STRESS DEPARTURE FROM PREFERRED ENVIRONMENT TRANSITION SATISFACTORY "HAZARDOUS" TIME Legal and administrative requirements are an integral part of long-range as well as short-term plans for environmental pollution abatement. It is selfevident that legal methodology must proceed forward hand in hand with the scientific. The Department of Defense is required to comply with a variety of legal and administrative procedures. Our concern is that in this broad area, subject as it is to a variety of influences, there should be developed improved understanding of the true complexity of the problem. Regardless of the approach taken in arriving at the legislative and administrative requirements, there are certain fundamentals which appear to be absolutely essential. These include: a. The necessity for determining whether or not the emphasis is to be upon performance standards or specific approval of equipment and practices. b. The need for flexibility to provide for the future. c. The recognition of the "test of practicality". This applies both to the feasibility of achieving what the law requires, and to the means of determination as to their achievement. There is a major difficulty affecting the establishment of programs for environmental pollution abatement arising from the problems which have been cited herein as to establishment of a true measure of the environmental quality desired. Anyone who is familiar with the many difficulties inherent in the establishment of allowable concentrations for industrial environmental exposures is aware of the differences of opinion regarding the significance of some of the number values utilized in such expressions as "maximum allowable concentrations," "threshold limit values," and "acceptable concentrations." Based on experience in this realm of environmental exposure control, there is a need for better understanding of the difference between a standard and a criterion. As pointed out in the State of California's excellent publication "Water Quality Criteria" the term "standard" as used in an environmental sense applies to a definitive rule, principal or measure established by authority. The comments in that publication on criteria, objectives, requirements and standards are worthy of quoting here. The term "standard" applies to any definite rule, principle, or measure established by authority. The key words in this definition are definite and established by authority. The fact that a standard has been established by authority makes it quite rigid, official, or quasi-legal. An authoritative origin does not necessarily mean that the standard is fair, equitable, or based on sound scientific knowledge, for it may have been established somewhat arbitrarily on the basis of inadequate technical data tempered by a cautious factory of safety. Where health is involved and where scientific data are sparse, such arbitrary standards may be justified. There is a tendency, however, for regulatory authorities to promulgate standards of questionable scientific justification to serve as a crutch that facilitates administrative action and enforcement. A far better word to describe an administrative decision by a regulatory body is "Requirement." It represents a requisite condition to fulfill a given mission. It does not necessarily have the connotation of scientific justification nor does it give an impression of immutability. Requirements are less likely to be as rigid or fixed as standards. In California, the regional water-pollution-control boards are directed to prescribe requirements for every existing or proposed discharge or sewage, or industrial waste, but such requirements may be revised from time to time (Section 13054 and 13054.1 of Division 7, California Water Code). Indeed, "No regional board, by prescribing requirements. shall be precluded thereafter from revising requirements relative to the same disposal area or receiving waters. A discharge pursuant to the prescribed requirements shall not create a vested right to continue such discharge under the same requirements" (Section 13002, Division 7, California Water Code). Examples of requirements by California WPC Boards are given in Chapter III. The word "objective" represents an aim or a goal toward which to strive, and it may represent an ideal condition that is difficult, if not impossible, of economic attainment. Most certainly, however, it does not imply strict adherence nor rigid enforcement by a regulatory agency. It is gaining favor among engineers on boards and commissions that strive to achieve water-pollution control by persuasive methods and cooperative action. It avoids the rigidity and authoritativeness of standards and it does not have the enforcement element of requirements. A "criterion" designates a means by which anything is tried in forming a correct judgment respecting it. Unlike a standard it carries no connotation of authority other than that of fairness and equity; nor does it imply an ideal condition. When scientific data are being accumulated to serve as yardsticks of water quality, without regard for legal authority, the term "criterion" is most applicable. For this reason, this report has been entitled "Water Quality Criteria." As a compendium of criteria, it should be useful in prescribing requirements in California, and it can be used as a guide by any agency that desires to establish standards or objectives. To be useful, a criterion should be capable of quantitative evaluation by acceptable analytical procedures. Without numerical criteria, vague descriptive qualitative terms are subject to legal interpretation or administrative decisions. A criterion should also be capable of definitive resolution, i.e., unaffected insofar as possible by synergism, antagonism, or other complicating factors. There is a tendency, which should be avoided assiduously, to let criteria become rigid and perhaps ripen into standards. For this reason, every criterion should be regarded as flexible information to be kept constantly under surveillance. Establishment of quality criteria The establishment of interim environmental quality criteria for those situations where no requirements have been promulgated by local, State, or Federal agencies is a function of the Medical Departments of the military services. In undertaking such tasks it has been recognized that in many instances the pace and progress of biological science, and the tools of ecological management have not kept pace with the advances in the physical sciences. Often available facts are not sufficient to support or contradict in a conclusive manner preliminary data. There are many pitfalls in attempting to extrapolate to the operation, or even to the test environment results of what are essentially biological or bioenvironmental investigations. Dr. Robert Kehoe, University of Cincinnati, in addressing the 2nd National Congress on Environmental Health at Ann Arbor, Michigan in June 1961 observed that the height of absurdity was reached "when one finds oneself soberly pondering the significance of a conventional mathematical expression of a borderline possibility concerning the effect or lack of effect of a given experimental procedure as applied to white rats under the artificial conditions of the laboratory when the question is not what happens in the laboratory but what will be the effects in the variable conditions of life." Instead of finite limits and strict numerical values as indicators of environmental quality, what appears to be most useful are ranges of environmental conditions, which are expected to produce certain predictable results. These multiple boundaries must be defined in such a manner that they