HIGHLY TOXIC CHEMICALS USED TO MAKE PESTICIDES.

EVENTUALLY, INVESTIGATORS CLAIMED TO HAVE TRACKED THE MATERIAL BACK TO VELSICOL. THE CHICAGO CHEMICAL FIRM HAD HIRED A COMPANY TO DISPOSE OF WASTE. THE FIRST FIRM HIRED A SECOND FIRM. THE PRESIDENT, SECRETARY-TREASURER AND AN EMPLOYEE OF THE SECOND FIRM WERE SUBSEQUENTLY INDICTED, CHARGED WITH DUMPING THE WASTES INTO A SEWER IN AN ABANDONED LOT.

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POINTS TO FBI VERDICT

VELSICOL CLAIMS AN INVESTIGATION BY THE FBI FOUND THE FIRM "DID NOT ACT NEGLIGENTLY."

BRUCE DAVIS, EXECUTIVE VICE PRESIDENT FOR THE INDUSTRIAL CHEMICALS GROUP OF HOOKER, MADE A SIMILAR CLAIM-- THAT A REPUTABLE COMPANY WAS HIRED TO DISPOSE OF WASTE-- TO THE COURIER EXPRESS IN TWO SEPARATE INCIDENTS INVOLVING THE MONTAGUE, MICH., PLANT.

IN ONE CASE, DAVIS SAILD HE WAS UNAWARE OF THE FACTS UNTIL THEY WERE POINTED OUT TO HIM BY THE COURIER-EXPRESS.

HE WAS ASKED ABOUT 6,500 GALLONS OF A CHEMICAL KNOWN AS C-56, USED TO MAKE PESTICIDES, WHICH WERE SITTING IN A DECREPIT SUMMIT NATIONAL SERVICES CHEMICAL TREATMENT SITE OUTSIDE AKRON, OHIO. DAVIS INITIALLY DENIED THE CHEMICALS IN A TANK TRUCK AND A STANDING TANK WERE FROM HOOKER.

SEVERAL HOURS LATER, HE CALLED BACK TO ADMIT THE MATERIALS WERE FROM HOOKER. HE SAID LOWER-LEVEL COMPANY OFFICIALS WERE AWARE OF THE MATERIAL AND HAD PICUTRES OF THE MESSY SITE.

MICHIGAN'S VIEW

ON FRIDAY, DAVIS SAID THE MATERIAL WAS STILL IN THE OHIO FIELD. IF MICHIGAN OFFICIALS HAVE THEIR WAY, IT WON'T COME BACK TO THEIR STATE. IT HAS BEEN IN OHIO FOR NEARLY TWO YEARS.

ON MARCH 11, 1977, JACK D. BAILS, CHIEF OF THE OFFICE OF PROGRAM REVIEW AND PROJECT CLEARANCE FOR THE MICIGAN DEPARTMENT OF NATURAL RESOURCES (DNR), REPORTED ON SUMMIT NATIONAL SERVICES TO HOWARD A. TANNER. DNR DIRECTOR. HE REPORTED ON A MEETING WITH SUMMIT OWNER DON GEORGEOFF:

"YOU WILL NOTE ON PAGE 2 OF THE MEETING NOTES THAT THE OWNER OF THE FACILITY, MR. GEORGEOFF, PROPOSES TO DIVERT OTHER WASTE SOURCES TO MICHIGAN WHILE HE REBUILDS HIS INCINERATOR. AT THIS POINT, I THINK A LETTER FROM THE ATTORNEY GENERAL INDICATING THAT NO SUCH WASTES WILL BE ALLOWED BACK INTO MICHIGAN WITHOUT AN APPROVE PLAN AND DISPOSAL LOCATION."

'WE WILL GET IT OUT'

DAVIS LATER COMMENTED TO THE COURIER-EXPRESS, "I DON'T KNOW HOW THE HELL WE'RE GOING TO GET IT OUT. BUT, WE WILL. FROM A LEGAL POINT OF VIEW, WE DON'T KNOW IF WE HAVE ANY RESPONSIBILITY. BUT, WE WILL GET IT OUT."

HOOKER AND MICHIGAN WERE INVOLVED IN AN EARLIER BATTLE OVER WASTE FROM MONTAGUE. IN THE SUMMER OF 1976, APPROVED INDUSTRIAL REMOVAL WAS HIRED BY HOOKER TO TAKE AWAY WASTE FROM THE MICHIGAN PLANT.

HOOKER SAID IT WAS TOLD BY THE HAULER THE WASTE WAS GOING TO A SPECIAL DISPOSAL SITE NEAR DETROIT.

INSTEAD, THE HAULER BURIED A 10,000-GALLON TANK IN A GARBAGC DUMP IN CENTRAL MICHIGAN. ABOUT 5,000 GALLONS OF C-56 WAS PUT INTO THE TANK. LATER, 3,000 GALLONS OF C-56 WAS PUT INTO ANOTHER BURIED 5,500-GALLON TANK.

SOMEONE BLEW THE WHISTLE ON THE SITUATION. THE STATE OBTAINED A COURT ORDER AND DUG UP THE WASTE SITE. THE TANKS WERE FOUND AND DUG UP. THE C-56 WAS SENT BACK TO HOOKER AND, ULTIMATELY, SENT TO AN INCINERATOR IN EL DORADO, ARK., FOR BURNING.

SOME C-56 IS REPORTED "MIGRATING" IN UNDERGROUND WATER FROM THE

MONTAGUE PLANT TOWARD WHITE LAKE, A DRINKING WATER SOURCE THERE. OTHER CHEMICALS ALLEGEDLY HAVE BEEN FOUND IN NEARBY WELLS.

THE STATE OF NEW JERSEY HAS A SERIOUS CHEMICAL WASTE PROBLEM. IT IS SO SERIOUS THAT ILLEGAL DUMPING IS A FORMAL SUBJECT OF INVESTIGATION OF THE WHITE COLLAR CRIME UNIT OF THE STATE DEPARTMENT OF LAW AND PUBLIC SAFETY.

DEPUTY ATTORNEY GENERAL ROBERT FORD TOLD THE COURIER-EXPRESS HE HAS A GRAND JURY LOOKING INTO THE WHOLE PROBLEM OF WASTE DISPOSAL AND "MIDNIGHT DUMPING."

HE ADDED, "WE'RE ACTUALLY SURVEILLING THE INDUSTRY."

IT WAS THE WORK OF THE WHITE COLLAR CRIME UNIT WHICH LED TO THE INDICTMENTS OF THE CHEMICAL CONTROL FOURSOME.

THE FOUR WERE ACCUSED OF EMPTYING A TANK TRUCK CONTAINING CHEMICAL WASTES INTO ELIZABETH CREEK AND INTO A SEWER WHICH LEADS INTO NEWARK BAY; DUMPING DRUMS OF CHEMICAL WASTE AT VARIOUS LOCATIONS, AND DIGGING PITS WITH A BULLDOZER, FILLING THEM WITH DRY GARBAGE, SATURATING THE GARBAGE WITH CHEMICAL WASTE AND HAULING THE CONTAMINATED GARBAGE TO LANDFILLS INTENDED FOR MUNICIPAL REFUSE.

ROBERT T. WINTER IS CHIEF OF THE ENFORCEMENT BUREAU IN THE DIVISION OF CRIMINAL JUSTICE OF THE NEW JERSEY DEPARTMENT OF LAW AND PUBLIC SAFETY. HE ADMITS IT'S NOT AN EASY AREA TO INVESTIGATE. WINTER NOTED TO A REPORTER:

"THEY MAKE A QUICK DUMP AND THEY'RE GONE."

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WASTE HANDLING SOLUTIONS CAN'T WAIT

SINCE HAZARDOUS WASTE ISN'T GOING TO GO AWAY OR STOP COMING SOMETHING HAS TO BE DONE, AND DONE QUICKLY, BEFORE IT BURIES EVERY CITIZEN.

THAT MAY SEEM OBVIOUS TO SOME, BUT IT IS APPARENTLY NOT OBVIOUS TO A WIDE ARRAY OF BUREAUCRATS IN VARIOUS LEVELS OF GOVERNMENT.

FOR EXAMPLE, THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) IS STILL DAWDLING ON THE RULES WHICH SHOULD TURN THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA) INTO SOMETHING MORE THAN A DEAD LETTER.

THE FEDERAL COMMERCE DEPARTMENT HAS THE LEGAL RESPONSIBILITY TO STUDY RECYCLING OF WASTES TO RE-USE THEM. IT HAS NO MONEY FOR STUDIES.

SMALL STAFF, BIG PROBLEM

CALIFORNIA HAS ONE PERSON ASSIGNED TO TRY TO FIND COMPANIES WHICH CAN USE WASTE FROM OTHER COMPANIES. THE GOLDEN STATE PRODUCES AN ESTIMATED 10 PERCENT OF THE NATIONAL ANNUAL TOTAL OF HAZARDOUS WASTE. EPA ESTIMATES THE NATIONAL TOTAL AT 92 BILLION POUNDS.

THE FEDERAL MARITIME COMMISSION IS PAYING FOR A STUDY OF SENDING WASTE OUT TO SEA TO BE BURNED IN A SPECIAL INCINERATOR SHIP. THE COURIER-EXPRESS WAS PRESENT ON WEDNESDAY WHEN STEFFEN W. PLEHN, EPA DEPUTY ASSISTANT ADMINISTRATORY FOR SOLID WASTE, LEARNED OF THE PROJECT FOR THE FIRST TIME.

EPA IS NOW PLANNING TO LLOK FOR FORMER WASTE DUMP SITES TO SEE WHAT IS IN THEM. THOSE PLANS WERE NOT ANNOUNCED UNTIL THURSDAY.

COURIER-EXPRESS REPORTER MICHAEL DESMOND TRAVELED 11,670 MILES AROUND THE NATION GATHERING MATERIAL FOR A SERIES OF ARTICLES ON THE HEALTH AND SAFETY THREAT POSED BY THE MISHANDLING OF TOXIC CHEMICAL WASTES. THIS IS THE 11TH AND FINAL INSTALLMENT. IT DEALS WITH WAYS IN WHICH THE HUGE CHEMICAL PROBLEM MAY BE SOLVED.

NEW YORK: HISTORY OF CALAMITIES

NEW YORK STATE HAS A HISTORY OF CHEMICAL WASTE CALAMITIES. IT HAS NO RECORD OF WHERE MANY WASTE DUMPS ARE. BUT IT IS DOING A SURVEY TO DETERMINE WHERE PRESENT SITES MIGHT BECOME FUTURE DISASTERS.

CONGRESS MUST BEAR STRONG CRITICISM BECAUSE IT HAS DONE ESSENTIALLY NOTHING TO FORCE EPA TO MEET THE MANDATES CONGRESS WROTE INTO RCRA. IT HAS ALSO PROVIDED VERY LITTLE MONEY FOR RESEARCH INTO NEWER AND BETTER METHODS FOR HANDLING WASTE.

WHILE ALL OF THIS HAS BEEN GOING ON, THE TAXPAYERS ARE BEING HIT FOR MASSIVE CLEANUP BILLS. A RECENT MICHIGAN STUDY INDICATES IT WILL COST STATE TAXPAYERS THERE $100 MILLION TO CLEAN UP A STRING OF ENVIRONMENTAL DISASTERS.

INDUSTRY AVOIDS COURT PRECEDENT

ONE ATTEMPT TO DETERMINE WHO SHOULD PAY FOR THE CLEANUP IN MICHIGAN FELL THROUGH WHEN A GROUP OF MAJOR INDUSTRIES PICKED UP THE CLEANUP COST IN ONE SITE RATHER THAN ALLOW A COURT TO SET A PRECEDENT BY DECIDING WHO SHOULD PAY.

IN GENERAL, THE SITUATION IS A LITTLE LIKE THE OLD JOKE ABOUT HAVING TO HIT THE MULE OVER THE HEAD WITH A TWO-BY-FOUR TO GAIN HIS ATTENTION. PERHAPS IF SOME OF THE BUREAUCRATS WANDERING THROUGH THE PROBLEM WERE FORCED TO LIVE ALONG THE LOVE CANAL IN NIAGARA FALLS OR DRINK FROM WELLS IN TOONE, TENN., OR LIVE DOWNWIND FROM THE SILRESIM CORP. IN LOWELL, MASS., THEY MIGHT DO SOMETHING.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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DRAWING OMITTED

THREE URGENT AREAS

THERE ARE THREE DISTINCT AREAS OF ACTIVITY WHICH HAVE TO BE UNDERTAKEN. THEY ARE:

1. COMPLETION OF RULES FOR THE ENTIRE WASTE DISPOSAL INDUSTRY.

2. LARGE AMOUNTS OF RESEARCH INTO RE-USING WASTE.

3. RESEARCH TO CHANGE PRODUCTION METHODS AND CUT DOWN THE AMOUNT OF WASTE.

FINDING PAST DUMP SITES IS INTERWOVEN WITH ALL THREE.

THE BASIC MISSING INGREDIENT IN THE WHOLE SITUATION IS ANY SENSE OF URGENCY. LIFE IN WASHINGTON, D.C., MOVES ALONG AT A STEADY, EVEN PACE, UNDISTRACTED BY ANY OF THE HARSHER REALITIES OF LIFE.

INSULARITY IN WASHINGTON

HIGH EPA OFFICIALS DON'T WORRY ABOUT WHAT IS GOING ON OUTSIDE OF WASHINGTON. IT IS THE LOWER LEVEL BUREAUCRATS WHO HAVE TO GO OUT AND ACTUALLY DEAL WITH THE SITUATIONS. IT IS AN ECKHARDT BECK (EPA REGION 2 CHIEF IN NEW YORK CITY) PERSONALLY GOING AROUND WASHINGTON TO GET ACTION ON THE LOVE CANAL DISASTER IN NIAGARA FALLS, OR A JAMES STAHLER (EPA ENVIRONMENTAL ENGINEER IN SAN FRANCISCO) HELPING CALIFORNIA PUT TOGETHER A GOOD HAZARDOUS WASTE PROGRAM AND THEN HELPING TO SEEL THE SAME PROGRAM TO OTHER STATES.

THERE ISN'T A LOT OF THAT.

INSTEAD, THERE IS PLEHN, WHO ADMITS THAT NO MATTER WHAT THE RCRA

RULES ARE, THE EPA WILL BE SUED BY SOMEONE. BUT THE AGENCY IS

RACING THROUGH THE RULES PROCESS LIKE A SNAIL.

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RULES DELAY INCREASES DANGERS

EVERY DAY THAT THE RULES ARE DELAYED-- THEY WERE DUE APRIL 21-- BAD DUMPS AROUND THE COUNTRY ARE FILLING UP AND POSING A FUTURE THREAT. EPA CAN DO NOTHING UNTIL THE RULES ARE COMPLETED. SO THE FEDERAL GOVERNMENT AND MANY STATE GOVERNMENTS ARE DOING NOTHING ABOUT DUMPS THAT ARE BEING CLOSED, IN THE ABSENCE OF RULES.

IN TRYING TO CONTROL THE SITUATION, GOVERNMENT OFFICIALS MUST WATCH FOR A DIFFERENT APPROACH FROM INDUSTRY. BASED ON PAST EXAMPLES, SOME COMPANIES MAY JUST TRANSFER THE MANUFACTURE OF CHEMICALS OVERSEAS, LEAVING THE WASTE OVERSEAS, ALSO.

MANY COUNTRIES HAVE NO ENVIRONMENTAL PROTECTION RULES AT ALL.

OBVIOUSLY, MOVING THE PRODUCTION OVERSEAS MIGHT EASE THE WASTE PROBLEM IN THIS COUNTRY. IT WOULD STILL NOT END WASTE AS A PROBLEM TO HUMAN BEINGS, BUT SIMPLY SHIFT IT.

PUBLIC DECISIONS NEEDED

THE PUBLIC IS ALSO GOING TO HAVE TO MAKE SOME DECISIONS. IF SOME OF THE CHEMICALS AND CHEMICAL PRODUCTS ARE GOING TO CONTINUE IN USE, IT IS GOING TO COST.

EPA'S PLEHN THREW OUT AN INTERESTING FIGURE IN AN INTERVIEW WITH THE COURIER-EXPRESS THE OTHER DAY. HE ESTIMATED IT MIGHT COST $600 MILLION TO $800 MILLION A YEAR TO MEET THE EVENTUAL RCRA REQUIREMENTS, WHEN THEY TAKE EFFECT. THAT IS A SUBSTANTIAL AMOUNT OF MONEY, BUT ONLY $3 TO $4 A YEAR FOR EACH CITIZEN.

HE POINTED OUT THE COST ITSELF MAY BRING ABOUT CHANGES. EPA HAS STUDIED THE SITUATION IN WEST GERMANY, WHERE CHEMICAL COMPANIES AND OTHER HAZARDOUS WASTE MAKERS ARENOW REQUIRED TO PAY THE FULL COST OF GETTING RID OF THE WASTE. SO THE CONSUMERS FOOT THE BILL.

UNDER THE LONG-DELAYED RCRA, THAT SYSTEM WOULD BE INSTITUTED IN THE U.S.

INDUSTRY'S BURDEN EYED

"THE VOLUME OF WASTE WILL BE LESS. THE AMOUNT OF WASTE WILL BE LESS WHEN THIS PROGRAM IS IN FULL OPERATION," PLEHN SAID.

THE CURRENT TARGET DATE FOR COMPLETION OF RCRA REGULATIONS IS JANUARY 1980. BUT ENVIRONMENTALISTS PREDICT EPA WILL NOT MEET THAT DATE.

WITHOUT A BLUDGEONING OF EPA BY CONGRESS OR THE PUBLIC, THE AGENCY WILL CONTINUE ON ITS LEISURELY WAY. CONGRESS REQUIRED EPA TO COME UP WITH THE RCRA REGULATIONS WITHIN 18 MONTHS OF ENACTMENT, WHICH WAS IN 1976. SO EPA WILL BE 21 MONTHS LATE-- IF IT STICKS TO ITS OWN SCHEDULE.

INDUSTRY IS ALREADY MOVING IN THE AREA OF CUTTING DOWN WASTE. FOR EXAMPLE, THE HOOKER CHEMICALS & PLASTICS CORP. HAS SPENT $10 MILLION IN ITS NIAGARA FALLS PLANT ON TWO OF ITS MANUFACTURING OPERATIONS. ONE CHANGE CUT OUT WASTE PRODUCTS COMPLETELY. THE OTHER CUTS THE WASTE PRODUCTION DRASTICALLY.

WASTE CAN'T BE HIDDEN

JOE LOUIS ONCE TALKED OF THE BOXING RING AS A PLACE WHERE YOU CAN RUN, BUT CAN'T HIDE. THIS IS TRUE OF HAZARDOUS WASTE. AS HAS SO OFTEN BEEN HORRIBLY PROVEN, IT'S EVERYWHERE.

THE PUBLIC HAS A STAKE IN THE SITUATION. THAT IS TRUE FOR THE CAPTAINS OF INDUSTRY AS WELL AS THE AVERAGE CITIZEN. SOMETIMES IT SEEMS AS IF EVERY DAY BRINGS ANOTHER REPORT OF THE BAD EFFECTS OF ANOTHER CHEMICAL IN ANOTHER LOCALE.

TODAY, THE NATIONAL CANCER INSTITUTE WILL RELEASE A REPORT ON THE WIDELY USED CHEMICAL ETHYLENE DICHLORIDE (EDC). THE STUDY INDICATES THE CHEMICAL CAUSES A WIDE VARIETY OF CANCER IN LABORATORY ANIMALS. THE CHEMICAL IS USED TO MAKE VINYL CHLORIDE, WHICH CAUSES CANCER IN HUMANS.

HAZARDOUS CHEMICAL ADDED TO FOOD

THE CHEMICAL IS WIDELY USED FOR EVERTHING FROM MAKING OTHER TOXIC CHEMICALS TO PRODUCING SPICES. IN A RELEASE, THE INSTITUTE NOTED, "EDC MAY APPEAR AS A FOOD ADDITIVE AS A RESULT OF ITS USE TO EXTRACT SPICES SUCH AS ANNATTO, PAPRIKA AND TUMERIC." BOTH ANNATTO AND TUMERIC ARE USED TO COLOR FOOD.

LONG-TERM DANGERS POSED

A 1974 STUDY ESTIMATED 163 MILLION POUNDS OF THE CHEMICAL WERE LOST INTO THE ENVIRONMENT IN 1974 AND THAT USE IS GROWING. IN AN EPA STUDY OF SURFACE WATER IN INDUSTRILIZED AREAS, THE CHEMICAL WAS FOUND IN 26 PERCENT OF THE WASTE SAMPLES.

THE CHEMICAL ALSO CAUSES PHYSICAL AILMENTS OF OTHER KINDS, ESPECIALLY BLOOD DISORDERS, AND LARGE DOSES ARE DEADLY.

THE PUBLIC MUST DEVELOP AN AWARENESS OF THE LONG-TERM DANGERS. THE LOVE CANAL DUMP HAD BEEN CLOSED FOR LESS THAN A QUARTER OF A CENTURY WHEN IT FAILED TO CONTAIN WASTES. WHETHER NEWER AND BETTER DESIGNED BURIAL SITES WILL BE MORE EFFECTIVE, ONLY TIME CAN TELL. A "SAFE" SITE TODAY COULD BE THE NEXT GENERATION'S LOVE CANAL.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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BOTH IN THE LONG RUN AND THE SHORT RUN, BETTER CONTROLS ON WASTE DISPOSAL ARE NO SUBSTITUTE FOR NOT HAVING AS MUCH WASTE TO DISPOSE OF.

BUT THERE ARE PROBLEMS. RICHARD HERBST IS A LAWYER AND MECHANICAL ENGINEER WHO IS A SENIOR POLICY ADVISER IN THE U.S. COMMERCE DEPARTMENT. ASKED WHAT THAT DEPARTMENT WAS DOING IN THE CHEMICAL WASTE FIELD, HE SAID, "TO BE QUITE FRANK, WE WERE NOT GIVEN APPROPRIATIONS UNDER THE LAW TO UNDERTAKE THE SORT OF PROGRAM WE SHOULD HAVE."

PAPER FLOWS, MONEY TRICKLES

ANOTHER COMMERCE DEPARTMENT OFFICIAL COMMENTED, "THERE'S A CONSTANT FLOW OF PAPER FROM EPA AND OTHERS IN RESOURCE CONSERVATION." HE ADDED, "THERE'S NEVER BEEN A PENNY APPROPRIATED FOR THE DEPARTMENT OF COMMERCE TO CARRY OUT THIS ACT (RCRA)."

THE METALLURGY RESEARCH CENTER OF THE FEDERAL BUREAU OF MINES IS DOING SOME RESEARCH IN THE FIELD OF TOXIC WASTES, ESPECIALLY WITH SLUDGES CONTAINING SOME METAL.

BUT, BASICALLY LITTLE IS BEING DONE BY EITHER GOVERNMENT OR THE PRIVATE SECTOR ABOUT HAZARDOUS WASTES.

FROM HIS FIELD PERSPECTIVE, STAHLER COMMENTED, "WE THINK THERE SHOULD BE TAX DISINCENTIVES OR EVEN TAX INCENTIVES." THAT IS, TOXIC WASTE PRODUCERS SHOULD BE PUNISHED OR REWARDED FOR INACTION OR ACTION.

OREGON HAS A SOMEWHAT DIFFERENT APPROACH. ITS POLICY IS THAT IF A MATERIAL CAN BE RECYCLED, IT MUST NOT BE THROWN AWAY.

OCCASIONALLY, PLEHN CAN CUT TO THE HEART OF THE ISSUE. HE TOLD THE COURIER-EXPRESS:

"THE PROBLEM DOES NOT GO AWAY. TO THE EXTENT THAT WASTES ARE NOT PROPERLY HANDLED OR DISPOSED, THEY TEND TO COME BACK AND LAY THEMSELVES AT YOUR FEET. THAT'S ONE OF THE GRISLY FACTS."

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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'SILENT (TILL) SPRING' ON WASTE?

WITH THE FEDERAL ENVIRONMENTAL PROTECTION AGENCY (EPA) DRAGGING ITS FEET IN DEALING WITH THE GARGANTUAN PROBLEM OF HAZARDOUS CHEMICAL WASTES, MUST CONGRESS DO THE SAME?

REP. FRED B. ROONEY, D-PA., WHOSE SUBCOMMITTEE ON ENVIRONMENT AND THE ATMOSPHERE HAD SCHEDULED HEARINGS ON THE WASTE PROBLEMS IN JUNE-- THEY WERE NEVER HELD-- NOW SAYS THAT HE WILL NOT HOLD HEARINGS UNTIL NEXT SPRING ON WHY THE EPA HAS NOT PUT THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) OF 1976 INTO EFFECT AND ALSO ON THE PROBLEM OF HANDLING WASTES ALREADY IN THE GROUND. (THE EPA, WHICH WAS SUPPOSED TO COME UP WITH IMPLEMENTING REGULATIONS BY LAST APRIL 21, NOW SAYS THAT THE RULES WON'T BE READY UNTIL JANUARY, 1980.)

WHY SHOULD A CONCERNED PUBLIC HAVE TO WAIT FOR HEARINGS UNTIL THE SPRING? BOTH HOUSES ARE MOVING TOWARD ADJOURNMENT AND THE NOVEMBER ELECTIONS. BUT SURELY A START COULD BE MADE ON THE HEARINGS IMMEDIATELY AFTER THE ELECTIONS ARE OVER. WITH A NATIONAL WASTE PROBLEM AS ALARMING AS THAT DISCLOSED IN THE RECENT SERIES OF ARTICLES IN THE COURIER-EXPRESS, THERE IS ABSOLUTELY NO EXCUSE FOR UNTOWARD DELAY. WE HOPE THE WESTERN NEW YORK CONGRESSIONAL DELEGATION, WHICH HAS AN ACUTE PROBLEM IN ITS OWN BACKYARD, WILL PUSH FOR PROMPT HEARINGS. REP. HENRY J. NOWA-, D-BUFFALO, HAS ALREADY REQUESTED THE HOUSE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATION TO SCHEDULE HEARINGS AS SOON AS POSSIBLE.

MEANWHILE, ONLY NOW IS THE EPA MOVING TO ACQUIRE AN INVENTORY OF THE MOST DANGEROUS WASTE DUMPS (AN AGENCY OFFICIAL HAS LABELED 300 SITES AS BEING IMMEDIATE HEALTH AND SAFETY HAZARDS, BUT THERE ARE SAID TO BE 20,000 INACTIVE, HAZARDOUS DUMPS THROUGHOUT THE COUNTRY). ONLY 10 REGIONAL STAFF MEMBERS ARE WORKING ON THE INVENTORY, WHICH IS EXPECTED TO TAKE UP TO 30 DAYS. WE FIND IT INCOMPREHENSIBLE THAT OF MORE THAN 11,000 EPA EMPLOYES, ONLY ABOUT 160 ARE ASSIGNED TO THE SOLID-WASTE PROBLEM. THIS SITUATION LENDS FURTHER SUPPORT TO THE NEED FOR ACCELERATING THE PACE OF THE INVESTIGATION.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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HOUSE PANEL SCHEDULES EPA HEARING UNIT TO EYE RULES DELAY ON WASTES NOWAK BID RESULTS IN OCT. 25 SESSION

BY DAVID E. LYNCH

WASHINGTON-- A HOUSE SUBCOMMITTEE ON FRIDAY ANNOUNCED THAT IT WILL HOLD A HEARING OCT. 25 ON THE ENVIRONMENTAL PROTECTION AGENCY'S FAILURE TO ISSUE REGULATIONS TO CONTROL THE DISPOSAL OF HAZARDOUS WASTES.

AS REQUESTED BY REP. HENRY J. NOWAK, D-BUFFALO, THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS WILL ALSO LOOK INTO THE POSSIBLE NEED FOR LEGISLATION TO DEAL WITH SOME 300 INACTIVE DISPOSAL SITES THAT THE EPA SAYS ARE IMMEDIATE HEALTH HAZARDS.

