EPA-904/9-83-112b Region 4
345 Courtland Street, NE
,™..w, Atlanta, GA 30365
oEPA Environmental Management
Report
Region IV
Pi lot\ Project
Appendices A and B
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DATE.
SUBJECT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Environmental Services Division, Athens, Georgia 30613
Transmittal of -Environmental Management Report
FROM
TO
Regional Administrator
Region IV
Joseph A. Cannon
Associate Administrator for Policy
and Resource Management
We are pleased to transmit Attachments A and B (enclosed) of the
final Region IV Environmental Management Report. As with Parts
1 and 2, Attachments A and B have also been extensively revised,
in accordance with both headquarters and state comments.
Please recognize that this is a pilot effort and that the Region
IV EMR is intended for internal distribution within EPA. Future
EMR's should also focus on accomplishments to give a more balanced
presentation of the results of both federal and state environmental
programs. We prefer that distribution outside the Agency be handled
by the Region.
We appreciate the opportunity to work with you and your staff on
this exercise. The guidance, encouragement and coordination from
your office have been greatly appreciated. We look forward to
working with you in the future as we integrate the EMR exercise
into other planning and management functions.
Charles R. Jeter
Attachments
EPA F«m 1320-6 (R.v. 3-76)
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ENVIRONMENTAL MANAGEMENT REPORT
REGION IV
(PILOT PROJECT)
ATTACHMENTS A AND B
NOTE: This report was prepared
primarily as an internal document,
MAY 1983
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REGION IV ENVIRONMENTAL MANAGEMENT REPORT
ATTACHMENTS A AND B
TABLE OF CONTENTS
Page
ATTACHMENT A: Medium-by-Medium Overview
Introduction 1
Air Quality 9
Water Quality 40
Drinking Water ' 86
Groundwater 95
Wetlands 106
Hazardous Waste Control 119
. RCRA
. Superfund
Radiation 162
Pesticides 177
ATTACHMENT B: Detailed Analysis of Significant Environ-
mental Problems
Air Quality Problems and Significant Projects 180
Synthetic Fuel Facilities 188
Electric Power Generation 192
The Biscayne Aquifer 196
Pesticides 200
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Region IV
ENVIRONMENTAL MANAGEMENT REPORT
PILOT PROJECT
Attachment A
Medium-by-Mediam Overview
INTRODUCTION
1 . Geography
The highest elevation (Mt. Mitchell at 6684 feet above
msl) and the lowest elevation (sea level) east of the
Mississippi River are located within Region IV as well as 16
percent of the nation's inland water surface and 2034 miles
of coastline. This results in a diversity of ecosystems
ranging from the Canadian life zones of the Appalachian
Mountains to the subtropics of south Florida. Each must be
regarded as unique with specific qualities to be considered
when dealing with pollution abatement.
Geomorphically, the Region has three dominant
provinces, the Mountains, the Piedmont, and the Coastal
Plain, and numerous sub-provinces (Fig. D-1). One of the
world's largest supplies of easily exploited, high quality
bituminous coal is found in these mountains. Most of the
rivers in Region IV originate in the Mountains and pass
through "the Piedmont before discharging into either the
Atlantic Ocean or the Gulf. The juxtaposition of headwaters
and industrial discharges create a historically bad water
pollution problem notably in western North Carolina,
Kentucky, and eastern Tennessee. The situation has improved
since the enactment of. the Clean Water Act, but acid mine
drainage and paper mill effluents are still major problems
to be addressed.
The Piedmont contains the bulk of the South's indus-
trial development and large cities. In addition to the
normal pollution associated with industries and cities,
erosion has been a serious problem evidenced by stream
turbidity, sedimentation, and the transport of nutrients and
agricultural chemicals into surface waters. The famous "red
clay" of the Southern Piedmont is really a laterized subsoil
which by requiring extensive fertilization to produce
successful crops compounds non-point source pollution.
The Fall Line is a definite demarcation between the
Piedmont and the Coastal Plain. The sudden drop in gradient
has lead to the construction of many dams, reservoirs, and
electric power plants. Because much of the Coastal Plain is
valuable as agricultural land, most of the native forests
have been removed and wetlands have been drained. The
streams and rivers are sluggish and meandering. Silts from
the Piedmont tend to settle here. Since the early 1800's,
deposition has caused swamps to be formed where once streams
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flowed. Natural waters are characteristically "tea" colored
with a high pH. Many streams have been dammed to form
innumerable small agricultural ponds. Because of the warm
climate, sluggish waters, and a high nutrient level, aquatic
weeds, which have long been a problem in Florida, are
becoming problems in other states. Land use changes have
lead to an increasing nutrient level in surface waters.
In summary, Region IV is characterized by extreme
variations in landforms, ecosystems, and economic activi-
ties. Thus, the approach to environmental protection must
be versatile and site specific.
2. Demography
A rapidly increasing population and an expanding_
•industrial base have reversed the socio-economic character-
istics of Region IV. At one time, Region IV had a negative
net emigration and an agricultural based economy. Region IV
now has the nation's highest rate of immigration and has a
service/manufacturing based economy. As a result, most
measures of economic viability are approaching the national
averages.
Regional population increased 22 percent (from 31.9 to
38.9 mil-lion) between 1970 and 1980. Interregional immigra-
tion accounted for 55 percent of this increase while natural
increases and resident population retention accounted for
the remainder. Population projections for the years 1980-
2010 show a 30 percent increase in Region IV compared to a
national projected growth of 21 percent (Figures D-2 and
D-3). The growing population will generate air, water, and
solid waste pollution problems to which the increasingly
older age group will be more sensitive. Projected land use
changes will add to the pollution problems. For example,
the protection of water supply watersheds in rapidly devel-
oping areas is becoming a major water quality issue in North
Carolina.
Population and manufacturing earnings in Region IV1s
coastal counties parallel the projected growth for their
states, and their share of state population and earnings is
projected to be stable between 1978 and 2000 (Tables D-1 and
D-2). Mississippi is the only state whose coastal counties
are projected to grow at rates greater than the state's
growth rate for both population and earnings. In all
V states except North Carolina, coastal Standard Metropolitan
Statistical Areas (SMSA) have a larger share of population
and earnings than non-SMSA counties and will generate the
greatest environmental impacts in Region IV's coastal areas.
However, the non-SMSA counties could suffer significant
impacts as population and industry grow over the next 20
years. Coastal growth will affect every EPA program to some
extent.
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One measure of pollution abatement effectiveness is the
quantity of pollutants eliminated by manufacturing sources.
The U.S. Bureau of the Census has conducted annual surveys
of such sources which show the elimination of 68.5 million
tons of air pollutants, 259.5 million tons of solid wastes,
and, since 1978, 11.5 million tons of water pollutants.
These quantities represent 13.9, 22.9 and 16.1 percent of
the nation's respective totals. Trends in pollutant
elimination have been stable for the past 2 years.
Estimates of the number of firms that may generate
hazardous waste show a 16.3 percent increase between 1973
and 1978 (from 34,053 to 39,616 firms). When categorized by
number of employees, 79.2 percent of the new firms had 20 or
less employees. Most of these small firms would not be
regulated since the amount of wastes generated would be less
than that required for reporting purposes. The growth of
these small firms has reduced the average number of employ-
ees per firm by 7.0 percent in this time period.
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Figure D-1. Geographic Provinces of Region IV
1 Southern Coastal Plain
2 Kentucky Sandstone & Shale
3 Kentucky Bluegrass & Nashville Basins
4 Highland Rim & Pennyroyal
5 Western Appalachian Plateaus &
Cumberland Mountains
6 Northern Appalachian Ridges & Valleys
7 Southern Piedmont
8 Carolina-Georgia Sandhills
9 Southern Mississippi Valley
10 Ala.-Miss. Blackland Prairies
11 Sand Mountain
12 Southern Appalachian Ridges
& Valleys
13 Blue Ridge
14 Atlantic Coast Flatwoods
15 Gulf Coast Flatwoods
16 Central Florida Ridge
17 Southern Florida Fleetwoods
18 Florida Everglades
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TABLE D-1
Region IV1s Coastal Counties Population Growth
Percent
of State Population
Percent of Increase
1978-1990 1978-2000
Coastal Coastal
1978 1990 2000 Counties State Counties State
Alabama
Florida
Georgia
Mississippi
North Carolina
South Carolina 21.3 21.4 21.2
11 ,
80,
6,
12,
9,
.6
.6
.4
.2
.3
12
80
6
12
9
.0
.4
.2
.9
.3
1
8
1
2.
1 .
6.
3.
8.
.1
.2
,2
.0
.9
11,
29,
8,
18,
13,
8,
29,
12,
12
12
17.8
48.7
19.8
32.2
18.1
13.6
47.6
22.9
24.0
23.2
15.3 14.6
24.9
25.9
TABLE D-2
Region IV s Coastal Counties Manufacturing Earnings Growth
Percent
of State Earnings
Percent of Increase
1978-1990 1978-2000
Coastal Coastal
1978 1990 2000 Counties State Counties State
Alabama •
Florida
Georgia
Mississippi
North Carolina
9.7
78.8
7.3
20.2
4.1
South Carolina 10.8
9.6 9.6
77.8 77.7
6.2 6.1
23.0 23.7
4.1 4.0
10.5 10.9
63.6
67.3
44.2
110.1
60.5
61 .5
64.5
69.3
70.8
84.1
61 .4
67.1
121.1
136.8
89.9
210.9
111.7
136.7
123.8
140.2
127.8
177.1
118.8
134.6
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TABLE D-3
Employment
Increase
Employment
Increase
INDUSTRIAL GROWTH
Past or Projected
Time Period
1969-1978
1978-2010
Region IV
27%
50%
National
18%
37%
Manufacturing
Employment
Increase
Manufacturing
Employment
Increase
1969-1978
1978-2010
16%
45%
2%
16%
Industrial
Earnings
Increase
1978-2010
209%
167%
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POPULATION DISTRIBUTION
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POPULATION GROUTH
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Figure D-3
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AIR QUALITY
1. Goals of the Clean Air Act and Overall Regional
Progress
The primary goal of the Clean Air Act is to protect and
enhance the quality of the nation's air resources so as to
promote the public health and welfare and the productive
capacity of its population.
Great progress toward this goal has been made in Region
IV over the last decade. Air pollution from stationary
sources has been greatly reduced. Figure AQ-1 displays a
trend indicating that the air quality is steadily improving
for the criteria pollutants. The major problems requiring
further work are nontraditional sources of particulate
emissions, stationary sources of volatile organic emissions,
vehicle emissions, and traditional pollutants in a few
areas.
The evaluation of trends in air quality and emission
data should be tempered with an understanding of trends in
the economy over the past few years. National steel produc-
tion is at 30% capacity and total national industrial pro-
duction is at 70% capacity. Figure AQ-2, Yearly Production
or Shipments for Certain Industries as a Percentage of 1979
Data, shows significant decreases in production. These data
are from the 1983 U.S. Industrial Economics, U.S. Department
of Commerce. A relationship exists between industrial
output and measured ambient air quality concentrations and
plant emissions, so there are significant decreases from
1980 through 1982. The emissions have generally decreased
in Region IV, partly because of a reduction in industrial
output.
The majority of sources emitting total suspended parti-
culates installed control equipment during the initial phase
of State Implementation Plan (SIP) control strategies in the
early 1970's. Most 1979 particulate control strategies for
nonattainment areas demonstrated that nontraditional sources
were the most significant contributors to the problems.
Because of the impending promulgation of an inhalable parti-
culate standard, EPA shut off funds for studying possible
controls on these nontraditional sources. Consequently,
many areas have made little progress in attaining the total
suspended particulates standard.
Major hydrocarbon or volatile organic compounds sources
have installed emission controls resulting in significant
reductions in emissions. Many stationary sources have
extended compliance schedules.
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2. Status of Ambient Air Quality in Region IV
a. Current and Projected Nonattainment Areas
(1) Carbon Monoxide (CO)
The Region has five post-1982 nonattainment areas for
CO. The states have submitted 1982 SIP revisions which
indicate that these areas will not come into compliance
until sometime after 1984. In addition to the post-1982
areas, six other counties may have difficulty in meeting the
CO standard in 1984 because they had violations of the CO
standard in 1981 and 1982. Historically, the growth rate of
emissions from mobile sources has been around three percent
per year, and the Federal Motor Vehicle Emission Control
Program (FMVCP) reduces emissions by only about the same
percentage. Thus, it is projected that if an area was
violating the CO standard in 1981 or 1982, the area could
still be violating the CO standard in 1984 (Figure AQ-3).
This assumption may be conservative because of the present
recession, which creates an atypical decrease in vehicle
miles traveled. In effect, the FMVCP is probably going to
offset slightly the growth of actual emissions until econo-
mic recovery occurs, and concentrations of CO are likely to
begin to decrease in the near future. During the next
several ,months the Region will be doing a thorough analysis
of these six additional areas with the state/local agencies
to more clearly define which ones should be designated
nonattainment.
(2) Ozone
The Region projects that several counties will not be
attaining the ozone standard in 1984 (Figure AQ-4). How-
ever, the Region plans to conduct a thorough analysis over
the next several months to ascertain if these projections
should be changed (also see discussion under Rural Ozone
Nonattainment).
(3) Sulfur Dioxide
Based on analysis of the Ambient Air Quality Data, all
areas in Region IV met the sulfur dioxide standards by
December 31, 1982 (Figure AQ-5),
(4) Total Suspended Particulates
The number of counties not meeting the total suspended
particulates standards has also greatly declined. The
majority of the remaining areas are in Kentucky, where the
problem is believed to be related to fugitive dust from haul
roads. The Region is also working with Tennessee and
Alabama to resolve their remaining problem areas. (Figure
AQ-6).
to
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b. Monitoring Areas and Measured Data
Figures AQ-7 thru AQ-12 indicate, in general, that the
Region IV ambient air quality is good and shows an improve-
ment during the period of 1977-1981 which should continue.
As the various monitoring programs and policies of the state
and local air pollution control agencies are refined and
improved, the quality of, and confidence in, the Regional
ambient air quality data submitted to the SAROAD data bank
by these agencies will be increased.
Stating that the data show good and/or improved ambient
air quality does not preclude the fact that problems exist
in attempting to interpret these data. Factors such as
changes in primary and/or secondary standards, changes in
siting criteria, changes in site locations, changes in
personnel responsible for monitoring a particular site and
changes in monitoring methodology and equipment contribute
to the difficulty of interpreting status and trends of
ambient air quality for specific geographic areas in the
Region. Figures AQ-13 thru AQ-18 indicate there are numer-
ous areas where monitoring is not being conducted. Addi-
tional monitoring for some of the criteria pollutants would
provide a better data base from which to assess ambient air
quality.
i -
3. Status Of Lead and Nitrogen Dioxide
a. Lead
No areas in Region IV have been identified as non-
attainment for the lead standard. However, violations of
the standard have been measured at two sites in Alabama.
b. Nitrogen Dioxide
Generally, nitrogen dioxide has not been a significant
problem in Region IV. In the late 1960's, the Chattanooga,
Tennessee, area was chosen for an epidemiological study
relating nitrogen dioxide to community health. The high
levels of nitrogen dioxide were from the Volunteer Army
Ammunition Plant which is no longer operating. Also, a few
large urban areas, such as Nashville, do approach the nitro-
gen dioxide standard.
4. Source Emission Trends
Trends in emission data can provide insight and serve
as a valuable indicator in the overall analysis of a parti-
cular area. However, it must be used in conjunction with
other data, such as air quality monitoring and modeling,
since emission data alone do not provide a complete picture.
Over the past several years, a low priority has been set on
maintaining the National Emission Data System, in which
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emissions data are kept. Consequently, EPA's current system
is very suspect and lacking in completeness, and thus would
not lend itself readily to use in trends analysis. Higher
priority must be given to this activity.
5. Trends And Projection Of Nonattainment In Region IV
a. Total Suspended Particulates
Measured total suspended particulates concentrations
have been decreasing in areas where significant controls
were installed and where production has declined because of
the recession. Numerous problems exist, however, and many
new ones are anticipated. If EPA adopts an inhalable parti-
culate standard there could be a significant reduction in
the number of nonattainment areas.
b. Ozone
Ozone concentrations appear to be declining at many
ambient monitoring sites; however, some sites are still
experiencing high concentrations. Most ozone sites in
southeast Florida (Broward, Dade and Palm Beach Counties)
have not measured exceedances of the standard. Two Miami
sites show violations of the standard. EPA policy defines an
urbanized area as an area with a population of greater than
200,000 and must include adjacent fringe areas of develop-
ment. Broward and Palm Beach Counties are adjacent to Dade
County and are considered to be one contigious urbanized
area.
Data for the Atlanta and Birmingham areas show slightly
downward trends, but the trends cannot be given much weight
because of the unreliability of short-term trends.
c. Sulfur Dioxide
Over the past ten years, ambient sulfur dioxide levels
have decreased because of economic trends, improved com-
pliance with State Implementation Plan emission limits, and
taller stacks. Tall stacks have replaced short stacks at
some older sources. A number of New Source power plants
generally have built tall stacks. Numerous sources switched
from coal to oil prior to the oil embargo, while others have
installed scrubbers or purchased low-sulfur coal or gas.
Dispersion modeling has been an excellent tool for predict-
ing the amount of control needed to achieve the sulfur
dioxide standard.
d. Carbon Monoxide
In many areas of the Region, ambient carbon monoxide
concentrations appear to have decreased slightly, but there
is no clear trend in the data. Some cities have extensions
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until 1987 to attain the standard and have therefore adopted
vehicle inspection and maintenance plans. Carbon monoxide
measurements in other cities—Miami, Fort Lauderdale,
Knoxville, Chattanooga, Durham and Raleigh—will require
further analysis. Such analyses may indicate a need for
vehicle inspection and maintenance. Most sites are measur-
ing exceedances of the 8-hour average carbon monoxide stan-
dard. Many sites have concentrations significantly over the
standard and are measuring numerous exceedances each year.
Unfortunately many sites have not been operating over a
sufficient number of years or collected enough data during
each year to show a definitive trend. Other cities have
more historical data but also have dramatic year-to-year
variations. Meteorological conditions have a tremendous
influence on the data measurements so several years of data
are needed to judge attainment.
6. Trends in Ambient Air Quality for Selected Sites
Review and evaluation of ambient air monitoring data
reported from selected sites in eight major metropolitan
areas in Region IV during the period of 1977-1981 indicates
a trend toward improvement of air quality (Figures AQ-7 thru
AQ-12). In addition to these specific sites, there was an
overall Regional improvement in air quality for the same
time period. The total number of violations of the National
Ambient'Air Quality Standards for five of the six criteria
pollutants decreased during 1977-1981; the primary standard
for nitrogen dioxide was not exceeded (Figure AQ-1).
