Recently in Clean Water Act Category

Surface water pollution from urban pesticide use is a known, widespread problem in the U.S.  This has been documented not only by USGS, but also by numerous scientific studies by academic researchers, data from municipal urban runoff programs, and surface water impairment designations under section 303(d) of the Clean Water Act (often these listings are for "toxicity" rather than a specific pesticide).  U.S. EPA's pesticides office is keenly aware of this problem.

Pesticide-related Toxicity in Surface Waters

In California, pesticide-related toxicity in surface waters receiving urban runoff is has been severe and widespread since the mid-1990s. Addressing this toxicity is a priority for Calfornia's water and pesticide regulators. With the phase-out of most urban uses of diazinon and chlorpyrifos, the toxicity has shifted--it is now occurring in both the water column (during storm events) and sediments (all the time) in urban creeks across California. 

The current toxicity is associated with the use of the currently most common class of urban insecticides--the pyrethroids (i.e. bifenthrin, cypermethrin, cyfluthrin, etc.).  Similar toxicity has also been documented in Texas urban areas.
Substituting Pesticides Also Causes Biodiversity Problems

Since some in this thread mentioned pesticide phase outs, it is important to recognize that the likely substitute for pyrethroids is fipronil, which is already seeing growing use in California--and is beginning to appear in surface water at levels close to those known to be toxic to sensitive aquatic organisms.  It is becoming clear that simply changing pesticides isn't going to solve these water quality problems.

Professional Insecticide Applicators Are the Link

Substantial effort is underway in California to identify the sources of pesticide-related urban surface water toxicity.  Available data show a direct link to outdoor, above-ground insecticide applications by professional applicators. 

Ants Are the Most Common Insect Problem in California

In California, ants are the most common insect problem and it is a common practice (particularly among commercial property owners and multi-family residential property managers) to retain a professional applicator to spray a band of insecticides around structures every 1-2 months.  Much of the treated area around structures is impervious surface, some of which is directly connected to storm drains (DCIA). 

Pre-construction termiticide and Post-construction Pyrethroids

Other possible sources include pre-construction termiticide ground surface treatments (if a rain event occurs before building foundations are poured), and both professional and non-professional applications in other outdoor locations (applications to lawns/landscaping have not been ruled out as potentially meaningful contributors to toxicity).

Underground injection of pyrethroids (i.e., for post-construction termite control) is unlikely to contribute to surface water toxicity.  Most California municipalities are served by separate storm drain systems comprised completely of hard surfaces (i.e., no vegetated channels)--thus pesticides in runoff are efficiently delivered to urban creeks.

Greatest Water Pollution Problem: Insecticides vs Herbicides

There is a long-time myth that homeowner lawn/garden applications of pesticides (particularly herbicides) are a big problem.  Maybe they are in some locations, but available scientific data strongly suggest that insecticides--not herbicides--are of greatest concern in urban areas and that (at least in California) professional pesticide applications--and intentional applications of pesticides to impervious surfaces--should be the priorities for stormwater quality management.

Urban Pesticides Pollution Prevention Project (UP3 Project)

With grant funding from the California State Water Resources Control Board, the Urban Pesticides Pollution Prevention Project (UP3 Project) is working with U.S. EPA, California EPA, municipalities, and other stakeholders to understand and prevent pesticide-related surface water pollution.  Pesticide regulators and pesticide manufacturers are aware of these problems and are working to change their systems to address them.  For more information (and reports that document the statements above), please see www.up3project.org.

Kelly Moran, Ph.D.
TDC Environmental
UP3 Project

P.S. Wastewater treatment plants are not immune to pesticide-related problems.  Discharges of certain pesticides (including biocides) to municipal wastewater treatment plants have been problematic, in some instances, for compliance with NPDES permit effluent limitations and operation of biological treatment processes.

EPA is working with dental offices to begin collecting dental amalgam before it enters the waste stream.

As part of its pretreatment standards review process, EPA is reviewing industrial sources of mercury, including dental facilities, for potential technology-based options for controlling mercury discharges to wastewater treatment plants. In addition, the Agency is working with wastewater treatment plants to begin implementing best management practices for collecting mercury from other industrial sources, as well as modifying surface water discharge permits to reflect stricter requirements in mercury discharges.