THE SUBCOMMITTEE IS THE CHIEF OVERSIGHT PANEL IN THE HOUSE, WITH THE MAIN FUNCTION OF INVESTIGATING THE ENFORCEMENT OF CONGRESSIONAL ACTS.

CITES GROWING CONCERN

"THE DECISION TO CONDUCT THIS HEARING SIGNALS THE GROWING CONCERN IN CONGRESS AND IN THE NATION ABOUT THE GRAVITY OF THE PROBLEM CONFRONTING US AND THE NEED TO BEGIN AN ACCELERATED EFFORT TO DEVELOP A MORE COMPREHENSIVE SOLUTION," NOWAK SAID.

THE CONGRESSMAN ALSO SAID "THE COURIER-EXPRESS AND REPORTER MIKE DESMOND ARE TO BE COMMENDED FOR THE PUBLIC SERVICE FUNCTION THEY PERFORMED IN THE PRESENTATION OF THE SERIES OF ARTICLES THAT HAS FOCUSED INTENSE ATTENTION ON THE DEPTH AND BREDTH OF THE HAZARDOUS WASTE DISPOSAL PROBLEM."

STAFF REPORTER DESMOND TRAVELED 11,870 MILES THROUGHOUT THE COUNTRY COLLECTING DATA ON HAZARDOUS WASTE PROBLEMS IN PREPARATION FOR AN 11-PART SERIES THAT CONCLUDED IN THE COURIER-EXPRESS TUESDAY.

THE SUBCOMMITTEE WILL TRY TO FIND OUT WHY THE EPA IS MORE THAN FIVE MONTHS LATE IN ISSUING REGULATIONS NECESSARY TO IMPLEMENT THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) OF 1976. THE ACT WOULD PROVIDE "CRADLE TO GRAVE" CONTROL OVER AND PROTECTION FROM HAZARDOUS WASTES.

REGULATIONS DELAYED

AND THE EPA NOW SAYS THESE REGULATIONS, WHICH WERE DUE APRIL 21, WILL NOT BE READY UNTIL JANUARY OF 1980.

THE SUBCOMMITTEE WILL ALSO TRY TO FIND OUT WHETHER LEGISLATION IS NECESSARY TO TAKE CARE OF THE RETROACTIVE ASPECT OF HAZARDOUS WASTE. RCRA IS SUPPOSED TO PREVENT FURTHER CHEMICAL CONTAMINATIONS ARISING FROM INADEQUATE DISPOSAL OF HAZARDOUS SUBSTANCES.

BUT THE EPA SAYS THERE IS NO LAW THAT NOW GIVES THE AGENCY THE

AUTHORITY TO DEAL WITH THE 100 TO 300 ABANDONED DISPOSAL SITES

THAT PRESENT AN IMMEDIATE HEALTH HAZARD.

THE AGENCY ESTIMATES THAT IT WILL COST $1.5 BILLION TO DEAL WITH THOSE 300 SITES ALONE, AND THAT MONEY IS NOT AVAILABLE. FURTHER EPA ESTIMATED THERE ARE A TOTAL OF 20,000 CHEMICAL DUMPS IN THE U.S.

NOWAK, WHO FIRST ASKED FOR THE HEARING LAST FRIDAY, SAID SUBCOMMITTEE CHAIRMAN JOHN E. MOSS, D-CALIF., WILL NOT BE ABLE TO CONDUCT THE HEARING BECAUSE OF A SCHEDULEING CONFLICT.

REP. GORE IN CHARGE

REP. ALBERT GORE JR., D-TENN., WILL CHAIR THE HEARING.

THE SUBCOMMITTEE IS WORKING ON A WITNESS LIST. NOWAK SAID HE EXPECTS THE FIRST WITNESSES TO BE EPA OFFICIALS CHARGED WITH ADMINISTERING THIS PROGRAM.

"IT IS OUR HOPE THAT AS A RESULT OF THIS HEARING, THE CONGRESS CAN REAFFIRM ITS URGENT INTENT THAT EPA MOVE A GREAT DEAL MORE EXPEDITIOUSLY IN IMPLEMENTING THIS VITAL PROGRAM OF CONTROLLING THE HAPHAZARD DISPOSAL OF TOXIC WASTES," NOWAK SAID.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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MR. GORE. THANK YOU, MR. NOWAK.

THIS HEARING WOULD NOT BE TAKING PLACE BUT FOR THE EFFORTS OF YOU TWO. YOU MENTIONED IT TO ME PERSONALLY, AND I READ THE EXCELLENT SERIES OF ARTICLES YOU REFERRED TO WHEN THEY WERE PLACED IN THE CONGRESSIONAL RECORD BY JOHN LAFALCE, AND OUR NEXT WITNESS IS THE HONORABLE JOHN LAFALCE.

STATEMENT OF HON. JOHN J. LAFALCE, A REPRESENTATIVE IN GONGRESS FROM THESTATE OF NEW YORK

MR. LAFALCE. THANK YOU VERY MUCH, MR. CHAIRMAN AND MR. WAXMAN.

AS THE CONGRESSMAN FOR THE LOVE CANAL AREA, I HAVE BEEN LIVING WITH THIS PROBLEM ON A DAILY BASIS SINCE IT FIRST CAME TO MY ATTENTION IN 1976-77. THIS TESTIMONY TODAY ON THE PROGRESS THAT THE FEDERAL GOVERNMENT HAS MADE IN THE IMPLEMENTATION OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 IS EXTREMELY EMPORTANT.

ON AUGUST 2, 1978, THE ATTENTION OF THE WORLD CAME TO THE LOVE CANAL AREA OF NIAGARA FALLS, ATTENTION WHICH WAS ONLY PREVIOUSLY GIVEN BY A TREMENDOUS SERIES OF ARTICLES IN THE NIAGARA GAZETTE OVER THE PREVIOUS YEAR AND THEN FOLLOWED UP VERY, VERY WELL BY THE BUFFALO COURIER-EXPRESS AND BUFFALO EVENING NEWS.

BUT ON AUGUST 2, 1978, WHEN THE NEW YORK STATE COMMISSIONER OF HEALTH ADVISED PREGNANT WOMEN AND CHILDREN UNDER THE AGE OF 2 TO EVACUATE THE LOVE CANAL AREA OF NIAGARA FALLS, THE WORLD BEGAN TO PAY ATTENTION TO THE SERIOUS PROBLEM POSED BY HAZARDOUS TOXIC SUBSTANCES.

EVENTUALLY OVER 230 FAMILIES MOVED FROM THE AREA. THEIR HOMES WERE BEING POLLUTED BY TOXIC CHEMICALS SEEPING FROM THE GROUND FROM AN ABANDONED CANAL WHICH HAD BEEN USED AS A HAZARDOUS WASTE LANDFILL SITE; 82 CHEMICALS, SOME OF WHICH ARE SUSPECTED CARCINOGENS, HAVE BEEN DETECTED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY TO BE IN THE AMBIENT AIR IN THE CANAL AREA.

THIS TERRIBLE TRAGEDY, CAUSED BY TOXIC WASTES HAVING BEEN INDISCRIMINATELY BURIED IN THE CANAL OVER 25 YEARS AGO, HAS BEEN REFERRED TO AS JUST ONE OF THE MANY-- PERHAPS THOUSANDS-- TICKING BOMBS, JUST ONE OF THE ABANDONED LANDFILL SITES AROUND THE COUNTRY.

LET ME FIRST DISCUSS RCRA. CONGRESS, WHEN IT PASSED RCRA IN 1976, HOPED TO PREVENT SUCH INCIDENTS BY PROVIDING FOR A HAZARDOUS WASTE REGULATORY PROGRAM; A PROGRAM TO ELIMINATE OPEN DUMPING, A PROGRAM FOR FINANCIAL AND TECHNICAL ASSISTANCE FOR PLANNING ENHANCED SOLID WASTE MANAGEMENT PROGRAMS; A GRANT PROGRAM TO RURAL COMMUNITIES TO IMPROVE SOLID WASTE MANAGEMENT SYSTEMS; AND AUTHORITY FOR RESEARCH, DEMONSTRATIONS AND STUDIES.

LET ME TAKE A FEW MINUTES, BECAUSE I THINK IT IS IMPORTANT, TO OUTLINE IN MORE DETAIL THE LAW AS CONGRESS PASSED IT IN 1976. IN THE INTEREST OF BREVITY, I HAVE EXTRACTED ONLY THOSE PORTIONS WHICH I THINK ARE RELEVANT TO TODAY'S TESTIMONY.

SUBTITLE A OF THE ACT REQUIRES THE FORMULATION OF GUIDELINES FOR SOLID WASTE RECOVERY AND THE PUBLICATION OF GUIDELINES ON ALTERNATIVE SOLID WASTE MANAGEMENT PROACTICES. THESE GUIDELINES WERE TO BE ISSUED WITHIN 1 YEAR OF ENACTMENT OF THE LAW.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

HEARING BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

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DESCRIPTIONS OF LEVELS OF TECHNICAL PERFORMANCE, LEACHATE CONTROL, AMBIENT AIR QUALITY, DISEASES, SAFETY, AND ESTHETICS WERE TO BE INCLUDED IN SIMILAR GUIDELINES PUBLISHED AFTER 2 YEARS.

SUBTITLE B ESTABLISHES AN OFFICE OF SOLID WASTE WITHIN THE ENVIRONMENTAL PROTECTION AGENCY HEADED BY A DEPUTY ASSISTANT ADMINISTRATOR TO OVERSEE THE IMPLEMENTATION OF RCRA. THIS POSITION IS CURRENTLY HELD BY MR. STEFAN PLEHN.

SUBTITLE C IS THE KEY TO THE BILL AS THIS IS THE SECTION WHICH IS CONCERNED WITH HAZARDOUS WASTE MANAGEMENT. THE LAW DIRECTS EPA, WITHIN 18 MONTHS OF ENACTMENT, TO IDENTIFY WHICH WASTES ARE HAZARDOUS AND IN WHAT QUANTITIES, QUALITIES, CONCENTRATIONS, AND FORMS OF DISPOSAL THEY BECOME A TRHREAT TO HEALTH OR THE ENVIRONMENT.

ADDITIONALLY, EPA IS MANDATED TO ISSUE STANDARDS FOR GENERATORS AND TRANSPORTERS OF HAZARDOUS WASTES, RESPECTING RECORDKEEPING, PRACTICES, LABELING, APPROPRIATE CONTAINERS, USE OF A MANIFEST SYSTEM, AND REPORTING OF QUANTITIES AND DISPOSTION.

PERHAPS MOST IMPORTUANTLY, PERSONS OWNING OR OPERATING FACILITIES FOR THE TREATMENT AND STORAGE OF HAZARDOUS WASTES ARE REQUIRED TO OBTAIN PERMITS WITHIN 90 DAYS AFTER IDENTIFICATION AND LISTING.

PERMIT APPLICATIONS MUST INDICATE COMPOSITION, QUANTITIES, THE RATE AT WHICH SUCH WASTES ARE TO BE DISPOSED OF, AND THE LOCATION OF THE DISPOSAL SITE. EPA OR STATES-- IN JURISDICTIONS HAVING HAZARDOUS WASTE PROGRAMS-- MAY REVOKE PERMITS OF NONCONFORMING USERS.

EIGHTEEN MONTHS AFTER ENACTMENT OF THE LAW, THE ADMINISTRATOR WAS TO PUBLISH GUIDELINES TO ENABLE THE STATES TO DEVELOP APPROVED HAZARDOUS WASTE PROGRAMS.

IN ORDER FOR EPA AND STATE OFFICIALS TO ENFORCE THESE REQUIREMENTS, THE ACT AUTHORIZES THEM TO INSPECT FACILITIES, COPY RECORDS, AND OBTAIN SAMPLES. THE INFORMATION OBTAINED IS TO BE MADE PUBLIC.

COMPLIANCE PROVISIONS OF THE LAW ARE TO BE ENFORCED THROUGH CIVIL AND CIRMINAL PENALTIES.

SUBTITLE D REQUIRES EPA WITHIN 6 MONTHS OF ENACTMENT TO PUBLISH GUIDELINES IDENTIFYING AREAS WITH COMMON SOLID WASTE MANAGEMENT PROBLEMS AND APPROPRIATE UNITS FOR PLANNING REGIONAL SOLID WASTE MANAGEMENT SERVICES.

THE AGENCY WAS ALSO TO PROMULAGATE WITHIN 18 MONTHS AFTER ENACTMENT GUIDELINES TO AID THE STATES IN THE DEVELOPMENT OF SOLID WASTE MANAGEMENT PLANS.

IT IS IMPORTANT TO NOTETHAT EACH PLAN MUST PROHIBIT THE ESTABLISHMENT OF NEW OPEN DUMPS AND REQUIRE THAT ALL NONHAZARDOUS WASTES BE EITHER USED FOR RESOURCE RECOVERY OR DISPOSED OF IN SANITARY LANDFILLS. EXISTING OPEN DUMPS WERE TO BE IMPROVED OR PHASED OUT.

WITHIN 1 YEAR AFTER ENACTMENT, THE EPA WAS TO PROMULGATE REGULATIONS SETTING FORTH CRITERIA FOR DETERMINING WHICH FACILITIES WOULD BE CLASSIFIED AS SANITARY LANDFILLS AND WHICH AS OPEN DUMPS.

OPEN DUMPS ARE PROHIBITED EXCEPT IN SITUATIONS WHERE A COMPLIANCE SCHEDULE IS ARRIVED AT PURSUANT TO A STATE PLAN. EPA UNDER SECTION 4005 OF THE ACT MUST ALSO PUBLISH AN INVENTORY OF ALL OPEN DUMPS WITHIN THE UNITED STATES.

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ANOTHER PROVISION IN THIS SUBTITLE TO BE NOTED IS ONE WHICH ALLOWS FOR SPECIAL COMMUNITIES. A SPECIAL COMMUNITY IS DEFINED IN RCRA AS ONE WHICH HAS A LOW POPULATION AND A HIGH LEVEL OF SOLID WASTE DISPOSAL.

STATES WITH SPECIAL COMMUNITIES WILL BE ELIGIBLE FOR GRANTS TO BE USED FOR CONVERSION, IMPROVEMENT, CONSOLIDATION OR CONSTRUCTION OF SOLID WASTE DISPOSAL FACILITIES.

GRANTS WILL ALSO BE PROVIDED FOR RURAL COMMUNITIES ASSISTANCE TO BE USED TO UPGRADE SOLID WASTE MANAGEMENT FACILITIES AND WILL BE APPORTIONED BY EPA TO THE STATES ON A POPULATION RATIO BASIS.

I AM GOING TO PASS OVER MY SUMMARY OF SUBTITLES E, F, G, AND H, ALTHOUGH ALL OF THEM ARE EXTREMELY IMPORTANT AND ALL OF THEM REQUIRE REGULATIONS TO IMPLEMENT THEM.

MR. GORE. WITHOUT OBJECTION, WE WILL INCLUDE THE COMPLETE TEXT OF YOUR STATEMENT IN THE RECORD, INCLUDING YOUR DISCUSSION OF THESE SUBTITLES. (SEE P. 72).

MR. LAFALCE. THANK YOU VERY MUCH, MR. CHAIRMAN.

HAVING OUTLINED IN BRIEF THE REQUIREMENTS OF THE LAW IN THE AREAS OF SOLID WASTE, HAZARDOUS WASTE, AND RESOURCE RECOVERY, LET ME TAKE UP THE ISSUE OF PROMULGATION OR LACK THEREOF OF REGULATIONS, WHICH IS SO NECESSARY FOR THE IMPLEMENTATION OF THIS ACT.

THE LAW IS INTENDED TO REGULATE SOLID WASTES FROM THE CRADLE TO THE GRAVE. HOWEVER, MOST OF THE PROVISIONS WHICH I OUTLINED ABOVE HAVE NOT YET BEEN IMPLEMENTED BECAUSE THE U.S. ENVIRONMENTAL PROTECTION AGENCY, THE FEDERAL AGENCY RESPONSIBLE FOR IMPLEMENTING THIS ACT, HAS NOT ISSUED REGULATIONS.

AS YOU WILL RECALL, THE REGULATIONS FOR SUBTITLE C, HAZARDOUS WASTE MANAGEMENT, WERE TO BE ISSUED WITHIN 18 MONTHS OF ENACTMENT OF THE LAW. EPA NOW STATES THAT IT WILL NOT BE ISSUING THE REGULATIONS FOR THIS SECTION OF THE LAW UNTIL 1980 BECAUSE IT NEEDS TO RESOLVE WHAT ARE ADMITTEDLY VERY COMPLEX TECHNICAL, FINANCIAL, LEGAL, AND ENVIRONMENTAL ISSUES.

EPA'S MAIN CONCER, AND PERHAPS TO AN EXTENT JUSTIFIABLY SO, IS TO ISSUE REGULATIONS WHICH WILL NOT BE TOSSED OUT BY THE COURTS. HOWEVER, BY NOT ISSUING REGULATIONS UNTIL JANUARY 1980, WHICH MEANS THAT THE REGULATIONS WOULD NOT TAKE EFFECT FOR AN ADDITION 6 MONTHS AFTER ISSUANCE, EPA IS DELAYING BY 2 YEARS PUTTING INTO EFFECT A PROGRAM WHICH IS URGENTLY NEEDED NOW.

BY DELAYING THE ISSUANCE OF REGULATIONS FOR SUCH IMPORTANT SECTIONS OF THE LAW AS GUIDELINES FOR SOLID WASTE MANAGEMENT LANDSCAPING PRACTICES, HAZARDOUS WASTE CRITERIA, IDENTIFICATION AND LISTING, STANDARDS FOR GENERATORS OF WASTE, STANDARDS FOR HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES, GUIDELINES FOR DEVELOPMENT OF STATE SOLID WASTE MANAGEMENT PROGRAMS, CRITERIA FOR CLASSIFICATION OF DISPOSAL FACILITIES, AND GUIDELINES FOR PROCUREMENT PRACTICES, WE ARE RENDERING THE LAW TOTALLY INEFFECTIVE.

FOR ALL THE GOOD THIS LAW IS CURRENTLY DOING, CONGRESS MIGHT WELL NOT HAVE PASSED IT AT ALL.

I HAVE GREAT RESPECT FOR THE ENVIRONMENTAL PROTECTION AGENCY. THE INDIVIDUALS I HAVE WORKED WITH ON THE LOVE CANAL PROBLEM HAVE BEEN UNCEASING AND UNTIRING IN THEIR EFFORTS.

IT HAS BEEN A DIFFICULT TASK TO PROTECT OUR ENVIRNMENT, BUT EPA HAS STILL PROVEN ITSELF DERELICT IN ITS DUTIES AND OBLIVIOUS TO ITS RESPONSIBILITIES FOR RCRA SO THAT IT CAN BE IMPLEMENTED IMMEDIATELY.

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BY DELAYING ISSUANCE OF THE RCRA REGULATIONS, EPA MAY BE COMPOUNDING ITS PROBLEMS BY ALLOWING THOSE WHO HANDLE, HAUL, OR DISPOSE OF HAZARDOUS WASTES TO DO SO IN AN UNSAFE MANNER.

ADDITIONALLY, THOSE COMPANIES WHICH ARE INVOLVED IN THE WASTE DISPOSAL BUSINESS ARE HESITANT TO INVEST IN NEW EQUIPMENT FOR FEAR THAT THE NEW FACILITIES WILL NOT MEET EPA STANDARDS WHEN THE REGULATIONS ARE ISSUED IN 1980.

ALSO, SINCE THE LAWS CONCERNING DUMPING NOW IN EFFECT ARE PRIMARILY STATE LAWS RATHER THAN FEDERAL LAWS, STATES WITH STRICT DUMPING REGULATIONS ARE HURTING THEMSELVES BECAUSE INDUSTRIES ARE MOVING TO THOSE STATES WITH WEAKER LAWS SO THAT THEY CAN DUMP WITHOUT PENALTY.

THE SOLID WASTES WHICH WE GENERATE IN THIS COUNTRY AS A RESULT OF OUR HIGHLY INDUSTRIALIZED ECONOMY ARE HERE TO STAY. THEY WILL NOT GO AWAY BUT RATHER WILL INCREASE EXPONENTIALLY IN THE FUTURE.

THUS, IN ORDER TO PREVENT LANDFILL OPERATORS FROM BEING ABLE TO CONDUCT THEIR BUSINESSES IN AN IRRESPONSIBLE MANNER, EPA MUST REGULATE.

THE PUBLIC FEARS THE PLACEMENT OF THESE LANDFILLS WHICH HAVE CREATED SERIOUS HEALTH AND ENVIRONMENTAL PROBLEMS FOR THE SURROUNDING AREAS DUE TO A LACK OF REGULATION OF THE LANDFILLS' ACTIVITIES.

WE CANNOT ALLOW THE PUBLIC TO REMAIN FEARFUL BECAUSE THE HAZARDOUS WASTE LANDFILL MUST EXIST AS LONG AS OUR SOCIETY CONTINUES TO MANUFACTURE PRODUCTS FROM MATERIALS WHICH ARE MADE FROM TOXIC SUBSTANCES WHICH ARE NOT BIODEGRADABLE.

WE CAN ONLY STEM THE LEGITIMATE, UNDERSTANDABLE FEARS OF THE PUBLIC IF WE INSIST THAT THE SOLID WASTE PRODUCERS, HANDLERS, HAULERS, AND LANDFILL OPERATORS BE FORCED TO CONDUCT THEIR BUSINESSES IN THE SAFEST MANNER KNOWN TO MAN.

I MUST MAKE NOTE AT THIS POINT THAT I AM NOT IN FAVOR OF REGULATING FOR THE SAKE OF REGULATING. GOVERNMENT HAS A TENDENCY SOMETIMES TO OVERREGULATE AND COST GOVERNMENT AND THE CONSUMER INORDINATE AMOUNTS OF MONEY.

HOWEVER, THERE ARE TIMES WHEN I BELIEVE THAT GOVERNMENT MUST STEP IN AND REGULATE IN ORDER TO PROTECT THE HEALTH AND WELFARE OF ITS CITIZENS. THIS IS SUCH A TIME.

THE PRESIDENT, AS PART OF HIS PHASE II ANTI-INFLATION MESSAGE DELIVERED LAST WEEK, REQUESTED FEDERAL AGENCIES TO AVOID ISSUING REGULATIONS WHICH WOULD PROVE TO BE ADVERSE TO THE PUBLIC INTEREST, INFLATIONARY OR NOT COST-EFFECTIVE.

EPA MUST NOT TAKE THIS MESSAGE TO MEAN THAT THE PRCSIDENT DOES NOT WANT IMPORTANT LAWS SUCH AS RCRA TO BE IMPLEMENTED, AND IMPLEMENTED IMMEDIATELY.

EPA SHOULD FOLLOW THE PRESIDENT'S DIRECTIVES BY REDIRECTING ITS RESOURCES TOWARD NECESSARY REGULATIONS AND ISSUING THEM AS EXPEDITIOUSLY, AS POSSIBLE. IN THIS MANNER, THE AGENCY WILL ALSO MEET THE PUBLIC'S EXPECTATIONS BY LIVING UP TO ITS OBLIGATION TO PRESERVE PUBLIC HEALTH, SAFETY AND THE ENVIRONMENT.

LOVE CANAL IS A PRIME EXAMPLE OF A TICKING TIMEBOMB, AN ABANDONED LANDFILL FULL OF TOXIC SUBSTANCES WHICH LITERALLY EXPLODED IN THE FACES OF THE PEOPLE WHO LIVED IN THE SURROUNDING AREA BECAUSE A LAW, SUCH AS RCRA, HAD NOT BEEN ON THE BOOKS 25 YEARS AGO AND HAD NOT BEEN ENFORCED DURING THE 1940'S AND 1950'S WHEN INDISCRIMINATE DUMPING OCCURRED IN THE CANAL.

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UNFORTUNATELY, RCRA DOES NOT ADEQUATELY ADDRESS THE ISSUE OF ABANDONED CHEMICAL DUMPS. THERE ARE FEW PROVISIONS IN THE ACT WHICH CAN DIRECTLY AID US IN EFFECTIVELY COPING WITH THE PROBLEMS THEY LEAVE BEHIND, EXCEPT PERHAPS SECTION 8001(A), WHICH PROVIDES FOR DEMONSTRATION PROJECTS AND UNDER WHICH WE DID GET $4 MILLION IN FUNDING AND SECTION 7003, RELATING TO IMMINENT HAZARDS.

CONGRESS, I BELIEVE, IN ALL ITS WISDOM SHOULD HAVE PROPERLY ADDRESSED THIS ISSUE IN 1976 WHEN IT ORIGINALLY PASSED THE LAW. HOWEVER, IT DID NOT AND, THEREFORE, I HAVE INTRODUCED LEGISLATION DURING THE FINAL DAYS OF THE 95TH CONGRESS, WHICH I BELIEVE MIGHT HELP US ADDRESS THE PROBLEMS CREATED BY ABANDONED WASTESITES. I WILL DISCUSS THIS BILL'S PROVISIONS A LITTLE LATER.

NEVERTHELESS, RCRA AS IT EXISTS TODAY CAN HELP US PREVENT FUTURE LOVE CANALS BUT ONLY IF EPA ACTS AND ACTS IMMEDIATELY. THERE ARE HAZARDOUS WASTE DISPOSAL AREAS CURRENTLY BEING OPERATED WHICH NEED TO BE REGULATED BETTER SO THAT THE PEOPLE WHO LIVE NEAR THEM CAN BE ASSURED THAT A FUTURE LOVE CANAL DOES NOT EXIST IN THEIR BACKYARDS.

I HAVE SEVERAL SUCH AREAS OPERATING CURRENTLY IN MY OWN CONGRESSIONAL DISTRICT. WE IN NEW YORK ARE FORTUNATE BECAUSE WE HAVE STRICT STATE LEGISLATION ON THE BOOKS.

HOWEVER, THE CITIZENS WHO LIVE, FOR EXAMPLE, IN MY CONGRESSIONAL DISTRICT IN LEWISTON, N.Y., NEAR THE SCA SERVICES, INC. SITE ARE VERY LEERY OF THE OPERATIONS AT THE SITE BECAUSE THEY DO NOT HAVE THE ASSURANCE THAT IT IS BEING REGULATED ACCORDING TO FEDERAL STANDARDS.

NOT ONLY ARE PEOPLE AFRAID THAT THESE SITES ARE NOT BEING REGULATED ENOUGH DUE TO THE LACK OF RCRA ENFORCEMENT, BUT WE ALSO HAVE THE EXAMPLES OF PCB'S BEING DISPOSED OF ALONG THE ROADS IN NORTH CAROLINA BY A MIDNIGHT HAULER AND ILLEGAL WASTE DUMPERS STREWING WASTES ALONG CANCER ALLEY IN NEW JERSEY.

THE RESULTS OF THESE ACTIONS ARE ADDITIONAL POLLUTANTS IN OUR DRINKING WATER, INCREASED BURDENS ON OUR SEWAGE TREATMENT PLANTS, INCREASED POLLUTION IN OUR RIVERS AND STREAMS, AND INCREASINGLY HIGHER AMOUNTS OF UNHEALTHY AND EVEN TOXIC CHEMICALS IN THE AIR WE BREATHE.

THIS ADDITIONAL POLLUTION, MUCH OF WHICH COULD HAVE BEEN PREVENTED, COSTS TAXPAYERS ADDITIONAL MONEY, IRREPARABLY HARMS THE ENVIRONMENT AND CREATES COSTS-- BOTH HEALTH AND FINANCIAL-- FOR THE INDIVIDUALS WHO SUFFER FROM THESE ACTIVITIES.

MANY OF US UNKNOWINGLY SUFFER DUE TO THE TOXICS ENTERING THE FOOD CHAIN. THE TOXIC WASTES SETTLE ON THE FLOORS OF THE BODIES OF WATER FROM WHICH WE FISH. I CAN GIVE EXAMPLE AFTER EXAMPLE. THESE ARE JUST A FEW OF THE EXAMPLES OF THE TOTAL EXTENT OF THE HARM THAT HAS BEEN DONE TO OUR ENVIRONMENT, HEALTH AND WELL BEING.