7. Population Exposure
One of the stated purposes of the Clean Air Act is to
protect and enhance the quality of the nation's air
resources so as to promote the public health and welfare and
the productive capacity of its population. An assessment of
Region IV population and land area exposed to nonattainment
levels of criteria pollutants show decreased numbers in both
categories (Figure AQ-19 and AQ-20). Population increases
in nearly all nonattainment counties were offset by
decreases in the number of nonattainment counties. In the
case of ozone, the actual number of people exposed to non-
attainment levels did increase but the percentage of the
total Regional population exposed, decreased. In counties
where only a portion of the county was designated as non-
attainment, the total population and land area for the
county were used for evaluation purposes.
Figures AQ-21, AQ-22 and AQ-23 identify the populations
of the current and projected nonattainment areas. These
figures indicate that for carbon monoxide and ozone, the
areas affected are major population centers, which is logic-
13
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al due to the relationship of these pollutants to motor
vehicles. The total population affected in Region IV is
9,763,000.
8. Corrective Actions
a. Improved Regulations
(1) Development of Generic Regulations
All States in Region IV except Mississippi and Florida
have adopted or are developing generic Emissions Trading
regulations as revisions to their State Implementation
Plans. The regulations, when adopted by a State or local
agency and approved by EPA, will enable the Agency to effect
State Implementation Plan changes at the state level for
many actions without prior EPA approval.
The major problems associated with developing EPA
approved state generic regulations are related to air qua-
lity modeling procedures for total suspended particulates,
sulfur dioxide, and carbon monoxide emission trades. Such
emission trades often require modeling under EPA's proposed
Emissions Trading policy statement (Level II modeling) and
must meet the following conditions:
(a) no net increase in applicable baseline emis-
sions ;
(b) emission points involved in the trade can be
modeled in a predescribed replicable manner. (To limit
variability in modeling results, the generic rule must
specify the models and modeling techniques that will be used
in particular situations and the procedures for selecting
input data. The models, techniques and procedures must be
sufficiently defined to assure that trades will not create
new ambient standards violations or interfere with the
removal of existing violations.);
(c) no significant ambient impact. (i.e., the
change in emissions after the trade does not cause an
increase of more than 10ug over a 24-hour period for total
suspended particulates 13ug/m3 [24-hr.] for sulfur dioxide
or 575ug/m3 [8-hr.] for carbon monoxide at the receptor of
maximum predicted impact).
Item (b) above is the major problem. EPA is working
with state agencies to resolve the issues. EPA is exper-
iencing some difficulty in devising modeling procedures that
are sufficiently stringent and replicable, and can be used
by all states.
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The Office of Air Quality Planning and Standards and
Headquarters EPA are working with Region IV to resolve this
problem. PEDCO Environmental has been retained by the
Office of Air Quality Planning and Standards to develop the
required modeling procedures. The Office of Air Quality
Planning and Standards has the lead in resolving the model-
ing issues. Considerable Regional resources are being used
in this effort(six meetings between September 1982 and
January 1983), and the expected completion date is April
1983.
EPA Region IV continues processing State Emissions
Trading actions through the State Implementation Plan pro-
cess; however, the request for such actions has declined
since EPA issued its proposed Emissions Trading policy
statement. Industry continues to benefit from application
of more economical emissions control procedures under the
bubble, and we expect increased activity in this area after
EPA resolves the modeling problems and issues in its final
policy statement.
More states will then adopt generic regulations for
Emissions Trading activities and other State Implementation
Plan actions. An increase in industry participation should
follow EPA's approval of the states' generic regulation.
•v
(2) Elimination Of Ambiguities In State Regula-
tion
Elimination of ambiguities in state regulations will be
resource intensive; however, probably less costly than
allowing the regulations to remain unchanged. This is
especially true when industry or others mount legal chal-
lenges to the regulations.
Many state compliance test regulations are written so
industry sometimes does not interpret the regulations as the
State or EPA interprets it. This is evident where visible
emissions, fugitive dust and intermittent emissions regula-
tions are involved. Testing of intermittent sources
presents special problems, requiring considerable Head-
quarters assistance.
Consistency is not adequate between state Start-up,
Shut-down and Malfunction Regulations. They lead to differ-
ent interpretations regarding compliance status during the
start-up, shut-down or malfunction periods.
(3) Improved Flexibility of Non-Generic
Regulations
In the past, states have been required to revise their
regulations based upon changes in EPA regulations. EPA and
states anticipate resource reductions. It is critical that
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future state regulations not affected by generic regula-
tions be as flexible but enforceable as possible to con-
serve resources. This flexibility should be given special
attention when EPA changes in requirements do not affect air
quality.
This flexibility could be very useful when EPA makes
changes in its ambient or source monitoring procedures or
source test procedures, and present state procedures are
adequate. Moreover, if EPA revises a regulation, and its
requirements are met in operating permits that are generic,
the State Implementation Plan revision process for the
regulation could be avoided.
b. Policy Changes
(1) Rural Ozone Nonattainment Areas
Present EPA policy requires that areas less than
200,000 population that are violating only the ozone stan-
dard adopt regulations for volatile organic compound sources
greater than 100 tons per year. Further, non-State Imple-
mentation Plan demonstration is required. Over the next
several months Region IV will be evaluating the adequacy of
this policy to attain and maintain the ozone standard.
Because-of elevated ozone readings in 1981 and only having
seen the first two quarters of 1982 data, the present policy
may be inadquate; an evaluation will be sufficiently com-
pleted by May 1983 to ascertain if the current policy is
adequate for Region IV. At this time plans are to make a
specific recommendation to Headquarters on needed changes.
The Region will also be looking at the present data recovery
from the ozone monitors during the time a site should rea-
sonably be expected to have violations of the standard.
Plans are to work with the states and local agencies to
assure a 75% data recovery for the 1983 summer ozone season.
A review of the data indicates that, for both rural and
urban site data, recovery is sparse. However, this may be
due to the fact that data were only collected during the
summer months.
(2) Newly Designated Nonattainment Areas
The current agency policy on newly designated non-
attainment areas is to propose sanctions at the same time
the proposed redesignation is made (February 3, 1983,
Federal Register, Part VI c). The reasoning for this is that
the State Implementation Plans are supposed to provide for
attainment and maintenance of the ambient air quality stan-
dards. This approach should be reevaluated to consider when
and where sanctions should be imposed, and when they should
be discretionary. Throughout this report, several such newly
designated nonattainment areas have been identified,making
this a real situation in Region iv.
u
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Policy decisions also must be made for what is required
in a new State Implementation Plan for a newly designated
nonattainment area or for current nonattainment areas that
did not demonstrate attainment by December 31, 1982, i.e.,
Tier II areas. Will vehicle inspection and maintenance be
required prior to adopting policy for State Implementation
Plans required for non-attainment areas after December 31,
1982? These questions need to be resolved very quickly.
(3) Automatic Delegations And Adoption Of State
Operating Permits
An emerging need in the area of delegations is the
streamlining of delegations of New Source Performance Stan-
dards and National Emission Standards for Hazardous Air
Pollutants by allowing for automatic delegations.
Several states are interested in establishing a procedure
whereby when EPA adopts a new category for New Source Per-
formance Standards or National Emission Standards for
Hazardous Air Pollutants, they automatically assume delega-
tions. Present agency regulation/policy does not provide
this mechanism.
Approximately one-third of the State Implementation
Plan revisions could be eliminated by establishing policy/
regulations providing for state operating permits to be
federally enforceable without a State Implementation Plan
submittal.
9. Emerging Air Quality Trends and Issues
a. Air Toxics
Based on proposed revisions to the Clean Air Act, it
appears likely that the number of pollutants regulated under
Section 112 will increase significantly from 4 to about 40.
Requests from state/local agencies for technical
information, EPA policies, and program implementation guid-
ance regarding air toxics issues have steadily increased in
number. In response to state/local needs, Region IV has
initiated an Air Toxics effort.
This newly initiated effort calls for improved communi-
cation and coordination so that Region IV staff:
o Has a clear understanding of the needs and problems
faced by state/local programs.
o Has full knowledge of the state-of-the-art in all
aspects of Air Toxics (e.g., sampling, analysis, regulation
development, program implementation, EPA policies, etc.)
17
-------
o Can establish the appropriate contacts at state/
local programs, EPA at Research Triangle Park, and EPA Head-
quarters.
o Can become familiar with other EPA Regions' efforts
and success in the air toxics areas.
In addition, Region IV is undertaking the development
of an Air Toxics Resource Center to provide answers to the
many air toxics questions asked by Region IV states/locals.
In order to ensure a thorough review of energy pro-
jects' applications and help evaluate the emission of air
toxics, EPA will continue to jointly review these applica-
tions along with the appropriate state agencies. Region IV
will look to Headquarters and Research Triangle Park (Office
of Research and Development) for emerging national policy,
advanced control technologies, updating of the Best Avail-
able Control Technology/Lowest Achievable Emission Rate
Clearinghouse, and health risk assessments of these pollu-
tants.
Each state program in Region IV has requested guidance
and technical assistance concerning:
o „Appropriate stack emission and ambient pollutant
limits or the methodology for deriving appropriate limits.
o Stack emission sampling methods with the correspond-
ing analytical procedures.
o Ambient air sampling methods with the corresponding
analytical procedures.
o Technical information regarding the synergistic
effects of air toxics pollutants.
Provisions are not made in the annual work plan for air
guidance or resources for monitoring for air toxics. EPA
does, through ORD and other Headquarters Office? spend large
sums of monies on developing contractor capability to moni-
tor for air toxics. Some air toxic monitoring is done by
the Region if the suspected source is a hazardous waste
disposal site under Superfund, but if the suspected source
does not fall under Superfund little or nothing can be done.
Citizens' requests for air toxics monitoring are answered by
a referral to their state agency. If a state decides to do
air toxics monitoring at any place other than a hazardous
waste site, the Region cannot support them in any meaningful
way for lack of funds, equipment and personnel. Guidance
and resources are needed.
-------
b. Acid Rain
Region IV has established a Federally funded, state
operated monitoring network to determine the extent of the
acid rain problem in the Southeast. The network will
ultimately consist of ten sites, eight of which are present-
ly on line. The monitoring data collected to date indicate
that large portions of Region IV are experiencing acid rain.
This is consistent with data reported by other industrial
and private groups which operate networks within the Region.
During FY 1984, the compiled data will be analyzed and
utilized in various models to characterize the sources and
causes of acid rain. To accomplish this level of activity,
additional resources will be needed.
Region IV1s participation with TVA in the Southern Blue
Ridge Province Study will provide the Southeast with an
ecosytem evaluation of the effects of acid rain, and elimin-
ate total dependence on effects research from much colder
climates.
-------
TRENDS IN VIOLATIONS OF NAAQS FOR
CRITERIA POLLUTANTS IN REGION IV
CO (SECOND 8 HR. MAX.)
OZONE (SECOND I HR. MAX.)
TSP (ANNUAL GEOMETRIC MEAN)
S02 (SECOND 24HR.MAX.)
LEAD (QUARTERLY ARITHMETIC MEAN)
— — TREND LINES
300 r-
250 -
1977
*ALL SITES
1981
Figure AQ - 1
20
-------
YEARLY PRODUCTION OR SHIPMENT
FOR CERTAIN INDUSTRIES
AS A PERCENTAGE OF 1979.DATA
I 10
100
90
f- 80
Z
UJ
O 70
UJ
°- 60
50
a PAPER S BOARD MILLS
b PETROLEUM REFINING
c CHEMICAL ALLIED PRODUCTS
d MOTOR VEHICLES
e STEEL MILL PRODUCTS
f PHOSPHATE FERTILIZERS
77 79 80 81
YEARS
82 83
Figure AQ - 2
-------
NUMBER OF REGION IV COUNTIES
NOT MEETING NAAQS FOR CO
6-
4-
2-
0 ~~
I
I
I
. , n rv
-B- i r
^-o
I
—
AL FL GA KY MS NC SC TN
78 82 84 78 32 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84
PRIMARY STANDARDS NOT MET
^PORTIONS OF COUNTIES
Figure Aq - 3
16-j
14-
NUMBER OF REGION IV COUNTIES
NOT MEETING NAAQS FOR OZONE
1 C
10-
8-
6-
4-
2-
n
AL
78 82
—
84
FL
78 82 84
—
••••••
1 o
GA KY MS
78 82 84 78 82 84 78 82 84
78
n-
0
0
NC SC TN
82 84 78 82 84 78 82 84
Figure AQ - 4
-------
N JMBER OF REGION IV COUNTIES
NOT MEETING NAAQS FOR SO,
10-
8-
6-
4-
2-
^X
^
78
^
1
AL
82
- n^o -o-
—
I
—
1
00 0 0 //,
FL GA KY MS NC SC
84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78
m
^ 0
TN
82 84
[""I PRIMARY STANDARDS NOT MET
E3 SECONDARY STANDARDS NOT MET
£2 PORTIONS OF COUNTIES
Figure AQ - 5
NUMBER OF REGION IV COUNTIES
NOT MEETING NAAQS FOR TSP
I 6-i
14-
12-
10-
8-
6
4-
2-
ii
%M
1
AL FL GA KY MS NC SC TN
78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84 78 82 84
[| PRIMARY STANDARDS NOT MET
\\ SECONDARY STANDARDS NOT MET
E3 PORTION OF COUNTIES
Figure AQ - 6
23
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RENDS IN R^BIENT HIR G
FOR CO IN REGION IV
r
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Figure AQ - 7
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Figure AQ - 10
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Figure AQ - 11
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-Ik
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Figure AQ - 12
-------
AMBIENT AIR QUALITY STATUS
REGION IV CO 1981
\ :»'*-~ -r
fny^^gp^^f^^Cp^
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
VIOLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 13
-------
AMBIENT AIR QUALITY STATUS
REGION IV OZONE 1981
•lc, ? ^ i Ji=W" JT'X r. ' i?
X -—•o ' ' i ^
/-"^ZZ r^r^J^Si. i ^""[-"jwii
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
VIOLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 14 ? •' '"
-------
AMBIENT AIR QUALITY STATUS
REGION IV SO, 1981
'"" '""'! ^"" ^~"''' {'••Vx;-> '^
-'&/
' "T'
I
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
V'OLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 15
32
-------
AMBIENT AIR QUALITY STATUS
REGIONAL IV TSP 1981
' " '
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
VIOLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 16 ^
-------
AMBIENT AIR QUALITY STATUS
REGION IV LEAD 1981
i i i A-vM^-r?-•>/i-^/
A—^ r^i~-V^ I ' 'Si» •••/""' X ' * . - v r ^^* ^^ ^ -rr^-^rf * >•• • —— " ™
^>v-T c-^^-vP^ I
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/— •, i 1 X.
t'"nffiV .X ' '--—»(«« [«"< 1 - i
•—^^""-1 ' —'
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
VIOLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 17
-------
AMBIENT AIR QUALITY STATUS
REGION IV NO2 1981
V.'— •—-\ ;••*>••• v''" x
CONTAINS NON-ATTAINMENT AREA
NO VIOLATION OF NAAQS
VIOLATION OF NAAQS
NO DATA AVAILABLE
Figure AQ - 18
-------
PERCENTAGE OF SQUARE MILES IN
NON-ATTAINMENT COUNTIES IN REGION IV
10 -
8 -
6 -
PERCENT
4 -
2 -
0
—
1 —
n h
78 82 78 82 78 82 78 82
TSP OZONE S02 CO
Figure AQ - 19 —
PERCENTAGE OF POPULATION IN
NON-ATTAINMENT COUNTIES IN REGION IV
50
PERCENT
30 •
20 •
10 •
0 -
—
—
—
78 82 78 82 78 82 78 82
TSP OZONE S02 CO
n'gure nQ - 20
-------
\ \ \
a
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o
m
o
o
o
o"
o
-------
POPULATION IN PROJECTED NONATTAINMENT OZONE AREAS
BIRMINGHAM
JEFFERSON CO., AL.
RUSSELL CO., AL.
COLUMBUS GA. AREA
ETOWAH CO., AL.
FT. LAUDERDALE
BROWARD CO., FL.
MIAMI
DADE CO., FL.
PALM BEACH
PALM BEACH CO., FL.
ATLANTA
FULTON CO., GA.
COLUMBUS
MUSCOGEE CO., GA.
ASHLAND, BOYD CO.,
KY.
DE SOTO CO.. MS
MEMPHIS, TN. AREA.
CHARLOTTE,
MECLEN8URG CO.. N.C.
CLEVELAND, BRADLEY
CO., TN.
CHATTANOOGA
HAMILTON CO., TN.
NASHVILLE
DAVIDSON CO., TN.
MEMPHIS
SHELBY CO., TN.
8
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b
o
o
-------
POPULATION IN PROJECTED NONATAINMENT TSP AREAS
GADSDEN, Al_.
BIRMINGHAM, A|_.
TAMPA, Fl_.
JACKSONVILLE, FL.
MIAMI, FL.
CHATHAM CO., GA.
BELL CO., KY.
BOYO CO., KY.
BALLITT CO.. KY.
CAMPBELL CO., KY.
OWENSBORO, KY.
HENDERSON CO,, KY.
JEFFERSON CO., KY.
LAWRENCE CO., KY.
McCRACKEN CO., KY.
MADISON CO., KY.
MARSHALL CO., KY.
MUHLENBERG CO, KY.
PERRY CO., KY.
PIKE CO., KY.
WHITLEY CO., KY.
CARTER CO.. KY.
GREENUP CO., KY.
LAUREL, MS.
CHARLESTON, S.C.
NASHVILLE. TN.
KNOXVILLE. TN.
COLUMBIA, TN
MEMPHIS. TN.
KINGSPORT, TN.
ui
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Figure AQ - 23
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WATER QUALITY
1 . Overview
Southeastern U.S. is blessed with a plentiful surface
water supply. The Region has over 90 rivers greater than 50
miles in length, and over 1000 lakes and impoundments 5
acres or larger. Yet, according to a 1978 EPA report, the
water quality of at least 74 percent of the river basins in
the South is adversely affected by industrial discharges and
91 percent by municipal discharges. The most widespread
problems continue to be bacteria, oxygen depletion and
nutrients, but the problems are not as severe as they were
10 years ago. Rapid population and industrial growth,
especially in coastal areas, have often outstripped the
abilities of local governments to provide adequate sewage
collection and treatment facilities. As a result, high
fecal coliform counts have been found in a number of swim-
ming and shellfishing areas, particularly along the Gulf
Coast and Carolina coastal waters.