See EPA's Effluent Guidelines Program web site (http://www.epa.gov/guide/) for more information.
The Clean Air Act (CAA) and its amendments are designed to "protect and enhance the nation's air resources so as to promote the public health and welfare and the productive capacity of the population." The CAA consists of six sections, known as Titles, which direct EPA to establish national standards for ambient air quality and for EPA, states, and tribes to implement, maintain, and enforce these standards through a variety of mechanisms. Under the CAA, many facilities are required to obtain operating permits that consolidate their air emission requirements. State, tribal, and local governments oversee, manage, and enforce many of the requirements of the CAA.

Healthcare Air Emissions / Pollutants

Healthcare air emissions come from  air conditioning and refrigeration, boilers, medical waste incinerators (if on site), asbestos, paint booths, ethylene oxide sterilization units, emergency generators, anesthesia, laboratory chemicals, and laboratory fume hoods.

EPA has established national ambient air quality standards (NAAQSs) to limit levels of "criteria pollutants," including carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant are designated as attainment areas; those that do not meet NAAQSs are designated as nonattainment areas.

Each state is requireed to develop a State Implementation Plan (SIP) to identify sources of air pollution and to determine what reductions are required to meet federal air quality standards.

New Source Performance Standards (NSPS)

The following NSPS are particularly relevant to the healthcare industry:

Boilers -Most hospital boilers are subject to the NSPS regulations.

Requirements for monitoring and recordkeeping. http://www.epa.gov/ttn/atw/boiler/boilerpg.html.

Medical Waste Incinerators - Under the CAA, EPA regulates air emissions from hospital and or medical/infectious wastes incinerators (HMIWI). For additional information visit: http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html.

Hazardous Air Pollutants

EPA establishes and enforces National Emission Standards for Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented toward controlling specific hazardous air pollutants (HAPs)

Asbestos (40 CFR 61 Subpart M) - A hospital that performs demolition and renovation operations will be subject to the CAA NESHAP for asbestos.

Industrial, Commercial and Institutional Boilers and Process Heaters (40 CFR 63 Subpart DDDDD) - This NESHAP may apply at hospitals that are major hazardous air pollutant emitters under the CAA.

Chemical Accident Prevention Provisions 

The CAA sets forth a list of regulated substances and thresholds, a petition process for adding or deleting substances to the list of regulated substances, etc.

Title V Permits

Title V of the CAA requires that all "major sources" (and certain minor sources) obtain an operating permit.

Refrigerant Recycling Rule 

The purpose of Section 608 of the CAA is to maximize the recovery and recycling of refrigerants during the servicing and disposal of stationary air conditioning and refrigeration equipment. Requirements include prohibition of venting, service requirements, equipment certification, leak repair, proper disposal, and recordkeeping.

EPA Resources for Clean Air Act Compliance and References

More information can be found at http://www.epa.gov/region02/cfc/.

EPA's Clean Air Technology Center, at (919) 541-0800 (in Spanish: (919) 541- 1800) or http://www.epa.gov/ttn/catc, provides general assistance and information on CAA standards.

The Stratospheric Ozone Information Hotline, at (800) 296-1996, or the Ozone Depletion web site (www.epa.gov/ozone), provides general information about regulations promulgated under Title VI of the CAA.

RCRA information pertaining to questions about accidental release prevention under CAA Section112(r), is available in the RCRA OnLine database (www.epa.gov/rcraonline),

Asearchable database of Frequently Asked Questions (FAQs) about RCRA, and through an on-line order form for RCRA publications (www.epa.gov/epaoswer/osw/publicat.htm).

Information on air toxics is at the Unified Air Toxics web site at http://www.epa.gov/ttn/atw/.

The Clean Air Technology Center's web site includes recent CAA rules, EPA guidance documents, and updates of EPA activities. Visit the Office of Air and Radiation (OAR) homepage for more information: (http://www.epa.gov/air/).

SOURCE:  EPA industry sector information: www.hercenter.org/links

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