BY NOT HAVING ISSUED REGULATIONS FOR RCRA, EPA IS CREATING A GAPING HOLE IN OUR NATIONAL POLICY TO REDUCE THE AMOUNT OF UNCONTROLLABLE POLLUTANTS IN THE ENVIRONMENT.

MR. CHAIRMAN, CONGRESS HAS PASSED OTHER LANDMARK LEGISLATION AS WELL, AND I DETAIL THAT LEGISLATION IN MY PREPARED TESTIMONY, AND I WILL PASS OVER IT FOR PURPOSES OF MY VERBAL PRESENTATION.

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THEY INCLUDE THE FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT OF 1972, THE CLEAN AIR ACTS OF 1970 AND 1977, THE HAZARDOUS MATERIALS TRANSPORTATION ACT OF 1974, THE WATER POLLUTION CONTROL ACT OF 1972, THE CLEAN WATER ACT OF 1977, THE SAFE DRINKING WATER ACT OF 1974, AND THE TOXIC SUBSTANCES CONTROL ACT OF 1976.

WHAT I WOULD NOW LIKE TO TURN TO, HOWEVER, IS THE WATER POLLUTION CONTROL ACT OF 1972 AND THE CLEAN WATER ACT OF 1977 ON PAGE 11 OF MY TESTIMONY BECAUSE I DO THINK THAT THERE ARE PROVISIONS WITHIN THAT PRESENT LEGISLATION WHICH IF IMPLEMENTED COULD BE OF ASSISTANCE TO SITUATIONS SUCH AS THE LOVE CANAL DISASTER.

WHEN I FIRST LEARNED OFTHEPOTENTIAL HORRORS AT THE LOVE CANAL -- ALL OF WHICH UNFORTUNATELY PROVED TO BE REAL, NOT JUST POTENTIAL-- I APPROACHED EPA FOR FUNDING OF THE CLEANUP OF THE CANAL UNDER BOTH RCRA AND THE CLEAN WATER ACT.

SPECIFICALLY, I DISCUSSED SECTIONS 201, 208, 311, AND 504. I BELIEVE THAT EACH SECTION, IF IMPLEMENTED IN A CREATIVE MANNER, COULD BE MOST USEFUL IN SITUATIONS SUCH AS THE LOVE CANAL. LET ME EXPLAIN.

SECTION 201 PROVIDES FOR GRANTS FOR CONSTRUCTION OF WASTEWATER TREATMENT WORKS. IS IS A $40 BILLION PROGRAM. THE SOLUTION WHICH HAS BEEN DESIGNED FOR CLEANING UP LOVE CANAL IS A MICRO SEWER SYSTEM. FRENCH TILE DRAINS ARE BEING LAID SO THE LEACHATE CAN BE COLLECTED. THE CONTAMINATED WASTES WILL THEN BE FLUSHED THROUGH A PRETREATMENT PLANT AND EVENTUALLY THROUGH THE MUNICIPAL SEWAGE TREATMENT PLANT. IF EPA WERE TO RECOGNIZE THE FACT THAT THIS PLAN OF ACTION IS, IN ESSENCE, A MICRO SEWER SYSTEM, THEN 201 FUNDS COULD BE USED IN THIS INNOVATIVE WAY. HOWEVER, EPA RESISTED THIS APPROACH FOR USE OF 201 MONEY, STATING THAT IT IS NOT A TRADITIONAL USE OF THESE FUNDS. LOVE CANALS ARE NOT TRADITIONAL PROBLEMS, AND I THINK EPA SHOULD BE LOOKING FOR INNOVATIVE USES OF ITS PROGRAMS FOR NEW PROBLEMS AS WELL AS TRADITIONAL ONES.

SECTION 208 IS THE SECTION OF THE LAW WHICH CALLS FOR STATE AND AREAWIDE PLANNING AND MANAGEMENT PROGRAMS TO ADDRESS NONPOINT SOURCE DISCHARGES. IT PROVIDES FOR LOCAL INPUT AND LOCALIZED PLANNING, 208 AGREEMENTS MUST BE CERTIFIED BY THE GOVERNOR AND NO 201 GRANTS CAN BE AWARDED WITHOUT THE 208 AGREEMENT IN PLACE. IT TOO MUST BE REVIEWED AND UPDATED EACH YEAR AS NECESSARY.

SECTION 311 PROVIDES FOR THE DESIGNATION OF HAZARDOUS SUBSTANCES WHICH, WHEN DISCHARGED, PRESENT AN IMMINENT AND SUBSTANTIAL DANGER TO THE PUBLIC HEALTH OR WELFARE, AND PROVIDES FOR PENALTIES FOR SUCH DISCHARGES. THAT WAS ON THE BOOKS FOR 5 YEARS, AND I CONTACTED PRESIDENT CARTER AND I SAID IT STILL HASN'T BEEN IMPLEMENTED. REGULATIONS HAVEN'T BEEN PROMULGATED. A SHORT WHILE AFTER I CONTACTED PRESIDENT CARTER, EPA DID ISSUE REGULATIONS, BUT THEN THEY WERE TOSSED OUT IN THE COURTS, AND WE STILL DO NOT HAVE REGULATIONS FOR SECTION 311.

FINALLY THERE IS SECTION 504 OF THE CLEAN WATER ACT WHICH AUTHORIZES THE ADMINISTRATOR TO PROVIDE ASSISTANCE IN EMERGENCIES CAUSED BY THE RELEASE INTO THE ATMOSPHERE OF ANY POLLUTANT OR OTHER CONTAMINANT INCLUDING, BUT NOT LIMITED TO, THOSE WHICH PRESENT, OR MAY REASONABLY BE ANTICIPATED TO PRESENT, AN IMMINENT AND SUBSTANTIAL DANGER TO THE PUBLIC HEALTH OR WELFARE. AND THIS MOST FITTINGLY ADDRESSES SITUATIONS SUCH AS THE LOVE CANAL. BUT THERE MR. CHAIRMAN, CONGRESS HAS BEEN DERELICT. WE HAVE AUTHORIZED MONEY TO THE TUNE OF APPROXIMATELY $10 MILLION BUT WE HAVE NOT APPROPRIATED ONE RED PENNY FOR IMPLEMENTATION OF SECTION 504, AND UNTIL WE DO SO WE CAN'T USE IT.

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LET ME TURN TO WHAT I THINK ARE ALSO NEEDED CHANGES IN RCRA AND ALSO IN A NEW LAW ON PAGE 15 OF MY TESTIMONY.

I INTRODUCED TWO BILLS INTO CONGRESS DURING THE LAST DAYS OF THE 95TH SESSION WHICH I HOPE WILL SERVE AS A BASIS FOR DISCUSSION AND BE INCLUDED IN THE REAUTHORIZATION BILL FOR RCRA.

THE FIRST BILL I INTRODUCED IS INTENDED TO HELP PREVENT HAZARDOUS SUBSTANCES FROM BEING HANDLED OR DISPOSED OF IN WAYS THAT THREATEN INJURIES TO AMERICAN CITIZENS OR TO THE ENVIRONMENT.

MY BILL WILL, I BELIEVE, HELP FILL THE GAPS WHICH HAVE BECOME EVIDENT IN RCRA BY AMMENDING IT TO: ESTABLISH A PROGRAM FOR THE IDENTIFICATION AND RECLAMATION OF ABANDONED HAZARDOUS WASTESITES; SET FEES TO BE PAID BY PRIVATE ORGANIZATIONS WHICH STORE OR DISPOSE OF HAZARDOUS WASTES; PROVIDE FOR A PROCESS FOR THE SELECTION OF SITES FOR FUTURE DISPOSAL OF HAZARDOUS WASTES.

MORE SPECIFICALLY, MY BILL STATES THAT A CONCERTED EFFORT MUST BE MADE TO IDENTIFY ALL ABANDONED LANDFILL SITES THAT DO OR MAY CONTAIN HAZARDOUS WASTES, AND ONCE THEY ARE IDENTIFIED THEY MUST BE RECLAIMED, IF FEASIBLE. IF RECLAMATION IS NOT FEASIBLE, THEY MUST BE MONITORED TO INSURE THAT PUBLIC AND ENVIRONMENTAL HEALTH AND SAFETY ARE NOT ENDANGERED. MY BILL ESTABLISHES A JOINT STATE/ FEDERAL PROCEDURE FOR ACCOMPLISHING THESE DIRECTIVES.

ADDITIONALLY, WHEN RCRA WAS PASSED IN 1976, FEW FORSAW THE WIDESPREAD PUBLIC OPPOSITION TO NEW HAZARDOUS WASTE DISPOSAL SITES WHICH HAS SWEPT THE NATION. THE GENERAL PUBLIC WAS NOT THEN FULLY AWARE OF THE LARGE NUMBER OF ABANDONED SITES THROUGHOUT THE COUNTRY, THE DELETERIOUS EFFECTS THEY WERE HAVING ON PEOPLE'S HEALTH AND SAFETY, AND THEIR DIRE IMPACT ON THE ENVIRONMENT. NOW THAT PUBLIC AWARENESS HAS GROWN, IN LARGE PART DUE TO THE LOVE CANAL EMERGENCY, CITIZENS ARE UNDERSTANDABLY LEERY ABOUT THE DUBIOUS HONOR OF HAVING A NEW SITE PROPOSED FOR LOCATION IN THEIR BACKYARDS.

HOWEVER, AS I NOTED EARLIER, THE HAZARDOUS WASTE DISPOSAL SITUATION IS HERE TO STAY. OUR ADVANCED TECHNOLOGY AND MANUFACTURING PROCESSES MUST PRODUCE WASTES AS BYPRODUCTS OF THOSE VERY ACTIVITIES WHICH ALLOW US TO ENJOY ONE OF THE HIGHEST STANDARDS OF LIVING IN THE WORLD.

THEREFORE, WE MUST CREATE A PROGRAM AND PROCESS FOR LOCATING NEW FACILITIES FOR THE TREATMENT, STORAGE, AND DISPOSAL OF HAZARDOUS WASTE MATERIALS IN AS RATIONAL, EFFECTIVE, AND EQUITABLE A MANNER AS POSSIBLE. THAT IS PRECISELY WHAT MY BILL IS INTENDED TO PROVIDE.

MR. CHAIRMAN, I ALSO ASK THAT WE INCLUDE WITHIN THE BODY OF MY REMARKS THE REMAINDER OF MY PREPARED STATEMENT WHICH DETAILS IN GREATER EXTENT THE FIRST BILL I INTRODUCED AND ALSO, THE SECOND BILL, THE TOXIC POLLUTANT COMPENSATION ACT, WHICH I DESIGNED TO PROVIDE RELIEF TO ALL PERSONS INJURED AS A RESULT OF TOXIC POLLUTANTS IN OUR ENVIRONMENT, REGARDLESS OF FAULT, ENABLING EPA, AFTER COMPENSATION OF THE VICTIMS, TO THEN GO AFTER THE POLLUTERS.

THANK YOU VERY, VERY MUCH FOR YOUR KIND ATTENTION TO WHAT I DO ADMIT WAS A RATHER EXTENSIVE TESTIMONY.

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STATEMENT OF HON. JOHN J. LAFALCE, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF NEW YORK

MR. CHAIRMAN: IT IS AN HONOR FOR ME TO TESTIFY BEFORE YOU TODAY ON THE PROGRESS THE FEDERAL GOVERMENT HAS MADE IN THE IMPLEMENTATION OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA).

ON AUGUST 2, 1978, THE NEW YORK STATE COMMISSIONER OF HEALTH ADVISED PREGNANT WOMEN AND CHILDREN UNDER THE AGE OF TWO TO EVACUATE THE LOVE CANAL AREA OF NIAGARA FALLS, WHICH IS IN MY CONGRESSIONAL DISTRICT. EVENTUALLY OVER 230 FAMILIES MOVED FROM THE AREA. THEIR HOMES WERE BEING POLLUTED BY TOXIC CHEMICALS SEEPING FROM THE GROUND FROM AN ABANDONED CANAL WHICH HAD BEEN USED AS A SOLID WASTE LANDFILL SITE. EIGHTY-TWO CHEMICALS, SOME OF WHICH ARE SUSPECTED CARCINOGENS, HAVE BEEN DETECTED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY TO BE IN THE AMBIENT AIR IN THE CANAL AREA. THIS TERRIBLE TRAGEDY, CAUSED BY TOXIC WASTES HAVING BEEN INDISCRIMINATELY BURIED IN THE CANAL OVER 25 YEARS AGO, HAS REFERRED TO AS JUST ONE OT THE MANY "TICKING TIMEBOMBS", JUST ONE OF THE ABANDONED LANDFILL SITES AROUND THE COUNTRY.

RCRA

CONGRESS, WHEN IT PASSED RCRA IN 1976, HOPED TO PREVENT SUCH INCIDENTS BY PROVIDING FOR A HAZARDOUS WASTE REGULATORY PROGRAM; A PROGRAM TO ELIMINATE OPEN DUMPING; A PROGRAM FOR FINANCIAL AND TECHNICAL ASSISTANCE FOR PLANNING ENHANCED SOLID WASTE MANAGEMENT PROGRAMS; A GRANTS PROGRAM TO RURAL COMMUNITIES TO IMPROVE SOLID WASTE MANAGEMENT SYSTEMS; AND UTHORITY FOR RESEARCH, DEMONSTRATIONS AND STUDIES.

LET ME TAKE A FEW MINUTES TO OUTLINE IN MORE DETAIL THE LAW AS CONGRESS PASSED IT IN 1976. IN THE INTEREST OF BREVITY I HAVE EXTRACTED ONLY THOSE PORTIONS WHICH I THINK ARE RELEVANT TO TODAY'S TESTIMONY.

SUBTITLE A OF THE ACT REQUIRES THE FORMULATION OF GUIDCLINES FOR SOLID WASTE RECOVERY AND THE PUBLICATION OF GUIDELINES ON ALTERNATIVE SOLID WASTE MANAGEMENT PRACTICES.

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THESE GUIDELINES ARE TO BE ISSUED WITHIN ONE YEAR OF ENACTMENT OF THE LAW. DESCRIPTIONS OF LEVELS OF TECHNICAL PERFORMANCE, LEACHATE CONTROL, AMBIENT AIR QUALITY, DISEASES, SAFETY AND AESTHETICS WILL BE INCLUDED IN SIMILAR GUIDELINES PUBLISHED AFTER TWO YEARS.

SUBTITLE B ESTABLISHES AN OFFICE OF SOLID WASTE WITHIN THE ENVIRONMENTAL PROTECTION AGENCY HEADED BY A DEPUTY ASSISTANT ADMINISTRATOR TO OVERSEE THE IMPLEMENTATION OF RCRA. THIS POSITION IS CURRENTLY HELD BY MR. STEFAN PLEHN.

SUBTITLE C IS THE KEY TO THE BILL AS THIS IS THE SECTION WHICH IS CONCERNED WITH HAZARDOUS WASTE MANAGEMENT. THE LAW DIRECTS EPA, WITHIN 18 MONTHS OF ENACTMENT, TO IDENTIFY WHICH WASTES ARE HAZARDOUS AND IN WHAT QUANTITIES, QUALITIES, CONCENTRATIONS AND FORMS OF DISPOSAL THEY BECOME A THREAT TO HEALTH OR THE ENVIRONMENT.

ADDITIONALLY, EPA IS REQUIRED TO ISSUE STANDARDS FOR GENERATORS AND TRANSPORTERS OF HAZARDOUS WASTES, RESPECTING RECORD KEEPING, PRACTICES, LABELING, APPROPRIATE CONTAINERS, USE OF A MANIFEST SYSTEM AND REPORTING OF QUANTITIES AND DISPOSITION.

PERHAPS MOST IMPORTANTLY, PERSONS OWNING OR OPERATING FACILITIES FOR THE TREATMENT AND STORAGE OF HAZARDOUS WASTES ARE REQUIRED TO OBTAIN PERMITS WITHIN 90 DAYS AFTER IDENTIFICATION AND LISTING. PERMIT APPLICATIONS MUST INDICATE COMPOSITION, QUANTITIES, THE RATE AT WHICH SUCH WASTES ARE TO BE DISPOSED OF, AND THE LOCATION OF THE DISPOSAL SITE. EPA OR STATES (IN JURISDICTIONS HAVING HAZARDOUS WASTE PROGRAMS) MAY REVOKE PERMITS OF NON-CONFORMING USERS.

EIGHTEEN MONTHS AFTER ENACTMENT THE ADMINISTRATOR MUST ALSO PUBLISH GUIDELINES TO ENABLE THE STATES TO DEVELOP APPROVED HAZARDOUS WASTE PROGRAMS.

IN ORDER FOR EPA AND STATE OFFICIALS TO ENFORCE THESE REQUIREMENTS, THE ACT AUTHORIZES THEM TO INSPECT FACILITIES, COPY RECORDS, AND OBTAIN SAMPLES. THE INFORMATION OBTAINED WILL BE MADE PUBLIC.

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COMPLIANCE PROVISIONS OF THE LAW WILL BE ENFORCED THROUGH CIVIL AND CRIMINAL PENALTIES.

SUBTITLE D REQUIRES EPA WITHIN 6 MONTHS OF ENACTMENT TO PUBLISH GUIDELINES IDENTIFYING AREAS WITH COMMON SOLID WASTE MANAGEMENT PROBLEMS AND APPROPRIATE UNITS FOR PLANNING REGIONAL SOLID WASTE MANAGEMENT SERVICES.

THE AGENCY WILL ALSO PROMULGATE WITHIN 18 MONTHS AFTER ENACTMENT GUIDELINES TO AID THE STATES IN THE DEVELOPMENT OF SOLID WASTE MANAGEMENT PLANS.

IT IS IMPORTANT TO NOTE THAT EACH PLAN MUST PROHIBIT THE ESTABLISHMENT OF NEW OPEN DUMPS AND REQUIRE THAT ALL NON-HAZARDOUS WASTES BE EITHER USED FOR RESOURCE RECOVERY OR DISPOSED OF IN SANITARY LANDFILLS. EXISTING OPEN DUMPS WILL BE IMPROVED OR PHASED OUT.

WITHIN ONE YEAR AFTER ENACTMENT, THE EPA WILL PROMULGATE REGULATIONS SETTING FORTH CRITERIA FOR DETERMINING WHICH FACILITIES WILL BE CLASSIFIED AS SANITARY LANDFILLS AND WHICH AS OPEN DUMPS. OPEN DUMPS ARE PROHIBITED EXCEPT IN SITUATIONS WHERE A COMPLIANCE SCHEDULE IS ARRIVED AT PURSUANT TO A STATE PLAN. EPA UNDER SECTION 4005 OF THE ACT MUST ALSO PUBLISH AN INVENTORY OF ALL OPEN DUMPS WITHIN THE U.S.

ANOTHER PROVISION IN THIS SUBTITLE TO BE NOTED IS ONE WHICH ALLOWS FOR "SPECIAL COMMUNITIES". A SPECIAL COMMUNITY IS DEFINED AS ONE WHICH HAS A LOW POPULATION AND A HIGH LEVEL OF SOLID WASTE DISPOSAL. STATES WITH SPECIAL COMMUNITIES WILL BE ELIGIBLE FOR GRANTS TO BE USED FOR CONVERSION, IMPROVEMENT, CONSOLIDATION OR CONSTRUCTION OF SOLID WASTE DISPOSAL FACILITIES.

GRANTS WILL ALSO BE PROVIDED FOR "RURAL COMMUNITIES" ASSISTANCE TO BE USED TO UPGRADE SOLID WASTE MANAGEMENT FACILITIES AND WILL BE APPROTIONED BY EPA TO THE STATES ON A POPULATION RATION BASIS.

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SUBTITLE E CONCERNS RESOURCE RECOVERY. IT DIRECTS THE SECRETARY OF COMMERCE TO STIJULATE BROADER COMMERCIALIZATION OF PROVEN RESOURCE RECOVERY TECHNOLOGIES BY PROVIDING ACCURATE SPECIFICATIONS FOR RECOVERED MATERIALS AND ENCOURAGEING THE DEVELOPMENT OF MARKETS FOR RECOVERED MATERIALS. WITHIN TWO YEARS AFTER ENACTMENT, THE SECRETARY MUST PUBLISH GUIDELINES FOR THE DEVELOPMENT OF SPECIFICATIONS AND CLASSIFICATIONS OF RECOVERED MATERIALS AND IDENTIFY THE GEOGRAPHIC LOCATION OF EXISTING OR POTENTIAL MARKETS FOR RECOVERED MATERIALS. THE SECRETARY IS ALSO EMPOWERED TO EVALUATE THE COMMERCIAL FEASIBILITY OF RESOURCE RECOVERY FACILITIES.

SUBTITLE F OUTLINES FURTHER FEDERAL RESPONSIBILITY IN THE AREA OF RESOURCE RECOVERY. IT STATES THAT TWO YERAS AFTER ENACTMENT EACH FEDERAL PROCUREMENT AGENCY WILL BE REQUIRED TO PROCURE ONLY THOSE ITEMS COMPOSED OF THE HIGHEST PERCENTAGE OF RECOVERED MATERIALS. THIS PROVISION WILL APPLY TO ALL ITEMS EXCEEDING $10,000 IN PURCHASE PRICE.

EPA IS GIVEN AUTHORITY TO ENTER INTO CONTRACTS WITH PUBLIC AGENCIES OR WITH PRIVATE PERSONS FOR CONSTRUCTION AND OPERATION OF FULL-SCALE DEMONSTRATION FACILITIES OR PROVIDE FINANCIAL ASSISTANCE IN THE FORM OF GRANTS FOR NEW OR IMPROVED TECHNOLOGIES.

THE AGENCY WILL ALSO CONDUCT SPECIAL STUDIES ON MARKETS FOR ENERGY RECOVERED FROM SOLID WASTE AND IT MAY THEN IMPLEMENT DEMONSTRATION PROJECTS TO TEST STUDY FINDINGS. THIS SUBTITLE ALSO DIRECTS EPA TO PREPARE GUIDELINES TO AID PROCURING AGENCIES IN COMPLYING WITH THE RECOVERED MATERIALS REQUIREMENT.

SECTIONS 7002 AND 7003 IN SUBTITLE G ARE EXTREMELY IMPORTANT. THESE PROVISIONS STATE THAT ANY PERSON MAY COMMENCE A CITIZEN SUIT AGAINST ANY PERSON (INCLUDING THE U.S. GOVERNMENT) WHO IS ALLEGED TO BE IN VIOLATION OF ANY PERMIT, STANDARD, OR REGULATION UNDER THE ACT OR AGAINST THE ADMINISTRATION FOR ALLEGED FAILURE TO PERFORM ANY DUTY UNDER THE ACT WHICH IS NOT DISCRETIONARY.

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THE ADMINISTRATOR MAY BRING SUIT TO ENJOIN ANY HANDLING, STORAGE, TREATMENT, TRASNPORTATION OR DISPOSAL OF ANY SOLID OR HAZARDOUS WASTE WHICH IS PRESENTING AN IMMINENT HAZARD TO PUBLIC HEALTH OR THE ENVIRONMENT.

EPA, UNDER SUBTITLE H, IS TO CONDUCT AND ENCOURAGE STUDIES AND RESEARCH ON FINANCING SOLID WASTE PROGRAMS, HEALTH EFFECTS OF SOLID WASTE DISPOSAL, MARKETING OF RECOVERED RESOURCES, PRODUCTION OF FUEL FROM SOLID WASTE, COLLECTION OF SOLID WASTE, RESOURCE RECOVERY SOURCE SEPARATION SYSTEMS, LAND DISPOSAL PRACTICES, SLUDGE, HAZARDOUS WASTE AND THE EFFECT OF BURNING SOLID WASTE ON AIR QUALITY.

PROMULGATION OF REGULATIONS UNDER RCRA

NOW THAT I HAVE OUTLINED THE REQUIREMENTS UNDER THE LAW IN THE AREAS OF SOLID WASTE, HAZARDOUS WASTE AND RESOURCE RECOFERY, I WOULD LIKE TO TAKE UP THE ISSUE OF THE PROMULGATION OF REGULATIONS WHICH IS NECESSARY FOR IMPLEMENTATION OF THIS ACT.

THE LAW IS INTENDED TO REGULATE SOLID WASTES FROM THE "CRADLE TO THE GRAVE". HOWEVER, MOST OF THE PROVISIONS WHICH I OUTLINED ABOVE HAVE NOT YET BEEN IMPLEMENTED BECAUSE THE U.S. ENVIRONMENTAL PROTECTION AGENCY, THE FEDERAL AGENCY RESPONSIBLE FOR IMPLEMENTING THIS ACT, HAS NOT ISSUED REGULATIONS. AS YOU WILL RECALL, THE REGULATIONS FOR SUBTITLE C-HAZARDOUS WASTE MANAGEMENT-WERE TO BE ISSUED WITHIN 18 MONTHS OF ENACTMENT OF THE LAW. EPA STATES THAT IT WILL NOT BE ISSUING THE REGULATIONS FOR THIS SECTION OF THE LAW UNTIL 1980 BECAUSE IT NEEDS TO RESOLVE VERY COMPLEX TECHNICAL, FINANCIAL, LEGAL AND ENVIRONMENTAL ISSUES. EPA'S MAIN CONCERN, AND PERHAPS TO AN EXTENT JUSTIFIABLY SO, IS TO ISSUE REGULATIONS WHICH WILL NOT BE TOSSED OUT BY THE COURTS. HOWEVER, BY NOT ISSUING REGULATIONS UNTIL JANUARY 1980, WHICH MEANS THAT THE REGULATIONS WOULD NOT TAKE EFFECT FOR AN ADDITIONAL 6 MONTHS AFTER ISSUANCE, EPA IS DELAYING BY TWO YEARS PUTTING INTO EFFECT A PROGRAM WHICH IS URGENTLY NEEDED.

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BY DELAYING THE ISSUANCE OF REGULATIONS FUR SUCH IMPORTANT SECTIONS OF THE LAW SUCH AS: GUIDELINES FOR SOLID WASTE MANAGEMENT LANDSPREADING PRACTICES; HAZARDOUS WASTE CRITERIA - IDENTIFICATION AND LISTING; STANDARDS FOR GENERATORS OF WASTE; STANDARDS FOR HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES; PERMIT REGULATIONS FOR HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES GUIDELINES FOR DEVELOPMENT OF STATE SOLID WASTE MANAGEMENT PROGRAMS; CRITERIA FOR CLASSIFICATION OF DISPOSAL FACILITIES; GUIDELINES FOR PROCUREMENT PRACTICES; IS TO RENDER THE LAW TOTALLY INEFFECTIVE. FOR ALL THE GOOD THIS LAW IS CURRENTLY DOING, CONGRESS MAY WELL NOT HAVE PASSED IT AT ALL. I HAVE GREAT RESPECT FOR THE ENVIRONMENTAL PROTECTION AGENCY, IT HAS A DIFFICULT TASK IN PROTECTING OUR ENVIRONMENT, BUT IT HAS PROVEN DERELICT IN ITS DUTIES AND OBLIVIOUS TO ITS RESPONSIBILITIES TO THE PEOPLE OF THIS COUNTRY BY NOT HAVING ISSUED ALL THE REGULATIONS FOR RCRA SO THAT IT CAN BE IMPLEMENTED IMMEDIATELY.

BY DELAYING ISSUANCE OF THE RCRA REGULATIONS, EPA MAY BE COMPOUNDING ITS PROBLEMS BY ALLOWING THOSE WHO AHNDLE, HAUL OR DISPOSE OF HAZARDOUS WASTES TO DO SO IN AN UNSAFE MANNER: ADDITIONALLY, THOSE COMPANIES WHICH ARE INVOLVED IN THE WASTE DISPOSAL BUSINESS ARE HESITANT TO INVEST IN NEW EQUIPMENT FOR FEAR THAT THE NEW FACILITIES WILL NOT MEET EPA STANDARDS WHEN THE REGULATIONS ARE ISSUED IN 1980. ALSO SINCE THE LAWS CONCERNING JUMPING NOW IN EFFECT ARE STATE LAWS RATHER THAN FEDERAL LAWS, STATES WITH STRICT DUMPING REGULATIONS ARE HURTING THEMSELVES BECAUSE INDUSTRIES ARE MOVING TO THOSE STATES WITH WEAK LAWS SO THAT THEY CAN DUMP WITHOUT PENALTY.