Through the NPDES program, pollution control efforts
have generally been more successful with industrial than
with municipal dischargers. The major municipal dischargers
are largely meeting permit limits, but needed improvements
include pretreatment of industrial wastewaters to remove
toxic chemicals. Recent attention to minor municipal
dischargers (under 1 mgd) has exposed serious violations
attributed to a variety of reasons including substandard
outdated construction and poor operation and maintenance.
Since the early 1970"s, large sums of money have been
spent for pollution control within the Region. Since 1973,
over $4.36 billion have been spent under Section 201 of the
Clean Water Act on construction of municipal wastewater
treatment plants in the Region. When PL92-500 was enacted,
there were approximately 100 primary wastewater treatment
plants in Region IV. Sixty-nine of those are still in
operation, but 35 have Step 3 grants and 21 have Step 1 or 2
grants. Only 13 plants have no grants. An inventory of
grant funds spent is shown in Figure WQ-1. Even greater
amounts have been spent by industry. Other monies include
Federal and state funds for the state pollution control
programs, Section 208 grants (largely for nonpoint source
controls), and other supplementary EPA funds such as those
under Section 205(g) and 205(j).
Implementation of Section 201 of the Clean Water Act
(PL 92-500) has resulted in the planning, design and con-
struction of sophisticated sewage treatment plants. These
complex systems require highly trained and motivated oper-
ators, and, because of salary, chemical cost, and energy
costs, they are expensive to operate and maintain. The
Federal, state and local governments have an enormous
-------
investment to protect; yet, the trend is to minimize opera-
tion and maintenance expenditures. If this trend is permit-
ted to continue, billions of dollars already spent toward
the clean-up of municipal sewage could be wasted.
Manufacturing establishments in Region IV spent an
estimated $4.2 billion on water pollution abatement between
1973 and 1980. Of this amount, $1.6 billion was for capital
expenditures and $2.6 billion was for operation and main-
tenance expenses. The leading manufacturing industries in
both capital and operational expenditures were chemical and
allied products, paper and allied products, and the primary
metal industry. Annual expenditures for the Region are
shown in the following table.
Annual Manufacturing Pollution Abatement
Expenditures, 1973-1980 ( $ million)
1973 1974 1975 1976 1977 1978 1979 1980
Capital 147.3 181.0 276.6 255.7 205.8 196.8 116.6 171.1
O&M 144.5 187.3 230.5 283.0 379.9 412.4 478.6 485.2
Total 291.8 368.3 507.1 538.7 585.7 609.2 595.2 656.3
-------
Besides these municipal and industrial point sources,
southern streams are also subject to nonpoint source pollu-
tion from urban runoff, mining (including oil and gas
production), agriculture and a variety of other land use
operations. No broad base regulatory program currently
exists that addresses nonpoint sources. Since the Clean
Water Act does not give EPA specific authority to regulate
these sources, compliance criteria have not been established
except for recommended "best management practices" for
various land uses. Control of nonpoint sources is largely
accomplished through voluntary programs and programs admin-
istered by other agencies.
2. Water Quality Standards
Almost all streams and rivers in the Region are classi-
fied "fishable" or "swimmable" (which includes all designat-
ed uses for fisheries, shellfishing, recreation, and drink-.
ing water) in accordance with the goals of the Clean Water
Act. Only three states have waters classified otherwise.
Alabama has two small streams in the Mobile area classified
"navigation," 59 small streams throughout the state classi-
fied "agricultural/industrial" and four small streams in the
Birmingham area classified "industrial operations." Florida
classified 5.7 miles of the Miami River near Miami and all
secondary tertiary canals wholly within aqricultural areas
for "agricultural supply." In Georgia, river miles 5-22
of the Savannah River is classified "navigation/ indus-
trial," the North River is "industrial" and, although
streams in urban areas are classified "fishing," intermit-
tent violations are expected from runoff and combined sewer
overflows. Kentucky is currently evaluating streams for
appropriate classification of state water bodies. The other
states in the Region have all streams classified as "fish-
able" or "swimmable." Exceptions to the "fishable/swim-
mable" criteria constitute only a negligable percentage of
the 17,000 miles of 135 major streams in the Region.
Unfortunately, it is not yet possible with currently avail-
able monitoring data to establish precisely what percentage
of these waters violate their classification standards. As
a rough estimate, water quality data for 1980-81 for 189
Basic Water Monitoring (BWMP) Stations in Region IV classi-
fied for "fishable/swimmable" uses show at least one viola-
tion of a measured parameter at 166 stations (88%), and
severe violations at 68 stations (36%). Severe violations
were defined at a station where at least one measured
parameter value exceeded its applicable criterion by 85% or
more. These percentages, however, present a somewhat nega-
tive bias because many of the stations are located in prob-
lem areas. "Average water quality", however defined, would
be better than this rough estimate.
-------
The "Use Impairment Maps" (Figures WQ-2 to WQ-8) show
degree of impairment of established State/Federal Water
Quality Standards at the state operated BWMP stations in
Region IV. For each station, STORET water quality monito-
ring data for 1980 and 1981 were compared to state criteria
for the station's estabished water use and a "use impairment
value" was calculated as follows:
For each criterion applicable to the use designation
for a given station, a comparison was made with the
STORET values for the appropriate parameter (e.g.,for
dissolved oxygen, both parameter codes 299 - probe
method, and 300 - Winkler method were used). A ratio
of parameter value to the criterion was calculated for
each value that exceeded the criterion; otherwise, the
ratio was set to zero. (An inverse ratio was used for
minimum criteria; and, because of the extremely high ,
values encountered in fecal coliform counts, the ratio
of the logs of the data and the criteria was used.)
The "severity values" for all parameters at a station
were then summed to obtain the total "use impairment
value" for the station.
The "fishable/swimmable" map (Figure WQ-2) includes all
stations with drinking, fishing, or recreational standards.
Each "parameter" map (Figures WQ-3 to WQ-8) shows the
calculated "severity values" for the individual parameters.
(Where the parameters are grouped, or if multiple standards
apply to a given station, only the highest "severity value"
was plotted on the "parameter" maps.) The relative impair-
ments were designated as follows.
USE IMPAIRMENT VALUES SEVERITY VALUES
Legend Fishable/Swimmable Parameter
Designation Map Maps
Negligible 0-.99 0
Moderate 1-9.9 0.01-0.99
Severe 10 & UP 1.0 & UP
The advantage of these "use impairment" maps is that
they show a measure of water quality as it is uniquely
related to the established numerical standards in that
location, as opposed to a more uniform analysis with a water
quality index (WQI). The main disadvantage is that applic-
able criteria may be entirely different from one site to
another. Moreover, because the "use impairment value" for a
station is the sum of the individual parameter "severity
values," larger "use impairment values" are more likely to
result at a station with many applicable criteria than at a
station with very few criteria. On the other hand, if
-------
parameters for which criteria have been adopted at a
station are not measured, smaller impairment values will be
calculated. Florida, Kentucky and North Carolina, for
example, all have a long list of criteria for the toxic
metals; and, as a result, the "fishable/swimmable" map shows
numerous violations in those states. In Alabama, on the
other hand, the Alabama Water Improvement Commission (now
part of the Department of Envirommental Management) did not
analyze for fecal coliform and numerical criteria are
relatively few. Consequently, relatively few violations are
shown in Alabama.
3. Trends
Based on "use impairment values" for the BWMP stations
having data for the indicated years, the following trends
were determined. (Water quality was considered to improve
if "use impairment values" decreased by more than one unit
over the indicated time span, to be the same if the change
was less than one and to be worse if the value increased by
more than one unit.)
-------
WATER QUALITY TRENDS
Based on "Use Impairment Values" expressed as percentage of
stations for which data were available in both time periods.
70/71 to 75/76 75/76 to 80/81 70/71 to 80/81
Improving
Same
Worse
61%
20%
19%
27%
52%
21%
54%
33%
13%
For comparison, based on a WQI analysis, using over
1000 stations on streams for the period 1972 to 1978, Region
IV showed improvement in 62 percent of the streams, no
trends in 19 percent, and downward trends in 19 percent.
These trend calculations are only as accurate as the
data base and the methodology. Fortunately, the EPA Office
of Water has committed to publishing a standard methodology
for trend determination, which should greatly improve the
uniformity of analysis across the country.
•*
4. Water Quality Problem Areas
Specific areas considered to have significant water
quality problems are indicated in Figures WQ-9 to WQ-14.
These maps should be used cautiously since the assessments
from state to state may be affected by variations in the
types of data collected and the criteria used to report
significant problems; e.g., some states use different
criteria to designate "severe," "moderate," or "slight"
problems. For example, the cluster of problem areas in
eastern Tennessee results largely from the diligence of
Tennessee and TVA in reporting problems. Moreover, some
states may not even officially recognize a problem that
another state considers a severe problem.
Two interstate rivers, the Ochlockonee between Georgia
and Florida and the Pigeon between North Carolina and
Tennessee, illustrate this latter problem. According to
Georgia's standards, the Ochlockonee has only "slight"
problems; but downstream, even though the quality has
improved, the problem becomes "moderate" when the river
crosses into Florida. The Pigeon likewise leaves North
Carolina meeting state standards, but crosses the state line
in violation of Tennessee's standards. A major problem thus
exists when water quality problems are quantified based on
state assessments which use different critieria.
-------
From the maps of water quality problem areas (Figures
WQ-9 to WQ-14) and those of calculated "use impairments,"
east Tennessee is one area that stands out as having multi-
ple problems. This is an area where concentrated industrial
and municipal discharges impact relatively small headwaters.
Coal mining and oil and gas drilling operations contribute
significantly to the problems of eastern Tennessee and
Kentucky. Excess nutrients are a major problem in the
warmer, flatter parts of the Region such as Florida, coastal
North Carolina and the Mississippi Delta. The severity of
problems in the Mississippi Delta is caused by extensive,
long-term use of pesticides, herbicides, and fertilizers.
Concentrations of these chemicals in the Mississippi Delta
surface water and sediment are among the highest in the
country.
Color is a common problem in areas affected by textile/
carpet mills and pulp/paper industries. Yet some states,
such as North Carolina, can do nothing since state law
prohibits state agencies from writing effluent limitations
more strict than those of the federal government. Since EPA
has not established a color standard, North Carolina can
have only a narrative standard (i.e., "will not impair the
waters for the best usage"), which is a source of contention
with the state of Tennessee concerning the Pigeon River.
The Water Quality Problem Area maps (Figures WQ-9 to
WQ-14) are based on the state 305(b) reports for 1980-81 and
a review by regional staff and all eight Region IV states
plus ORSANCO.
5. Toxics
a. State by State Review
A review of toxics monitoring data reveals scattered
problems throughout Region IV. Major extant problems are
from contamination by heavy metals (Hg, Cr, Pb, etc.), PCB's
and persistent pesticides such as DDT, endrin, chlordane and
toxaphene. A state by state review of very sparse and
incomplete data follows:
- ALABAMA
o Mercury
The lower Mobile River has had a mercury
problem for many years that is now nearly dissi-
pated. Sampling of fish tissues begun in 1970 was
terminated this year. Mercury is still leaching
in small quantities into the river from existing
landfills.
-------
PCB
A PCB problem exists in Weiss Reservoir
(Georgia-Alabama) resulting from input from .
industry in Georgia. The input has been elimin-
ated, but residual PCB's are still present in
Weiss Reservoir, and sampling of fish tissues
continues.
Choccolocco Creek near Anniston has an on-
going PCB problem. Fish tissues have been col-
lected and sent to Auburn University for analyses.
The state is still waiting for results of the
analyses.
There is a small operation in Greenville
County that is still a problem. Anticipated
monitoring of fish tissues will probably begin
this year.
Pesticides
DDT production on Redstone Arsenal in
Huntsville, Alabama, during World War II caused
widespread dispersal of DDT and its derivatives
into the Tennessee River. The plant has been
closed, but residual DDT is present in large
amounts in Spring Branch and Indian Creek. After
being sued, the Company responsible for the
contamination agreed January 10, 1983, to provide
clean up and citizen compensation. They have
presented a 10-year study and monitoring program.
National Pesticide Monitoring Program
The USFWS has had a national fish tissue
pesticide monitoring program in operation since
1969. Fish tissues are analyzed for numerous
pesticides, but data for most of them are very
sparse. The overall data were reviewed, but
because of the paucity of data for most para-
meters, only four pesticides were selected for
representation. They are endrin, dieldren,
toxaphene and total DDT. The data were analyzed
for levels of concentration and trends over time.
Whole fish samples are utilized in this program as
opposed to fillets used by FDA to determine action
levels. At present, there is no calculated
correlation between whole fish values and fillets,
but the following comments utilize the FDA action
level as an indicator of possible concern. The
analyses were performed on all species collected
during a sampling period.
-------
Alabama has two stations represented in the
national network: Tombigbee River near Mclntosh
and Alabama River near Chrysler.
Concentration
No concentrations reached FDA action
levels.
Trends
Significant denotes a trend at the 95%
confidence limit. Nonsignificant denotes a
visual trend that is not statistically
significant at the 95% level.
Total DDT: Alabama River — significant (95%)
decrease
Tombigbee River — no trend
Endrin: Alabama River — significant
increase
Tombigbee River — significant
increase
Dieldrin: Alabama River — nonsignificant
decrease
Tombigbee River — significant
decrease
Toxaphene: Alabama River — significant
increase
Tombigbee River — nonsignificant
increase
- FLORIDA
Mercury
Mercury has been detected in shellfish tissue
in the southwest portion of the state. This
discovery is being followed up with sediment
sampling and analysis.
PCB
Sediment samples from the St. John's River
suggested a possible problem in the Jacksonville
area. Concentrations of PCBs in fish tissues were
very low. There is no follow-up study anticipated
at this time.
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o National Pesticides Monitoring Program
Florida has one station represented in the
network. It is located on the St. Lucie canal
near Indiantown.
Concentration
None above FDA action limits.
Trends
Total DDT: Nonsignificant decrease
Endrin: All levels below detection
Dieldrin: Nonsignificant decrease
Toxaphene: Significant increase
- GEORGIA
o Mercury
A mercury problem was detected in the
. Savannah River in 1972, but the source was cleaned
up and the problem eliminated.
o PCB
A major problem developed in the Coosa River
where very high concentrations of PCB's were found
in various species of fish. The source has since
been eliminated, but high residual levels of PCB
still remain in the fish tissues. As a result of
the contamination, commercial fishing was banned
from the confluence of the Etowah and the Coosa to
the state line. That ban is still in effect.
Lake Hartwell was contaminated with PCB's
from a source in South Carolina. A warning
against the eating of fish from the lake was
released but soon rescinded for the portion of the
lake located in Georgia.
o National Pesticide Monitoring Program
Georgia has two stations in the pesticide
network: Savannah River at Savannah and the
Altamaha River near Doctortown.
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Concentration
None above FDA action level.
Trends
Total DDT:
Endrin:
Altamaha River — Nonsig-
nificant decrease
Savannah River — Signifi-
cant decrease
Altamaha River — Nonsig-
nificant decrease
Savannah River — Nonsig-
nificant decrease
Dieldrin:
Toxaphene:
Altamaha River
cant decrease
Savannah River
cant decrease
Altamaha River
Savannah River
samples zero
Signifi-
Signifi-
No trend
All
- KENTUCKY
Mercury and Other Heavy Metals
The state is involved in sediment sampling
associated with the Basic Water Monitoring Program
and the Stream Use Designation programs. The data
from these programs are evaluated by a scheme
developed by EPA, Region V. The scheme has three
categories ranging from nonpolluted, moderately
polluted, and heavily polluted. Each category has
a range of values for 19 parameters. This proce-
dure, along with a biological and physiochemical
sampling program, have identified problem areas in
several regions of the state.
PCB
No known problems in the state.
Pesticides
There are several areas in the state where
lindane and pentachlorophenol (PCP) have been
detected. The PCP has usually been associated
with the wood preservation industry.
-------
There are some elevated levels of chlordane
in fish tissues at several locations. These are
generally localized problems in urbanized areas
which could be attributed to pest control chemi-
cals.
o National Pesticide Monitoring Program
The only stations associated with the pesti-
cide network located in Kentucky are on the Ohio
River. There are nine such stations located along
the state's boundary. These are generally located
in highly populated areas on both sides of the
river making it difficult to isolate particular
problems; therefore, no statistical analyses were
performed on the data from these stations. While
there are areas of elevated concentrations of
contaminants in the river, there has been a
general improvement in the water quality and
community structure of the Ohio over the past few
years.
- MISSISSIPPI
o Mercury
No known problems.
o PCB
No known problems.
o Pesticides
Pesticides appear to be a major problem in
Mississippi. Areas known to have problems are:
Pearl River downstream from Jackson, Okatibbee
Creek downstream from Meridian, Town Creek down-
stream from Tupelo and the Delta lakes in general.
Areas under suspicion are the following river
basins: Yazoo, Tallahatchee and Sunflower. Data
developed from a fish tissue analysis program from
these river basins will be available soon.
o National Pesticide Monitoring Program
Mississippi has one station in the pesticide
network: the Yazoo River near Redwood.
Concentration
DDT and toxaphene are present in total
fish residue above the FDA action level for
fish fillets.
51
-------
Trends
Total DDT: Nonsignificant decrease
Endrin: Significant decrease
Dieldrin: Nonsignificant decrease
Toxaphene: No trend
NORTH CAROLINA
o Mercury
Abbot's and Leonard's Creeks are contaminated
with mercury. Commercial fishing in the creeks is
banned and' there is a warning on sports fisheries.
The ban and warning do not extend into High Rock
Lake.
There is concern about high levels of mercury
in the Pamlico-Albermarle peninsula, and the
state will initiate a study of that area next
year.
o , PCB
The only PCB problem recently was the road-
side spill, which has been cleaned up.
o Pesticides
No known problems.
o National Pesticide Monitoring Program
North Carolina has two stations in the
pesticide network: Cape Fear River near
Elizabethtown and Roanoke River near Roanoke
Rapids.
Concentration
There were no average concentrations of
pesticide above the FDA action level.
Trends
Total DDT: Roanoke River — Significant
decrease
Cape Fear River — Significant
decrease
52-
-------
Endrin: Roanoke River — Nonsigni-
ficant decrease
Cape Fear River — Nonsigni-
ficant decrease
Dieldrin: Roanoke River — Significant
decrease
Cape Fear River — Nonsigni-
ficant decrease
Toxaphene: Roanoke River — Significant
increase
Cape Fear River — Nonsigni-
ficant increase
The pesticide monitoring program also moni-
tors for PCBs, but except for the Roanoke River
station, concentrations were very low and declin-
ing. Concentrations of PCBs in the Roanoke River,
however, increased at a significant upward trend.