can be measured. The method of measurement ought preferable to be applied to the environment, rather than to a biological response, although the effect can be quantified in such terms. Lest there be any misunderstanding, on this subject, nothing in the foregoing should be construed as a plea for delay pending development of better knowledge or improved technology. As shown in Figure 4, the passage of time and the increase of information from observations and experimentation will provide for changes in the state of knowledge. Initial concepts, and procedures, based on the then available appreciation of the situation may be either confirmed, found to be too conservative, or not stringent enough. Emergence of a whole new technology, or disappearance of some element of the problem may also alter the situation drastically. The actions taken by the military departments in relation to several potential environmental pollution situations, for which well established rules or environmental quality standards were not available exemplify the approaches which can be taken to provide for the public welfare. Typical of these actions to meet the needs of environmental pollution control, even in the absence of guidelines and standards, are those taken with regard to shipboard waste disposal, and waste from munition manufacturing operations. These represent situations in which both interservice and interagency cooperation has been necessary to a high degree. The Navy, Army, and Air Force alike operate vessels, and the U.S. Corps of Engineers in its Civil Works functions has a number of boats and surface craft on rivers and harbors. The nature of design of military vessels present some problems, and the needs of the dockside situation, as contrasted with open water operations are also different. Close cooperation is being achieved with the Federal Water Pollution Control Agency, and the U.S. Public Health Service to develop the necessary guidance as to performance and methodology. In the case of the munitions manufacturing waste problem, both the Army and Navy are concerned in their own facilities, and those which are contractor oper ated. Extensive investigations conducted by the U.S. Army Environmental Hygiene Agency have been reviewed by the National Academy of Sciences Advisory Center on Toxicology, and again cooperative efforts are being undertaken on an interagency basis to develop appropriate guidance as to permissible concentrations of these materials in the environment, and to use these as the basis for engineering design of abatement works. Of special interest are the programs regarding environmental pollution associated with rocket and space propellants. Many of the materials which have a possible use in this program are known to possess toxic and hazardous properties. In some instances there is incomplete data even with regard to routine occupational exposures. In other instances difficult situations are presented in attempting to determine the environmental quality values for non-occupational off-site situations. A major effort has been undertaken within the Department of Defense to provide for adequate protection against air and general environmental pollution hazards arising from our research, development, test and evaluation programs. This matter has been of some concern in recent hearings of the Senate Special Subcommittee on Air and Water Pollution, and is a matter of major opinion by the military departments concerned. Considerable testimony regarding this subject was presented in the 1964 Senate Subcommittee hearings and in 1965 before the Subcommittee on Public Health and Welfare of the Committee on Interstate and Foreign Commerce of the House of Representatives. A summary of information on the precautions associated with this material are included in the report of the hearings on S. 3112 before the Subcommittee on Air and Water Pollution of the Committee on Public Works, United States Senate (reference pages 443-453). It is worthwhile to point out in addition that here again, in the absence of definitive legislative or other regulatory requirements, initiative has been taken by the Department of Defense to provide to the extent consistent with available knowledge for the protection of the health of the population. The actions taken by the Air Force and the other military departments involved have been based upon appreciation of the need for the most thorough evaluation of the many facets of the problem. During the four year period of Fiscal Years 1964-1967, approximately $1,700,000 was expended in investigations on the atmospheric dispersion of beryllium particles from testing of rocket propellants; on testing and evaluation of sampling and analytical procedures and on fundamental toxicological studies. The Department of the Air Force has maintained close coordination with the U.S. Public Health Service so as to provide for an exchange of information. We have recognized that the problem is one in which there are major epidemiological implications and are depending upon the U.S. Public Health Service to furnish us with the necessary evaluations and guidance in that regard. Micrometeorological studies and investigations on this and other rocket propellants provide information which may be useful in civilian industry and communities. It is generally agreed that the industrial occupational exposure limit values should not be used as a basis for establishment of air pollution quality values insofar as continuous exposures are concerned. The rocket propellant test operations, on the other hand, represent air pollution situations generally discontinuous in nature and of extremely short duration. Some guidance as to permissible exposures can be obtained for on-site personnel from the industrial guidelines. Careful scrutiny of epidemiological data, toxicological studies, and the application of value judgments on the industrial levels can be utilized while more precise information is being accumulated. The application of the science of micrometeorology is also involved in determining and assessing possible distribution of contaminants in the environment. A summary of some of the more important air quality criteria for liquid propellants is provided in Figure 5, and for some other chemical substances in Figure 6. It is emphasized that these are not community air quality values, and are furnished only to give an appreciation of the difference in effects of various concentrations. There is a major possible contribution to knowledge and technology needed in air pollution resulting from this work. Among these are the improvements in diffusion prediction methodology, environmental sampling techniques, and in the realm of administrative rule making. This last, in company with the experience in interdepartmental coordination and industry cooperation may be of the greatest significance to the future. BUBSTANCES Alkyl Boranes-Skin Aniline-Skin Chlorine Trifluoride Diborane Diethylenetriamine (DETA) < 0.01 (13) (Skin penetration Short Immediately (NEF-3 NiCal-3 are not very volatile but can produce enough vapor to cause toxic effects. HEF-2 10 rather volatile, HEF-3 and Hical-p are sore dangerous then NEF-2() is more of an industrial hazard, Unknown - Because of tendency to skin & pulmonary sensitization, all exposure must be reduced to lowest possible level. (3) DETA does not bave good warning powers. (12) Due to its low vapor pressure, it does not vaporize readily at normal temperatures, and little respiratory irritation is evident. (12) Sensitization is the primary hazard. •PPM Parts of vapor or gas per million parts of air by volume at 25°C and 760 an lig pressure FIGURE 5 |