THE SOLID WASTES WHICH WE GENERATE IN THIS COUNTRY AS A RESULT OF OUR HIGHLY INDUSTRIALIZED ECONOMY ARE HERE TO STAY - THEY WILL NOT GO AWAY BUT RATHER INCREASE EXPONENTIALLY IN THE FUTURE.

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THUS, IN ORDER TO PREVENT LANDFILL OPERATORS FROM BEING ABLE TO CONDUCT THEIR BUSINESSES IN AN IRRESPONSIBLE MANNER, EPA MUST REGULATE. THE PUBLIC FEARS THE PLACEMENT OF THESE LANDFILLS WHICH HAVE CREATED SERIOUS HEALTH AND ENVIRONMENTAL PROBLEMS FOR THE SURROUNDING AREAS DUE TO A LACK OF REGULATION OF THE LANDFILLS' ACTIVITIES. WE CANNOT ALLOW THE PUBLIC TO REMAIN FEARFUL, BECAUSE THE HAZARDOUS WASTE LANDFILL MUST EXIST AS LONG AS OUR SOCIETY CONTINUES TO MANUFACTURE PRODUCTS FROM MATERIALS WHICH ARE MADE FROM TOXIC SUBSTANCES WHICH ARE NOT BIODEGRADABLE. WE CAN ONLY STEM THE LEGITIMATE FEARS OF THE PUBLIC IF WE INSIST THAT THE SOLID WASTE PRODUCERS, HANDLERS, HAULERS AND LANDFILL OPERATORS BE FORCED TO CONDUCT THEIR BUSINESSES IN THE SAFEST MANNER KNOWN TO MAN.

I WOULD LIKE TO MAKE NOTE AT THIS POINT THAT I AM NOT IN FAVOR OF REGULATING FOR THE SAKE OF REGULATING. GOVERNMENT HAS A TENDENCY SOMETIMES TO OVERREGULATE AND COST GOVERNMENT AND THE CONSUMER INORDINATE AMOUNTS OF MONEY. HOWEVER, THERE ARE TIMES WHEN I BELIEVE THAT GOVERNMENT MUST STEP IN AND REGULATE IN ORDER TO PROTECT THE HEALTH AND WELFARE OF THE CITIZENS. THE PRESIDENT, AS PART OF HIS PHASE II ANTI-INFLATION MESSAGE DELIVERED LAST WEEK, REQUESTED FEDERAL AGENCIES TO AVOID ISSUING REGULATIONS WHICH COULD PROVE TO BE ADVERSE TO THE PUBLIC INTEREST, INFLATIONARY, OF NON COST-EFFECTIVE. EPA MUST NOT TAKE THIS MESSAGE TO MEAN THAT THE PRESIDENT DOES NOT WANT IMPROTANT LAWS SUCH AS RCRA TO BE IMPLEMENTED. EPA SHOULD FOLLOW THE PRESIDENT'S DIRECTIVES BY REDIRECTING ITS RESOURCES TOWARD NECESSARY REGULATIONS AND ISSUING THEM AS EXPEDITIOUSLY AS POSSIBLE. IN THIS MANNER THE AGENCY WILL ALSO MEET THE PUBLIC'S EXPECTATIONS BY LIVING UP TO ITS OBLIGATION TO PRESERVE PUBLIC HEALTH, SAFETY AND THE ENVIRONMENT.

THE LOVE CANAL IS A PRIME EXAMPLE OF A "TICKING TIMEBOMB"-- AN ABANDONED LANDFILL FULL OF TOXIC SUBSTANCES WHICH LITERALLY EXPLODED IN THE FACES OF THE PEOPLE WHO LIVED IN THE SURROUNDING AREA BECAUSE A LAW, SUCH AS RCRA, HAD NOT BEEN ON THE BOOKS AND HAD NOT BEEN ENVORCED DURING THE 1940'S AND 50'S WHEN INDISCRIMINATE DUMPING OCCURRED IN THE CANAL.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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UNFORTUNATELY, RCRA DOES NOT ADDRESS THE ISSUE OF ABANDONED CHEMICAL DUMPS. THEREFORE, THERE IS NO PROVISION IN THE ACT WHICH CAN AID US IN COPING WITH THE PROBLEMS THEY LEAVE BEHIND. CONGRESS, I BELIEVE, IN ALL ITS WISDOM, SHOULD HAVE ADDRESSED THIS ISSUE IN 1976 WHEN IT ORIGINALLY PASSED THC LAW; HOWEVER, IT DID NOT, AND THEREFORE, I HAVE INTRODUCED LEGISLATION DURING THE FINAL DAYS OF THE 95TH CONGRESS WHICH I BELIEVE MIGHT HELP US ADDRESS THE PROBLEMS CREATED BY ABANDONED WASTE SITES. I WILL DISCUSS THIS BILL'S PROVISIONS A LITTLE LATER.

NEVERTHELESS, RCRA CAN HELP US PREVENT FUTURE LOVE CANALS, BUT ONLY IF EPA ACTS AND ACTS IMMEDIATELY. THERE ARE HAZARDOUS WASTE DISPOSAL AREAS CURRENTLY BEING OPERATED WHICH NEED TO BE REGULATED BETTER SO THAT THE PEOPLE WHO LIVE NEAR THEM CAN BE ASSURED THAT A FUTURE LOVE CANAL DOES NOT EXIST IN THEIR BACKYARDS. I HAVE SEVERAL SUCH AREAS OPERATING CURRENTLY IN MY OWN CONGRESSIONAL DISTRICT. WE IN NEW YORK ARE FORTUNATE BECAUSE WE HAVE STRICT LEGISLATION ON THE STATE BOOKS. HOWEVER, THE CITIZENS WHO LIVE, FOR EXAMPLE, IN LEWISTON, NEW YORK, NEAR THE SCA SERVICES, INC., SITE, ARE VERY LEARY OF THE OPERATIONS AT THE SITE BECAUSE THEY DO NOT HAVE THE ASSURANCE THAT IT IS BEING REGULATED ACCORDING TO FEDERAL STANDARDS.

NOT ONLY ARE PEOPLE AFRAID THAT THESE SITES ARE NOT BEING REGULATED ENOUGH DUE TO THE LACK OF RCRA ENFORCEMENT, BUT WE ALSO HAVE THE EXAMPLES OF PCB'S BEING DISPOSED OF ALONG THE ROADS IN NORTH CAROLINA BY A "MIDNIGHT HAULER", AND ILLEGAL WASTE DUMPERS STREWING WASTES ALONG "CANCER ALLEY" IN NEW JERSEY. THE RESULTS OF THESE ACTIONS ARE ADDITIONAL POLLUTANTS IN OUR DRINKING WATER, INCREASED BURDENS ON OUR SEWAGE TREATMENT PLANTS, INCREASED POLLUTION IN OUR RIVERS AND STREAMS, AND INCREASINGLY HIGHER AMOUNTS OF UNHEALTHY AND EVEN TOXIC CHEMICALS IN THE AIR WE BREATHE. THIS ADDITIONAL POLLUTION, MUCH OF WHICH COULD HAVE BEEN PREVENTED, COSTS TAXPAYERS ADDITIONAL MONEY, IRREPARABLY HARMS THE ENVIRONMENT, AND CREATES COSTS-- BOTH HEALTH AND FINANCIAL-- FOR THE INDIVIDUALS WHO SUFFER FROM THESE ACTIVITIES. MANY OF US UNKNOWINGLY SUFFER DUE TO THE TOXICS ENTERING THE FOOD CHAIN. THE TOXIC WASTES SETTLE ON THE FLOORS OF THE BODIES OF WATER FROM WHICH WE FISH. THE SEDIMENTS ARE EATEN BY PHYTOPLANKTON, WHICH IN TURN ARE EATEN BY THE ZOOPLANKTON, WHICH IN TURN ARE CONSUMED BY SMALL FISH.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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THE SMALL FISH ARE EATEN BY LARGER ONES AND THEN YOU AND I CONSUME THE LARGER FISH, BRINGING THE TOXICS INTO YOUR SYSTEM AND AND MINE. NEW YORK'S COMMISSIONER OF ENVIRONMENTAL CONSERVATION HAD TO BAN THE CONSUMPTION OF FISH FROM LAKE ONTARIO DUE TO UNHEALTHY AMOUNTS OF MIREX, A PESTICIDE, BEING PRESENT IN THE FISH. PCB'S IN THE HUDSON IS ANOTHER PRIME EXAMPLE OF HOW TOXIC WASTES HARM NOT ONLY THE CONSUMER, BUT ALSO THE PERSON WHO IS TRYING TO EARN A LIVING FROM OUR NATURAL RESOURCES, WHICH WOULD BE PROTECTED IF WE WOULD ENFORCE OUR LAWS.

THESE ARE JUST A FEW EXAMPLES OF THE TOTAL EXTENT OF THE HARM THAT HAS BEEN DONE TO OUR ENVIRONMENT, HEALTH AND WELL-BEING.

BY NOT HAVING ISSUED REGULATIONS FOR RCRA, EPA IS CREATING A GAPING HOLE IN OUR NATIONAL POLICY TO REDUCE THE AMOUNT OF UNCONTROLLABLE POLLUTANTS IN THE ENVIRONMENT.

OTHER LEGISLATION

CONGRESS HAS PASSED OTHER LANDMARK LEGISLATION, SUCH AS THE CLEAN AIR ACT; THE CLEAN WATER ACT; THE SAFE DRINKING WATER ACT; THE FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT, THE HAZARDOUS MATERIALS TRANSPORTATION ACT; AND THE TOXIC SUBSTANCES CONTROL ACT TO CONTROL TOXIC SUBSTANCES. RCRA IS ONLY ONE LINK IN THE CHAIN OF ENVIRONMENTAL SAFEGUARDS CONGRESS HAS ENACTED. YET AS WE ALL KNOW, A CHAIN IS ONLY AS STRONG AS ITS WEAKEST LINK. THUS, WITHOUT FULL IMPLEMENTATION OF RCRA, THE CHAIN CONGRESS HAS CREATED IS NOT COMPLETE.

YET CONGRESS, TOO, HAS BEEN TAX IN ITS RESPONSIBILITY TO FUND THE AUTHORIZING LEGISLATION LISTED ABOVE TO ITS FULL EXTENT, AND THUS HAS HELPED TO CRIPPLE EPA'S IMPLEMENTATION EFFORTS. LET ME JUST OUTLINE BRIEFLY WHAT EACH OF THESE ACTS DOES, HOW THEY TIE TOGETHER, AND THE NEED TO FUND THOSE SECTIONS DEALING WITH TOXICS TO MAKE THE CHAIN A STRONG ONE.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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THE FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT OF 1972, COMMONLY REFERRED TO AS FIFRA. THIS ACT WAS AMENDED DURING THE 95TH CONGRESS. FIFRA HELPS TO CONTROL THE ENTRY OF PESTICIDES INTO OUR WATERWAYS. ALL PESTICIDES IN THE U.S. MUST BE REGISTERED WITH EPA AND CLASSIFIED BY EPA FOR GENERAL OR RESTRICTED USE. EPA MUST ESTABLISH PROCEDURES FOR THE STORAGE AND DISPOSAL OF PESTICIDES. PROPER IMPLEMENTATION OF THIS ACT HELPS TO PREVENT WATER POLLUTION FROM NON-POINT SOURCES.

THE CLEAN AIR ACTS OF 1970 AND 1977. THESE LAWS PROVIDE FOR THE PROTECTION AND ENHANCEMENT OF AIR QUALITY THROUGH REGULATION OF POLLUTANT EMISSIONS AND ESTABLISHMENT OF AIR QUALITY STANDARDS. LEVELS OF POLLUTANTS, SUCH AS SULFUR OXIDES, PARTICULATES, HYDROCARBONS, CARBON MONOXIDE,NITROGEN OXIDES, LEAD, ETC., ARE SET FOR AMBIENT AIR STANDARDS. SECTION 112 COVERS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTION; THESE POLLUTANTS ARE CONTAINED AT THE SOURCE. ASBESTOS, BERYLLIUM, MERCURY, AND VINYL CHLORIDE ARE CURRENTLY REGULATED. ARSENIC, BENZENE, AND OTHERS ARE CURRENTLY UNDER STUDY.

ATMOSPHERIC FALLOUT FROM SUCH EMISSIONS IS NOT RECOGNIZED AS AN IMPORTANT FACTOR IN WATER POLLUTION. SCIENTISTS ESTIMATE THAT AS MUCH AS 60% OF THE PCB'S IN THE GREAT LAKES COMES FROM THE ATMOSPHERE, POSSIBLY AS A RESULT OF IMPROPER INCINERATION.

THE HAZARDOUS MATERIALS TRANSPORTATION ACT OF 1974. THIS LAW REGULATES THE TRANSPORTATION IN COMMERCE OF HAZARDOUS MATERIALS. THE SECRETARY OF TRANSPORTATION IS GIVEN WIDE LATITUDE IN DEFINING "HAZARDOUS" UNDER THIS LAW. HOWEVER, IT IS GENERALLY DEFINED AS FLAMMABLE AND COMBUSTIBLE SOLIDS, LIQUIDS OR GASSES; POISONS; OXIDIZING OR CORROSIVE MATERIALS; COMPRESSED GASSES; EXPLOSIVES AND THE LIKE.

THE SECRETARY ISSUES REGULATIONS WHICH APPLY TO THOSE OFFERING HAZARDOUS MATERIALS FOR TRANSPORT, TO THOSE MANUFACTURING CONTAINERS FOR USE IN SUCH TRANSPORT, AND TO THE TRENSPORTERS THEMSELVES.

THE COAST GUARD REGULATES MARINE TRANSPORT.

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THE SECRETARY IS AUTHORIZED TO ESTABLISH CRITERIA FOR AHNDLING, SUCH AS NUMBER, QUALIFICATION AND TRAINING OF PERSONNEL; INSEPCTIONS; USE OF EQUIPMENT; AND MONITORING AND SAFETY PROCEDURES.

THE WATER POLLUTION CONTROL ACT OF 1972 AND THE CLEAN WATER ACT OF 1977.

THESE LAWS PROVIDE FOR UNIFORM, ENFORCEABLE NATIONAL STANDARDS FOR CLEAN WATER AND REGULATIONS TO ENFORCE THEM; A NATIONAL PERMIT PROGRAM FOR POINT-SOURCE DISCHARGES; FEDERAL FUNDS TO CONSTRUCT SEWAGE TREATMENT SYSTEMS; AND STATE AND AREA-WIDE PLANNING AND MANAGEMENT PROGRAMS TO ADDRESS NON-POINT SOURCE DISCHARGES.

SECTION 307 REQUIRES EPA TO PUBLISH A LIST OF TOXIC POLLUTANTS FOR WHICH AN EFFLUENT STANDARD WILL BE ESTABLISHED.

THE CLEAN WATER ACT, AMENDING THE WATER POLLUTION CONTROL ACT OF 1972, HAS SEVERAL SECTIONS CONCERNING TOXICS WHICH I WOULD LIKE TO DISCUSS WITH YOU FOR A MOMENT.

WHEN I FIRST LEARNED OF THE POTENTIAL HORRORS AT THE LOVE CANAL-- ALL OF WHICH UNFORTUNATELY PROVED TO BE REAL, NOT JUST POTENTIAL-- I APPROACHED EPA FOR FUNDING OF THE CLEANUP OF THE CANAL UNDER BOTH RCRA AND THE CLEAN WATER ACT.

SPECIFICALLY, I DISCUSSED SECTIONS 201, 208, 311, AND 504. I BELIEVE THAT EACH SECTION, IF IMPLEMENTED IN A CREATIVE MANNER, COULD BE MOST USEFUL IN SITUATIONS SUCH AS THE LOVE CANAL. LET ME EXPLAIN.

SECTION 201 PROVIDES FOR GRANTS FOR CONSTRUCTION OF WASTEWATER TREATMENT WORKS. IT IS A $40 BILLION PROGRAM. THE SOLUTION WHICH HAS BEEN DESIGNED FOR CLEANING UP LOVE CANAL IS A MICRO SEWER SYSTEM. FRENCH TILE DRAINS ARE BEING LAID SO THE LEACHATE CAN BE COLLECTED. THE CONTAMINATED WASTES WILL THEN BE FLUSHED THROUGH A PRETREATMENT PLANT AND EVENTUALLY THROUGH THE MUNICIPAL SEWAGE TREATMENT PLANT. IF EPA WERE TO RECOGNIZE THE FACT THAT THIS PLAN OF ACTION IS, IN ESSENCE, A MICRO SEWER SYSTEM, THEN 201 FUNDS COULD BE USED IN THIS INNOVATIVE WAY. HOWEVER, EPA RESISTED THIS APPROACH FOR USE OF 201 MONEY, STATING THAT IT IS NOT A "TRADITIONAL" USE OF TESE FUNDS. LOVE CANALS ARE NOT TRADITIONAL PROBLEMS, AND I THINK EPA SHOULD BE LOOKING FOR INNOVATIVE USES OF ITS PROGRAMS FOR NEW PROBLEMS AS WELL AS TRADITIONAL ONES.

OVERSIGHT -- RESOURCE CONSERVATION AND RECOVERY ACT

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SECTION 208 IS THE SECTION OF THE LAW WHICH CALLS FOR STATE AND AREAWIDE PLANNING AND MANAGEMENT PROGRAMS TO ADDRESS NON-POINT SOURCE DISCHARGES. IT PROVIDES FOR LOCAL INPUT AND LOCALIZED PLANNING. "208 AGREEMENTS" MUST BE CERTIFIED BY THE GOVERNOR AND NO 201 GRANTS CAN BE AWARDED WITHOUT THE 208 AGREEMENT IN PLACE. IT MUST BE REVIEWED AND UPDATED EACH YEAR AS NECESSARY.

I ATTEMPTED TO GET NEW YORK STATE TO AGREE TO USE SOME OF ITS FUNDS FROM THE 208 PROGRAM FOR PLANNING AT THE LOVE CANAL. THIS WAS ALSO MET WITH RESISTANCE, HOWEVER, BECAUSE THE PROBLEM WAS NOT INTERPRETED TO BE WITHIN THE INTENT OF THE LAW. TOXIC CONTAMINATION OF GROUNDWATER AT MUSKEGON, MICHIGAN, WAS TRACED TO SEEPAGE LAGOONS, BURIED SLUDGES AND CORRODING WASTE BARRELS AT A CHEMICAL PLANT. NO ONE YET KNEW IF THE LOVE CANAL PROBLEMS HAD REACHED SUCH EXTREMES BECAUSE DEEP WATER WELLS HAD NOT YET BEEN DUG BY EITHER THE STATE OR EPA. HOWEVER, IT WOULD SEEM TO ME THAT THE QUESTION OF WHETHER THERE WAS DEEP WASTER CONTAMINATION, AND THE PLANNING WHICH WOULD HAVE TO GO HAND IN HAND WITH SUCH A PROGRAM WOULD FIT UNDER THE INTENT OF SECTION 208. AGAIN, I THINK WE NEED TO USE MORE CREATIVITY IN THE IMPLEMENTATION OF THE LAWS WE HAVE TO ADDRESS PROBLEMS OF WHICH WE ARE ONLY NOW BECOMING AWARE.

SECTION 311 PROVIDES FOR THE DESIGNATION OF HAZARDOUS SUBSTANCES WHICH, WHEN DISCHARGED, PRESENT AN IMMINENT AND SUBSTANTIAL DANGER TO THE PUBLIC HEALTH OR WELFARE, AND PROVIDES FOR PENALTIES FOR SUCH DISCHARGES. A NATIONAL CONTINGENCY PLAN IS TO PROVIDE FOR EFFECTIVE ACTION TO MINIMIZE DAMAGE FROM OIL AND HAZARDOUS DISCHARGES. A REVOLVING FUND IS AUTHORIZED TO PAY FOR CLEAN UP OF SPILLS OF OIL AND HAZARDOUS WASTES, WITH EPA'S ADMINISTRATOR GIVEN AUTHORITY TO SEEK TO RECOVER COSTS FROM POLLUTERS THROUGH THE JUDICIAL PROCESS.

EPA WAS FIVE YEARS LATE IN ISSUING THE REGULATIONS FOR HAZARDOUS SUBSTANCES UNDER 311. IT WAS AFTER MY URGING THAT THESE REGULATIONS WERE FINALLY PROMULGATED, IN MARCH OF THIS YEAR. THE REGULATIONS, HOWEVER, WERE CHALLENGED IN THE COURTS AND DISMISSED BY THE JUDGE, WHO CALLED THEM ARBITRARY AND CAPRICIOUS. THUS, USE OF SECTION 311 IS ONCE AGAIN A MOOT POINT. I HOPE EPA WILL NOT TAKE AS LONG THE SECOND TIME AS IT DID THE FIRST, AND ISSUES A NEW SET OF REGULATIONS IMMEDIATELY.

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FINALLY THERE IS SECTION 504 OF THE CLEAN WATER ACT WHICH AUTHORIZES THE ADMINISTRATOR TO PROVIDE ASSISTANCE IN EMERGENCIES CAUSED BY THE RELEASE INTO THE ATMOSPHERE OF ANY POLLUTANT OR OTHER CONTAMINANT INCLUDING, BUT NOT LIMITED TO, THOSE WHICH PRESENT, OR MAY REASONABLY BE ANTICIPATED TO PRESENT, AN IMMINENT AND SUBSTANTIAL DANGER TO THE PUBLIC HEALTH OR WELFARE.

THIS SECTION ADDRESSES MOST FITTINGLY SITUATIONS SUCH AS THE LOVE CANAL. I, ALONG WITH THE ASSISTANCE OF MY SENATE COLLEAGUES FROM NEW YORK, TRIED TO OBTAIN FUNDING FOR THE CANAL UNDER SECTION 504. BOTH MR. JAVITS AND MR. MOYNIHAN SPOKE VERY ELOQUENTLY ON THE FLOOR OF THE SENATE IN BEHALF OF AN AMENDMENT TO THE SUPPLEMENTAL APPROPRIATIONS BILL OF FISCAL YEAR 1978 IN AN ATTEMPT TO OBTAIN FUNDING FOR THE CLEAN UP OF THE LOVE CANAL IN ORDER TO ABATE THE HEALTH AND ENVIRONMENTAL EMERGENCY. HOWEVER, FUNDING UNDER SECTION 504 WAS OBJECTED TO DUE TO A FEAR THAT FUNDING UNDER SECTION 504 FOR ANY SITUATION WOULD "OPEN THE PROVERBIAL FLOODGATES" FOR FUNDING FOR ANY SIMILAR SITUATION. I'M NOT SURE THIS ARGUMENT IS A GOOD ONE WHEN BALANCED AGAINST OUR DUTY TO PROTECT THE HEALTH AND WELFARE OF OUR CITIZENS WHEN THEY ARE UNABLE TO PROTECT THEMSELVES WITHOUT OUTSIDE ASSISTANCE. CONGRESS INCLUDED SECTION 504 IN THE CLEAN WATER ACT OF 1977 FOR SITUATIONS JUST LIKE THE LOVE CANAL. CONGRESS AUTHORIZED $10 MILLION FOR THIS SECTION AND YET, TO DATE, NOT ONE PENNY HAS BEEN APPROPRIATED FOR IT. THIS IS ONE AREA IN WHICH IT IS UP TO THE CONGRESS TO ACT.

THE SAFE DRINKING WATER ACT OF 1974. THIS LAW REQUIRES EPA TO ESTABLISH REGULATIONS FOR DRINKING WATER APPLICABLE TO PUBLIC WATER SYSTEMS. THESE APPLY ONLY TO WATER AFTER TREATMENT AND ADDRESS MAXIMUM CONTAMINANT LEVELS ALLOWED (HEALTH RELATED) AS WELL AS THOSE AFFECTING TASTE, ODOR, OR APPEARANCE.

TO PROTECT UNDERGROUND SOURCES OF DRINKING WATER, EPA MUST ALSO DEVELOP REGULATIONS FOR STATE UNDERGROUND INJECTION CONTROL PROGRAMS.

THE ACT GIVES THE STATES PRIMARY ENFORCEMENT RESPONSIBILITY, BUT IF THEY FAIL TO ACT, EPA MUST ASSUME RESPONSIBILITY.

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VERY LITTLE MONEY IS AVAILABLE UNDER THIS LAW TO THE MUNICIPALITIES TO BRING THEIR DRINKING WATER SUPPLIES INTO COMPLIANCE WITH FEDERAL STANDARDS - A FACT WHICH IS NOW CAUSING MANY COMMUNITIES TO SUFFER A HEAVY FINANCIAL BURDEN. HOWEVER, THE COSTS FOR CLEANING UP OUR DRINKING WATER SUPPLIES PERHAPS WOULD NOT BE SO HIGH IF THE CLEAN WATER ACT, CLEAN AIR ACT, AND ALL THE OTHERS WHICH FORM THE CHAIN WERE TO BE ENFORCED TO THE MAXIMUM EXTENT.

THE TOXIC SUBSTANCES CONTROL ACT OF 1976. THIS LAW GIVES EPA BROAD DISCRETIONARY AUTHORITY TO CONTROL HAZARDOUS CHEMICAL SUBSTANCES, EXCLUDING PESTICIDES WHICH ARE COVERED UNDER FIFRA. IT PROVIDES FOR DIRECT CONTROL OF NEW AND EXISTING CHEMICALS, REQUIRES PREMARKET SCREENING OF NEW CHEMICALS, AND PROVIDES AUTHORITY TO REQUIRE THE TESTING OF A CHEMICAL'S TOXICITY.

IF AN UNREASONABLE RISK IS POSED BY A CHEMICAL, THE EPA CAN PROHIBIT OR LIMIT ITS MANUFACTURE, PROCESSING, DISTRIBUTION, USED AND DISPOSAL THROUGH ADMINISTRATIVE RULEMAKING.

THE EPA CAN ALSO INITIATE CIVIL ACTION IN A FEDERAL DISTRICT COURT TO ALLEVIATE ANY IMMINENT HAZARD TO HEALTH OR ENVIRONMENT.

INFORMATION IS NOW BEING GATHERED UNDER TSCA ABOUT THE 70,000 COMMERCIAL CHEMICALS NOW IN USE AND THE POTENTIAL HAZARDS WE MIGHT FACE FROM ANY ONE OF THEM. THIS ACT WILL HELP US IN THE FUTURE TO CONTROL TOXICS AT THE SOURCE, WHILE RCRA WILL HELP US CONTROL TOXICS DURING THE COURSE OF THEIR DISPOSAL.

AS YOU CAN NOTE, EACH OF THESE LAWS FORMS A LINK IN THE CHAIN TO PROTECT US AGAINST TOXIC SUBSTANCES IN OUR ENVIRONMENT. BUT WITHOUT IMPLEMENTATION OF RCRA, THE CHAIN FALLS APART. BOTH A NEW LAW AND CHANGES IN RCRA ARE NEEDED.

BUT TODAY'S HEARINGS SHOULD GO EVEN FARTHER THAN TO DISCUSS THE OVERSIGHT OF THE PRESENT LAW, FOR RCRA COMES UP FOR REAUTHORIZATION NEXT YEAR. THUS, WE MUST BE CONCERNED WITH THE FUTURE AS WELL AS THE PAST. WE MUST ASK OURSELVES IF RCRA WOULD GO FAR ENOUGH TO PROTECT THE ENVIRONMENT AND CITIZENRY EVEN IF IT WERE FULLY IMPLEMENTED.

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BOTH CHANGES IN RCRA AND A NEW LAW ARE NEEDED

I BELIEVE THERE ARE SOME INHERENT PROBLEMS WITH THE LAW AS IT NOW WRITTEN AND SOME HOLES IN THE OVERALL APPROACH WE HAVE TAKEN TO THE COMPENSATION OR LACK OF COMPENSATION OF VICTIMS OF TOXIC POLLUTANTS IN THE ENVIRONMENT.