The uppermost levels were still below FDA action
levels for fillets.
- SOUTH CAROLINA
o „ Mercury
Elevated levels of mercury were found in fish
tissues in the Savannah River in the early 1970"s,
but subsequent sampling revealed a decline in
concentration, and at this time no problem exists.
There were elevated levels of mercury in the
water and sediment in Lake Jocassee soon after
filling, but it was determined to be natural, and
the fishing advisory was lifted in 1979.
High mercury levels are appearing in samples
taken along the coast, and the state is investi-
gating to determine whether they are valid.
There are elevated levels of mercury in fish
from Edisto River, but these are thought to be
natural in origin.
PCB
Lake Harwell is contaminated with PCBs from
Town Creek. The pollution source was eliminated,
but residual PCBs are still present in Lake
Hartwell. A sports fish warning is in effect in a
portion of the lake. A monitoring program still
in effect shows that the concentration of PCBs in
fish tissue is diminishing.
5*3
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Pesticides
There have been some fish kills connected
with the use of toxaphene and endosulfan by tomato
farmers. The problem began in late 1970 and is
still continuing. Citizen groups are trying to
get a ban on the use of endosulfan, which is
relatively toxic to warmblooded animals.
National Pesticides Monitoring Program
South Carolina has two stations in the
pesticide network: Pee Dee River near Johnson-
ville and Cooper River at Lake Moultrie.
Concentration
No concentrations above FDA action
level.
Trends
Total DDT:
Endrin:
Dieldrin:
Toxaphene:
Cooper River — Signifi-
cant decrease
Pee Dee River — Nonsigni-
ficant increase
Cooper River — Nonsigni-
ficant decrease
Pee Dee River — Nonsigni-
ficant decrease
Cooper River — Nonsigni-
ficant increase
Pee Dee River — Signifi-
cant decrease
Cooper River — Nonsigni-
ficant increase
Pee Dee River — very low
but too sparse to evaluate
- TENNESSEE
Mercury
North Fork of Holston River is still under a
ban for taking fish. The pollution source has
been closed, but leakage from holding ponds
remains a problem. Clean-up began last year.
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PCB
Several areas of concern are: Fort London
Reservoir near Knoxville, Marine Corps Base at
Knoxville, and Beach Creek near Waynesboro.
Organic Chemicals
Memphis area — industrial
Chattanooga Creek in Chattanooga —
industrial
Pesticides
Reelfpot Lake — last few years of sampling
indicate developing problem.
Mississippi River at Memphis — Chlordane and
other chlorinated hydrocarbons in fish
tissue.
National Pesticide Monitoring Program
Tennessee has two stations in the pesticide
network: Tennessee River near Savannah and
Mississippi River near Memphis.
Concentrations
DDT concentrations in fish tissue in the
Mississippi exceeded FDA limits in the early
sampling but had dropped below 5.0 ppm by
1978.
Trends
Total DDT: Mississippi River — Significant
decrease
Tennessee River — Nonsignificant
decrease
Endrin: Mississippi River — Nonsigni-
ficant decrease
Tennessee River — Nonsignificant
increase
Dieldrin: Mississippi River — Nonsigni-
ficant increase
Tennessee River — Nonsignificant
increase
Toxaphene: Mississippi River — No trends
established. Most values were
5*5
-------
zero.
Tennessee River — Significant
increase
b. Point Source Toxicity Testing
Since 1975, toxicity studies have been conducted on
effluents from 598 industrial facilities in EPA Region IV.
Although all facilities studied had installed BPT facili-
ties, approximately 65 percent (388 sites) were discharging
wastes containing substances lethal to aquatic life (Table
WQ-1). These data indicate widespread potential for
instream damage, and thus additional study is needed at many
of these sites.
The Tennessee Department of Public Health reported, as
a result of further bioassay testing, the following results
as of May 1983. Other states would be expected to confirm
similar high percentages of toxic wastes.
Bioassays Performed on Tennessee Dischargers (1978-present)
Static Bioassays
142 Non-toxic.(55%) 26 Municipal (10%)
117 Toxic (45%) 233 Industrial (90%)
259 259
Flow-thru
18 Non-toxic (36%) 12 Municipal (24%)
22, Toxic (64%) 38 Industrial (76%)
50 50
6. Dissolved Oxygen
Dissolved oxygen depletion is perceived by state
officials as a common and persistent problem. The most
widespread or serious violations in the Region are along the
Atlantic and Gulf Coasts, the lower Mississippi, the
Tennessee River basin, and the Ohio River basin. Since
municipal sewage and industrial waste are the almost exclu-
sive sources of degradable organic pollutants, low D.O.
problems are frequently found downstream from cities and
industrial complexes. Improvement programs in wastewater
treatment plants and operator training are the main methods
of improving D.O.
Nonpoint sources can also contribute significantly to
D.O. depletion — for example, stratified reservoirs and
areas where animals are concentrated. The Reservoir
Releases Program is a significant method of improving D.O.
-------
7. Nutrients
Excessive nutrients such as phosphorous and nitrogen
combined with the south's warm temperatures stimulate the
growth of algae and rooted aquatic plants and accelerate
eutrophication and oxygen depletion. These effects can
result in fish kills, reduced recreational opportunities,
and taste and odor problems in water supplies. Nutrient
problems are evident in every state in the Region. For
example, the Chowan River in North Carolina had experienced
severe surface algal blooms, Lake Marion in South Carolina
has recently had problems with Elodea and Florida has
extensive aquatic weed infestation. The severe nutrient
problems in the Region are caused by a combination of
factors including industrial and municipal discharges
combined with urban and agricultural runoff.
8. Bacterial (Fecal Coliform) Pollution
Bacterial pollution, as indicated by high fecal coli-
form levels, is widespread through the Region, as indicated
on Figure WQ-12. Most bacterial problems are related to
inadequate treatment in municipal treatment facilities, and
many of the problems indicated will be reduced or eliminated
once treatment works now in the planning or construction
phases are completed. Poor operation and maintenance of
existing facilities and urban runoff, especially from
combined sewers, are also common causes of bacterial prob-
lems. Many of the indicated problems are on small streams
(especially in eastern Tennessee) where the resulting
bacterial counts are much more severe than in large streams
where ample dilution is available.
Pulp and paper mills also generate high levels of
coliforms indistinguishable from those of fecal origin.
Chicken processing plants and tanneries, important indus-
tries in the Southeast, cause severe but dispersed problems
in surface waters. Beef and hog lots and pasturelands are
also major contributors to fecal coliform pollution.
Fecal coliforms always indicate a potential health
problem, but the most widespread effects of even low bacter-
ial counts are in shellfishing water where harvesting must
be greatly restricted. (See also the discussion of Shellfish
Waters).
9. pH
The pH problems in Region IV are associated primarily
with mining activities. Virtually all the significant pH
problems in Kentucky and Tennessee are caused by the expo-
sure of sulfur bearing strata or materials to the weathering
process, resulting in acid mine drainage. Some small creeks
in eastern Tennessee commonly have a pH as low as 2.
-------
In northern Florida, phosphate mining on Swift Creek
produces dissolved solids sufficient that the pH of the
Suwannee River increases by 2 pH units downstream from its
confluence with Swift Creek. This violates Florida criteria
for pH.
Other man-made pH problems in the Region are attributed
to agricultural and urban runoff, textile discharges, and
overloaded sewage treatment plants. Natural pH depressions
are common in blackwater swamp areas of the coastal plain
where pH values of 3 to 4 are not uncommon.
Although the Region has several acid-rain-susceptible-
lakes (alkalinity below 15 mg/L as CaCCOr there are no
widespread problem areas as in the Northeast. Preliminary
results show, however, that some lakes in Florida and in the
southern Appalachians may be experiencing the first effects
of acid rain.
10. Siltation/Turbidity
Siltation is a major economic problem in navigable
harbors where turbid fresh water encounters the salt water
wedge. The worst of these problems in Region IV is
Charleston Harbor, South Carolina, where 10 million cubic
yards must be dredged annually just to maintain the harbor.
Because 'of the enormous dredging costs of $14,000,000 per
year, the Corps of Engineers is planning to redivert 80
percent of the flow of the Cooper River back to the Santee
River, from which it was diverted originally in 1942. Other
major dredging problems because of siltation are shown in
Figure WQ-15. Many other areas not shown require annual
dredging of one-half million cubic yards per year or less.
On rivers such as the Mississippi, especially, and the Ohio,
Tennessee and Cumberland to a lesser extent, most of the
dredged material is simply dumped back into the river, and
data for comparisons are not available.
Mining and agriculture are the primary localized causes
of siltation in Region IV. Virtually every stream on the
Piedmont has persistent turbidity because of colloidal clay,
and the total suspended sediment load of these streams is
variable depending the amount of construction, agriculture,
clear-cutting or other activities carried out in the water-
sheds. Construction of highways, residential sub-divisions,
and industrial facilities also frequently contributes
harmful quantities of silt to surface waters during rainy
periods.
The siltation problem in the mining areas of Kentucky
and Tennessee also correspond to low pH problems and concen-
tration of lead, zinc, mercury, cadmium, iron and other
metals. For example, siltation in the Ocoee River in
eastern Tennessee is the result of a copper smelting opera-
-------
tion at Copper Hill. In years past, the entire valley was
denuded of vegetation by sulfuric fumes from the smelting.
The ensuing erosion was so severe that the area was aptly
described as a "moonscape". Recovery is slowly progressing
through extensive conservation measures, but siltation is
still a problem in the Ocoee River.
11. Shellfishing
Shellfishing is a profitable commercial activity in the
six coastal states of Region IV, which include 27.4 percent
of the nation's total estuarine waters. Since shellfish are
consumed by humans, the waters in which they live are
carefully monitored for pollutants. The national trend in
shellfish waters approved for commercial shellfish harvest-
ing has increased from 38.7 percent in 1966 to 52 percent in
1980 (a 13.3% increase) according to the 1980 National
Shellfish Register. If this trend is assumed to be a result
of increased water pollution abatement programs, then the
upward trend should continue unless these programs are
reduced. Region IV, however, is slightly behind the nation-
al average with 34.9 percent in 1966 increasing to 48.4
percent in 1980 (a 13.5% increase). The acreage and status
of shellfish harvesting waters for our six coastal states
and for the Region as a whole, according to the 1980
National, Shellfish Register of Classified Estuarine Waters,
are shown in Figures WQ-16 and WQ-17 and the table below.
The following definitions apply.
o Open - These areas are available for shellfish
harvesting at all times of the year without
restriction.
o Conditional - This category includes some slightly
polluted areas which may be used for shellfish
cultivation or harvesting if the shellfish are
then placed in clean water for a period of time
before marketing. This allows the shellfish to
cleanse themselves of bacteria, thus negating the
impact of moderate pollution levels. Note
however, that this procedure is not effective for
shellfish from heavily polluted areas. This
category also includes areas that are open for
shellfish harvesting on a seasonal basis. In
certain seasons, polluted conditions make them
unavailable for shellfish harvesting.
o Closed - Shellfish cultivation and harvesting is
forbidden in these areas at all times because of
polluted conditions.
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Classification of Waters in Acres
State Open Conditional Closed
North Carolina 1,769,049 0 356,565
South Carolina 205,401 908 73,154
Georgia 53,651 0 150,436
Florida 512,577 110,281 292,484
Alabama 73,919 193,468 103,736
Mississippi 120,201 171,213 98,840
TOTAL 2,734,798 475,870 1,075,215
North Carolina had a greater increase in approved
waters than any other state. North Carolina followed the
upward U.S. trend, but exceeded the average. South Carolina
continued the upward trend begun in 1971 and paralleled the
present U.S. pattern of increased approved area acreage and
decreased prohibited area acreage. Georgia followed the
U.S. trend, also, with an increase in approved waters and a
decrease^ in prohibited area waters. Shellfish waters in
Georgia "are only opened when an area is proposed for har-
vesting. Many areas are simply not monitored that probably
could be opened if there was sufficient demand. Florida has
shown great changes in the past five years. Approved area
waters decreased by nearly 150,000 acres, whereas about
730,000 acres of prohibited waters were declassifed and put
into the NS/NP category. Alabama did not follow the U.S.
trend; it lost approved area acreage. Most of the state
waters are classified as conditional. Mississipi has
recently classified large areas of the Mississippi Sound for
the purpose of relaying shellfish. As in Alabama, most of
the waters are classified as conditional. The state did not
follow the U.S. trend.
Within Region IV, large areas of shellfish waters are
often located adjacent to sewered population areas from
which treated wastewaters must be discharged. Examples are
Mobile, Alabama; the Mississippi Gulf coast; St. Augustine,
Florida; and Apalachicola, Florida. Because the Food and
Drug Administration (FDA) has overview jurisdiction of state
agencies charged with opening or closing the shellfish
harvesting beds, EPA must consult with the FDA when sewerage
facility plans are developed for these areas.
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12. Lakes & Reservoirs
Seven Region IV states (Alabama did not participate)
have taken advantage of Section 314 matching funds to
identify and classify the condition of publicly owned
freshwater lakes. A total of 1034 natural lakes and
impoundments encompassing 3,268,153 acres were studied
(Table WQ-2).
A variety of problems were identified at 376 (36%) of
the lakes and impoundments studied (Table WQ-3). The five
problems most frequently encountered were weed infestation,
hypolimnetic oxygen deficits, sedimentation, nuisance algal
blooms and fishkills. Nutrient loading, both point source
(41 lakes) and non-point (87 lakes), was identified as a
factor contributing to the problems identified. Sedimenta-
tion and turbidity were serious problems resulting from
improper land use at approximately 100 lakes studied. Most
of the exotic problems (19 lakes) were found in Tennessee
and Mississippi, and likely resulted from agricultural
pesticides in runoff from the intensively farmed Mississippi
Delta.
Recreational use was impaired on 424,860 acres (13% of
total acreage) of lakes and impoundments in the 7 southeast-
ern states studied.
A total of 238 urban lakes, encompassing 110,139 acres,
were studied. Sixty-seven (28%) of the urban lakes totaling
80,096 acres (73% of the total acreage) have problems that
need to be addressed. Weed infestations, sedimentation,
nuisance algal blooms, depleted oxygen, fishkill and turbid-
ity head the list of problems encountered at urban lakes.
(Table WQ-3)
The data reported in Table WQ-2 point out, not that the
problems are necessarily different from state to state, but
that each state perceives the problems differently. Inter-
preting the data requires a judgment call by each state.
Tennessee, for example, takes a much stricter position than
some other states; hence, the table makes Tennessee look
inordinately bad.
13. Oceans
a. Ocean Disposal of Dredged Material
The EPA shares responsibilities with the Corps of
Engineers to administer the program for ocean disposal of
dredged materials through the Marine Protection, Research,
and Sanctuaries Act of 1972. In Region IV, 43 dredged
material disposal sites have been given interim site
designations. A consent decree stipulated that 10 of these
sites would have EIS's prepared and Final Site Designations
-------
implemented. The remaining 33 sites must also receive Final
Site Designations in the future. All of these sites receive
material from navigation channels and harbors that must
remain operational for economic reasons. All regional ports
compete with each other to some extent and most wish to have
deeper channels for servicing larger and deeper draft
vessels.
b. Ocean Discharge
(1) EPA's authority under Section 403 of the Clean
Water Act provides guidelines for issuing NPDES permits to
dischargers to the territorial seas, the contiguous zone,
and the oceans. Section 301(h) authorizes EPA to grant
variances for federal minimum secondary treatment require-
ments for municipal discharges to marine waters.
(2) Number of Discharges
In Region IV, there are approximately twenty-five
permitted discharges to the Atlantic Ocean or the Gulf of
Mexico. Approximately fifteen of these are for minor,
near-shore discharges, seven are for major municipal dis-
charges, and three are for power plants. All but one are in
Florida. Offshore oil and gas related discharges are not
included in these figures.
(3) 301(h) Waivers
In Region IV, eight applications for Section 301(h)
variances were received prior to the 12/29/82 deadline,
including one estuarine discharge and one proposed new
discharge. Seven of the eight are large discharges, and all
will require additional field work to support the variance
requests. Based on EPA's experience with the first round
301 (h) applications, it is estimated that the time for field
work and EPA review will take two or more years prior to a
decision on approval or denial of the variance requests.
Impacts of ocean discharges are evaluated at the time
of a 403 or 301(h) determination, prior to NPDES permits
issuance. Data obtained from permittee monitoring are
reviewed periodically, as required by the permit, or at
permit renewal.
(4) Outer Continental Shelf (OCS) - Drilling
Impacts
The Alabama and Mississippi state staffs and the region-
al staff have expressed concern over possible environmental
impacts to state waters in the near shore coastal zone by
drilling fluids and other discharges from the rigs. These
wastes are known to be toxic to organisms. Efforts are
underway to develop a study plan that will determine the
-------
fate of these fluids in this system. When a plan is com-
pleted the industry will be asked to perform the studies.
The industry has adamantly stated that they want the regula-
tory agencies to participate in this study; therefore,
resources needed from EPA may include the CSV ANTELOPE and a
portion of a scientific crew.
Significant finds of hydrocarbons on the OCS will
require pipelines to transport the material ashore. These
structures would have varied impacts to the beaches, dunes,
wetlands and other coastal habitats. Mitigation measures to
reduce these impacts should be developed and monitoring
programs to evaluate long term impacts should be implement-
ed.
(5) Sewage Sludge
There is currently no municipal entity disposing of
sewage sludge via ocean dumping in Region IV. The states
bordering on the Atlantic Ocean could be considered possible
candidates for such a disposal technique. Two areas where
ocean dumping of sewage sludge has even been considered to
any extent are the Jacksonville and the Ft. Lauderdale areas
of Florida. In the case of Ft. Lauderdale, current plans
indicate that a joint compost disposal technique with the
City of^Hollywood is the most feasible alternative. In
Jacksonville, the development of sludge disposal alterna-
tives is being conducted now. Various disposal techniques
are under review. Preliminary discussions have recently
been held regarding the possible ocean disposal of municipal
sludge from Charleston, S.C.
(6) Outer Continental Shelf (OCS) - NPDES Permits
Within the last few years the oil and gas industry has
begun drilling wells in the eastern Gulf of Mexico; this
year wells are being drilled just outside of state waters of
Mississippi and Alabama. Permits for discharges from
drilling activities at the rigs are issued under the NPDES
of the Clean Water Act. Presently, there are five new
permits for wells within 6.7 miles of these state waters.