I INTRODUCED TWO BILLS INTO CONGRESS DURING THE LAST DAYS OF THE 95TH SESSION WHICH I HOPE WILL SERVE AS A BASIS FOR DISCUSSION AND BE INCLUDED IN THE REAUTHORIZATION BILL FOR RCRA.

THE FIRST BILL I INTRODUCED IS INTENDED TO HELP PREVENT HAZARDOUS SUBSTANCES FROM BEING HANDLED OR DISPOSED IN WAYS THAT THREATEN INJURIES TO AMERICAN CITIZENS OR TO THE ENVIRONMENT.

MY BILL WILL, I BELIEVE, HELP TO FILL THE GAPS WHICH HAVE BECOME EVIDENT IN THE RCRA BY AMENDING IT TO: ESTABLISH A PROGRAM FOR THE IDENTIFICATION AND RECLAMATION OF ABANDONED HAZARDOUS WASTE SITES; SET FEES TO BE PAID BY PRIVATE ORGANIZATIONS WHICH SOTRE OR DISPOSE OF HAZARDOUS WASTES; PROVIDE FOR A PROCESS FOR THE SELECTION OF SITES FOR FUTURE DISPOSAL OF HAZARDOUS WASTES.

MORE SPECIFICALLY, MY BILL STATES THAT A CONCERTED EFFORT MUST BE MADE TO IDENTIFY ALL ABANDONED LANDFILL SITES THAT DO OR MAY CONTAIN HAZARDOUS WASTES, AND ONCE THEY ARE IDENTIFIED THEY MUST BE RECLAIMED, IF FEASIBLE. IF RECLAMATION IS NOT FEASIBLE THEY MUST BE MONITORED TO ENSURE THAT PUBLIC AND ENVIRONMENTAL HEALTH AND SAFETY ARE NOT ENDANGERED. MY BILL ESTABLISHES A JOINT STATE/ FEDERAL PROCEDURE FOR ACCOMPLISHING THESE DIRECTIVES.

ADDITIONALLY, WHEN RCRA WAS PASSED IN 1976, FEW FORESAW THE WIDESPREAD PUBLIC OPPOSITION TO NEW HAZARDOUS WASTE DISPOSAL SITES WHICH HAS SWEPT THE NATION. THE GENERAL PUBLIC WAS NOT THEN FULLY AWARE OF THE LARGE NUMBER OF ABANDONED SITES THROUGHOUT THE COUNTRY, THE DELETERIOUS EFFECTS THEY WERE HAVTNG ON PEOPLE'S HEALTH AND SAFETY, AND THEIR DIRE IMPACT ON THE ENVIRONMENT. NO THAT PUBLIC AWARENESS HAS GROWN, IN PART DUE TO THE LOVE CANAL EMERGENCY, CITIZENS ARE UNDERSTANDABLY LEERY ABOUT THE DUBIOUS HONOR OF HAVING A NEW SITE PROPOSED FOR LOCATION IN THEIR BACKYARDS.

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HOWEVER, AS I NOTED EARLIER, THE HAZARDOUS WASTE DISPOSAL SITUATION IS HERE TO STAY. OUR ADVANCED TECHNOLOGY AND MANUFACTURING PROCESSES MUST PRODUCE WASTES AS BY-PRODUCTS OF THOSE VERY ACTIVITIES WHICH ALLOW US TO ENJOY ONE OF THE HIGHEST STANDARDS OF LIVING IN THE WORLD.

THEREFORE, WE MUST CREATE A PROGRAM AND PROCESS FOR LOCATING NEW FACILITIES FOR THE TREATMENT, STORAGE, AND DISPOSAL OF HAZARDOUS WASTE MATERIALS IN AS RATIONAL, EFFECTIVE AND EQUITABLE A MANNER AS POSSIBLE. THAT IS PRECISELY WHAT MY BILL IS INTENDED TO PROVIDE. A PERMIT SYSTEM WILL BE ESTABLISHED UNDER WHICH PERMITS WILL BE ISSUED ONLY AFTER ASSURANCES ARE GIVEN ABOUT THE ENVIRONMENTAL SAFETY AND SOUNDNESS OF ANY NEW FACILITY'S LOCATION. AFFECTED LOCAL RESIDENTS, LOCAL GOVERNMENTS AND STATES WOULD BE INCLUDED IN THE PROCESS AND MUST BE CONSULTED, AND PANLES OF SCIENTIFIC EXPERTS WOULD BE FORMED TO HELP ANSWER THE MANY QUESTIONS THAT ARISE IN SUCH SITUATIONS.

MY BILL ALSO CREATES A PROGRAM FOR THE TERMINATION OF EXISTING OR NEW HAZARDOUS WASTE DISPOSAL SITES IN A SAFE MANNER. THIS IS MOST IMPORTANT, FOR IT WILL PROVIDE ASSURANCES TO COMMITTEES SURROUNDING SUCH SITES THAT THEY WILL NOT CAUSE PROBLEMS IN THE FUTURE SUCH AS THOSE WE ARE EXPERIENCING AS A RESULT OF PAST LANDFILL SITES BEING ABANDONED AND IMPROPERLY SEALED.

THE BILL WOULD INITIATE A SYSTEM OF FEES TO BE LEVIED ON PERMIT HOLDING OPERATORS OF HAZARDOUS WASTE TREATMENT, STORAGE OR DISPOSAL FACILITIES. THE FEES WILL BE DEPOSITED INTO A FUND TO BE USED FOR TWO PURPOSES: 1) THE MAINTENANCE OF NEW OR EXISTING SITES AND 2) THE MAINTENANCE AND RECLAMATION OF ABANDONED SITES.

HALF OF ALL FEES COLLECTED WILL BE PAID INTO A SPECIAL ACCOUNT AND USED FOR NEW SITE MAINTENANCE. THE FEES WILL BE SET AT A LEVEL SUFFICIENT TO ASSURE THAT ALL COSTS FOR MAINTENANCE WILL BE BORNE BY THIS ACCOUNT, THUS MAKING THIS A PROGRAM FUNDED ENTIRELY BY THE INDUSTRY WHICH CREATED THE NEED FOR THE PROGRAM IN THE FIRST PLACE. THESE COSTS, PREVIOUSLY BORNE BY SOCIETY IN GENERAL THROUGH ENVIRONMENTAL AND HEALTH HAZARDS AND DAMAGES, WILL NOW BE SHIFTED TO THE INDUSTRY THROUGH THIS USER FEE.

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THE OTHER HALF OF THE FEES WILL BE DEPOSITED INTO A SECOND FUND TO HELP DEFRAY THE COSTS OF MONITORING AND RECLAIMING ABANDONED SITES. IT IS ANTICIPATED THAT THE FEES WILL PROVIDE 50% OF THE COSTS; THE REMAINDER NEEDED FOR THESE PURPOSES WOULD BE PROVIDED THROUGH A FEDERAL/STATE PROGRAM FUNDED ON A 90-10 BASIS.

MY BILL WOULD ALSO ESTABLISH A PROGRAM AND CONTINGENCY FUND FOR EMERGENCY ASSISTANCE AND PAYMENT OF COSTS FOR CLEAN UP OPERATIONS IN THE EVENT THAT ANY POLLUTANT OR CONTAMINANT ASSOCIATED WITH ANY FACILITY FOR THE TREATMENT, STORAGE OR DISPOSAL OF HAZARDOUS WASTE PRESENT AN IMMINENT AND SUBSTANTIAL DANGER TO THE PUBLIC HEALTH AND WELFARE. THIS PROVISION IS ACCOMPANIED BY THE PROVISION THAT THE GOVERNMENT MAY BRING ACTION AGAINST OWNERS OR OPERATORS OF FACILITIES WHERE SUCH EMERGENCIES ARISE TO RECOVER THE COSTS OF THE CLEAN UP OPERATIONS.

THE SECOND BILL I INTRODUCED WAS THE TOXIC POLLUTANT COMPENSATION ACT, DESIGNED TO PROVIDE RELIEF TO ALL PERSONS INJURED AS A RESULT OF TOXIC POLLUTANTS IN OUR ENVIRONMENT. ESSENTIALLY THE BILL DISTINGUISHES AMONG THREE CLASSES OF VICTIMS - THOSE WHO HAVE SUSTAINED THEIR INJURIES AS A RESULT OF THE FAULT OF THE MANUFACTURER, THOSE VICTIMS WHO SUSTAINED THEIR INJURIES IN THE COURSE OF THEIR EMPLOYMENT, AND THOSE VICTIMS WHO SUSTAINED THEIR INJURIES AS A RESULT OF A TOXIC POLLUTANT, BUT WITHOUT FAULT. WHILE THE BILL TREATS EACH OF THESE THREE CLASSES SOMEWHAT DIFFERENTLY, IT DOES PROVIDE A CENTRAL THEME: THE ENVIRONMENTAL PROTECTION AGENCY IS DIRECTED TO STUDY PHYSICAL INJURIES AND TO DETERMINE WHICH SUCH INJURIES ARE CAUSED BY TOXIC POLLUTANTS. IN MAKING THIS DETERMINATION, EPA WILL TAKE INTO ACCOUNT THE EXPOSURE TO THE TOXIC POLLUTANT - BOTH AS TO TIME AND PLACE - NECESSARY TO PRODUCE THE PHYSICAL INJURY. EPA'S DETERMINATION WILL GREATLY EXPEDITE THE COMPENSATION PROCESS SINCE THE BILL PROVIDES FOR THE UTILIZATION OF THIS FINDING IN SUBSEQUENT LEGAL AND/OR ADMINISTRATIVE PROCEEDINGS.

THE MEASURE ALSO PROVIDES FOR THE CREATION OF A COMPENSATION AGENCY. GENERALLY, THIS AGENCY WILL PAY BENEFITS UP TO $50,000 TO PERSONS (OTHER THAN EMPLOYEES) WHO HAVE SUSTAINED INJURY AS A RESULT OF TOXIC POLLUTANTS. THESE BENEFITS WILL BE AVAILABLE REGARDLESS OF WHETHER OR NOT A MANUFACTURER IS ULTIMATELY DETERMINED TO BE RESPONSIBLE FOR THE PHYSICAL INJURIES. HOWEVER, IN THE EVENT THAT A MANUFACTURER IS AT FAULT, EPA WILL BE SUBROGATED TO THE RIGHTS OF THE INJURED PERSON, AND WILL EITHER SHARE IN ANY RECOVERY HE MAY RECIEVE OR INITIATE ITS OWN ACTION AGAINST THE PERSON AT FAULT.

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CONCLUSION

AS I HAVE TRIED TO POINT OUT THROUGHOUT MY TESTIMONY, THERE IS A NEED FOR A GREATER LEGISLATIVE AND REGULATORY ROLE IN THE CONTROL OF TOXICS IN THE ENVIRONMENT, ESPECIALLY IN REGARD TO ITS ULTIMATE DISPOSAL. EPA, AS THE FEDERAL REGULATORY AGENCY AND CONGRESS, AS THE LEGISLATIVE BODY, HAVE BOTH MORAL AND LEGAL OBLIGATIONS TO THE CITIZENS OF THIS COUNTRY TO DO EVERYTHING POSSIBLE TO PROTECT THEIR HEALTH, WELFARE AND ENVIRONMENT.

THE ENVIRONMENTAL PROTECTION AGENCY HAS STATED THAT THERE ARE MORE THAN 25,000 TICKING TIMEBOMBS AROUND THE COUNTRY. DO YOU KNOW IF THERE ARE ANY IN YOUR BACKYARD, NEIGHBORHOOD OR CONGRESSIONAL DISTRICT?

I KNOW THERE ARE 39 ABANDONED DUMPS IN NIAGARA COUNTY ALONE IN MY CONGRESSIONAL DISTRICT, MUCH OF THE CONTENTS OF WHICH ARE UNKNOWN. I KNOW THAT THERE ARE CASES PERTAINING TO ENVIRONMENTAL INCIDENTS IN DANVILLE, ILLINOIS; AKRON, OHIO; LOWELL, MASSACHUSETTS; AND SEYMOUR, INDIANA, WHICH THE EPA ENFORCEMENT DIVISIONS CONSIDER TO BE EMERGENCIES.

IF ANOTHER TICKING TIMEBOMB EXPLODES, CAN WE AS FEDERAL OFFICIALS AND MEMBERS OF CONGRESS SAY THAT WE HAVE ACTED RESPONSIBLY?

BUT MORE IMPORTANTLY, THE CITIZENS OF THIS COUNTRY ENTRUSTED US TO LEGISLATE AND EPA TO ENFORCE LAWS TO SAFEGUARD THEIR HEALTH AND WELFARE, AND TO PROTECT THE ENVIRONMENT SO THAT OUR COUNTRY CAN BE A SUITABLE PLACE IN WHICH SUCCESSIVE GENERATIONS CAN LIVE. CAN WE SAY THAT WE HAVE DONE ALL WE CAN TO PREVENT ANOTHER ENVIRONMENTAL AND HEALTH TRAGEDY FROM OCCURING?

THANK YOU FOR ALLOWING ME TO APPEAR BEFORE YOU THIS MORNING.

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MR. GORE. WITH THE TRAGEDY YOU HAVE EXPERIENCED IN YOUR CONGRESSIONAL DISTRICT, I UNDERSTAND THE AMOUNT OF ATTENTTON YOU WANT TO DEVOTE TO IT. IT WAS A VERY EXCELLENT STATEMENT. I HAVE READ IT IN ITS TOTALITY AND IT WILL BE INCLUDED IN TOTALITY IN THE RECORD.

THANK YOU BOTH VERY MUCH FOR HELPING US IN OUR INVESTIGATION INTO THIS VERY SERIOUS PROBLEM. YOU ARE WELCOME TO JOIN US ON THE DAIS FOR PARTICIPATING IN QUESTIONS, IF YOU WISH.

OUR NEXT WITNESSES ARE MR. AND MRS. WOODROW STERLING FROM TOONE, TENN.

IF YOU WOULD COME AND JOIN US AT THE WITNESS TABLE THERE. WOULD YOU STAND AND BE SWORN, PLEASE. THIS IS A PROCEDURE WE NORMALLY GO THROUGH. DO YOU SWEAR THE TESTIMONY YOU ARE ABOUT TO GIVE WILL BE THE TRUTH, THE WHOLE TRUTH, AND NOTHING BUT THE TRUTH, SO HELP YOU GOD?

MR. STERILING. I DO.

MRS. STERLING. I DO.

MR. GORE. WOULD YOU IDENTIFY YOURSELVES TO THE REPORTER.

TESTIMONY OF WOODROW STERLING AND CHRISTINE STERLING, TOONE, TENN.

MR. STERLING. YES. MY NAME IS WOODROW STERLING.

MRS. STERLING. AND I AM CHRISTINE STERLING.

MR. GORE. THANK YOU VERY MUCH. I AM GOING TO ASK OUR COUNSEL, TOM GREENE, TO GET A LOT OF THE FACTS ON THE RECORD WITH YOU SO WE CAN LAY OUT THE INCREDIBLE STORY YOU HAVE LIVED THROUGH.

MR. GREENE. THANK YOU, MR. CHAIRMAN.

LET ME DEAL VERY QUICKLY WITH TWO BUSINESS MATTERS FIRST. STAFF WILL REQUEST PERMISSION TO INTRODUCE DOCUMENTS AS NECESSARY AND APPROPRIATE IN THE COURSE OF TODAY'S HEARING.

MR. GORE. WITHOUT OBJECTION, IT IS SO ORDERED.

MR. GREENE. SECOND, I WOULD LIKE THE CLERK TO PROVIDE THE STERLINGS WITH THE PACKET OF DOCUMENTS WHICH WE HAVE PREPARED FOR THEIR REVIEW AND FOR THE REVIEW OF THE MEMBERS TODAY.

MR. GORE. WITHOUT OBJECTION.

MR. GREENE. THANK YOU, MR. CHAIRMAN.

(TESTIMONY RESUMES ON P. 212.)

(THE DOCUMENTS REFEREED TO FOLLOW).

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EXHIBIT A

VELSICOL TRUCK WITH WASTE DRUMS AT TRENCH. PHOTOGRAPH TAKEN AT THE VELSICOL PESTICIDE WASTE DUMP; TOONE-TEAGUE ROAD; HARDEMAN COUNTY, TENNESSEE; TAKEN JUNE 1966

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WASTES ARE DUMPED INTO TRENCH.

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DAMAGED BARRELS RELEASE CONTENTS IN TRENCH.

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WASTES AND DRUMS SURFACE PRIOR TO FILL.

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WASTE DRUMS ARE COVERED WITH SHALLOW LAYER OF EARTH.

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EXHIBIT AA

HARDEMAN COUNTY DUMP SITE . . . DEPRESSION IN EARTH DEVELOPED ABOVE BURIAL TRENCH.

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/1/ CARCINOGENS OR SUSPECTED CARCINOGENS.

EXHIBIT B PARTIAL LIST OF PESTICIDE AND PESTICIDE DEGRADATION COMPOUNDS BURIED AT THE VELSICOL HARDEMAN COUNTY DUMP SITE. (1964-1972)

HEPTACHLOR /1/

DIELDRIN /1/

ENDRIN /1/

HEPTACHLOR EXPOSIDE /1/

PENTACHLOROCYCLOPENTADIENE

HEXACLOROBICYCLOHEPTADIENE

CHLORDENE

ISODRIN

ALDRIN /1/

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MICROFORM REFILMED; SEE APPENDICES.

EXHIBIT C PUBLIC HEALTH DEPARTMENT OF THE STATE OF TENNESSEE IN THE MATTER OF VELSICOL CHEMICAL CORPORATION MEMPHIS, SHELBY COUNTY, TENNESSEE DIVISION OF WATER QUALITY CONTROL DAVIDSON COUNTY COMPLAINT

COMES NOW THE COMMISSIONER OF THE DEPARTMENT OF PUBLIC HEALTH, STATE OF TENNESSEE, EUGENE W. FOWINKLE, M.D., OR HIS DULY AUTHORIZED REPRESENTATIVE, HENRY JONES, DIRECTOR, DIVISION OF WATER QUALITY CONTROL, AND THE STATES THAT:

1. VELSICOL CHEMICAL CORPORATION, MEMPHIS, SHELBY COUNTY, TENNESSEE, OWNS AND HAS POSSESSION OF APPROXIMATELY 242 ACRES OF LAND LOCATED IN HARDEMAN COUNTY, TENNESSEE. THE DESCRIPTION OF SAID PROPERTY FOUND IN DEED BOOK C-4, PAGE 417, COUNTY REGISTRAR, BOLIVAR, HARDEMAN COUNTY, TENNESSEE, IS AS FOLLOWS:

BEGINNING AT A POINT IN THE TOONE AND TEAGUE PUBLIC ROAD SOUTH 55 1/4 DEGREES WEST 56 LINKS FROM ONE HICKORY POINTER AND SOUTH 31 DEGREES EAST 32 1/2 FROM ANOTHER HICKORY POINTER, NORTH 37 1/2 DEGREES EAST (VARIATION FOR HILLHOUSE 65 ACRES ALONG THIS ROAD IS ABOUT 4 1/2 DEGREES EAST IN 1915 AND FOR ALL OTHER LINES OF THIS BRADFORD TRACT ALONG ROAD WAS 3-3/4 DEGREES EAST IN 1915) 11 POLES TO THE POINT IN ROAD, WHITE OAK POINTERS, NORTH 17 1/2 DEGREES EAST 40 POLES TO A STAKE ON THE WEST MARGIN OF ROAD; NORTH 12-3/4 DEGREES EAST 20.9 POLES TO A DOUBLE WHITE OAK, THE CORNER ABSOLUTE ON WEST MARGIN OF SIAD TOONE AND TEAGUE ROAD, THE SOUTHEAST CORNER OF A 65 ACRE TRACT CONVEYED BY GEO. BRADFORD TO JACK WILLOUGHBY; HENCE WITH THE SAME AS BEFORE NAMED NORTH 16 DEGREES EAST 50 1/2 POLES TO A POINT IN ROAD; NORTH 26 DEGREES EAST 12 POLES TO THE POINT IN ROAD; NORTH 18 DEGREES WEST CUTTING ACROSS AN ABRUPT BEND OF ROAD 36 POLES TO A POINT IN THE WEST MARGIN OF ROAD, FORMERLY A DOUBLE RED OAK; NORTH AGAIN CUTTING ACROSS BEND OF ROAD 33 POLES TO A POINT IN SAID ROAD WITH A CRAB APPLE POINTER, ALSO A PERSIMMON POINTER STANDING SOUTH 30 1/4 DEGREES WEST 32 LINKS FROM THE CORNER; THENCE LEAVING SAID HILLHOUSE'S NORTHEAST CORNER ABOUT FOLLOWING SAID ROAD NORTH 36 DEGREES WEST 44 POLES TO A POINT ON THE WEST MARGIN OF SAID ROAD; NORTH 11-3/4 DEGREES WEST 36 POLES TO A POINTER ON EAST MARGIN OF SAID ROAD; NORTH 28 1/2 DEGREES WEST 26 POLES TO A STAKE ON NORTH SIDE OF SAID ROAD, SOUTH 21/2 DEGREES WEST 31 1/2 LINKS FROM A DOUBLE SASSAFRAS ON NORTHWEST CORNER OF FIELD; NORTH 62 DEGREES EAST 24.6 POLES TO A STAKE ON EAST MARGIN OF SAID ROAD; NORTH 9-3/4 DEGREES EAST 23-1/3 POLES TO A STAKE IN NEAR CENTER OF SAID ROAD; NORTH 36 DEGREES WEST 15 1/2 LINKS FROM A BLACK OAK POINTER, AND SOUTH 56 1/4 DEGREES EAST 20 LINKS FROM A SMALL DOUBLE SWEET GUM POINTER ON THE SOUTH BOUNDARY OF WILLIAM J.RHODES LAND; THENCE WITH THE SAME EAST (V. 3-3/4 DEGREES EAST IN 1908) 84.6 POLES TO A STAKE WITH POST OAK AND DOGWOOD POINTERS, THE NORTHEAST CORNER OF A 192 1/2 ACRE TRACT GRANTED TO W.D. RUFFIN DEC. 1, 1951 AND ON THE WEST BOUNDARY OF ENTRY NO. 339 FOR 142 ACRES IN THE NAME OF J. B. MILLER; THENCE WITH THE WEST LINE OF A 17 ACRE TRACT SOLD BY WILLIAM J. RHODES TO GEO. L. BRADFORD, NORTH 2 DEGREES EAST (V. 3-3/4 DEGREES EAST IN 1915) 12.6 POLES TO A WHITE OAK WITH DOGWOOD POINTERS, THE NORTHWEST CORNER OF THE SAME; THENCE NORTH 65 1/2 DEGREES EAST 30.3 POLES TO A STAKE WITH BLACK GUM AND DOGWOOD POINTERS, THE NORTHEAST CORNER OF SAID 17 ACRES; THENCE EAST 43.4 POLES TO A STAKE WITH TWO BLACK GUM POINTERS ON THE RIGHT-OF-WAY OF THE I.C.R.R.; THENCE WITH THE SAME SOUTH 1 1/2 DEGREES EAST 54.7 POLES; SOUTH 2 1/2 DEGREES WEST 16 POLES; SOUTH 10-3/4 DEGREES WEST 40 POLES; SOUTH 12-1/8 DEGREES WEST 34 POLES; SOUTH 7 1/4 DEGREES WEST 72 POLES; SOUTH 21 1/2 DEGREES WEST 56 POLES; SOUTH 15 DEGREES WEST 19 POLES; SOUTH 7-1/8 DEGREES WEST 12 POLES; SOUTH 4 1/2 DEGREES WEST 80.16 POLES TO A STAKE ON SAID RIGHT-OF-WAY LINE WITH A BLACK OAK STUMP POINTERS, THE NORTHWEST CORNER OF B. N. HILLHOUSE'S LAND; THENCE WITH THE SAME WEST (V.4 DEGREES EAST IN 1915) 102.6 POLES TO THE BEGINNING, AND BEING THE SAME TRACT OF LAND CONVEYED TO BOND BROS. AND HOWARD POWELL BY J.B. BRADFORD BY DEED RECEIVED IN DEED BOOK L-3, PAGE 133, AND SAID LAND BEING CONVEYED BY BOND BROS. AND HOWARD POWELL TO CHAS. G. FRADY.

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AND BEING THE SAME REAL ESTATE CONVEYED TO WILSON G. KEYES

BY WARRANTY DEED DATED THE 9TH DAY OF JULY, 1964, AND RECORDED

IN BOOK C-4, AT PAGE 377, IN THE OFFICE OF THE REGISTER OF

HARDEMAN COUNTY, TENNESSEE.

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VELSICOL CHEMICAL CORPORATION USES SAID PROPERTY AS A BURIAL GROUND FOR RESIDUES, BY-PRODUCTS AND SOLID WASTE MATERIALS FROM THE PRODUCTION OF CHLORINATED HYDROCARBON PESTICIDES AT ITS PLANT IN MEMPHIS, SHELBY COUNTRY, TENNESSEE.

VELSICOL CHEMICAL CORPORATION HAS BEEN USING THE PROPERTY DESCRIBED IN PARAGRAPH 1, AS A DUMP FOR APPROXIMATELY SEVEN (7) YEARS. THE COMPANY TRANSPORTS BY TRUCK THE AFOREMENTIONED SUBSTANCE, CONTAINED IN 59 GALLON DRUMS, FROM MEMPHIS, TENNESSEE, SO SAID PROPERTY IN HARDEMAN COUNTY, AND DEPOSITED.

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THERE IS IN THE GROUND NOW, APPROXIMATELY ONE QUARTER MILLION, 55 GALLON DRUMS OF RESIDUES. IN MANY INSTANCES, THE DRUMS BURST UPON IMPACT WITH THE GROUND, SPILLING THEIR CONTENTS INTO THE SOIL. NO CARE IS TAKEN TO INSURE AGAINST BURSTING DRUMS AND THE TRENCHES ARE NOT LINED WITH ANY IMPERMEABLE MATERIAL TO PREVENT THESE CHLORINATED HYDROCARBON COMPOUNDS FROM LEACHING INTO THE SOIL.

3. THE AFOREMENTIONED SUBSTANCES BEING BURIED AT THE HARDEMAN COUNTY DUMP SITE CONTAIN SIGNIFICANT PERCENTAGES OF CHLORINATED HYDROCARBONS. THE DANGERS PRESENTED BY THESE COMPOUNDS ARE DIRECTLY RELATED TO THEIR HIGH TOXICITY, AND PERSISTENT TOXICITY OVER LONG PERIODS TIME. AMONG THE COMPOUNDS FOUND AT THE DUMP ARE ENDRIN, DIELDRIN, ALDRIN, HEPTACHLOR, ISODRIN, HEXACHLOROCYCLOPENTADIENE, AND HECACHLOROBICYCLOHEPTADIENE. THE CHARACTERISTICS OF THESE COMPOUNDS WHICH CREATE A DANGER TO BOTH MAN AND THE ENVIRONMENT INCLUDE EXTREME TOXICITY EVER LONG PERIODS OF TIME, INDICATING VERY SLOW DEGRADATION; NEAR INSOLUBILITY IN WATER WITH THE TENDENCY TO CLING OR ADHERE TO PARTICULATE MATTER; AND THE ABILITY TO ACCUMULATE IN THE FATTY TISSUES OF MOST ANIMALS AND TO BE ABSORBED BY VEGETABLE CROPS FROM CONTAMINATED SOIL, THEREBY, ENTERING MAN'S FOOD CHAIN.

4. IN 1966 AND 1967, THE UNITED STATES GEOLOGICAL SERVICE (U.S.G.S.) CONDUCTED AN INDEPTH SURVEY OF A PORTION OF THE AREA USED BY VELSICOL AS A DUMP. THE NORTHERN SECTION OF THE PROPERTY WAS FIRST USED BY VELSICOL AND CONTAINS ALMOST ALL THE WASTES. THIS NORTHERN AREA COMPRISED MOST OF THE SURVEY AS SHOWN IN FIGURE 1, ATTACHED TO THIS COMPLAINT. FIGURE 4, ATTACHED TO THIS COMPLAINT, SETS FORTH THE POSITION OF THE WASTES IN RELATION TO GROUND WATER. SEE ALSO FIGURE 5, ATTACHED HERETO.

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MICROFORM REFILMED; SEE APPENDICES.

AND FLOWS NORTHEAST, DISCHARGING TO PUGH CREEK AND ITS TRIBUTORY OF THE NORTH END OF THE DUMP. BELOW THE LOCAL AQUIFER IS AN ARTESIAN AQUIFER WHICH SLOPES AND FLOWS WESTWARD. THIS AQUIFER IS USED AS A WATER SUPPLY BY MANY WEST TENNESSEE CITIES, INCLUDING MEMPHIS.

5. THE FINDINGS OF THE U.S.C.S. SURVEY ARE BEST UNDERSTOOD BY REFERRING TO FIGURES 2, 3, AND 4 ATTACHED HERETO. U.S.G.S. FOUND THAT SURFACE AND GROUND CONTAMINATION HAD ALREADY TAKEN PLACE; AND THAT CONTAMINATION OF THE PERCHED ZONE HAD TAKEN PLACE, AND HAD ALMOST REACHED THE LOCAL AQUIFER. U.S.G.S. CONCLUDED: "THE CONTAMINATES THAT ARE ENTRAINED IN THE FLOW SYSTEMS OF THE PERCHED WATER ZONE AND THE WATER TABLE AQUIFER WILL MOVE LATERALLY TOWARD THE DISCHARGING BOUNDRIES OF THOSE GROUNDWATER BODIES."

6. WITH THE EXTENSION OF THE BURYING OPERATIONS TO THE MIDDLE AND NORTHERN PORTIONS OF THE PROPERTY, TWO MAJOR HAZARDS HAVE DEVELOPED. THE FIRST IS THAT THE UNDERGROUND CONDITIONS AND GROUNDWATER MOVEMENT DIRECTIONS ARE NOT KNOWN IN THESE AREAS. CONTAMINATED GROUNDWATER COULD MOVE WESTWARD AND CONTACT WATER SUPPLIES. THE SECOND DANGER IS PRESENTED BY THE PROXIMITY OF THE SOUTHERN BOUNDARY OF THE DUMP TO THE HEADWATERS OF A STREAM WHICH FLOWS SOUTHWEST THROUGH THE TOWN OF TOONE, TENNESSEE. SEE FIGURE 5. THIS FACTOR IS SIGNIFICANT BECAUSE THIS STREAM PROBABLY SERVES AS A RECHARGE FOR THE GROUNDWATER SUPPLY USED BY TOONE. THEREFORE, EXPANDED BUYING ACTIVITIES MEANS: (1) AN INCREASE IN THE AMOUNT OF POTENTIAL CONTAMINATES; (2) INCREASED HAZARD FOR LOCAL WATER SUPPLIES NEAR THE DUMP AND (3) A POSSIBLE HAZARD TO THE WATER SUPPLY OF TONNE, TENNESSEE.

7. FINALLY, THE IMMEDIATE DANGERS OF THESE CHLORINATED HYDROCARBON COMPOUNDS, AS SET FORTH IN PARAGRAPH THREE (3), WHEN BURIED, ARE DIRECTLY RELATED TO TWO CHARACTERISTICS; (1) PERSISTANCE OF HIGH TOXICITY; AND (2) INSOLUBILITY IN WATER. IT IS COMMON SCIENTIFIC KNOWLEDGE THAT CHLORINATED HYDROCARBONS REMAIN TOXIC FOR LONG PERIODS OF TIME.

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THIS IS THE QUALITY THAT MAKES THEM DESIRABLE AS INSECTICIDES. THE TIME NEEDED FOR COMPLETE DEGRADATION OF THE COMPOUNDS BURIED IN HARDEMAN COUNTY BY VELSICOL IS UNKOWN, EVEN BY THE COMPANY; BUT IT IS KNOWN THAT THE EXTREMELY SLOW DEGRADATION AFFORDED BY THE SURFACE AND AQUATIC ENVIRONMENT IS NOT AVAILABLE TO BURIED WASTES, AND THE BREAKDOWN OF SOME CHLORINATED HYDROCARBONS CREATES BY-PRODUCTS THAT ARE AS TOXIC, IF NOT MORE TOXIC, THAN THE ORIGINAL COMPOUND. THE MOVEMENT OF THESE COMPOUNDS INTO THE SURFACE ENVIRONMENT WOULD NOT MEAN THEIR DISAPPEARANCE. IN ADDITION, THE COMPOUND'S INSOLUBILITY AND CLINGING CHARACTERISTIC CAN ONLY MEAN THAT WATER CAN BE, AND IS, A MEDIUM BY WHICH CONTAMINATED PARTICULATE MATTER IS MOVED. THERE IS EVERY REASON TO BELIEVE THAT THE CONTINUOUS ACTION OF WATER MOVING THROUGH THE CONTAMINATED SUBSURFACE ZONES OF VELSICOL'S DUMP IN HARDEMAN COUNTY WOULD SLOWLY MOVE THE CONTAMINATES ALONG ITS PATH.

8. THE EXISTENCE OF A PESTICIDE DUMP IN AN AREA USING GROUNDWATER SUPPLIES, AND LOCATED CLOSE TO THE HEADWATERS OF THE HATCHIE RIVER, HARDEMAN COUNTY, PRESENTS GRAVE RISKS TO WATER QUALITY. THE CONCLUSION REACHED BY U.S.G.S. AFTER ITS 1966-67 STUDY IS:

"IN VIEW OF THE SEVERITY OF THE RISKS INVOLVED, IT MUST BE ASSUMED THAT ANY GROUNDWATER ORIGINATING IN OR PASSING THROUGH THE CONTAMINATED ZONE IS SUSCEPTIBLE TO CONTAMINATION AND THEREFORE BECOMES A SERIOUS THREAT TO ANY WATER SUPPLIES DOWNGRADIENT FROM THE DISPOSAL AREA."

FOR THE REASONS STATED IN THE FOREGOING SEVEN (7) PARAGRAPHS, AND WITH THE KNOWLEDGE THAT THE AFOREMENTIONED CONTAMINATES ARE BURIED AND ARE BEING BURIED IN SUCH CLOSE PROXIMITY WITH SUBSURFACE WATERS THAT THEY WILL LIKELY CAUSE POLLUTION OF SUCH WATERS, AND FURTHER, WITH THE KNOWLEDGE THAT IF SUCH POLLUTION OCCURS, THE HARM DONE TO SAID WATERS WILL BE IRREPAIRABLE AND IRRETRACTABLE, IT IS CONCLUDED THAT THE BURYING OF CHLORINATED HYDROCARBON COMPOUNDS AND ANY OTHER CONTAMINATED SUBSTANCES ON THE PROPERTY DESCRIBED IN PARAGRAPH ONE (1) IS A VIOLATION OF T.C.A. SECTION 70-336 OF CHAPTER 164 OF THE PUBLIC ACTS OF 1971.

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MICROFORM REFILMED; SEE APPENDICES.

9. IN ADDITION TO THE FOREGOING DATA, THE DEPARTMENT OF PUBLIC HEALTH, DIVISION OF WATER QUALITY CONTROL HAS BEEN MADE AWARE OF FEASIBLE, ALTERNATE METHODS OF DISPOSAL OF CHLORINATED HYDROCARBON COMPOUNDS. THE DIVISION HAS HAD COMMUNICATIONS WITH THE CANADIAN DEFENSE RESEARCH ESTABLISHMENT, SUSSIFVILLE-RALSTON, ALBERTA, CANADA, AND DOW CHEMICAL CORPORATION, NIDLAND, MICHIGAN, BOTH OF WHICH PRESENTLY INCINERATE SOLID AND LIQUID PESTICIDE AND INSECTICIDE RESIDUES. IN ADDITION, THE DIVISION IS AWARE THAT DR. FRED SCHUMAN, PROFESSOR, MISSISSIPPI STATE UNIVERSITY, STARKVILLE, MISSISSIPPI, IS CONDUCTING A STUDY ON INCINERATION OF PESTICIDES WITH THE AID OF A USDA GRANT. DR. SCHUMAN HAS ALREADY PUBLISHED SOME REPORTS, COPIES OF WHICH ARE FILED IN THE DIVISION OF WATER QUALITY CONTROL, AND WITH DR. WARREN C. SHAW, ASSOCIATE DIRECTOR, PLANT INDUSTRIES STATION, UNITED STATES DEPARTMENT OF AGRICULTURE, BETTSVILLE, MARYLAND. COMMUNICATIONS WITH THESE PARTIES, AND THE MICHIGAN WATER QUALITY CONTROL DIVISION, REVEALS THAT INCINERATION DOES BREAK DOWN CHLORINATED HYDROCARBONS TO ACCEPTABLE ELEMENTS.

THEREFORE, PURSUANT TO THE AUTHORITY GRANTED ME AS COMMISSIONER OF PUBLIC HEALTH, OR TO MY DULY AUTHORIZED REPRESENTATIVE, IN TENNESSEE CODE ANNOTATED SECTION 70-331, AND IN CONSIDERATION OF (1) THE HAZARDOUS NATURE OF THE SUBSTANCES BURIED AND BEING ON THE PROPERTY DESCRIBED IN PARAGRAPH 1 ABOVE, OWNED BY VELSICOL CHEMICAL CORPORATION, HARDEMAN COUNTY; (2) THE IMMEDIATE AND POTENTIAL ENVIRONMENTAL CONTAMINATION OF SOIL AND WATER PRESENTED BY THESE SUBSTANCES; (3) THE LACK OF ADEQUATE INFORMATION CONCERNING THE TIME AND CONDITIONS NECESSARY FOR THE REDUCTION OF THE TOXICITY OF THESE SUBSTANCES WHEN BURIED; AND (4) THE ACKNOWLEDGED AVAILABILITY OF AN ALTERNATE AND MORE ACCEPTABLE METHOD OF DISPOSAL OF CONTAMINANTS, I ORDER VELSICOL CHEMICAL CORPORATION, MEMPHIS, TENNESSEE, ARE MR. WILLIAM ANTHONY, PLANT MANAGER, TO TAKE THE FOLLOWING ACTION.

(A) ON OR PRIOR TO JUNE 19, 1972, SUBMIT TO THE TENNESSEE DEPARTMENT OF PUBLIC HEALTH, AN ENGINEERING REPORT DETAILING A METHOD TO INCINERATE ALL CHLORINATED HYDROCARBON COMPOUNDS AND OTHER CONTAMINATED SUBSTANCES PRODUCED BY VELSICOL CHEMICAL CORPORATION.

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FOLLOWING ACTION:

(A) ON OR PRIOR TO JUNE 19, 1972, SUBMIT TO THE TENNESSEE DEPARTMENT OF PUBLIC HEALTH, AN ENGINEERING REPORT DETAILING A METHOD TO INCINERATE ALL CHLORINATED HYDROCARBON COMPOUNDS AND OTHER CONTAMINATED SUBSTANCES PRODUCED BY VELSICOL CHEMICAL CORPORATION.

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SAID ENGINEERING REPORT MUST TAKE INTO CONSIDERATION AIR POLLUTION PROBLEMS ASSOCIATED WITH INCINERATION, AND PROVIDE FOR HEAT AT TEMPERATURES SUFFICIENT TO REDUCE SAID COMPOUNDS TO ACCEPTABLE ELEMENTS. THE ENGINEERING REPORT MUST ALSO PROVIDE FOR A REASONABLE TIME SCHEDULE FOR DESIGN, INSTALLATION AND OPERATION OF SAID INCINERATION DEVICE INCLUDING A MEANS OF STORING SAID RESIDUE COMPOUNDS UNTIL INCINERATION BECOMES OPERATIONAL.

(B) ON OR PRIOR TO AUGUST 21, 1972, CEASE ALL BURYING OPERATIONS ON THE PROPERTY LOCATED IN HARDEMAN COUNTY, TENNESSEE, DESCRIBED IN PARAGRAPH 1 ABOUVE, WITH THE SOLE EXCEPTION THAT NON-TOXIC AND/OR NON-CONTAMINATE MATERIAL MAY BE BURIED AT SAID SITE IN HARDEMAN COUNTY, UPON APPLICATION TO, AND EXPRESSED, WRITTEN PERMISSION FROM THE COMMISSIONER OF THE DEPARTMENT OF PUBLIC HEALTH, AND IN COMPLIANCE WITH T.C.A. SECTION 53-4301 ET SEQ.

ISSUED IN THE OFFICE OF THE TENNESSEE WATER QUALITY CONTROL DIVISION, WORD OMITTED DEPARTMENT OF PUBLIC HEALTH, NASHVILLE, TENNESSEE, ON THIS THE TWENTY-FIRST DAY OF FEBRUARY, 1972.

EUGENE W. FOWINKLE, M.D., COMMISSIONER TENNESSEE DEPARTMENT OF PUBLIC HEALTH

S. LEARY JONES, DIRECTOR DIVISION OF WATER QUALITY CONTROL.

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FIG. 5 VELSICOL DUMP LOCATION MAP

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FIG. 2 ARCAL EXTENT SYMBOL OMITTED OF PERCHED WATER ZONE THAT IS SUSCEPTIBLE TO CONTAMINATION-- AS OF TIME OF U.S.G.S. REPORT (1966).

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FIG. 3 ARCAL EXTENT OF WATER TALBE AQUIFER THAT IS SUSCEPTIBLE TO CONTAMINATION AS OF TIME OF U.S.G.S. REPORT (1966). ARROW INDICATES DIRECTION OF GRADIENT.

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FIG. 4 CROSS SECTION OF NORTHERN AREA OF DUMP LOOKING NORTH.

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FIG. 1 VELSICOL DUMP AREA 1" = 1.3 MILES

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SAMPLING FREQUENCY PRIVATE WELLS - TOONE TEAGUE AREA HARDEMAN COUNTY, TENNESSEE

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RESULTS OF QUANTITATIVE ANALYSIES OF PRIVATE WELLS IN TOONE-TEAGUE COMMUNITY HARDEMAN COUNTY, TENNESSEE (PARTS PER BILLION)

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EXHIBIT F MEMORANDUM:

DATE: OCTOBER 30, 1978

TO: THE MEMBERS OF THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

FROM: SUBCOMMITTEE STAFF

SUBJECT: CHEMICALS FOUND IN THE STERLINGS' DRINKING WATER (TOONE, TENNESSEE)

WATER SAMPLES OBTAINED FROM WOODROW STERLING'S WELL AND TAP INDICATE THAT AT LEAST SIX SUSPECTED CARCINOGENS ARE IN THIS FAMILY'S DRINKING WATER. (SEE ATTACHMENT) ONE OF THE SUSPECTED CARCINOGENS, CARBON TETRACHLORIDE, WAS FOUND IN CONCENTRATIONS APPROXIMATELY 2400 TIMES THE MAXIMUM DAILY EXPOSURE SUGGESTED BY THE NATIONAL INSTITUTE FOR OCCUPATION SAFETY AND HEALTH (NIOSH) AS SAFE FOR WORKERS.

CARBON TETRACHLORIDE IS ACUTELY TOXIC AND IS READILY ABSORBED IN THE BODY (SEE, THE SUBCOMMITTEE'S REPORT ENTITLED "CARBON TETRACHLORIDE CONTAMINATION OF PUBLIC DRINKING WATER" PP. 14-15). SOME SCIENTISTS BELIEVE CHRONIC AND SUBCHRONIC INGESTION OR INHALATION TO IT MAY CAUSE A VARIETY OF AILMENTS, INCLUDING KIDNEY, LIVER, LUNG AND CENTRAL NERVOUS SYSTEM DAMAGE.

THE ENVIRONMENTAL PROTECTION AGENCY (EPA) HAS BEEN MOST CONCERNED ABOUT THE PRESENCE OF CARBON TETRACHLORIDE IN DRINKING WATER. IN FEBRUARY OF 1976, EPA FOUND CONCENTRATIONS OF CARBON TETRACHLORIDE IN DRINKING WATER DRAWN FROM THE OHIO RIVER OF LESS THAN 100 PARTS PER BILLION (PPB). THE AGENCY IMMEDIATELY CAUTIONED THE PUBLIC ALONG THE OHIO RIVER NOT TO DRINK THE WATER WITHOUT BOILING IT. FIRST THE LEVEL OF CARBON TETRACHLORIDE FOUND IN THE STERLINGS' WELL IS AT LEAST 48 TIMES THE LEVEL FOUND IN CINCINNATI'S DRINKING WATER DURING THE PERIOD WARNINGS WERE IN EFFECT.

IN ADDITION TO CARBON TETRACHLORIDE, EPA AND THE STATE OF TENNESSEE IDENTIFIED CHLOROFORM, BENZENE, AND THE PESTICIDES HEPTACHLOR AND CHLORDANE IN THE DRINKING WATER. ALL OF THESE CHEMICALS ARE SUSPECTED CARCINOGENS. OTHER COMPOUNDS FOUND IN THE STERLINGS' WELL WATER INCLUDE CHLOROBENZENE WHICH IS SUSPECTED OF CAUSING CENTRAL NERVOUS SYSTEM DEPRESSION AND NARCOSIS AT HIGH LEVELS.

LITTLE TOXICOLOGY IS AVAILABLE ON MOST OF THE CHEMICALS FOUND IN THE STERLINGS' WELL. HOWEVER, WE DO KNOW THAT MANY OF THESE POTENTIALLY DANGEROUS COMPOUNDS CAN BE ABSORBED THROUGH THE SKIN. SINCE THE STERLINGS ARE STILL BATHING IN THIS WATER, THEY CONTINUE TO BE EXPOSED TO POTENTIAL ADVERSE HEALTH EFFECTS.

SINCE VERY LITTLE IS KNOWN ABOUT THE CHRONIC AND SUBCHRONIC EFFECTS OF INGESTION, ABSORPTION OR INHALATION AT THESE LEVELS OF THESE ORGANIC CHEMICALS, HEALTH STUDIES OF THE POPULATION EXPOSED ARE ESSENTIAL. TESTS FOR ORGANIC CHEMICALS IN BLOOD, FATTY TISSUE AND MOTHERS MILK ARE READILY AVAILABLE. ALTHOUGH THE STERLINGS HAVE BOLUNTEERED TO GO THROUGH COMPLETE HEALTH EXAMINATIONS INCLUDING THESE TESTS, EPA HAS MADE NO PLANS TO CONDUCT SUCH EXAMINATIONS. QUESTIONS CONCERNING THE POTENTIAL ADVERSE EFFECTS OF CONSUMING THESE CHEMICALS CANNOT BEGIN TO BE EXAMINED PROPERLY UNTIL HEALTH EFFECTS RESEARCH IS CONDUCTED.

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RESULTS OF QUANTITIATIVE ANALYSES OF PRIVATE WELLS IN TOONE-TEAGUE COMMUNITY HARDEMAN COUNTY, TENNESSEE (PARTS PER BILLION)

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DATA REPORTING SHEET

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EXHIBIT G

UNITED STATES DEPARTMENT OF THE INTERIOR

GEOLOGICAL SURVEY POTENTIAL CONTAMINATION OF THE HYDROLOGIC ENVIRONMENT FROM THE PESTICIDE WASTE DUMP IN HARDEMAN COUNTY, TENNESSEE

BY D. R. RIMA, E. BROWN, D. F. GOERLITZ, AND L. M. LAW WATER RESOURCES DIVISION

ADMINISTRATIVE REPORT TO THE FEDERAL WATER POLLUTION CONTROL ADMINISTRATION

AUGUST 1967.

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ILLUSTRATIONS

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POTENTIAL CONTAMINATION OF THE HYDROLOGIC ENVIRONMENT FROM THE PESTICIDE WASTE DUMP IN HARDEMAN COUNTY, ENNESSEE

BY

D. R. RIMA, E. BROWN, D. F. GOERLITZ, AND L. M. LAW

THE PROBLEM

IN OCTOBER 1964, THE VELSICOL CHEMICAL CORPORATION BEGAN DISPOSING OF TOXIC WASTE MATERIALS FROM THE MANUFACTURE OF CERTAIN CHLORINATED HYDROCARBONS (PESTICIDES) BY SHALLOW BURIAL AT A SITE IN NORTHEASTERN HARDEMAN COUNTY, TENNESSEE. UPON LEARNING OF THIS ACTIVITY, PUBLIC HEALTH OFFICIALS BECAME GRAVELY CONCERNED ABOUT THE POTENTIAL HEALTH HAZARD OWING TO THE TOXIC NATURE OF THE WASTES. PARTICULAR CONCERN WAS EXPRESSED BY HEALTH OFFICIALS OVER THE POSSIBILITY THAT THESE TOXIC WASTES MIGHT CONTAMINATE, AND THUS RENDER USELESS, LOCAL AND TIGUOUS WATER SUPPLIES. THE COMPANY, ON THE OTHER HAND, EXPRESSED THE OPINION THAT AHALLOW BURIAL OF TOXIC WASTES WAS A TIME-HONORED PRACTICE AND IT DID NOT POSE ANY REAL OR IMMEDIATE HAZARD OF PUBLIC HEALTH.

IN ORDER TO RESOLVE THIS QUESTION, THE FEDERAL WATER POLLUTION CONTROL ADMINISTRATION REQUESTED THE U.S. GEOLOGICAL SURVEY TO INVESTIGATE THE DISPOSAL SITE AND DETERMINE THE SUSCEPTIBILITY OF CONTAMINATION OF THE HYDROLOGIC ENVIRONMENT RESULTING FROM THE SHALLOW BURIAL OF PESTICIDE WASTES. CONCERN ABOUT CONTAMINATION IN THE HYDROLOGIC ENVIRONMENT CENTERED ON FOUR PERTINENT QUESTIONS. ANSWERES TO THESE QUESTIONS ARE SUMMARIZED IN THE CONCLUSIONS WHICH FOLLOW.

CONCLUSIONS 1. IS THERE NOW CONTAMINATION OF THE

ENVIRONMENT FROM DISPOSAL PITS; IF SO, WHAT

POSTION IS NOW CONTAMINATED AND TO WHAT

DEGREE?

THE ANALYTICAL RESULTS SHOW CLEARLY THAT THE SHALLOW BURIAL OF PESTICIDE WASTES IN HARDEMAN COUNTY HAS CONTAMINATED PORTIONS OF BOTH THE SURFACE AND SUBSURFACE ENVIRONMENT AT THE DISPOSAL SITE. EVIDENCE OF CONTAMINATION OF THE SURFACE ENVIRONMENT WAS FOUND IN SAMPLES OF THE SURFACE SOIL AT THE DISPOSAL SITE, IN SAMPLES OF SEDIMENT WASHOFF FROM THE DISPOSAL SITE, AND IN SAMPLES OF THE BEDLOAD IN PUGH CREEK AS FAR AS 1 1/2 MILES DOWNSTREAM FROM THE SITE. ON THE OTHER HAND, THE WATER PORTION OF SAMPLES FROM PUGH CREEK DID NOT CONTAIN ANY DETECTABLE AMOUNTS OF CHLORINATED HYDROCARBONS.

THE DEGREE OF CONTAMINATION OF THE SURFACE ENVIRONMENT IS INDICATED BY THE FOLLOWING TABLE WHICH COMPARES THE ANALYSIS OF PLANT WASTE WITH THE MAXIMUM REPORTED ONCENTRATIONS OF PESTICIDE MATERIALS IN SAMPLES FROM VARIOUS SAMPLING SITES.

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MAXIMUM VALUE REPORTED IN ANALYTICAL RESULTS OF SOIL AND SEDIMENT SAMPLES (RESULTS IN MICROGRAMS PER KILOGRAM)

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IT IS OBVIOUS FROM THE FOREGOING TABLE THAT ATTENUATION ACCOMPANIES THE OVERLAND MOVEMENT OF THE REPORTED CONTAMINANTS.

IN THE SUBSURFACE THE BURIED WASTES HAVE PRODUCED A ZONE OR ENCLAVE OF CONTAMINATION DIRECTLY BENEATH AND PERIPHERAL TO THE DISPOSAL PITS. LATERALLY, THE LIMITS OF THE ENCLAVE APPEAR TO BE CONFINED WITHIN A DISTANCE OF 25 FEET FROM THE OUTERMOST MARGINS OF THE DISPOSAL PITS. THE DEPTH OF THE ENCLAVE, HOWEVER, EXTENDS NEARLY TO THE WATER TABLE WHICH IS ABOUT 90 FEET BENEATH THE LAND SURFACE.

WITHIN THE CONTAMINATED ENCLAVE THE DEGREE OF CONTAMINATION IS GREATEST IN THE FORMATION IN WHICH THE WASTES ARE DEPOSTED WHERE VALUES OF UP TO 6 MILLION PG/KG (MICROGRAMS PER KILOGRAM) OF ORGANIC CHLORINE WERE FOUND. IT IS LEAST IN THE OUTERMOST FRINGE WHERE A CONCENTRATION OF 5 UP/KG OF ORGANIC CHLORINE WAS RECOGNIZED AS A POSITIVE INDICATION OF CONTAMINATION. ATTENUATION OF THE CONTAMINATION WITH DEPTH WAS CLEARLY EVIDENT IN THE ANALYTICAL RESULTS.

II. WHAT IS THE POTENTIAL CONTAMINATION

HAZARD TO LOCAL GROUNDWATER FROM

PERCOLATION?

THE VERTICAL MOVEMENT OF THE PESTICIDE CONTAMINANTS FROM THE DISPOSAL PITS POSES A CONTAMINATION HAZARD FOR 2 OF THE 3 GROUND-WATER BODIES THAT OCCUR BENEATH THE DISPOSAL PITS. THE SHALLOWEST GROUND-WATER BODY (A PERCHED WATER ZONE) HAS ALREADY BECOME CONTAMINATED AS EVIDENCED BY ANALYTICAL RESULTS OF WATER SAMPLES FROM SHALLOW WELLS MARGINAL TO THE DISPOSAL PITS (TABLE 1). THE PORTION OF THIS ZONE, THAT IS OR CAN BE CONTAMINATED, HOWEVER, IS LIMITED IN AREAL EXTENT TO ABOUT 40 ACRES. MOREOVER, IT IS NOT USED AS A SOURCE OF WATER SUPPLY BECAUSE IT HOLDS NO WATER DURING DRY SEASONS.

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IN ADDITION TO THE PERCHED WATER ZONE, A SUBSTANTIAL PORTION OF THE LOCAL WATER-TABLE AQUIFER, THE PRINCIPAL SOURCEOF LOCAL DOMESTIC WATER SUPPLIES, IS EXPOSED TO THE HAZARD OF CONTAMINATION FROM THE PESTICIDE WASTE DISPOSAL PITS. THE EXPOSED PORTION HAS AN AREAL EXTENT OF ABOUT 150 ACRES AND INCLUDES THE SEGMENTS OF THE -QUIFER THAT UNDERLIE AND RECEIVE RECHARGE FROM THE PORTION OF THE PERCHED WATER ZONE THAT IS SUSCEPTIBLE TO CONTAMINATION, AND THE DRAWS WHICH CARRY CONTAMINATED WASH-OFF FROM THE DISPOSAL SITE. IN ADDITION, IT INCLUDES THE PART OF THE WATER-TABLE AQUIFER THAT IS DOWN GRADIENT FROM THE SOURCES OF POTENTIALLY CONTAIMINATED RECHARGE.

THERE IS LITTLE LIKELIHOOD THAT GROUND WATER IN THE ARTESIAN AQUIFER WILL EVER BE EXPOSED TO CONTAMINATION FROM THE DISPOSAL PITS BECAUSE THIS AQUIFER DOES NOT RECEIVE RECHARGE FROM ANY OF THE AFOREMENTIONED CONTAMINATED OR POTENTIALLY CONTAMINED PORTIONS OF THE ENVIRONMENT.

III. WHAT IS THE POTENTIAL CONTAMINATION

HAZARD TO CONTIGUOUS GROUNDWATERS?