Should finds be made at these wells, production platforms
and pipelines will further impact this coastal system. With
recent discoveries of hydrocarbons in Mobile Bay and the
Delta areas, the trend is for abundant infrastructures as
are presently in Texas and Louisiana.
c. Future Programs
(1) Ocean Disposal of Dredged Materials
Dredge material disposal will continue to require
Regional resources for permit reviews and site determina-
tion. Evaluation of the 10 sites proposed for final desig-
-------
nation must be implemented along with EIS's and Final
Designations for the additional 33 existing interim sites.
The EIS's can be developed by the EPA or the Corps of
Engineers. It remains undetermined at this time which •
agency will prepare the EIS's. That agency providing
resources will probably be the one responsible for the
EIS's. Certain of these sites should be monitored in order
to evaluate the fate and effects of'dredged material dispos-
al; again, this could be performed by the EPA, the Corps of
Engineers, or the National Oceanic and Atmospheric Adminis-
tration. Region IV prefers to assume this monitoring
responsibility. This effort will require resource commit-
ments which should be provided for in personnel ceilings.
(2) Monitoring of Ocean Discharges
Section 403 authorizes EPA to impose permit conditions
requiring effluent analysis, bioassay analysis, and field
studies. Section 301(h) variance applicants must develop a
monitoring program providing for effluent monitoring, water
quality monitoring, and biological monitoring. EPA review
and approval of the monitoring program is part of the 301(h)
process. Successful applicants will be required to imple-
ment the monitoring programs.
State regulatory agencies would be reluctant to permit
ocean dumping of sewage sludge because of its unknown
impacts. In all likelihood, EPA Region IV would require the
preparation of a generic Environmental Impact Statement on
ocean dumping of sewage sludge before it would be allowed.
Individual EIS's would be required for site-specific pro-
jects.
14. Future Outlook
In the future, water quality problems in Region IV are
likely to intensify more than in most areas of the country
because of anticipated population, industrial, and agricul-
tural growth. Current trends in land use, changing from
rural to urban, increase the pressures on water quality.
Locations where environmental issues are expected to be most
intense are:
o Coastal zone areas, especially Florida,
Mississippi and Mobile Bay, from multiple sources.
o Coastal areas of North Carolina from the rapid,
recent conversion of lowlands and wetlands to
"superfarms."
o Appalachian region of Kentucky and Tennessee from
mining, gas and oil industry and oil shale
development in eastern-central Kentucky.
-------
Piedmont in the Carolinas from urban and indus-
trial development.
The Tennessee-Tombigbee Waterway because of
extensive anticipated industrial growth in the
area. In addition, the capacity of existing
streams has been greatly reduced by channeliza-
tion, and heavy industrialization already exists
on the portion of the Tennessee River that will
flow into the Waterway. The potential development
of lignite mining in northeast Mississippi may
further exacerbate these environmental problems.
The Mississippi Delta area where wetlands clearing
and pesticide residues will continue to be signi-
ficant problems.
-------
TABLE WQ-1 TOXICITY OF INDUSTRIAL WASTES (1975-1982)
Agency No Facilities No. Effluent Lethal %Lethal
EPA 352 250 71
TN 150 84 56
FL 69 37 54
SC 27 17 63
TOTAL 598 388 65
LL
-------
Table
STATUS OF LAKES AND IMPOUNDMENTS IN REGION IV
TN
MS
NC
KY
SC
GA
FL
REGIONAL
AL TOTAL
Number of Lakes
Surveyed
109
24
62
46
40
173
580 NIA* 1,034
Total Known Surface 682,516 129,359 227,752 353,353 447,802 387,169 1,040,202 NIA 3,268,153
Area in Acres
Type:
Impoundment 108 24 49 46 40 170 5 NIA
Natural Lake 1 0 13 0 0 3 575 NIA
Location:
Urban 15 1 17 4 5 50 111 NIA
Rural 94 23 45 42 35 123 464 NIA
Problems:
Weeds
Hypolimnion Dissolved
Oxygen Depletion
Sedimentation
Nuisance Blooms
Fishkills
Turbidity or Solids
Dissolved Oxygen
PH
Toxics
Coliform
Temperature
Taste & Odor
Color
Oils
Number of Lakes with 1 0 34 36 7 146 434 NIA
No Serious Problems
Recreational Use:
Number of Lakes 13 0 12 10 9 3 NIA NLA
Percent of Total Acres 1 08211 NIA NIA
Impaired
3
70
9
21
11
12
18
24
10
16
15
6
4
1
3
0
5
0
0
10
0
0
9
0
0
0
0
0
9
0
22
0
0
0
0
0
1
0
0
0
0
0
2
1
0
3
0
4
2
1
0
0
0
1
0
0
16
12
19
3
0
4
0
0
0
0
1
0
0
0
13
7
8
13
4
11
5
0
0
2
0
0
0
1
88 NIA
0 NIA
0 NIA
20 NIA
33 NIA
0 NIA
5 NIA
0 NIA
0 NIA
0 NIA
0 NIA
0 NIA
0 NIA
0 NIA
*NIA = No Information Available
tsi
-------
Table WQ-3
URBAN LAKES
RECREATIONAL
TOTAL PROBLEM LAKES TOP 3 PROBLEMS IMPAIRMENT IMPAIRMENT
STATE NUMBER ACRES NUMBER ACRES 1 2 3 NO. ACRES PROBLEMS
Tennessee 15 7,430 14 7,428 Depleted Nuisance Fishkills 1 14.2 Coliform, D:
Dissolved Blooms solved Oxygc
Oxygen in Non-point
Hypolimnion
Mississippi 1 33,000 1 33,000 Weeds 0 0
North 17 9,783 10 2,120 Sediment Weeds 5 543.6 Sediment/We
Carolina
Kentucky 4 324 1 51 Dissolved Weeds Nuisance 1 51 Weeds/Bloom:
Oxygen Blooms
South 5 12,908 5 12,908 Weeds Sediment Turbidity 2 550 Weeds
Carolina
Georgia 50 2,368 15 1,625 Blooms Weeds Turbidity 0 0
Florida 146 44,326 21 22,964 Weeds Fishkills Nuisance NIA* NIA NIA
Blooms
Alabama NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA
TOTALS 238 110,139 67 80,096 ' 9 1158.8
*NIA - No information available
-------
201 FUNDING 1973-82
<
o
1000
900
800
700
600
500
400
300
200
100
0
DOLLARS
73
74
75
76
77 78
YEAR
79
80
82
Figure WQ - 1
-------
STATIONS WHERE DESIGNATED USE OF
'FISHABLE/STOIMABLE' IS SUSPECTED OF BEING IMPAIRED
BASED ON AVAILABLE MONITORING DATA FOR 1980-81
REGION 4
90
88° 86' 84' 82" 80" 78' 76°
38
38
PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
•*• NEGLIGIBLE—FOR EACH DESIGNATED USE,
IMPAIRMENT VALUE IS 0 - .99
X MODERATE--FOR AT LEAST ONE DESIGNATED USE,
IMPAIRMENT VALUE IS 1 - 9.9
3K SEVERE—FOR AT LEAST ONE DESIGNATED USE,
IMPAIRMENT VALUE IS 10 & UP
FIGURE WQ-2
-------
STATIONS WHERE TOXICS ARE SUSPECTED
OF CONTRIBUTING TO USE IMPAIRMENT PROBLEMS
BASED ON AVAILABLE MONITORING DATA FOR 1980-81
REGION 4
•4- PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
+ NEGLIGIBLE—IMPAIRMENT VALUE IS 0
X MODERATE—IMPAIRMENT VALUE IS .01 - .99
3K SEVERE—IMPAIRMENT VALUE IS 1.0 & UP
FIGURE WQ-3
11
-------
STATIONS WHERE LOW DISSOLVED OXYGEN IS SUSPECTED 01
CONTRIBUTING TO USE IMPAIRMENT PROBLEMS-
BASED ON AVAILABLE MONITORING DATA FOR 1980-81
REGION 4
38
38
4- PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
^ NEGLIGIBLE—IMPAIRMENT VALUE IS 0
X MODERATE—IMPAIRMENT VALUE IS .01 - .99
3K SEVERE—IMPAIRMENT VALUE IS 1.0 6, UP
FIGURE WQ-4
-------
STATIONS WHERE FECAL COLIFORMS ARE SUSPEfTFn OR
C°™fUTING TO USE IMPAIRMENT PROBLEMS
BASED ON AVAILABLE MOMTOR.NC DATA FOR ,980-8,
REGION 4
84" 82" 80" 78
PARAMETER NOT MEASURED OR
X MODERATE-IMPAIRMENT VALUE IS .01 - .99
* SEVERE-IMPAIRMENT VALUE IS 1.0 4 UP
FIGURE WQ-5
73
-------
STATIONS WHERE LOW PH IS SUSPECTED OF
CONTRIBUTING TO USE IMPAIRMENT PROBLEMS
BASED ON AVAILABLE MONITORING DATA FOR 19HO-01
REGION 4
x' £^^^J^^^2^!
J^C^-p^™ -"• ^ iws^r^w^.; v«^ ;
-J- PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
+ NEGLIGIBLE—IMPAIRMENT VALUE IS 0
X MODERATE—IMPAIRMENT VALUE IS .01 - .99
3(£ SEVERE—IMPAIRMENT VALUE IS 1.0 <& UP
FIGURE WQ-6
74
-------
STATIONS WHERE TEMPERATURE IS SUSPECTED OF
CONTRIBUTING TO USE IMPAIRMENT PROBLEMS
BASED ON AVAILABLE MONITORING DATA FOR 1980-01
REGION 4
90° 88° 86° 84° 82° 80- 78
28° {
26°
PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
NEGLIGIBLE — IMPAIRMENT VALUE IS 0
X MODERATE — IMPAIRMENT VALUE IS .01 - .99
3K SEVERE—IMPAIRMENT VALUE IS 1.0 & UP
FIGURE WQ-7
75
-------
STATIONS WHERE TURBIDITY, DISSOLVED SOLIDS, FE,
MN, AND OIL & GREASE ARE SUSPECTED POLLUTANTS
BASED ON AVAILABLE MONITORING DATA FOR
REGION 4
38
36
82° 80° 70°
-f- PARAMETER NOT MEASURED OR
NOT INCLUDED IN STATION CRITERIA
^ NEGLIGIBLE—IMPAIRMENT VALUE IS 0
X MODERATE—IMPAIRMENT VALUE IS .01 - .99
5(6 SEVERE—IMPAIRMENT VALUE IS 1.0 & UP
FIGURE WQ-8
-------
MAJOR TOXICS PROBLEM AREAS IN REGION IV
^ RIVER SEGMENTS WITH SEVERE PROBLEMS
• RIVTR SEGMENTS WITH MODERATE PROBLEMS
^ WHOLE BASINS WITH SEVERE PROBLEMS
A WHOLE BASINS WITH MODERATE PROBLEMS
Figure WQ-9
77
-------
MAJOR LOW DISSOLVED OXYGEN PROBLEM AREAS IN REGION IV
0 RIVER SEGMENTS WITH SEVERE PROBLEMS
• RIVER SEGMENTS WITH MODERATE PROBLEMS
A WHOLE BASINS WITH SEVERE PROBLEMS
A WHOLE BASINS WITH MODERATE PROBLEMS
Figure WQ-10
-------
MAJOR NUTRIENTS PROBLEM AREAS IN REGION IV
RIVER SEGMENTS WITH SEVERE PROBLEMS
RIVER SEGMENTS WITH MODERATE PROBLEMS
U1IOLE BASINS WTTH SEVERE PROBLEMS
A WHOLE BASINS WITH MODERATE PROBLEMS
Figure WQ-11
-------
MAJOR BACTERIAL PROBLEM AREAS IN REGION IV
Q RIVER SEGMENTS WITH SEVERE PROBLEMS
• RIVER SEGMENTS WITH MODERATE PROBLEMS
A WHOLE BASINS KITH SEVERE PROBLEMS
A WHOLE BASINS WITH MODERATE PROBLEMS
Figure WQ-12
-------
MAJOR PH PROBLEM AREAS IN REGION IV
RIVER SEGMENTS WITH SEVERE PROBLEMS
RIVER SEGMENTS WITH MODERATE PROBLEMS
WHOLE BASINS WITH SEVERE PROBLEMS
WHOLE BASINS WITH MODERATE PROBLEMS
Figure WQ-13
-------
MAJOR SILTATION PROBLEM AREAS IN REGION IV
^ RIVER SEGMENTS WITH SEVERE PROBLEMS
• RIVER SEGMENTS UITH MODERATE PROBLEMS
^ UIIOLE BASINS WITH SEVERE PROBLEMS
A W)10LE BASINS UITH MODERATE PROBLEMS
Figure WQ-14
-------
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-------
DRINKING WATER
1. Bacteriological Concerns
The compliance analyses of the FY 81 bacteriological
contaminant data which have been completed for each of the
eight states in Region IV, and FY 82 data which are available
for the states of Kentucky, Florida, Mississippi and
Tennessee, have been utilized to assess the bacteriological
compliance record and identify significant trends.
The FY 81 Maximum Contamination Level (MCL) and Moni-
toring and Reporting (M/R) violation rates for community
water systems in Region IV were 9.3% and 31.8% respectively,
whereas the national average violation rates for MCL and M/R
were 8.5% and 25.6%. The FY 81 Region IV data represent a
decrease, however, from the FY 80 violation rates of.11.2%
(MCL) and 38.2% (M/R). Regional comparisons appear to show
a good correlation between the number of small and very
small systems and violation rates.
During FY 81 three of the states had a significant
decrease in their MCL violation rates, and seven states had
a decrease in their M/R violation rates. Tennessee and
Mississippi have decreased significantly their MCL and M/R
rates during FY 82. Preliminary results indicate Florida's
rates of violations for MCL and M/R have increased. Table
DW-1 lists the FY 80 and 81 MCL and M/R violation rates for
each state in Region IV and the FY 82 rates for the states
for which information is presently available.
A majority of the water systems in Region IV use
groundwater as their source. Of the 11,735 community water
systems in Region IV, 10,176 utilize groundwater. The FY 81
violation rates for groundwater systems are 9.8% (MCL) and
32.3% (M/R). This compares with violation rates for surface
systems of 6.5% (MCL) and 28.4% (M/R). This difference is
likely attributable to the higher number (on a percentage
basis) of very small systems that utilize groundwater as a
source of potable water. As noted below, smaller systems
are more probably violators of both MCL and M/R require-
ments.
The community water systems in Region IV have been
categorized by system size into one of seven population
groups. The largest number of MCL and M/R violations and
the highest percentage of M/R violations occurred in the
population group serving 100 people or less (Table DW-2).
The high violations rates are indicative of the problems
that states generally have in dealing with small systems
where low operating budgets and least qualified operators
result in higher violation frequencies.
-------
Each of the states in Region IV is divided into regions
or districts. For each district or region the percentage of
systems with MCL and M/R violations has been calculated.
Systems with an MCL violation rate greater than 20% or a M/R
violation rate greater than 40% are presented in Table DW-3.
An analysis of the frequency and duration of M/R
violations indicates that in Region IV persistent violators
(systems with a minumum of four M/R violations) comprise
6.8% of the total number of community water systems, but
account for greater than 50% of the M/R violations. Table
DW-4 presents the number of persistent violators and a
percentage of the total number of community water systems
that are persistent violators in each state. Therefore,
maximum effort in dealing with bacteriological violations
will be directed toward persistent violators.
Based upon' an analysis of the FY 81 and preliminary FY
82 data the following conclusions can be made:
. Region IV is experiencing a problem with bacterio-
logical contamination in treated water in the states of
Kentucky, Florida, Tennessee and Mississippi.
. The smallest systems have the highest percentage of
systems with MCL and M/R violations.
. There are particular regions or districts that have
high violation rates (when compared to national average
rates) for MCL and M/R. These regions or districts are
identified in Table DW-3.
. Regionally, a large number of violations are occurring
in a small number of systems. Programs stressing
persistent violators are being developed to alleviate
this problem.
2. Turbidity
During FY 81 there were a total of 209 community water
systems in Region IV that had turbidity M/R violations. Of
these 209 systems, 157 systems were in Kentucky. All other
states in Region IV had turbidity violation rates well below
the national average rates of 4.9% for MCL and 14.2% for
M/R. Kentucky's violation rate for M/R in FY 81 was 36%.
However, based on FY 82 results, Kentucky had a total of 90
systems with violations out of 482 systems that monitor for
turbidity. This represents a violation rate of 18.6%, a
significant decline from FY 81.
-------
3. Organics
a. Trihalomethanes (THMs)
There are 53 systems'in Region IV serving greater than
75,000 people and eight of the systems are or were in
violation of the 0.10 mg/1 MCL for THMs. Four of the
systems not in compliance are expected to be brought into
compliance through minor adjustments in the treatment
process. The remaining four cities of Jackson, Mississippi,
Lexington, Kentucky, and Melbourne, Florida, and Charleston,
South Carolina have contracted with consulting firms to
investigate the problems and recommend methods for reducing
THMs.
The states are implementing extensive monitoring
programs to monitor the systems in the population range of
10,000-75,000, but little data are available at this
time for any conclusions.
b. Other Organic Contaminants
In an EPA conducted sampling and analysis program for
volatile organic compounds (VOCs) in finished water from 945
water supplies throughout the United States, Region IV had a
total of^ 219 systems sampled (107 random and 112 non-
random)." Of the systems in Region IV sampled, 40 systems or
18% contained measurable levels of VOCs other than THMs.
The seven compounds that occurred most frequently in
the samples analyzed during the survey are listed below
along with their frequency of occurrence and the range of
detected concentrations of each compound.
Volatile Organic
Compounds
Frequency of Occurrences
Number
Percent
Range of
Detected
Concentration ug/1
Cis-and/or
Trans-1,2-
Dichloroethylene 13
Trichloroethylene 13
Tetrachloroethylene 10
1,1-Dichloroethylene 9
1,1-Dichloroethane 9
1 ,1 ,1-Trichloroethane 9
Carbon Tetrachloride 7
5.9
5.9
4.6
4.1
4. 1
4.1
3.2
0.23-15.0
0.24-19.0
0.21-12.0
0.23-16.0
0.20-1.2
0.23-13.0
0.29-3.0
As a result of the study, Region IV has recommended the
closing of ten wells, marginal use of eight wells, and
additional monitoring for twelve wells. The location of
each of these wells is indicated on a regional map designat-
ed as Figure DW-1.
-------
With the increased incidence of drinking water contami-
nation by organic chemicals, the Agency emphasis appears to
be shifting away from biological water quality. It is
important that the Agency not lose sight of the relative
significance of the two types of contamination. While a
number of the organic chemicals that have been found in
drinking water are suspected or known animal and human
carcinogens, their effect normally requires an extended
period of exposure. Rarely has the concentration of any
organic compound been present in a drinking water well at
concentrations which would be acutely toxic.
On the other hand, only a small number of microbio-
logical organisms are required to cause disease. The
disease caused by ingested organisms is expressed within a
few hours to weeks (depending upon the organism) of the
exposure. Repeated, long term exposure is not necessary for
biological agents to result in disease; therefore, it is
important for the Agency to continue to work toward accept-
able biological monitoring and MCL compliance for water
supplies at the same time it works toward control of organic
chemicals in drinking water.
4. Radiological and Inorganic Violations
There were approximately twenty systems in the Region
in FY 81 and 82 which exceeded the maximum contaminant
levels for the inorganic drinking water standards. These
violations were spread throughout the Region, with fluoride
being the contaminant most frequently exceeding the regula-
tions.
There are five systems in Georgia and eight in North
Carolina exceeding the radiological standards based upon FY
81 data. Most of these problems have been eliminated or are
being corrected by finding new sources of water or adding
additional treatment. The violations should be eliminated
by the end of 1983.
5. Shortage Concerns
A major problem related to quantity of available and
suitable water for drinking has begun to emerge in the
Southeast. As population and industrial growth continue,
the adequacy of water supplies to meet the resulting demands
becomes an increasingly important issue. As contamination
problems become more widespread, the available water supply,
which is already under pressure from a shortage standpoint,
will be further reduced.
Because of the expansion of pollution control efforts,
especially in the 1970"s, many surface sources of potable
water have improved (or not deteriorated further). However,
quality of groundwater has, in many isolated cases, dete-
-------
riorated, since many of these pollution control efforts did
not address groundwater contamination. As the expansion of
various uses of water occurs, problems will increase.
Considerable effort will be required to balance economic
growth and protection of water resources in the future.
6. Conclusions
1. Regional bacteriological MCL and M/R violation
rates are in excess of the national average. The
high rate, however, may be attributed to the large
number of small community water systems in the
Region.
2. The small systems and groundwater systems are
experiencing the highest MCL and M/R violation
rates. Since smaller systems generally use
groundwater, the high violation rates for ground-
water may be the result of unqualified operating
personnel and low budgets.
3. There are districts in Kentucky, Florida, and
Georgia that have high bacteriological violation
rates in treated water when compared to the
national average.
+
4. Persistent violators are responsible for a large
number of bacteriological violations when compared
to the national average.
5. Kentucky has a high turbidity M/R violation rate,
however, the other states in the region have a
violation rate lower than the national average.
6. Radiological violations have occurred in several
states but are generally not widespread. Where
they are persistent, alternative sources are being
used or will be available by the end of 1983.
7. Isolated instances of shortage problems have been
and are occurring particularly along coastal areas
of the Region. It is expected that as the expan-
sion of various uses of water occurs, problems
with quantity of water available for potable water
supplies will increase.
8. The National Groundwater Survey (NGWS) has identi-
fied high levels of organic contaminants in south
and central Florida.
9. The inorganic violation rate is low and violations
are scattered throughout the Region.
-------
Table DW-1
Compliance Comparison For Microbiological Violations
State
AL
FL
GA
KY
MS
NC
SC
TN
MCL%
FY 80
10.6
6.1
14.3
12.6
17.1
15.8
6.6
0.0*
FY 81
6.7
7.8
6.0
15.0
17.9
9.9
5.0
7.1
FY 82
N/A
14.1
N/A
11 .9
14.2
N/A
N/A
4.9
FY 80
7.8
57.4
38.4
68.1
35.3
35.0
18.3
11 .5
M/R%
FY 81
5.3
47.5
35.5
58.1
29.7
19.7
16.4
47.3
FY 82
N/A
53.7
N/A
48.9
23.6
N/A
N/A
30.2
Total 11.2 9.3 38.2 31.8
N/A - Not Available
* - Complete Data Not Available
-------
Table DW-2
Microbiological Violations By System Size
FY 81 Data
Percent Percent
Size Number Systems with Systems with Systems with Systems
Category of systems MCL Violations M/R Violations MCL Violations M/R
100 4091
101-500 3402
501-2,500 2511
2,501-5,000 731
5,001-10,000 453
10001-75,000 448
75,000 and up 99
406
296
272
66
29
24
0
1582
1045
580
270
131
107
14
9.9
8.7
10.8
9.0
6.4
5.6
0 •
38.7
30.7
23.1
36.9
28.9
24.1
14.1
Total 11735 1093 3729 9.3 31.8
-------
Table DW-3
Districts or Regions with a Greater than
20% MCL or 40% M/R Violation Rate
State District or
Region
M/R Violation
Rate
MCL Violation
Rate
**Florida
*Georgia
**Kentucky
Pensacola
Jacksonville
Orlando
Tampa
Middle (Macon)
1 (Paducah)
2 (Madisonville)
5 (Florence)
7 (Columbia)
8 (Morehead)
9 (London)
10 (Hazard)
* - FY 81 Data
** - FY 82 Data
65.5
57.7
55.5
57.6
40.7
Southeast (Brunswick) 40.7
43.6
48.9
58.0
46.2
61 .8
53.5
71 .2
23.8
-------
Table DW-4
Community Water Systems With A Minimum of 4 M/R Violations
State CWS with a Number of Percent of
Minimum of 4M/R Viol. Violations _ Total CWS
Alabama
Florida
Georgia
*Kentucky
*Mississippi
N. Carolina
S. Carolina
*Tennessee
6
389
96
107
74
25
16
88
37
2889
653
930
565
164
131
827
0.9
25.2
6.5
15.1
5.3
0.9
1.3
12.1
801 6196 6.8
* FY 82 Data
-------
GROUNDWATER
1. Groundwater Use and Aquifer Systems
Groundwater is one of the Southeast's most important
resources. The use of groundwater increased by 160 percent
between 1960 and 1980. The USGS estimated that groundwater
met 41 percent of the Region's freshwater consumptive use
need in 1980. Overall, Florida, Mississippi, and Georgia
are the most dependent on groundwater. Rural users in North
Carolina, Florida, and Georgia are almost totally dependent
on groundwater as a water supply source. In 1970, almost 70
percent of the population in the Southeast obtained its
drinking water from groundwater sources.
Southeast aquifer systems can be grouped into five
Groundwater Provinces based on differences in hydrology:
Central Plateau; Valley and Ridge; Piedmont and Blue Ridge;
Atlantic and Gulf Coastal Plain; and the Floridan. (Figure
GW-1 )
The Central Plateau of Kentucky contains several broad
regional (multi-county) aquifers which are composed of
essentially horizontal carbonate rocks and regolith
deposits. Groundwater occurs primarily in solution-enlarged
bedding -planes and to a lesser extent in enlarged joints and
faults. The extensive karst areas within the province are
the most vulnerable to groundwater contamination because of
direct conduits provided by sinkholes and sinking streams.
In contrast to the broad regional aquifers of the
Central Plateau, the localized aquifers of the Valley and
Ridge Groundwater Province are limited by the folded and
faulted geologic structure of the province. Like the
Central Plateau, karst areas in the Valley and Ridge Pro-
vince are abundant, and groundwater flow is generally
fracture controlled in the sandstones, shales and limestones
of the province.
In the Piedmont and Blue Ridge Province, fractures
comprise the major storage transport network in the igneous
and metamorphic rocks and associated saprolites. Unlike the
sedimentary rocks in the other four provinces, no distinct
aquifers can be delineated in the crystalline rock of the
Piedmont and Blue Ridge.
Numerous layers of consolidated and unconsolidated
sedimentary rocks form the region aquifer systems in the
Atlantic and Gulf Coastal Plain Groundwater Province.
Beginning as a thin wedge overlying the consolidated rocks
of the northern provinces, the unconsolidated clay, sand,
gravel, and consolidated and semiconsolidated limestones
thicken and dip seaward in the east and south or toward the
Mississippi River in the west.
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Though very similar to the Atlantic and Gulf Coastal
Plain, the hydrogeology of the Floridan Groundwater Province
is distinguished by the Ploridan Aquifer, a highly produc-
tive and extensive carbonate rock formation. The Floridan
is the major water supply aquifer in Florida and large parts
of the Coastal Plain of Georiga. The aquifers in the
sedimentary rocks overlying the Floridan are of the same
lithologic type aquifer systems serving as the principal
sources of potable water in Southeast Florida (the Biscayne
Aquifer) and in coastal areas where the Floridan yields
brackish water. As in the Central Plateau and Valley and
Ridge Provinces, the Floridan contains karst areas, princip-
ally on the Ocala uplift and in Central Florida.
Throughout the Southeast, alluvial deposits and asso-
ciated rivers and streams form localized, surficial aquifers
utilized for domestic water supplies.
2. Groundwater Problems
Serious groundwater degradation problems tend to be
highly localized. However, in parts of the Atlantic and
Gulf Coastal Plains and most of Florida the problems are
more pervasive. The full extent of groundwater quality
problems is not well known due to inadequate data manage-
ment. Problems originate from lack of coordination and
information exchange between and within agencies involved.
Inadequate technical and financial support for well networks
and sampling, inconsistent or conflicting terminology
associated with aquifer zones, and under-utilization of
existing data bases are further examples of these problems.
(SPDD, 1982, Section 5.5) Development of the needed com-
prehensive data storage, analysis and retrieval programs
could be accomplished with a relatively small amount of
resources. Most, if not all, of the states in the Region
are struggling with the problem of data management.
Perhaps the major reason we know so little about
groundwater pollution problems is because no serious attempt
has been made at the regional or national level to identify
and track such problems. Such an information base can and
should be established. However, many obstacles and ques-
tions would have to be resolved before implementation could
occur. As a start, groundwater problems have been categor-
ized by pollution source for this report. Because pollution
sources are numerous, problems are widespread, and specific
data are limited, groundwater problems and concerns relative
to each pollution source are discussed below in general
terms.
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a. Surface Impoundments
In 1978, EPA undertook a nationwide study to determine
the potential effect of surface impoundments on groundwater.
At that time, little data were available on the number,
location, or construction of surface impoundments, and their
potential for groundwater contamination was unknown. The
Surface Impoundment Assessment (SIA) was primarily a desk-
top study although some states did field verification of the
results. Five major categories of impoundments were used;
(1) industrial, (2) municipal, (3) agricultural, (4) mining,
and (5) oil and gas. The potential effect of the surface
impoundments was then assessed by using a numerical rating
scheme which took into account hydrogeologic setting, waste
type, construction features, groundwater quality, and avail-
ability of monitoring data. As part of the state SIA
report, state'teams submitted representative case studies
and provided descriptions of state regulatory authorities
and programs pertaining to surface impoundments.
The eight State reports for Region IV were reviewed by
Groundwater Section Staff and form the basis of a regional
SIA report now in preparation. Although content and type of
information varied from report to report, certain general
conclusions can be drawn:
(1) Case histories show that groundwater contamin-
ation is occurring in all categories of impoundments and in
all geologic settings.
(2) The assessment results indicate that two-
thirds of the surface impoundments in the Region have a high
potential for contamination of groundwater beneath the
sites.
(3) The potential for groundwater contamination by
unlined surface impoundments is primarily controlled by
geology of the site; type of waste in the impoundment is a
secondary controlling factor.
(4) Regardless of the site geology or type of
waste, the number of lined impoundments is small (< 3%).
(5) With the exception of those impoundments now
subject to RCRA Subtitle C standards, federal regulations
and programs do not adequately address surface impoundments.
At this time, about half the states in Region IV have
permitting procedures for surface impoundments (excluding
RCRA facilities) which take groundwater contamination into
account.
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b. Landfills
Over the years, EPA Region IV has received numerous
calls and letters from citizens alledging contamination of
their wells by nearby landfills. These complaints were (and
still are) routinely referred to the states. State agency
response to such complaints varies from state to state.
State agencies are understandably reluctant to test water
samples every time a complaint of well contamination is
received because of the cost. In those instances where well
samples have been collected and analyzed by the states, the
testing is typically limited to inorganic constituents (i.e.
PDWS's). There is at least one case involving a Superfund
site in which limited testing for inorganics failed to
indicate water supply contamination. Upon further testing
by EPA, several samples from wells near the site were found
to be contaminated by organics.
Although the contamination problem mentioned above is
not typical of the type or degree of contamination one would
expect from a landfill, the potential for such incidents is
probably greater than generally believed. This conclusion
is based on two observations. First, serious efforts to
curtail disposal of industrial waste in municipal landfills
have only occurred in the past five years; many currently
operating landfills are older than 5 years and many will
continue to receive hazardous waste from small generators.
Second, the majority of landfills currently operating do not
have monitoring systems, and that monitoring which has been
done has focused almost exclusively on inorganic parameters.
c. Uncontrolled Sites
Superfund is intended to address health and environ-
mental threats associated with past incidents of uncon-
trolled dumping of hazardous waste. In this Region, numer-
ous cases of groundwater contamination are attributable to
such incidents. Many of these have been listed as priority
hazardous waste sites. The public and EPA must recognize
that because of the large number of potential problem sites
in this Region and nationwide and the high costs associated
with assessment of groundwater contamination and aquifer
restoration, only the most acute problems can be rectified.
However, decision makers in the Superfund program must
resist the temptation to downplay the potential health risks
associated with trace levels of toxic organics in drinking
water and limit remedial action on groundwater pollution
problems to consideration of existing primary drinking water
standards.
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d. RCRA Land Disposal Facilities
Approximately 325 RCRA facilities (landfills, surface
impoundments, land application sites) in the Region monitor
groundwater in accordance with interim status standards.
Six of these facilities appear on the Superfund list because
of documented contamination. Some of these sites have both
abandoned and active disposal units, and it may not be clear
which particular units have caused contamination. Part B
applications are being called in on these six facilities on
a priority basis. Additional RCRA facilities are probably
contaminating groundwater, but these sites will not be
identified until June 1983, or later, when the results of
the first round of semi-annual monitoring under interim
status have been compared to background data collected the
previous year. Additional time will be required to assess
the extent and severity of groundwater contamination at
sites where problems are indicated.
e. Septic Tanks
Septic tanks are common in Region IV, and their number
is expected to increase in the future with the influx of
population to the "Sunbelt" states. The groundwater contam-
ination threat is directly related to the density of septic
tanks allowed in a given area. The most common density of
septic tanks in the Southeast is one per acre, but densities
may range upwards to four per acre. For instance, in the
Ft. Morgan Penninsula on the Alabama coast, beach houses are
constructed on 1/4 acre lots. Each house has a septic tank
and a private well for drinking water. Widespread ground-
water contamination by pathogenic organisms and nitrates
have prompted county health officials to order a ban on
well-water use.
Nitrates and pathogens are the most common groundwater
contaminants from septic tanks. More recently, the use of
solvents, such as TCE, as septic tank cleaners has raised
concern of contamination by synthetic organic chemicals.
Often, the overall effect of septic tanks is low level
degradation of groundwater over a wide area.
Little data exist in the Region on groundwater contam-
ination by septic tanks. The septic tank regulations of the
states and/or counties are often inadequate or poorly
enforced. For instance, the State of Tennessee allows
blasting to provide space for septic tank drain fields in
rock. Some states, however, such as North Carolina have
developed new site-specific guidelines for septic tank
construction.
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f. Injection Wells
Groundwater contamination problems involving injection
wells are not as widespread and severe, at present, as other
problems in Region IV. Two major types of injection wells
cause problems in Region IV. Improperly constructed or
mechanically defective Class II saltwater disposal wells are
causing groundwater contamination in oil producing areas, as
described in the section on oil and gas development below.
Class V drainage wells have caused many localized contamina-
tion problems in Florida and Kentucky.
In Florida, over 3000 drainage wells have been per-
mitted to receive stormwater and street runoff or to be used
for surface water/lake level control. Since the water moves
relatively rapidly through the karstic aquifers (rates of
feet per minute in some cases), little or no in-aquifer
attenuation of any contaminants present in the storm water
or lakewater occurs. Problems with bacterial contamination
are documented in the literature for Orange County and
Suwannee County, Florida. In Kentucky, drainage wells are
used extensively in the extremely well developed karstic
limestone in the Bowling Green area. Drainage wells termin-
ating in cave systems are used for storm water drainage and
in some cases, the disposal of raw sewage and other waste.
*
Minor problems may exist with Class I wells constructed
before the implementatin of the UIC program, but permit
review is expected to find those wells which do not meet
current contruction standards. It should be noted that
three States have banned or are expected to ban Class I
wells. Also, Alabama will not permit any new Class I wells.
g. Land Application
Land application of wastewater and/or sewage sludge has
been encouraged principally because of the costs associated
with the increased level of treatment necessary to meet
surface water quality standards. The construction grants
program offered additional financial incentive to communi-
ties considering land treatment systems. As of 1981,
approximately 90 publicly owned land treatment systems were
in operation or under construction in Region IV with more
than 30 in Florida. Probably many more industrial and
privately owned land treatment systems are in operation.
Florida alone has over 2500 permitted sites for land dispos-
al of domestic wastewater. Not much is known about this
impact on groundwater quality. Only a few of the sites in
Florida are monitored on a regular basis, and the same is
probably true of sites in other states.
100
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h. Spills and Leaks
Spills and leaks rank as the most common contamination
source requiring well replacement with the most frequent
pollutants being hydrocarbon products. Contamination of
groundwater can occur from leaky and ruptured pipelines and
storage tanks, transportion accidents, and "poor house-
keeping" practices by industry, airports, service stations.
and farms. Recently, incidents involving contamination of
water supplies in two states came to our attention. In
Belleview, Florida, a minimum of 10,000 gallons of gasoline
leaked into the city's well field causing the city to seek
alternative water sources. In Stuart, Florida, at least
four private wells have been contaminated by gasoline. Both
incidents have been attributed to leaking storage tanks at
service stations. In Perdido, Alabama, benzene has
contaminated a number of private wells. The source of the
contamination is thought to be a 1965 train derailment in
which benzene and other chemical were spilled. In most
cases, spills or leaks are discovered after they have
already polluted water supplies. While little can be done
to control releases caused by accidents, steps can and
should be taken to reduce the incidents of spills and leaks
from pipelines and buried storage tanks. Possibly, pressure
testing of underground storage tanks and lines should be
required within specified time periods.
i. Oil and Gas Development
Groundwater contamination caused by oil and gas activi-
ties is one of Region IV's greatest concerns. Problems are
mostly due to lax enforcement of state or federal regulatory
requirements in problem areas. The most common contaminant
associated with petroleum production is the concentrated
salt brine which naturally occurs with the oil in the rock
formation and is brought to the surface when oil is pro-
duced. These brines are extremely concentrated with total
dissolved solids content often many times that of sea water.