THE CONTAMINANTS THAT ARE ENTRAINED IN THE FLOW SYSTEMS OF THE PERCHED WATER ZONE AND THE WATER-TABLE AQUIFER WILL MOVE LATERALLY TOWARD THE DISCHARGING BOUNDARIES OF THESE GROUND WATER BODIES. THE CONTAMINANTS ENTRAINED IN THE PERCHED WATER ZONE WILL MOVE TOWARD THE DISCHARGING BOUNDARIES THAT ARE LOCATED WITHIN THE SURFACE REVINES DRAINING THE DISPOSAL PITS. THE MAXIMUM RATE OF MOVEMENT IN THE ZONE UNDER PREVAILING HYDRAULIC GRADIENTS IS CALCULATED TO BE ABOUT 2 FEET PER DAY. HENCE, THE ENTRAINED CONTAMINANTS COULD REAPPEAR AT THE LAND SURFACE IN AS LITTLE AS 100 OR AS MANY AS 1200 DAYS AFTER ENTRY INTO THE PERCHED ZONE.

THE CONTAMINANTS ENTRAINED IN THE FLOW SYSTEM OF THE WATER-TABLE AQUIFER WILL MIGRATE NORTHEASTERLY FOLLOWING THE SLOPE OF THE PREVAILING WATER-TABLE GRADIENT. EVENTUALLY, THESE CONTAMINANTS WILL BE DISCHARGED INTO PUGH CREEK. THE MINIMUM TIME THAT WOULD BE REQUIRED FOR THE ENTRAINED CONTAMINANTS TO REACH THE CREEK IS CALCULATED TO BE 5 YEARS.

WITHDRAWALS FROM WELLS CO-LD CONCEIVABLY INDUCE THE CONTAMINANTS ENTRAINED IN THE FLOW SYSTEM OF THE WATER-TABLE AQUIFER TO MOVE OUTSIDE THE PORTION OF THE AQUIFER THAT IS IN DANGER OF CONTAMINATION. ASSUMING THE WITHDRAWALS ARE MADE AT THE MAXIMUM YIELD OF THE AQUIFER (40 GALLONS PER MINUTE) AND CONTINUED FOR AN INDEFINITE PERIOD OF TIME, WELLS ON THE WESTERN SIDE OF THE DISPOSAL SITE (UPGRADIENT) WOULD NEED TO BE LOCATED WIHTIN 900 FEET OF THE POINTS OF ENTRY OF CONTAMINANTS INTO THE AQUIFER IN ORDER FOR CONTAMINATED WATER TO REACH POINT OF WITHDRAWAL. LIKEWISE, WELLS NORTH OR SOUTH OF THE DISPOSAL SITE (PERPENDICULAR TO THE PREVAILING GRADIENT) WOULD NEED TO BE LOCATED WITHIN 1500 FEET OF THE POTENTIALLY CONTAMINATED PORTION OF THE AQUIFER. IF PUMPING IS INTERMITTENT OR AT A LOWER RATE THAN THE MAXIMUM YIELD OF THE AQUIFER, THE DISTANCE THAT POTENTIALLY CONTAMINATED WATER CAN BE DIVERTED IS, OF COURSE, COMMENSURATELY LESS. WELLS OUTSIDE THE LIMITS INDICATED ARE IN NO POTENTIAL DANGER OF CONTAMINATION BY SUBSURFACE MOVEMENT OF CONTAMINANTS.

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IV. ARE THERE OTHER HYDROLOGIC FACTORS

RELATED TO CONTAMINATION HAZARD THAT HAVE

BECOME EVIDENT DIRECTLY OR INDIRECTLY FROM

THIS STUDY, SUCH AS TOPOGRAPHY, DRAINAGE,

OR RUNOFF INTENSITY?

THE CONTAMINANTS APPEAR TO HAVE A GREATER AFFINITY FOR CLAYEY EARTH MATERIALS THAN FOR WATERS. IT IS, THEREFORE, DOUBTFUL THAT THE CONTAMINANTS WILL MOVE AS RAPIDLY IN THE SUBSURFACE AS GORUND WATER IS ABLE TO MOVE. IT IS ALSO UNLIKELY THAT CONTAMINATED PARTICLES OF SEDIMENT IN THE DRAWS AND IN PUGH CREEK WILL BE RELIEVED OF CONTAMINANTS MERELY BY ASSOCIATION WTIH WATER.

CERTAIN FEATURES OF THE ENVIRONMENT OF THE DISPOSAL SITE SERVE TO DELAY THE CONTAMINATION HAZARD TO THE HYDROLOGIC SYSTEM. THESE ARE:

1. THE 90-FOOT DEPTH TO THE WATER TABLE

2. THE PRESENCE OF 3 BEDS OF LOWLY PERMEABLE CLAYEY MATERIAL IN THE ZONE OF AERATION

3. THE PREVAILING EASTERLY WATER-TABLE GRADIENT

4. THE REMOTENESS OF THE DISPOSAL SITE FROM LOCAL INHABITANTS.

ALTHOUGH NOT SPECIFICALLY QUESTIONED, IT IS PERTINENT THAT SOME OF THE PESTICIDE WASTE IS VERY ACIDIC (PH 1-2). SOME OF THE CONTAMINATED CORE SAMPLES WERE ALSO ACIDIC (PH 3.45). THE PRESENCE OF THIS ACIDIC CONDITION MIGHT INCREASE OR DECREASE THE VERTICAL PERMEABILITY OF THE EARTH MATERIALS IN THE SUBSURFACE, AND THEREBY AFFECT THE RATE OF VERTICAL MOVEMENT OF CONTAMINANTS THROUGHTHE ZONE OF AERATION.

INTRODUCTION

AS EVIDENCED BY THE FOREGOING QUESTIONS, THE SCOPE OF THE INVESTIGATION INCLUDED THE TOTAL FIELD OF MOVEMENT OF THE PESTICIDE WASTE MATERIALS WITHIN THE HYDROLOGIC SYSTEM. CONSIDERED WERE SUCH HYDROLOGIC FACTORS AS SURFACE RUNOFF, SEDIMENT TRANSPORT, HYDRAULICS OF GROUND-WATER MOVEMENT, LEACHING AND THE INTERACTION OF THE WASTES WITH THE ENVIRONMENT. DURING THE INVESTIGATION, APPROXIMATELY 100 SAMPLES OF SURFACE RUNOFF AND WASHOFF WERE COLLECTED FOR PESTICIDE ANALYSIS FROM A NETWORK OF STRATEGIC SAMPLING SITES. IN ADDITION, ABOUT 200 CORE SAMPLES AND 10 SAMPLES OF GORUND WATER WERE OBTAINED FOR ANALYSIS FROM THE SUBSURFACE BENEATH AND ADJACENT TO THE DISPOSAL SITE.

INSOFAR AS THE ANALYTICAL WORK WAS CONCERNED, THE SCOPE OF THE INVESTIGATION WAS ORIGINALLY LIMITED TO THE FOUR CHLORINATED HYDROCARBONS; DIELDRIN, ENDRIN, HEPTACHLOR, AND HEPTACHLOR EPOXIDE BECAUSE THESE COMPOUNDS WERE CONSIDERED TO BE CHARACTERISTIC OF THE BURIED WASTE MATERIALS. FOR THESE

PESTICIDES THE LOWER LIMITS OF MEASURMENT AS REPORTED HEREIN

ARE 0.01 MICROGRAMS PER LITER FOR WATER SAMPLES AND 0.1

MICROGRAMS PER KILOGRAM FOR SEDIMENT AND CORE SAMPLES. LATER,

TO PROVIDE A MORE COMPLETE DESCRIPTION OF THE WASTE MATERIAL

IN CORE SAMPLES, TOTAL ORGANIC CHLORINE WAS DETERMINED TO A

LOWER LIMIT OF 0.5 MICROGRAMS PER KILOGRAM.

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THE INVESTIGATION DID NOT INCLUDE AN EVALUATION OF THE IMPLICATIONS OF THE HYDROLOGIC FINDINGS UPON THE DANGERS TO PUBLIC HEALTH AND WELFARE BECAUSE SUCH AN EVALUATION IS CLEARLY THE PREROGATIVE OF HEALTH AND POLLUTION CONTROL AGENCIES.

DESCRIPTION OF THE DISPOSAL SITE

THE DISPOSAL SITE IS LOCATED ON A 300-ACRE FARM IN NORTHEASTERN HARDEMAN COUNTY, TENNESSEE. IT IS ABOUT 1 1/2 MILES NORTHWEST OF THE INTERSECTION OF STATE HIGHWAYS 18 AND 100. (SEE FIGURE 1). THE SITE LIES WITHIN THE DRAINAGE AREA OF PUGH CREEK, A NORTHWARD-FLOWING TRIBUTARY TO CLOVER CREEK, AND IS SITUATED NEAR THE DRAINAGE DIVIDE ALONG THE WESTERN SIDE OF PUGH CREEK VALLEY. HENCE, THE GENERAL DIRECTION OF SUFACE DRAINAGE FROM THE SITE IS TOWARD THE EAST.

TOPOGRAPHICALLY, THE DISPOSAL SITE IS SITUATED ON AN UPLAND REMMANT OF A MATURELY DISSECTED, FLUVIAL TERRACE. THE GENERAL LEVEL OF THE UPLAND IS ABOUT 80 TO 100 FEET ABOVE THE FLOOD PLAIN OF PUGH CREEK. BETWEEN THE FLOOD PLAIN AND THE UPLANDS, THE LAND SURFACE IS MARKED BY FAIRLY STEEP-SIDED GULLIES AND RAVINES.

THE DISPOSAL SITE IS UNDERLAIN BY A SEQUENCE OF NEARLY HORIZONTAL STRATA THAT ARE COMPOSED OF DEPOSITS FF SAND, SILT, AND CLAY. TO A DEPTH OF ABOUT 100 FEET THESE STRATA CONSIST PREDOMINANTLY OF SAND DEPOSITS INTERBEDDED WITH A FEW THIN DEPOSITS OF SILT AND CLAY, BUT BELOW A DEPTH OF 100 FEET BEDS OF CLAY ARE PREDOMINANT. THE SEQUENCE AND GENERAL CHARACTER OF THE UPPERMOST 250 FEET OF STRATA ARE SHOWN DIAGRAMATICALLY BY THE GEOLOGIC CROSS-SECTION IN FIGURE 2. THE BEDS OF SAND ARE NUMBERED SEQUENTIALLY FROM THE SURFACE DOWNWARD TO FACILITATE IDENTIFICATION IN THE TEXT.

SAND NUMBER 1 IS A YELLOWISH-ORAGE TO REDDISH-BROWN, FINE- TO VERY COARS-GRAINED, POORLY SORTED QUARTZ SAND. IT IS WEAKLY STRATIFIED AND CONTAINS SMALL POCKETS AND LENSES OF LIGHT GRAY TO REDDISH-BROWN SILT, SMALL PIECES OF IRONSTONE, AND SCATTERED PEBBLES OF QUARTZITE. EXCEPT FOR IRON OXIDE WHICH OCCURS AS GRAIN COATINGS AND CEMENTING MATERIAL, THIS DEPOSIT IS MINERALOGICALLY ALMOST PURE SILICA (SIO2).

THE BED OF CLAYEY MATERIAL THAT UNDERLIES SAND NUMBER 1 IS A REMNANT OF AN ANCIENT SOIL THAT DEVELOPED BENEATH THE SURFACE OF EROSION WHICH EXISTED PRIOR TO THE DEPOSITION OF SAND NUMBER . IT CONTAIN A NEARLY CONTINUOUS BED OF IRONSTONE (IRON OXIDE CEMENTED SILTSTONE OR SANDSTONE) ALONG ITS UPPER SURFACE.

SANDS 2, 3, AND 4 ARE LIGHT GRAY TO YELLOWISH, FIME-TO VERY COARSE-GRAINED, POORLY TO WELL SORTED, QUARTZ SAND. THESE DEPOSITS ARE DISTINCTLY STRATIFIED WITH THIN (GENERALLY LESS THAN ONE FOOT) ALTERNATING BEDS OR LENSES OF SAND THAT DIFFER IN GRAIN SIZE AND SORTING. SOME OF THE INDIVIDUAL BEDS OR LENSES OF SAND IN SAND NUMBER 4, ARE COMPOSED OF VERY COARSE, WELL SORTED QUARTZ SAND.

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FIGURE 1 -- MAP OF PUGH CREEK DRAINAGE BASIN

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FIGURE 2 -- GEOLOGIC CROSS-SECTION OF DISPOSAL SITE.

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THE 2 BEDS OF CLAYEY MATERIAL THAT SEPARATE SAND NUMBER 3 FROM SANDS NUMBERED 2 AND 4 (FIG. 2) CONSIST OF IRREGULAR-SHAPED LENSES AND CIRCULAR, OBLATE, AND TABULAR MASSES OF KAOLINITIC CLAY IN A QUARTZOSE SAND MATRIX.

THE UPPER AND LOWER CONFINING BEDS ARE COMPOSED OF GRAY- TO BLUISH-GRAY, LAMINATED- TO THICK-BEDDED AND BLOCKY SILT AND CLAY. THESE BEDS CONTAIN CARBONACEOUS PLANT REMAINS, SIDERITE CONCRETIONS, AND FERRUGINOUS SILTSTONES.

SAND NUMBER 5 IS A LIGHT GRAY - TO YELLOWISH-GRAY, MEDIUM TO VERY COARSE-GRAINED, POORLY SORTED QUARTZ SAND.

THE UPPERMOST 250 FEET OF STRATA BENEATH THE DISPOSAL SITE EMBRACES 3 DISTINCT BODIES OF GROUND WATER; A PERCHED WATER ZONE, A WATER-TABLE AQUIFER, AND AN ARTESIAN AQUIFER (FIG. 2). THE PERCHED WATER ZONE OCCURS IN THE BASAL PART OF THE UPPERMOST SAND (SAND NO. 1) IMMEDIATELY ABOVE THE LESS PERMEABLE CLAYEY STRATUM THAT DIRECTLY UNDERLIES THE SAND. WATER OR ANY OTHER LIQUID THAT ENTERS THE SUBSURFACE AND MIGRATES DOWNWARD UNDER THE INFLUENCE OF GRAVITY IS PRONE TO ACCUMULATE AT THIS HORIZON BECAUSE THE CLAYEY MATERIAL ON WHICH THE SAND RESTS HAS SUBSTANTIALLY LESS PERMEABILITY THAN THE SAND. THE PERCHED WATER ZONE EXPANDS DURING THE WINTER AND SPRING SEASONS OWING TO THE ABUNDANCE OF RECHARGE AND CONTRACTS OR DISSIPATES DURING THE SUMMER AND FALL SEASONS WHEN RECHARGE IS MINIMAL. DOUBTLESS, SOME WATER ESCAPES FROM THE PERCHED ZONE BY MOVEMENT DOWNWARD THROUGH THE CLAYEY SUBSTRATUM, AND SOME ESCAPES BY LATERAL MIGRATION TO SURFACE SEEPS ALONG THE SLOPES THAT BORDER THE DISPOSAL SITE.

TEH WATER-TABLE AQUIFER OCCURS AT A DEPTH OF ABOUT 90 FEET BELOW THE SURFACE OF THE DISPOSAL SITE AND 60 FEET BELOW THE BASE OF THE PERCHED WATER ZONE. IT OCCUPIES A 10-FOOT INTERVAL AT THE BASE OF SAND NO. 4 (FIG. 2). MEASUREMENTS OF WATER LEVELS IN OBSERVATION WELLS AT THE DISPOSAL SITE INDICATE THAT THE WATER TABLE SLOPES GENERALLY TOWARD THE EAST. THE WATER-TABLE AQUIFER IS RECHARGED LOCALLY BY LEAKAGE FROM THE PERCHED WATER ZONE THROUGH THE THIN CLAYEY STRATA THAT OCCUR BETWEEN THE PERCHED WATER ZONE AND THE WATER TABLE. IT IS ALSO RECHARGED BY THE INFILTRATION OF RAINFALL IN THOSE AREAS WHERE THE PERCHED WATER ZONE IS ABSENT. DISCHARGE FROM THE WATER-TABLE AQUIFER TAKES PLACE THROUGH SEEPS AND SPRINGS WHICH ARE IN EVIDENCE WHEREVER THE LAND SURFACE INTERSECTS THE WATER TABLE. THE POINT OF DISCHARGE FROM THIS AQUIFER NEAREST THE DISPOSAL SITE IS LOCATED IN THE CHANNEL OF PUGH CREEK A FEW HUNDRED FEET UPSTREAM FROM THE INTERSECTION OF THE CHANNEL AND THE 400-FOOT CONTOUR (FIG. 1). DOWNSTREAM FROM THIS POINT, PUGH CREEK IS A PARENNIAL STREAM DERIVING ITS DRY-WEATHER FLOW FROM THE WATER-TABLE AQUIFER.

THE ARTESIAN AQUIFER OCCURS AT A DEPTH OF 200 TO 225 FEET BENEATH THE DISPOSAL SITE. IT IS SEPARATED FROM THE WATER-TABLE AQUIFER BY A BED OF SILT AND CLAY THAT IS ABOUT 100 FEET THICK. THIS INTERVENING BED IS AN UPPER CONFINING BED TO THE ARTESIAN AQUIFER.

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EVEN THOUGH THE HEAD IN THE ARTESIAN AQUIFER AS MEASURED IN THE VELSICOL WELL IS LESS THAN THAT IN THE WATER-TABLE AQUIFER AS MEASURED IN WELL W-1 (FIG. 3), THE THICKNESS AND CHARACTER OF THE UPPER CONFINING BED PRECLUDE ANY DIRECT HYDRAULIC CONNECTION BETWEEN THE WATER TABLE AND ARTESIAN AQUIFERS. HENCE, RECHARGE TO AND DISCHARGE FROM THE ARTESIAN AQUIFER ARE BELIEVED TO TAKE PLACE MAINLY IN THE OUTCROP AREA OF THE AQUIFER WHICH IS LOCATED SEVERAL MILES EAST FROM THE DISPOSAL SITE. SOME ADDITIONAL DISCHARGE FROM THE ARTESIAN AQUIFER IS OCCASIONED BY WITHDRAWALS FROM WELLS THAT TAP THE AQUIFER SUCH AS THE VELSICOL WELL NEAR THE ENTRANCE OT THE DISPOSAL SITE.

CHARACTER OF THE WASTES AND METHOD OF DISPOSAL

THE BULK OF THE WASTE MATERIALS THAT ARE BING TRANSPORTED TO HARDEMAN COUNTY FOR DISPOSAL CONSIST OF STILL BOTTOMS AND DRY SPENT CATALYST AND REACTOR SOLIDS FROM THE MANUFACTURE OF ENDRIN, HEPTACHLOR, AND HEPTACHLOR EPOXIDE. INCLUDED WITH THESE WASTES IS A MINOR AMOUNT OF MISCELLANEOUS TRASH CONSITING OF CONTAMINATED EARTH, LABORATORY WASTES, AND CONVENTIONAL LAND-FI-L MATERIALS.

ALTHOUGHTHE CHEMICAL CONTENT OF THE WASTES IS NOT DETERMINED PRIOR TO BURIAL, IT IS OBVIOUS THAT THE COMPOUNDS CONTAINED THEREIN INCLUDE, IN ADDITION TO THE 3 MANUFACTURED COMPOUNDS, SEVERAL RELATED COMPOUNDS THAT ARE EITHER INTERMEDIATES OR BY-PRODUCTS IN THE MANUFACTURING PROCESS. SAMPLES OF THE LIQUID AND SOLID WASTES PROVIDED BY THE MANUFACTURER WERE ANALYZED BY ELECTRON CAPTURE GAS CHROMATOGRAPHY AND FOUND TO CONTAIN 1200 TO 1500 MG/KG (MILLIGRAM PER KILOGRAM) OF DIELDRIN, 4500 TO 5900 MG/KG OF ENDRIN, 200,000 MG/KG OF HEPTACHLOR AND 39 MG/KG OF HEPTACHLOR EPOXIDE (SEE TABLE 6). ACCORIDNG TO THE MANUFACTURER, SOME OF THE RELATED COMPOUNDS THAT CAN BE EXPECTED TO OCCUR IN THE WASTES ARE ISODRIN, ALDRIN, CHLORDENE, HEXACHLOROCYCLOPENTADIENE, AND HEXACHLOROBICYCLOHEPTADIENE. THE RELATIVE QUANTITIES OF THESE COMPOUNDS IN THE WASTES, HOWEVER, ARE NOT KNOWN.

AS THE WASTE MATERIALS ARE GENERATED AT THE PLANT, THEY ARE PLACED IN USED 55-GA-LON STEEL DRUMS AND FIBER CARTONS. THE DRUMS CONTAINING LIQUID WASTES ARE CLOSED WITH LIDS TO PREVENT SPILLAGE DURING SHIPMENT. THE WASTES ARE HAULED TO THE DISPOSAL SITE IN LARGE DUMP TRUCKS; USUALLY SEVERAL TRUCKLOADS ARE TAKEN TO THE DISPOSAL SITE EACH DAY. UPON ARRIVAL AT THE SITE THE WASTES, INCLUDING THE CONTAINERS, ARE DUMPED INTO ELONGATED PITS OR TRENCHES WHICH HAVE BEEN EXCAVATED TO A DEPTH OF ABOUT 12 FEET AND WIDTH OF ABOUT 15 FEET. IN THE PROCESS OF DUMPING, MANY OF THE CONTAINERS ARE CRUSHED OR OTHERWISE RUPTURED AND THEIR CONTENTS RELEASED WITHIN THE TRENCHES. AFTER EACH DUMPING THE WASTES ARE COVERED WITH A MINIMUM OF 3 FEET OF EARTH MATERIAL.

AS OF THE WRITING OF THIS REPORT (JUNE 1967), THE TRENCHES IN WHICH PESTICIDE WASTES HAVE BEEN BURIED ARE GROUPED INTO 3 ADJOINING AREAS OR PLOTS AS SHOWN ON FIGURE 3. WITHIN EACH PLOT THE TRENCHES ARE SPACED FROM 5 TO 12 FEET APART. PLOT NUMBER 1 WAS USED FOR DUMPING FROM OCTOBER 1964 UNTIL MAY 1966, AND PLOT NUMBER 2 WAS USED FROM APRIL 1966 UNTIL MAY 1967. PLOT NUMBER 3 HAS BEEN IN USE SINCE MID-MARCH 1967.

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FIGURE 3 -- MAP OF THE DUMP SITE SHOWING THE LOCATIONS OF THE WASTE BURIAL PLOTS AND THE SAMPLING SITES AND TEST WELLS

FIGURE OMITTED

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EXPERIMENTAL PROCEDURE

DURING THE COURSE OF THE INVESTIGATION OF THE PESTICIDE DUMP, ABOUT 320 SAMPLES OF WATER AND EARTH-MATERIALS WERE COLLECTED FROM VARIOUS LOCATIONS IN AND NEAR THE DUMP SITE. THE LOCATION OF THE SAMPLING SITES ARE SHOWN ON FIGURE 3. SPECIAL PRECAUTIONS WERE TAKEN TO ENSURE THAT THE SAMPLING APPARATUS AND SAMPLE CONTAINERS WERE NOT CONTRIBUTORS OF CONTAMINATION.

ABOUT 90 SAMPLES OF RUNOFF AND SEDIMENT WASHOFF WERE COLLECTED FROM THE SAMPLING DEVICES THAT WERE INSTALLED IN THE 4 RAVINES OR DRAWS LOADING AWAY FROM THE DUMP. THE WASHOFF SAMPLING A-PARATUS CONSISTED OF A V-SHAPED ALUMINUM PAN AND A GLASS SAMPLE BOTTLE. THE PAN SERVED TO DIVERT THE SEDIMENT-LADED WASHOFF AND CONVEY IT INTO THE GLASS BOTTLE WHICH WAS PLACED UNDER THE OPEN NOSE OF THE PAN. THE BOTTLE WAS COVERED WITH A STOPPER THROUGH WHICH AN ALUMINUM FUNNEL AND AN AIR BLEED PROTRUDED TO TRAP THE SAMPLE IN THE BOTTLE. AFTER EACH HEAVY RAINFALL THE SAMPLE-FILLED BOTTLE WAS RETRIEVED AND CAPPED FOR SHIPMENT TO THE LABORATORY. IN ADDITION, A SAMPLE OF THE MATERIAL RETAINED ON THE V-SHAPED PAN WAS COLLECTED FOR SHIPMENT TO THE LABORATORY. AFTER EACH SAMPLE COLLECTION, THE SAMPLING APPARATUS WAS MECHANICALLY CLEANED, RINSED WITH NANOGRADE (R) HEXANE AND REASSEMBLED WITH A FRESH SAMPLE BOTTLE.

AN ADDITIONAL 16 SAMPLES OF RUNOFF AND SEDIMENT WERE COLLECTED FROM PUGH CREEK. ONE OF THESE SAMPLES WAS COLLECTED AT A SAMPLING SITE UPSTREAM FROM THE DISPOSAL SITE (FIG. 3. INSET MPA). THE REAMINDER WAS COLLECTED DURING PERIODIC VISITS TO THE DOWNSTREAM SITE (FIG. 3, INSET MAP). DURING MOST OF THESE VISITS, A SAMPLE OF THE BEDLOAD MATERIAL WAS ALSO COLLECTED.

SAMPLES OF GROUND WATER WERE COLLECTED FROM THE NEAREST AVAILABLE WELLS TAPPING EACH OF THE 3 WATER-BEARING ZONES. SAMPLES FROM THE PERCHED WATER ZONE WERE OBTAINED FROM WELLS A-1, A-2, B-1, AND B-2 WHICH ARE LOCATED ON THE PERIPHERY OF THE DUMP SITE (FIG. 3). SAMPLES FROM THE WATER-TABLE AQUIFER WERE OBTAINED FROM THE KING AND STERLING WELLS (FIG. 3, INSET MAP) AND SAMPLES FROM THE ARTESIAN AQUIFER WERE OBTAINED FROM THE VELSICOL WELL NEAR THE ENTRANCE TO THE DISPOSAL SITE.

THE INVESTIGATE THE OCCURRENCE OF PESTICIDES IN THE

SUBSURFACE, ABOUT 200 CORE SAMPLES WERE OBTAINED AT SELECTED

DEPTHS FROM 18 TEST WELLS THAT WERE DRILLED AT VARIOUS DISTANCES

FROM THE MARGINS OF THE DISPOSAL SITE. THE LOCATIONS OF THESE

TEST WELLS ARE ALSO SHOWN ON FIGURE 3. SIX OF THESE WELLS

WERE DRILLED ON AN ANGLE TO OBTIAN SAMPLES OF EARTH MATERIAL

FROM DIFFERENT STRATIGRAPHIC HORIZONS BENEATH THE DISPOSAL PITS

WITHOUT PENETRATING THE BURIAL TRENCHES.

AS THE COVER SOIL AT THE DISPOSAL SITE WAS KNOWN TO BE CONTAMINATED (TABLE 6), IT WAS NECESSARY TO DEVELOP CORE SAMPLING TECHNIQUES THAT WOULD NOT SPREAD THE CONTAMINATION IN THE DRILLING PROCESS. TO AVERT THIS DANGER, A PORTE FIXED-PISTON DRIVE SAMPLER WAS USED BECAUSE THE CORE BARREL OF THIS DEVICE REMAINS CLOSED UNTIL THE PISTON IS REMOVED FOR SAMPLING BY MEANS OF A CERTER ROD.

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TO OBTAIN A CORE SAMPLE, THE DEVICE WAS INSERTED INTO THE BOREHOLE AND THE BARREL WAS DRIVEN 6 OR 8 INCHES INTO THE BOTTOM OF THE HOLE BEFORE THE PISTON WAS REMOVED. THEN, WITH THE CORE BARREL OPENED AT THE BOTTOM, THE SAMPLER WAS DRIVEN AN ADDITIONAL 2 TO 4 FEET TO OBTAIN THE CORE SAMPLE.