Generally, newer oil fields produce very little brine, but
as the oil is removed from underground reservoirs, increas-
ing amounts of saline water move in and are extracted with
the oil. In stripper wells, which produce less than 10
barrels of oil per day, ratios of 10 barrels of saltwater to
1 barrel of oil are not uncommon. Other problems may arise
when the well is improperly constructed or improperly
abandoned allowing movement of the often pressured brine
along the well bore into fresh water aquifers. Minor
contamination problems have also occurred in Kentucky where
natural gas has leaked and contaminated private wells.
Kentucky and Mississippi suffer from widespread and
locally severe problems due to brine contamination. For
instance, in Magoffin County, Kentucky, the governor
declared a state of emergency last year when both surface
101
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water and groundwater supplies became heavily contaminated
with salt. In Mississippi, data released by the USGS in
1982 show shallow groundwater contamination and/or surface
water contamination by brine in every oil producing area
studied. EPA has been informed of at least two public water
systems relying on groundwater and numerous private wells
which have been contaminated by brine in Mississippi.
Another state, Florida, has documented problems with improp-
erly plugged and abandoned oil test wells, many drilled in
the 1920's and 1930's. Some of these wells have become
"wild flowing wells" with pressured salt water moving up
from deeper formations and causing contamination of surface
and groundwater. Eastern Kentucky may have similar prob-
lems; oil exploration began around the turn of the century
and records of well location and abandonment procedures are
far from complete. A major problem with brine contamination
is its longevity; problems possibly caused by brine improperly
disposed of decades ago are only now reaching private wells.
There are four ways by which groundwater contamination
by brines is or may be occurring in Region IV. The first
and most common is the use of earthen pits or "evaporation
ponds" for brine disposal. Earthen pits for brine disposal
are banned in every state except Kentucky where brine is
disposed of to either earthen pits or to surface water.
Another -major problem is the use of improperly constructed
and operated injection wells. Mechanical integrity testing
mandated by the UIC program will help with this problem;
however, there are, at present, wells of adequate construc-
tion in Mississippi which are designed to inject saltwater
brines into freshwater aquifers. A third widespread problem
is that of illegal disposal. Inadequate enforcement in
Mississippi allows the use of some illegal pits to continue.
The fourth problem area is that of inadequate production
well casing and cementing requirements. Some states require
only a minimal amount of surface casing and cement allowing
groundwater of differing quality to migrate along the well
bore.
j. Groundwater Development
There are two major types of problems associated with
groundwater development. The first concern the quantity of
groundwater available. Increased demand may cause an area
to run out of good quality water and to resort to a supply
of lesser quality or greater expense. Overpumping may
cause physical problems such as land subsidence and sinkhole
collapse. Quantity problems are common in Region IV and
many states have permitting programs to control water usage.
The second type of problem associated with groundwater
development involves quality changes in water. Overpumping
can decrease artesian pressure in an aquifer from an adja-
cent body of saltwater or upconing, where saline waters from
underlying aquifers are pulled up into fresh water. The
-------
problem is a serious one and almost irreversible. If
groundwater withdrawal exceeds the safe yield, and water
levels decline, for every foot of decline in the fresh water
table, salt water rises 40 feet.
Every coastal state in Region IV has documented prob-
lems with saltwater intrusion and the literature describes
problems with upconing in most. An added problem caused by
overpumping has been the lowering of artesian water levels
on offshore islands threatening wildlife dependent upon
naturally occurring freshwater springs.
Barrier islands and coastal beaches are particularly
susceptible to salt water intrusion brought on by overpump-
ing. These aquifers usually consist of shallow lenses of
fresh water floating on top of deeper salt water replenished
by rainfall. The Southern beaches and peninsula of Pinellas
County, Florida, for instance, contaminated their shallow
aquifer decades ago by overpumping and associated saltwater
intrusion, and they now must obtain water from counties
further inland. The barrier islands of North Carolina,
Sanibel Island, Florida, and the Florida Keys are documented
as having problems ranging from moderate to severe. It
would be safe to assume that every developed coastal beach
or barrier island in Region IV is affected to some degree by
saltwater intrusion.
k. Energy and Mineral Mining
Mining activities in Region IV that have the greatest
potential to impact groundwater are coal and phosphate.
Coal is mined principally in Kentucky, Alabama and
Tennessee, and phosphate is mined predominantly in Florida,
North Carolina and Tennessee. Mining impacts groundwater by
altering the land surface which may, in turn, alter aquifer
recharge characteristics. Disturbance of the subsurface
increases the dissolved solids content of groundwater and
alters the natural geochemistry of the system by exposing
previously unexposed minerals. Dewatering lowers water
levels in adjacent areas commonly affecting private drinking
water supply wells. Finally, leachate from waste stacks and
spoils stockpiles may contaminate the groundwater system.
Coal mined from the surface is regulated under the
Federal Surface Mining Control and Reclamation Act (SMCRA)
which requires an assessment of the project's impact on the
hydrologic resources as well as groundwater monitoring.
This helps to reduce this activity's impact on groundwater
resources. However, coal mined below the surface and
phosphate mining are not regulated by the SMCRA and there-
fore pose a more direct threat to groundwater resources.
Phosphate waste stacks are known to contaminate the shallow
groundwater system. Shallow groundwater pumped into the
deeper Floridan Aquifer as part of the dewatering process
-------
has elevated levels of radium in localized areas of the
Floridan Aquifer as well. Dewatering activities in the
phosphate mines in Florida as well as the coal mines in
Kentucky have dropped water levels in adjacent private wells
to the point that the wells are no longer useful.
1. Agricultural Activities
Contamination of groundwater can occur from a number of
activities associated with crop production, dairy farming
and livestock management. Introduction of chemicals at the
surface which eventually migrate to the water table and the
accumulation of salts in groundwater due to irrigation
practices are the principal causes. In a sampling of water
well drillers, contamination of wells by pesticides, ferti-
lizers and feedlots accounted for 10 percent of the cases
of groundwater contamination requiring well replacement.
Water table aquifers beneath the Coastal Plain of North
Carolina, South Carolina, Georgia, Florida and Alabama were
found to be particulary susceptable to nitrate and pesticide
contamination (Miller, et al, 1977).
The pesticide - groundwater contamination studies cited
in the Miller report focus on environmentally persistent
pesticides such as DDT and dieldrin. Many of the pesticides
on the market today are easily degraded in the environment
and are therefore thought to be less of a threat to ground-
water. However, recent incidents such as the discovery of
aldecarb (Temik) in groundwater beneath citrus groves in
central Florida, and ethlene dibromide in an irrigation well
in south Georgia may indicate a need for tighter control
over the use of these and other pesticides where certain
hydrogeologic conditions (i.e. sandy soils, low pH, and
shallow aquifers) exist.
Farming operations are not the only source of nitrate
and pesticide contamination of groundwater. The heavy use
of fertilizers and pesticides by homeowners and pest control
companies in urbanized areas may have an important impact on
groundwater quality, especially in rapidly growing areas
along the Atlantic and Gulf Coast which are dependent on
shallow aquifers for drinking water supplies.
References
Science and Public Policy Program (SPPP), University of
Oklahoma, 1982. "Groundwater Management Issues in the
Southeast," draft report. Norman, Oklahoma.
Miller, D. P. Hackenberry, and F. Deluca, 1977. "Ground-
water Problems in the Southeastern United States." EPA
600/3-77-012, U.S. Environmental Protection Agency,
Washington, D.C.
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REGION IV
GROUNDWATER PROVINCES*
PROVINCE SYMBOLS
|H CENTRAL PLATEAU
ffiS VALLEY a RIDGE
\\' PIEDMONT 3 BLUE RIDGE
•^§ ATLANTIC a GULF COASTAL PLAIN
FLORIDAN
SURFICIAL AQUIFER 8
INTERMEDIATE AQUIFE
8ISCAYNE AQUIFER
'MODIFIED FROM HEATH (1982)
Figure GW - 1
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WETLANDS
1 . Wetland Losses through Dredge and Fill Activities
Figures W-1 and W-2, respectively, show the losses by
dredging and filling saltwater wetlands and freshwater
wetlands from 1955-1975. Prior to the passage of Section
404 of the Clean Water Act in 1972, the only Federal salt-
water wetland protection legislation in the coastal states
was Section 10 of the 1899 River and Harbor Act. That
jurisdiction extended shoreward to the mean high tide line.
However, in many coastal areas much of the wetland was
shoreward of this jurisdiction line. Typically developers
would fill all of the wetlands they owned that were above
the mean high tide line and then would apply for Section 10
permits to fill the more deeply flooded marsh and open
water. There was no protection for freshwater wetlands. In
March 1975, the Corps' regulatory authority was expanded to
include all waters of the U.S., including wetlands.
In July 1975, the Corps issued regulations that
required individual permit activities in saltwater wetlands
above mean high water and freshwater wetlands adjacent to
navigable streams. During 1976 and 1977, the requirement
for individual permits was expanded to include wetlands
upstream to the point where the stream flow is 5 cfs or
greater.
The average annual loss of wetlands from 1955 to 1975
was approximately 450,000 acres. Figure W-3 shows the
freshwater and saltwater acreages for 1975.
Although no formal record-keeping procedures are in
effect, the results of a questionnaire sent to all the Corps
Districts in Region IV suggest that dredging and filling
destroys approximately 2,500 acres of saltwater and fresh-
water wetlands each year in Region IV. The State and
Federal agencies know from experience that the rate of
saltwater wetland loss due to dredging and filling was
greatly curtailed after the implementation of the 1975 Corps
regulations; however, these same regulations have not
greatly reduced the rate of freshwater wetland loss.
The following needed improvements in the Corps' program
were ascertained from discussion with Corps personnel and
with other Federal agencies:
o No program exists to quantify the wetlands author-
ized to be dredged or filled by issued permits.
Issued permits usually do not contain acreage
figures. Any information regarding wetland losses
can usually be found only in the individual
project files. Annual reports documenting cumula-
tive impacts are not prepared. Reports document-
in L
-------
ing the trend in the overall condition of wetlands
in any geographic area are not prepared. Appar-
ently, neither the Corps nor the Assistant Secre-
tary of the Army for Civil Works requires reports
that document the effectiveness of the program.
No program exists to quantify the wetlands dredged
or filled as a result of violation of issued
permits. A recent study by the National Marine
Fisheries Service indicated violation of 64% of
the permits issued by the Mobile District. Some
Corps Districts had no permit violations.
No program exists to quantify the wetlands lost to
drainage and/or permanent flooding as a result of
issued permits. Often this wetland destruction
cannot be accomplished unless there is an issued
Section 10 and/or 404 permit.
No program exists to quantify the wetlands dredged
or filled as a result of violation of Section 10
of the 1899 River and Harbor Act or filled as a
result of violation of Section 301 of the Clean
Water Act (failure to obtain Section 10 and 404
permits). The federal and state review agencies
have observed that often more wetlands are lost to
violation than to permitted activities. Data
submitted by the Charleston Corps district for
1981 and 1982 show that only 16 acres of wetlands
were lost due to permitted dredge and fill activi-
ties; however, a violation that had destroyed 400
acres of wetlands was discovered in January 1983.
In 1980, one violation in Mississippi resulted in
the destruction of 4,000 acres of wetlands.
No program exists to quantify the wetlands lost
during construction of Federal projects. Many
acres of wetlands are impacted each year by
disposal of dredged material, dredging, impound-
ment flooding and drainage projects. Addition-
ally, many acres of wetlands are impacted due to
loss of periodic flooding below flood control
structures. Some of these projects have met
404(r) exemption and do not need Section 404
permits.
No program exists to quantify the wetlands lost
due to general permits.
Corps' records regarding permit activities are for
District boundaries. Unless a District boundary
coincides with a state boundary, data for an
individual state are not obtainable.
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In order to determine accurate trends for the loss of
wetlands in this nation, it will be necessary for the Corps
to initiate programs to correct the referenced deficiencies.
We recommend that the Agency notify the Assistant Secretary
of the Army of the deficiencies in the Corps' program.
2. Dredge and Fill Problem Areas
North Carolina (Coastal)
Problem -
Loss of the pollution abatement provided by
wetlands. The primary problems are wetland
removal for conversion to agriculture,
drainage to improve the production of pine
timber and stream channelization. As a
result of this wetland degradation, water
quality in the North Carolina estuaries
continues to decline.
Due to the expanded nationwide permitting
provided by current Corps regulations,
these problems are difficult to solve. The
nationwide permit for all isolated wetlands
should be rescinded.
Problem - Phosphate mining in wetlands.
Solution -
Solution -
Problem
Solution -
If it can be demonstrated that restoration
of mined wetlands can be accomblished,
perhaps mining in the wetlands and open
water can be allowed. Transfer of phos-
phate nutrients to estuarine waters during
the mining operation is expected to be a
continuing problem.
Discharge of freshwater into the estuaries
is altering the salinity balance. This
problem is primarily caused by the large-
scale clearing of wetlands to gain more
agriculture land.
This problem has been studied for a number
of years. No one has proposed any solution
acceptable to all involved parties.
North Carolina (Mountains)
Problem
Increasing pressure by the State Transport-
ation Agency to construct highways in
stream beds and adjacent wetlands. Many
streams are becoming riprapped corridors.
I A 5?
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Solution - None known.
South Carolina (Coastal)
Problem
Solution -
Problem
Solution
Problem
Solution -
Problem -
Solution -
Marina development in productive shellfish
areas. Closure of oyster and clam beds due
to contamination by fecal coliform bacteria
from boats concentrated at marinas.
Destruction of oyster beds by wakes from
recreational boating near marinas.
Additional studies are underway to evaluate
the extent of these problems. When the
problems cannot be reduced to an acceptable
level, the Section 10/404 permits should be
denied.
Conversion of bottomland hardwood swamp to
agricultural land has just begun.
Can be handled through the permit review
process if the Corps required individual
permit applications. Based on past exper-
ience in North Carolina, the Corps will
likely determine that over 50% of the
wetlands are covered under Secion 404
nationwide permits.
In many small streams the total stream flow
is used for irrigation.
None; irrigation canals are exempt from 404
jurisdiction provided the spoil from the
ditch is not placed in continuous piles
that block water flow.
Conversion of wetlands for duck
impoundments.
Permit denial. We need support from the
Administrator and the Office of Federal
Act ivities.
Georgia (Coastal Plain)
Problem
Solution -
Drainage of swamps for conversion to pine
plantations. Much of this activity is
unauthorized. Large acreages of swamps are
involved.
The Savannah Corps District must institute
a surveillance program and vigorously
enforce Section 404. While some areas
require individual permits, problems can be
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Florida
Problem
Solution -
Problem
Solution
Problem
Solution
Problem
Solution -
Problem
Solution -
handled through a vigorously applied permit
review process. EPA can request the Corps
to exert discretionary authority over
especially valuable wetlands now covered
under nationwide permits; however, the
Corps does not always agree to this.
Large numbers of applications for fill
material in saltwater and freshwater
wetlands.
Need more staff and more travel money so
all permit applications can be adequately
reviewed. This would provide opportunities
for better coordination with federal,
state, and local officials.
Large number of unauthorized fills in
saltwater and freshwater wetlands.
Increased surveillance by Corps personnel.
Elimination of the recent changes in the
Corps regulations which have enhanced
violators' chances of obtaining after-the-
fact permits.
Continued pressure by the phosphate mining
industry to mine wetlands.
Prohibit mining in highly valuable wet-
lands. Ensure that permits for mining in
wetlands of moderate value are conditioned
to require wetland restoration. Need more
staff and travel money.
Increasing drainage of swamps to plant pine
trees.
Require individual permits. See discus-
sions for North Carolina and Georgia.
Continued expansion of agricultural opera-
tions into the wetlands south of Lake
Okeechobee. This expansion further
threatens the water quality in much of
South Florida.
Continued review of individual permits.
Need more staff and travel money to improve
coordination with State and Federal agen-
cies.
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Alabama
Problem
Solution -
In the port area of Mobile, the existing
sites for industrial development are
rapidly being used. Pressure is increasing
to fill shallow water areas to accommodate
industrial development. This expansion
threatens water quality and the fishery
resources of Mobile Bay.
Existing shallow water areas need to be
maintained. Permit applications should be
denied.
Mississippi (Inland)
Problem
Solution -
Thousands of acres of forested floodplain
wetland continue to be converted to agri-
cultural use. Not only are the wetlands
and their water quality menaced and habitat
values destroyed, but the additional crop-
lands contribute runoff that further
impacts streams already degraded by exist-
ing agricultural pollution. Pesticide
contamination of sediments and fish in
Mississippi River Valley streams is among
the worst in the country. The loss of
wetlands results from the failure of the
Corps or EPA to adopt jurisdictional
boundaries that include all significant
floodplain wetlands and conversion of
wetlands to farmlands.
The Corps and/or EPA need to adopt wetland
jurisdictional boundaries including all
floodplain wetlands that play a significant
role in water quality maintenance and
wildlife enhancement. Additionally, land
clearing and subsequent conversion to
cropland needs to be regulated so signifi-
cant floodplain wetlands are protected.
Legal precedence for the regulation of
wetland clearing has been established
(i.e., Avoyelles Sportsman League versus
Clifford Alexander, e_t a^.) . Support by
the EPA Administrator would be needed.
Tennessee
Problem
Destruction of thousands of acres of
bottomland hardwoods. Soil eroded from
hilly farmland fills streams and is depo-
sited around trees in adjacent swamps.
Farmers cut the trees, build levees to
III
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protect the area from flood waters, and use
the protected land for farming. Construc-
tion of the levees increases the flood
elevations downstream.
Solution - See comments on similar problems in
Mississippi. Litigation resulting from
damages caused by higher floods may tend to
restrain the building of levees.
Kentucky
Problem - Destruction of bottomland hardwood swamps
by channelization, conversion to agricul-
ture and surface mining.
Solution - See comments for Mississippi and Tennessee.
3. Review the Dredge and Fill Permit Program
The most severe problem with the administration of the
Section 10/404 review program is the recent Memorandum of
Agreement (MOA) between EPA and the Corps. In order to
increase the efficiency and effectiveness of the program, we
recommend that the current MOA with the Corps be modified
after consultation with the Region.