LOADING AND UNLOADING THE CORE BARREL WERE CAREFULLY ATTENDED. PRIOR TO USE, THE BRASS CORE BARREL LINERS AND CAPS WERE FIRST WASHED IN ALCOHOLIC SOLIUM HYDROXIDE, THEN IN DILUTE HYDROCHLORIC ACID, AND FINALLY RINSED IN DISTILLED WATER. AFTER AIR DRYING, THE LINERS AND CAPS WERE WRAPPED SEPARATELY IN ALUMINUM FOIL AND SENT TO THE TEST SITE. IN THE CORING PROCESS THE CORE BARREL AND ALL ATTACHMENTS WERE THOROUGHLY CLEANED AND RINSED WITH NANOGRADE (R) HEXANE. THEN THE LINERS WERE UNWRAPPED AND INSERTED INTO THE CORE BARREL. NEXT, THE CENTER ROD WITH ITS FIXED PISTON WAS POSITIONED IN THE CORE BARREL SO THAT THE BOTTOM END OF THE CORE BARREL WAS COMPLETELY CLOSED. AS AN ADDITIONAL PRECAUTION, GLASS WOOL WAS PACKED INTO THE CORE BARREL EXTENSION AROUND THE PISTON ROD JUST ABOVE THE CORE CHAMBER. THIS WAS DONE TO PRVENT DIRT FROM DROPPING DOWN INTO THE CORE BARREL DURING THE CORING OPERATION.

AFTER RETRIEVING THE CORE BARREL FROM THE BOREHOLE, THE CORE-FILLED LINERS WERE REMOVED FROM THE BARREL AND WRAPPED IN NEW FOIL FOR SHIPMENT TO THE LABORATORY. POLYETHYLENE GLOVES WERE WORN BY FIELD PERSONNEL DURING THE LATTER STEP TO AVOID CONTAMINATING THE SAMPLE.

AS PREVIOUSLY STATED, THIS STUDY INVOLVED A CONSIDERABLE NUMBER OF LABORATORY ANALYSES. TO ACHIEVE THE DESIRED OBJECTIVES, THE ANALYSES WERE PERFORMED BY TWO LABORATORIES. THE WATER, SOIL, AND SEDIMENT SAMPLES WERE ANALYZED BY THE USGS PESTICIDE LABORATORY AT SACRAMENTO, CALIFORNIA, AND THE CORE SAMPLES WERE ANALYZED BY THE USGS PESTICIDE LABORATORY AT MENLO PARK, CALIFORNIA.

GAS CHROMATOGRAPHY USING BOTH ELECTRON CAPTURE AND MICROCOULOMETRIC MODES OF DETECTION WAS USED AS THE PRINCIPAL METHOD OF ANALYSIS FOR THIS STUDY. THE HIGH RESOLVING CHARACTERISTICS OF THE GAS CHROMATOGRAPH ENABLES THE ANALYST TO SEPARATE AND IDENTIFY THE COMPONENTS IN A MIXTURE OF VOLATILE ORGANIC COMPOUNDS. THE ELECTRON CAPTURE DETECTOR IS EXTREMELY SENSITIVE, CAPABLE OF DETECTING A FEW PICOGRAMS (10-12 GRAMS) OF COMPOUND, BUT IS NONSPECIFIC. THE MICROCOULOMETRIC DETECTOR, WHILE LESS SENSITIVE, REQUIRING AT LEAST 10-8 GRAMS OF COMPOUND, SPECIFICALLY DETECTS HALOGENATED COMPONENTS. GAS CHROMATOGRAPHY IS A WIDELY ACCEPTED METHOD FOR THE DETERMINATION OF PESTICIDE RESIDUES.

ANALYSIS OF WATER AND SEDIMENT SAMPLES

OWING TO THE NATURE OF THE SAMPLING DEVICES USED AND THE RUNOFF CONDITIONS, THE RUNOFF AND SEDIMENT WASHOFF SAMPLES CONTAINED VARYING PROPORTIONS OF WATER AND SEDIMENT -- FROM DRY SOIL TO ESSENTIALLY ALL WATER.

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WHENEVER IT WAS POSSIBLE TO DO SO, THE WATER AND SEDIMENT WERE SEPARATED AND ANALYZED SEPARATELY. SAMPLES WERE ANALYZED BY MICROCOULOMETRIC TITRATION OR BY ELECTRON CAPTURE GAS CHROMATOGRAPHY OR BOTH DEPENDING UPON THE CONCENTRATION OF ORGANIC MATERIAL IN THE SAMPLE.

WATER SAMPLES

WATER SAMPLES OBTAINED FROM THE WELLS AND PUGH CREEK WERE SUFFICIENTLY LOW IN COLOR AND INTERFERING ORGANIC MATTER THAT CLEANUP WAS NOT REQUIRED. ANALYSIS WAS ACCOMPLISHED BY SIMPLE EXTRACTION OF 1-LITER SAMPLES WITH 75 M1 (MILLILITERS) OF HEXANE, EVAPORATION OF THE EXTRACTANT TO 5.0 ML, AND INJECTION OF 5.0UL (MICROLITERS) INTO THE GAS CHROMATOGRAPH (LAMAR AND OTHERS. 1966, P. 187). IN ALL CASES, INJECTIONS INTO TWO DIFFERENT COLUMNS WERE MADE. OPERATING CONDITIONS FOR THE ELECTRON-CAPTURE GAS CHROMATOGRAPHIC PROCEDURE WERE AS FOLLOWS:

INSTRUMENT: AEROGRAPH HY-FI MODEL 600-D, WITH A WILKENS MODEL 328 ISOTHERMAL TEMPERATURE CONTROLLER

COLUMNS: 1. 1/8 INCH BY 5 FOOT PYREX GLASS, PACKED WITH 60/80 MESH GAS-CHROM Q COATED WITH 5 PERCENT W/2 (WEIGHT PER WEIGHT) DC 200

2. 1/8 INCH BY 5 FOOT PYREX GLASS, PACKED WITH 60/80 MESH GAS-CHROM Q COATED 5 PERCENT W/W QF-1

OVEN TEMPERATURE: 187 DEGREES C

DETECTOR: ELECTRON-CAPTURE, CONCENTRIC TUBE DESIGN

CARRIER GAS: NITROGEN AT 40 ML/MIN.

INJECTION VOLUME: 5.0 MICROLITERS

WATER SAMPLES OBTAINED FROM SURFACE RUNOFF DOWN THE 4 DRAWS GENERALLY CONTAINED SUFFICIENT CHLORINATED ORGANIC COMPOUNDS TO PERMIT MICROCOULOMETRIC ANALYSIS IN ADDITION TO THE MORE SENSITIVE ELECTRON CAPTURE GAS CHROMATOGRAPHY.

THESE SAMPLES USUALLY CONTAINED LARGE AMOUNTS OF EXTRANEOUS MATERIAL AND REQUIRED THE APPLICATION OF A CLEANUP PROCEDURE PRIOR TO ANALYSIS. PREPARATION FOR ANALYSIS INCLUDED EXTRACTION OF 1-LITER SAMPLES WITH 75 ML OF HEXANE, EVAPORATION OF THE EXTRACTANT TO 0.5 ML, AND CLEANUP OF THE CONCENTRATED EXTRACT BY COLUMN CHROMATOGRAPHY. WOELM ALUMINA DEACTIVATED BEFORE USE WITH 5 PERCENT W/W WATER (DE FAUBERT MAUNDER AND OTHERS, 1964), WAS USED IN A MICRO COLUMN AS DESCRIBED BY GOERLITZ AND LAMAR (1967). WHEN THE 0.5 ML OF THE EXTRACT WAS ELUTED THROUGH A 4 BY 30 MM (MILLIMETER) ALUMINA COLUMN WITH 5.0 ML OF HEXANE, THE FIRST 1.5 ML OF ELUATE CONTAINED ANY HEPTACHLOR IN THE SAMPLE. THE SECOND ELUATE FRACTION OF 4.0 ML CONTAINED ANY DIELDRIN, ENDRIN, OR HEPTACHLOR EPOXIDE. FOLLOWING ELUTION, THE TWO FRACTIONS WERE PREPARED FOR GAS CHROMATOGRAPHIC ANALYSIS BY DILUTION WITH HEXANE TO 2.0 AND 5.0 ML RESPECTIVELY.

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SINCE THE DIELDRIN FRACTION SELDOM CONTAINED SUFFICIENT MATERIAL TO PERMIT MICROCOULOMETRY, IT WAS ANALYZED BY INJECTION OF 5.0 UL INTO TWO ELECTRON-CAPTURE GAS CHROMATOGRAPHIC COLUMNS. THE HEPTACHLOR FRACTION, WHICH ALWAYS CONTAINED THE MAJOR AMOUNT OF CHLORINATED ORGANICS PRESENT IN ANY SAMPLE, WAS ANALYZED BY INJECTION OF 5.0 TO 40.0 UL INTO THE MICROCOULOMETER. OPERATING CONDITIONS FOR THE MICROCOULOMETRIC ANALYSIS WERE AS FOLLOWS:

A. CHROMATOGRAPH

COLUMN: 1/4 INCH BY 5 FOOT PYREX GLASS, PACKED WITH MESH GAS CHROM Q COATED WITH 100 PERCENT W/W DC200

INJECTION TEMPERATURE: 210 DEGREES C

COLUMN TEMPERATURE: 187 DEGREES C

CARRIER GAS: NITROGEN AT 120 ML/MIN.

B. MICROCOULOMETER

INLET SWEEP GAS: NITROGEN AT 10 ML/MIN.

COMBUSTION GAS: OXYGEN AT 60 - 70 ML/MIN.

INLET TEMPERATURE: 220 DEGREES C.

COMBUSTION TUBE TEMPERATURE: 920 +- 10 DEGREES C

SOIL AND SEDIMENT SAMPLES

SAMPLE MATERIAL COLLECTED FOR ANALYSIS IN THIS CATEGORY INCLUDED: SOIL FROM THE SURFACE OF THE DUMP AREA; SURFACE SOIL ONE MILE AWAY FROM THE DUMP; SEDIMENT TRANSPORTED DOWN THE DRAWS DURING RUNOFF EVENTS; SUSPENDED SEDIMENT AND BED MATERIAL FROM PUGH CREEK; AND CLAY HAULED IN TO REPACK THE WELLS DRILLED TO MONITOR WATER MOVEMENT AWAY FROM THE DUMP SITE.

OF THESE MATERIALS, ONLY THE SOIL FROM THE SURFACE OF THE DUMP PROPER AND THE SEDIMENT MOVED DOWN THE DRAWS BY RAINFALL CONTAINED CHLORINATED ORGANIC COMPOUNDS IN SUFFICIENTLY HIGH CONCENTRATION TO ALLOW ANALYSIS BY MICROCOULOMETRY. OTHER SOIL AND SEDIMENT SAMPLES WERE ANALYZED BY ELECTRON CAPTURE GAS CHROMATOGRAPHY FOLLOWING SUITABLE SAMPLE PREPARATION.

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MOST SAMPLES WERE RECEIVED IN A MOIST CONDITION. TO AVOID THE RISK OF LOSING VOLATILE COMPONENTS DURING DRYING, ALL SAMPLES WERE ANALYZED AS RECEIVED. THE DRY SAMPLE WEIGHTS WERE COMPUTED FROM MOISTURE DETERMINATIONS AND THE RESULTS REPORTED ON A DRY WEIGHT BASIS.

IN OTHER TO IMPROVE EXTRACTION AND REMOVAL OF ORGANICS FROM THE MOIST MATERIALS, ALL SAMPLES WERE EXTRACTED WITH ACETRONITRILE ACCORDING TO THE FOLLOWING PROCEDURE. A 25 - TO 100-GRAM SAMPLE OF SOIL WAS EXTRACTED WITH 25 TO 100 ML (MILLILITERS) OF ACETONITRILE AND FILTERED. THE FILTERED EXTRACT WAS DILUTED WITH AN EQUAL VOLUME OF WATER AND THEN 25 ML OF HEXANE WERE ADDED. AFTER SEPARATION AND DRYING, THE HEXANE WAS REDUCED IN VOLUME TO 0.5 ML. THESE EXTRACTS WERE SUBJECTED TO THE ALUMINA CLEANUP PROCEDURE PREVIOUSLY DESCRIBED AND ANALYZED BY EITHER MICROCOULOMETRY OR ELECTRON CAPTURE GAS CHROMATOGRAPHY, DEPENDING ON THE CONCNETRATION OF ORGANIC MATERIAL PRESENT. THIS METHOD PROVED TO BE AN EFFICIENT METHOD FOR THE EXTRACTION OF THE FOUR PESTICIDES FROM THE SOIL SAMPLE

DISCUSSION OF RESULTS

IT SHOULD BE NOTED THAT THE FOUR PESTICIDE COMPOUNDS (DIELDRIN, ENDRIN, HEPTACHLOR, AND HEPTACHLOR EPOXIDE) COULD NOT ALWAYS BE IDENTIFIED AMONG THE CHLORIN-TED HYDROCARBON MATERIALS THAT WERE OBSERVED. NEVERTHELESS, THE OBSERVED COMPOUNDS ARE BELIEVED TO BE CLOSELY RELATED AND OF EQUAL SIGNIFICANCE IN INDICATING THE CONTAMINATION OF THE ENVIRONMENT OF THE DUMP SITE. THEREFORE, THE FACT THAT THE ANALYTICAL RESULTS ARE, IN SOME INSTANCES, PRESUMPTIVE RATHER THAN CONCLUSIVE DOES NOT DETRACT FROM THEIR USE IN DESCRIBING THE EXTENT AND DEGREE OF CONTAMINATION FROM THE DISPOSAL PITS.

WELLS - THE ANALYTICAL RESULTS OF WATER SAMPLES FROM WELLS ARE GIVEN IN TABLE 1. ANALYSIS OF SAMPLES OBTAINED FROM THE 3 WATER-SUPPLY WELLS (KING, STERLING, AND VELSICOL WELLS) NEAREST THE DUMP SITE SHOWED NO EVIDENCE OF CONTAMINATION BY CHLORINATED HYDROCARBONS. HOWEVER, THE WATER SAMPLES THAT WERE OBTAINED FROM 3 OUT OF 4 OF THE SHALLOW WELLS (A-2, B-1, AND B-2), LOCATED ON THE MARGIN OF THE DUMP SITE DID CONTAIN CHLORINATED HYDROCARBONS THESE WELLS WERE SAMPLED, PUMPED DRY, ALLOWED TO REWATER, AND RESAMPLED. THE VALUES REPORTED IN TABLE 1 FOR EACH SAMPLE ARE THOS OBTAINED BY ELECTRON CAPTURE GAS CHROMATOGRAPHY UTILIZING TWO DIFFERENT COLUMNS. THE QUANTITIES OF THE 4 PESTICIDE COMPOUNDS FOUND, HOWEVER, ARE RELATIVELY SAMLL, RANGING FROM 0.01 TO 0.11 UG/KG (MICROGRAMS PER KILOGRAM).

PUGH CREEK - RESULTS OF ANALYSIS OF WATER AND SEDIMENTY SAMPLES OBTAINED FROM PUGH CREEK ARE GIVEN IN TABLE 2. THESE DATA INCIDCATE THE PRESENCE OF SMALL AMOUNTS OF CHLORINATED HYDROCARBONS IN THE STREAM BOTTOM SEDIMENT 1 1/2 MILES DOWNSTREAM FROM THE DISPOSAL SITE. THE QUANTITY FOUND IS IN EXCESS OF THAT PREVALENT IN THE AREA AWAY FROM THE DUMP SITE AND IS THEREFORE PRESUMED TO HAVE ORIGINATED FROM THE PIT AREA.

ONLY 2 SAMPLES OF WATER GAVE ANY INDICATION OF THE PRESENCE OF ANY OF THE 4 PRIMARY CHLORINATED COMPOUNDS. HENCE, CONTAMINATION OF THE WATER IN PUGH CREEK FROM THE DISPOSAL PITS IS ONLY AN ASSUMPTION.

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DRAWS - THE ANALYTICAL RESULTS OF RUNOFF AND WASHOFF SAMPLES FROM THE 4 DRAWS DRAINING THE DISPOSAL SITE ARE GIVEN IN TABLE 3. RESULTS OF TWO-COLUMN ELECTRON CAPTURE GAS CHROMATOGRAPHY INDICATED THE PRESENCE OF DIELDRIN, ENDRIN, AND HEPTACHLOR EPOXIDE IN MOST OF THE DRAW SAMPLES TESTED. THE PRESENCE OF HEPTACHLOR WAS INDICATED BY MICROCOULOMETRIC TITRATION FOLLOWING ONE COLUMN SEPARATION BUT DUPLICATION OF THESE RESULTS ON A SECOND COLUMN COULD NOT BE OBTAINED. IT MUST BE CONCLUDED, THEREFORE, THAT HEPTACHLOR WAS NOT PRESENT IN ANY OF THE DRAW SAMPELS ANALYZED, BUT A CHLORINATED COMPOUND SIMILAR TO HEPTACHLOR WAS DETECTED. THE AMOUNTS OF THESE COMPOUNDS THAT WERE FOUND RANGED FROM AS LITTLE AS 0.02 PG/KG TO AS MUCH AS 1,600 UG/KG.

IT WAS GENERALLY NOTED THAT HIGHER CONCENTRATIONS WERE FOUND IN THOSE SAMPLES THAT WERE COLLECTED FROM THE BOTTLE PORTION OF THE SAMPLERS THAN WERE FOUND IN THE ALL-SED-MENT SAMPLES THAT WERE RETRIEVED FROM THE PAN PORTION OF THE SAMPLERS. THIS WAS PROBABLY DUE TO LOSS OF THE MORE VOLATILE ORGANIC MATERIALS FROM THE PAN SAMPLE AS A RESULT OF EXPOSURE TO THE ATMOSPHER AND SUNLIGHT BEFORE THE SAMPLES WERE PICKED UP BY FIELD PERSONNEL.

ALTHOUGH A GREAT DEAL OF VARIATION CAN BE NOTED IN THE CONCENTRATIONS OF ORGANIC MATERIALS FOUND, BOTH AS TO TIME AND PLACE, THERE DOES APPEAR TO BE A DEFINITE DECREASE IN CONCNETRATION IN EACH DRAW WITH INCREASE IN DISTANCE AWAY FROM THE PIT AREA. THIS OBSERVATION, TOGETHER WITH THE OCCURRENCE OF HIGH CONCENTRATIONS IN SAMPLES WITH SEDIMENT, INDICATES THE RPINCIPAL MODE OF TRANSPORT TO BE ADSORPTION ON SEDIMENT PARTICLES. MORE PRECISE QUANTITATIVE RELATIONSHIPS COULD NOT BE DEVELOPED OWING TO THE LIMITED DATA AVAILABLE AND LACK OF ADEQUATE SAMPLING CONTR-L.

ANALYSIS OF CORE SAMPLES

THE CORE SAMPELS WERE ANALYZED FOR DIELDRIN, ENDRIN, HEPTACHLOR, AND HEPTACHLOR EPOXIDE. IN ADDITIO, THE TOTAL ORGANIC CHLORINE CONTENT, MOISTURE CONTENT (ASSOCIATION OF OFFICIAL AGRICULTURAL CHEMISTS, 1940, P. 1) AND PH (PEACH, 1965, P. 914) OF MOST OF THE SAMPLES WERE DETERMINED. AS A CONTROL, THE TOP AND BOTTOM SECTIONS OF EACH CORE SAMPLE WERE ANALYZED SEPARATELY TO IDENTIFY ANY CONTAMINATION THAT MIGHT HAVE BEEN INTRODUCED DURING THE CORING PROCESS. THE ROUTINE ANALYSIS OF THE CORES CONSISTED OF THE FOLLOWING PROCEDURES.

EXTRACTION

A 50.0 G SAMPLE OF PULVERIZED SOIL WAS SHAKEN IN AN ACETONE HEXANE SOLVENT. THE EXTRACT WAS DECANTED FROM THE SOIL INTO A SEPARATORY FUNNEL. THIS WAS REPEATED THREE TIMES AND THE COMBINED EXTRACTS WERE WASHED WITH WATER TO REMOVE THE ACETONE. THE EXTRACT WAS DRIED OVER SODIUM SULFATE. THE DRIED EXTRACT WAS THEN EITHER CONCENTRATED OR DILUTED TO A KNOWN VOLUME. THIS METHOD WAS FOUND TO BE ADEQUATE FRO THE EXTRACTION OF THE FOUR PESTICIDES FROM THE SOIL SAMPLES.

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GAS CHROMATOGRAPHY

THE GAS CHROMATOGRAPHIC ANALYSIS WAS PERFORMED IN A STEPWISE MANNER. FIRST, THE EXTRACT WAS ANALYZED BY ELECTRON CAPTURE GAS CHROMATOGRAPHY USING A 1/8 INCH BY 5-FOOT GAS CHROM Q COLUMN COATED WITH 5.0 PERCENT W/W DC-200 AND 0.5 PERCENT W/W CARBOWAX 20M. FURTHER CONCENTRATION ADJUSTMENTS AND CLEANUP (AS DESCRIBED) UNDER ANALYSIS OF WATER AND SEDIMENT SAMPLES IF INDICATED, WERE PERFORMED AT THIS TIME. THE EXTRACT WAS ANALYZED A SECOND TIME BY ELECTRON CAPTURE GAS CHROMATOGRAPHY USING A 1/8 INCH BY 5-FOOT GAS CHROM Q COLUMN COATED WITH 5.0 PERCENT W/W QF-1 AND 0.5 PERCENT W/W CARBOWAX 20M. IF A PARTICULAR COMPOUND OF INTEREST WAS INDICATED BY THE PREVIOUS TWO ANALYSES, A THIRD ANALYSIS WAS MADE ON A 1/8 INCH BY 5 FOOT GAS CHROM Q COLUMN COATED WITH 2.3 PERCENT W/W VERSAMID 930. IF THE CONCENTRATION OF THE COMPONENTS(S) WAS HIGH ENOUGH, MICROCOULOMETRIC DETECTION WAS EMPLOYED FOR THE THIRD ANALYSIS, OTHERWISE THE MORE SENSETIVE ELECTRON CAPTURE DETECTOR WAS USED AGAIN. IF THE SOIL EXTRACT HAD ONLY 3 OR 4 MAJOR COMPONENTS, GAS CHROMATOGRAPHIC IDENTIFICATION WAS MADE USING 3 DIFFERENT TYPES OF COLUMNS. FURTHER, WHEN A COMPONENT WAS PRESENT IN AMOUNTS LARGE ENOUGH TO PERMIT MICROCOULOMETRY, AGREEING QUANTITATIVE DATA FROM THE TWO DETECTION SYSTEMS WAS CONSISERED ESSENTIAL TO IDENTIFICATION. GAS CHROMATOGRAPHY ALONE WAS NOT SUFFICIENT FOR ANALYSIS OF MOR COMPLEX MIXTURES, THEREFORE, THIN-LAYER CHROMATOGRAPHY WAS USED FOR PRELIMINARY SEPARATION OF COMPONENTS.

THIN-LAYER CHROMATOGRAPHY

MICROLITER QUANTITIES OF THE EXTRACT WERE SPOTTED ON A SILICA GEL THIN-LAYER CHROMATOGRAPHIC PLATE AND DEVELOPED WITH HEXANE. THE COMPONENTS THAT MIGRATED A DISTANCE EQUAL TO THAT OF STANDARDS SPOTTED AND VISUALIZED ON THE SAME PLATE WERE SCRAPED FROM THE PLATE AND WXTRACTED INTO HEXANE. THE RESULTING SOLUTION WAS THEN SUBJECTED TO THREE-COLUMN GAS CHROMATOGRAPHIC ANALYSIS.

TOTAL CHLORINE

TO PROVIDE A MORE COMPLETE ESSAY OF THE SOIL CONTAMINANTS THAN COULD BE OBTAINED FROM THE MEASUREMENT OF ONLY A FEW OF THE IDENTIFIABLE COMPONENTS BY CONVENTIONAL GAS CHROMATOGRAPHY,A METHOD WAS DEVISED WHEREBY THE TOTAL CHLORINE CONTENT OF THE VOLATILE EXTRACTABLES COULD BE MEASURED. THE TOTAL CHLORINE ANALYSIS INVOLVED TEMPERATURE PROGRAMMED MICROCOULOMETRIC GAS CHROMATOGRAPHY ON A VERY SHORT COLUMN. THE SOIL EXTRACT WAS CONCENTRATED TO A SUITABLE VOLUME AND INJECTED ONTO A 3 PERCENT W/W APIEZON L COLUMN, 1/4 INCH O.D. BY 3.0 INCHES LONG. THE SOLVENT WAS SWEPT FROM THE COLUMN WITH NITROGEN GAS AT ROOM TEMPERATURE. AFTER A PREDETERMINED TIME THE COLUMN WAS HEATED TO 300 DEGREES C IN TWO MINUTES. FOLLOWING COMBUSTION OF THE ELUATE THE TOTAL CHLORINE WAS MEASURED WITH A MICROCOULOMETRIC TITRATING CELL. AN EXPERIMENTAL CHECK OF THE TOTAL CHLORINE PROCEDURE DEMONSTRATED THAT THIS TECHNIQUE IS APPLICABLE TO DETERMINING THE TOTAL CHLORINE CONTENT OF COMPOUNDS HAVING BOILING POINTS AS LOW AS HEXACHLOROCYCLOPENTADIENE AND AS HIGH AS METHOZYCHLOR. THE TOTAL CHLORINE IN AN EXTRACT FROM 50 G OF SOIL SAMPLE WAS MEASURED TO A LOWER LIMIT OF 0.5 UG/KG.

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DISCUSSION OF RESULTS

WHEN WASTE MATERIALS WERE DETECTED IN SIGNIFICANT AMOUNTS IN THE CORE SAMPLES THEY APPEARED AS COMPLEX MIXTURE. HOWEVER, NONE OF THE COMPOUNDS OF PRIMARY INTEREST (DIELDRIN, ENDRIN, HEPTACHLOR AND HEPTACHLOR EPOXIDE) WAS POSITIVELY IDENTIFIED (LIMIT OF MEASUREMENT 0.1 MICROGRAMS PER KILOGRAM) IN THE 200 CORE SAMPLES THAT WERE EXAMINED. INITIAL QUALITATIVE RESULTS SUGGESTED THE PRESENCE OF HEPTACHLOR, BUT COMPARISON OF ELECTRON CAPTURE AND MICROCOULOMETRIC DATA SHOWED A MARKED DIFFERENCE IN RESPONSE. THIS OBSERVATION INDICATED THAT EITHER ANOTHER COMPOUND, OR COMPOUNDS, ELUTED WITH HEPTACHLOR, ON BOTH DC-200 AND QF-1 COLUMNS, OR THAT HEPTACHLOR WAS NOT PRESENT. THE INTRODUCTION OF A THIRD ANALYTICAL COLUMN, VERSAMID 930, PROVIDED THE NECESSARY RESOLUTION OF COMPONENTS AND PROVED THAT THE COMPOUND IN QUESTION WAS NOT HEPTACHLOR.

BECAUSE NONE OF THE COMPONENTS EXTRACTED FROM THE SOIL SAMPLES WAS IDENTIFIED AS ONE OF THE FOUR COMPOUNDS OF PRIMARY INTEREST, THE ANLAYSIS WAS EXPANDED TO INCLUDE OTHER PESTICIDES AND CHEMICALS INVOLVED IN THE MANUFACTURE OF PESTICIDES. IN ADDITION TO THE PREVIOUSLY MENTIONED PESTICIDES THE COMPOUNDS ALDRIN, CHRLORDENE, CHLORDENECHLOROHYDRIN, HEXACHLOROBICYCLOHEPTADIENE, HEXACHLOROCYCLOPENTADIENE AND ISODRIN WERE INCLUDED. OWING TO THE MULTIPLICITY OF COMPONENTS IN THE SOIL EXTRACT IT WAS NOT POSSIBLE TO IDENTIFY THE INDIVIDUAL COMPOUNDS BY SIMPLE GAS CHROMATOGRAPHIC ANALYSIS.

ADEQUATE PRELIMINAR