This Region has adequate experience with the 404(b)
Guidelines to determine that only minor changes need to be
made in that document. The current guidelines work extreme-
ly well. Meeting between Regional and Headquarters staff
held at least annually are essential for effective
coordination.
4. Review of Problems with Dredge Spoil Disposal from
Federal Navigation Projects
Disposal of dredged material from Federal navigation
projects is becoming a critical problem. For the past 15
years the Corps has come under mounting pressure to mitigate
the environmental impacts of the disposal of dredged spoil
material. Many harbors are running out of disposal areas
and,in many instances, the Corps will not be able to obtain
either upland or wetland disposal areas. EPA Region IV has
for years encouraged the Corps to develop suitable equipment
for transportation of dredged material from the harbors and
access channels to the Atlantic Ocean or the Gulf of Mexico.
Studies by the Corps show that the technology exists and
that in many cases ocean disposal of material dredged from
the harbors is cost effective. At this time we need strong
support and leadership from the Administrator to help
convince the Corps that the time has come to move forward
with this program in a meaningful way.
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The selection of ocean disposal sites in Region IV
should be accomplished by Region IV personnel. Region IV
should also have complete authority for all environmental
studies and the issuance of all ocean dumping permits. The
total transfer of these responsibilities to the Regions
would greatly improve the efficiency of the program. The
Washington Office should be concerned with overall national
policy.
Specific Problems by state are:
North Carolina
Problem
Solution -
Inadequate disposal areas for 102 million
cubic yards per year (mcyy) in the Sunny
Point Terminal area.
The solutions from an environmental stand-
point in preferred order are: (1) upland
disposal with recycling, (2) diked upland
disposal and (3) ocean disposal. The Corps
has resisted ocean disposal as a solution
because of high costs and the lack of a
program to develop adequate equipment.
Soqth Carolina
Problem
Solution -
Upland disposal areas are in short supply.
Thousands of acres of wetlands have already
been destroyed and it is unlikely that any
additional areas will be made available to
the Corps. At present 12 mcyy are dredged
and disposed of in diked areas.
The Corps' implementation of the Cooper
River Rediverson project should reduce
dredging and disposal to 3-4 mcyy. This
material could possibly be disposed of in
the ocean.
Dredging of the Savannah Harbor generates
approximately 7 mcyy of material which is
disposed of in diked disposal areas along
the river. Thousands of acres of wetlands
have been destroyed. A boundary dispute
with South Carolina was also involved.
Solution - Same as comments for North Carolina.
Problem - Acceptable disposal areas for the dredged
material from the intermediate channel at
Brunswick are difficult to obtain.
Georgia
Problem
113
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Solution - Possible disposal in the ocean.
Florida
Problem -
Solution
Problem
Solution -
Alabama
Problem
Solution -
Mississippi
Problem
Recent improvements in the dredged spoil
disposal areas in the upper reaches of
Tampa Harbor should provide disposal
capacity for 20-50 years. These disposal
areas cannot be expanded without further
disruption of circulation and adverse
impacts on water quality. Locating an
adequate disposal area in the Gulf for the
material dredged from the lower channel is
a problem.
The long-term solution is disposal at an
acceptable site in the Gulf.
The Corps has disposed of dredged spoil
material in Apalachicola Bay for many
years. There is concern that this disposal
practice has disrupted circulation and
adversely impacted biological productivity.
Existing spoil banks should be broken to
reestablish circulation. Much of the
future maintenance material should be
disposed of at upland sites or in the Gulf.
Only one year's capacity remains in the
dredged spoil disposal area in Mobile
Harbor. Thousands of acres of shallow-
water habitat and marshes have been
destroyed by past disposal. The Corps has
requested permission to use 385 acres of
additional wetlands for spoil disposal as
an interim solution. This plan is being
resisted by the review agencies.
A satisfactory solution appears to be
disposal in the Gulf.
Acceptable spoil sites in Mississippi Sound
for the navigation channels to Pascagoula
and Biloxi are in the planning stages.
114-
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Solution -
Kentucky
Problem -
Disposal in the Gulf or near-shore shallow
waters of the Sound.
Freshwater wetland areas are used as spoil
disposal areas. The loss of wetlands is
proceeding at a rapid rate. Big Sandy
drainage has problems with coal dredging in
the river and disposal of the resulting
dredge material.
115
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HAZARDOUS WASTE—RCRA
1. Overview
The hazardous waste regulations are issued under the
authority of the Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act of 1976 (RCRA).
Subtitle C of RCRA establishes a federal program to provide
comprehensive regulation of hazardous waste. RCRA directs
EPA to identify the characteristics of, and to list, those
hazardous wastes which are subject to regulation. RCRA also
requires EPA to establish standards for generators, trans-
porters and treatment, storage and disposal facilities of
hazardous waste, which will ensure proper handling of
hazardous waste. For those states interested in administer-
ing the RCRA program instead of EPA, the regulations issue
guidelines under which states may seek authorization to
carry out the program. Finally, all persons engaged in
activities subject to RCRA regulations must notify EPA or
states having authorized RCRA hazardous waste programs.
Region IV has maintained an aggressive RCRA program in
delegation of authority to the states (Figure R-1). All
eight states in Region IV have Phase I Interim Authoriza-
tion. Five states have been delegated Phase II Interim
Authorization, Components A and B. Although it will take a
great deal of effort and commitment by both EPA and the
states, it is expected that seven states will receive Phase
II, Component C, sometime in 1983 and all Region IV states
will be granted Final Authorization by early 1984. To
achieve that optimistic prediction, there are a lot of
hurdles to overcome.
The approval process which the agency has adopted
requires multiple networking and crosswalking coordination.
The review and approval process is cumbersome and time-
consuming. Legislative changes and regulatory changes are
very difficult to achieve in these austere budget settings.
Many states have hiring freezes which do not allow them to
achieve the resource levels which were predicted.
These problems result in a slowing of the authorization
process which in effect increases the workload on the EPA
staff. The process of Final Authorization is expected to be
slower and more cumbersome than the interim process due to
the finality of the agency's decision.
The Agency's groundwater strategy must encompass and
embrace the RCRA permit program. These permits for land
disposal facilities are a principal part of protecting the
groundwater resources of the region. The states will
administer the RCRA permit program in the Southeast; how-
ever, they are dependent upon EPA for financial assistance,
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technical assistance and as a mainstay in difficult enforce-
ment areas. The EPA laboratory support is also the founda-
tion upon which state laboratory support builds. States
rely upon the EPA laboratory for quality assurance, training
and evaluation of new procedures and methodologies.
Figure R-2 shows a large degree of compliance with 265
requirements by the Treatment, Storage, and Disposal Facili-
ties (TSDFs). Some exceptions to the compliance are ground-
water monitoring and financial assurance. These areas are
receiving increased emphasis by the state programs during FY
83. The states have realized that many of the real environ-
mental problems will be highlighted by the groundwater data.
The financial assurance regulations have not been in effect
long enough in most states for them to know the degree of
compliance. They are aggressiv.ely receiving the submission
and working through their compliance staffs to achieve a
high degree of compliance. The states recognize the impor-
tance of having the financial resources available should
environmental problems develop in the future.
The permit program is in its infancy. The numbers of
true TSDFs which need a permit are far less than the present
data base indicates. The part B call letters to date have
resulted in a high drop out rate. As the calls proceed, the
regulated community will have to address the questions which
require them to decide if they in fact want and need a
permit (Part B preparation cost,, financial assurance cost
and liability for post closure).
The permit applications received have to date been of
poor quality which increases the review time. This is
further addressed under problem areas.
The Act, the Agency and the States anticipate improved
air, surface water and groundwater quality as a result of
the RCRA regulatory program. This premise cannot be quanti-
fied at this time because of the lack of a good data base.
Progress will become measurable as the complete inventory is
developed of the regulate community and the types and
volumes of waste generated, transported, disposed, treated,
and recycled. The data from the permit application will be
needed as well as the historical compliance data to accur-
ately measure the total environmental effect.
As the program proceeds, it will develop into actual
measures of progress and quantifications.
IZO
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2. Problem Areas
a. Regulations
From the experience in regulating hazardous wastes
under the present RCRA regulations, several areas where the
regulations do not adequately address the problems encoun-
tered have been identified.
(1) Synfuel Facilities
One area of concern in Region IV is the impact on
public health and the environment created by wastes from
synfuel facilities. The wastes generated at these facil-
ities are in large volume and contain many organics, some of
which are carcinogenic. Much of the solid waste from these
facilities is included in the Congressional exemption for
mining waste and thereby in the RCRA regulation at 40 CFR
§261,4(b)(7).
Of the twelve major synfuel facilities planned for the
region, four are located within a 40 mile band along the
Ohio River in Kentucky. The solid wastes containing toxic
organics, and the air emissions from these four facilities
plus five additional conventional coal fired generating
plants existing or planned for the same 40 mile band provide
the potential for the development of significant public
health and environmental problems. More information is
needed on the hazards associated with synfuel wastes.
Should these wastes be fully regulated by RCRA?
At present, as solid wastes only, these and the large
volumes of wastes from coal fired plants are regulated by
the states using state resources. The large volume of fly
ash produced at coal fired plants is exempt from being a
hazardous waste by 40 CFR §261.4(b)(4).
(2) Hazardous Air Emissions
Air emissions from hazardous waste facilities in the
form of volatile organics and gases are a problem at facili-
ties with surface impoundments, land treatment facilities
and open tanks. The regulations do not address low concen-
tration nor do they provide adequate methods for estab-
lishing non-compliance.
(3) Recycling
A number of facilities that recycle or reuse hazardous
wastes have, in the past, caused significant damage to the
public health and the environment. Under the present
regulations, many of these facilities can store hazardous
wastes that are hazardous by characteristics only for an
unlimited time without having to meet any RCRA standards.
Ill
-------
The new definition of solid waste may address this problem,
but until the regulations are changed, a large inconsistency
exists in the regulations.
(4) Burning Hazardous Waste as Fuel
If a waste is burned as a fuel, it is exempt from the
definition of a solid waste (40 CRP §261 .2(c)(2)). At
present, EPA has no definition of a fuel. A waste that is
ignitable and toxic can be burned for "energy recovery"
without having to meet any standards under RCRA for toxic
emissions. Most of the toxics produced are not addressed by
either the Clean Air Act or any state air pollution laws.
b. Growth and Waste Generation Increase
A recent study, The Southern Regional Environmental
Assessment, Environmental Status Report, Volumes II and III,
predicts that industrial production in the sunbelt (Region
IV) will increase substantially by the year 2010. The
greatest increase is projected in major hazardous waste
producing industries (Table R-1). With the increase in
production, an increase in hazardous waste generation is
projected. This increase translates to the potential for
greater and more environmental problems in the Southeast.
Furthermpre, this increase in hazardous waste generators
will necessitate increase in state and regional efforts to
protect the groundwater in the region. Groundwater is one
of the Southeast's most important resources. In 1970, 70
percent of the population in the Southeast obtained drinking
water from groundwater sources. Protecting this resource is
vital now and in the future (see the Groundwater Section).
(1) Small Generators
Along with the increase in large generators of hazar-
dous waste is an expected increase in industries generating
less than 1000 kg of hazardous waste per month. These
industries can dispose of their waste in state approved
solid waste landfills. This and the projected increase will
put an additional burden on the state disposal facilities.
As the RCRA regulations are implemented, industries seem to
be switching to off-site disposal methods. This increases
the need for new off-site disposal facilities. In siting
hazardous waste and solid waste disposal facilities, much
public opposition is generated.
(2) Public Opposition
Intense public opposition has blocked siting of new
hazardous waste management facilities, forestalled expansion
of existing facilities, and, in several instances, caused
operating facilities to be closed. A study on the capacity
of the hazardous waste management industry concluded that
JZZ
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public opposition was the most critical factor affecting
future capacity (Booz Allen Hamilton, and Putnam, Hayes &
Bartlett, 1980, p. VI-1). Dealing with this opposition is
very resource intensive at both state and federal levels.
At the Regional level at least two workyears are devoted to
giving technical assistance to the state solid waste program
and responding to the public's information requests, ques-
tions, letters and complaints on solid waste collection,
transportation and disposal. A program of public relations
and education would reduce some of the opposition and the
resulting burden on state and federal resources needed in
issuing a permit.
(3) Solid Waste (Non-Hazardous) Disposal
The increasing population in the Southeast, as well as
increasing industrial production, brings -significant
increases in non-hazardous solid waste generation. These
wastes must be safely disposed after collection. The
predominant disposal method in the Southeast is still
landfilling. The trend of cities, counties and other local
authorities responsible for solid waste management is to
wait until the situation becomes a crisis before taking
positive action due to public opposition to landfill siting.
The siting of landfills for non-hazardous solid waste
is a drain on regional resources although the Region has no
resource allocation for this task. The Region must respond
to complaints, congressional questions and requests for
information.
(4) Recycling and Waste to Energy
The Agency has ceased to provide any leadership in the
area of recycling solid wastes or waste to energy. States,
while supportive of these efforts, do not have the resource
expertise or legislative charge to provide this leadership
in most cases. The impetus for these activities should be
provided at the national level. This could be in the form
of financial assistance to states to develop recycling
programs or to maintain and expand existing programs.
(5) Large Commercial Land Disposal Facilities
The two large commercial land disposal facilities in
the Region accept large quantities of hazardous waste from
all over the nation. The host states, Alabama and South
Carolina, expend considerable resources in regulating these
facilities. The present grant formula does not take this
extra workload into account. Along with the increase in
workload at the facilities, the facilities create additional
problems associated with increase in transportation of waste
and the potential for accidents. Citizen concerns about the
12.3
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groundwater and surface water contamination for these
facilities result in a substantial increase in workload for
the state regional staff.
c. Emerging Problem Areas
(1) Annual Report
In determining workload, resource allocations and
trends, it is important to know the type, quantities,
distribution, and method of handling and disposal of wastes
across the country. This was the purpose of the annual
report for generators and TSD's. All of the Region IV
states are requiring an annual report. Most were requested
to do so by their state legislators in order to have better
data to allocate resources and assess the need for new
legislation. Annual submissions are expected to continue to
be required by the states which creates confusion when EPA
requires bi-annual reports. The annual report should be
retained.
(2) Groundwater
In the area of groundwater monitoring and groundwater
monitoring reports, several problems exist. Facilities have
been monitoring the groundwater for only one year and the
data are just coming in to the states. Therefore, we cannot
know yet what contamination problems exist at the majority
of the land disposal facilities. At facilities where
obvious groundwater contamination exists, corrective action
has been initiated. But there are a very limited number of
the total facilities subject to groundwater monitoring.
Additional facilities with groundwater contamination are
certain to be found. Adequate data to make that deter-
mination do not exist at this time. An additional problem
is quality control of all aspects of the groundwater moni-
toring program. There is no provision in RCRA or state law
for regulation requiring quality control (i.e., state
monitoring of well installation) nor is there any provision
for requiring quality control of the sampling analyses of
the groundwater samples. The data obtained may not be
adequate for use in permit application or any enforcement
actions. There is a need for additional regulation in this
area.
(3) Training of State Personnel
Training of state personnel is an area not adequately
addressed in the RCRA program. Most of the state programs
and personnel are new and not familiar with the complex
hazardous waste program. Training given at the state level
only gives the employee a view of the state program. It is
important for all state hazardous waste personnel to have an
understanding of the federal program. Unlike the Clean
12-4
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Water Act, RCRA has no treatment plant operator training.
Some provision should be made to develop training for state
personnel by EPA on all aspects of hazardous waste manage-
ment. This could be done through the state grant.
(4) State Authorization
The final authorization process may be long and diffi-
cult and consume many workyears of effort, not only at
Headquarters and state levels, but especially at the region-
al level. In order to meet the January 1985 deadline for
final authorization, work has already begun in earnest at
the state and regional levels to identify and notify states
of any and all problems that must be corrected in order to
receive final authorization. The actual application review
process will take at least 270 days if no major problems are
encountered. This means January 1984 is when application
should be submitted to EPA. With some state legislatures
meeting only once every two years, the states will have only
one chance to get any needed changes through the legisla-
ture. The possibility definitely exists for states to lose
their authorization because of failure to receive final
authorization by the statutory date.
Many problems can develop at the state level that may
delay or^ prevent them from receiving final authorization.
Obtaining agreements from other state agencies is often a
problem. Obtaining commitments from the State Attorney
General is very often a major stumbling block.
At the regional level, the workload associated with
coordinating the review of the states' applications by the
Region and Headquarters review teams, negotiating solutions
to the problems encountered, and coordinating with the
states on any revisions needed will be a monumental task
requiring many workyears of effort per state.
The following is a brief description of possible
impediments each state in Region IV may experience in
obtaining final authroization of the RCRA program:
Kentucky
Kentucky is experiencing problems with two statutes -
special waste and confidentiality. These problems must be
remedied for the January 1984 legislative session. This
places Kentucky on a restrictive schedule for final author-
ization.
Tennessee
Tennessee also needs statute revisions in the following
areas:
Increase penalties to at least $10,000
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Allow for citizen intervention
Authority for Liability Insurance
Revise TCA 6305(c) regarding air and water
pe rm i t s
North Carolina
North Carolina is introducing legislation to allow for
citizen intervention during the January 1983 session. If it
passes, there should be no obstacle to receiving final
authorization.
South Carolina
South Carolina intends to introduce new legislation and
revised regulations in the January 1984 session - this will
put them on a tight schedule for receiving final author-
ization.
Florida
Present state statute may require a change. It has
been determined that the 90-day "Permit by Default" provi-
sion is a problem. The state program cannot be delegated
Phase II until that provision is changed. Also, because
Florida'.s financial requirements will not be effective until
July, they may not be able to get Phase II until that time.
For final authorization, the 90 day "Permit by Default"
is also a question that must be answered. An additional
problem is an EPA requirement that the landowner as well as
the operator sign RCRA permit applications. Florida has a
waiver provision in this area, EPA does not.
Georgia
Georgia is adopting federal regulation by reference,
and recent amendments to the state rules should qualify the
state for final authorization.
Mississippi
No problems are expected in granting Mississippi final
authorization.
Alabama
Alabama has failed to pass legislation to regulate
railroads in a manner equivalent to the federal program. As
yet, Alabama has not enacted all financial responsibility
regulations, and must adopt the land disposal regulations.
Also, Alabama statute S-22-30-12(c)(1) states that permit
applications must be approved or disapproved within 90 days.
-------
Thus, they may be forced to issue permits by default if the
permit process cannot be completed within 90 days. This
problem must be resolved prior to final authorization.
Should the Alabama legislature reject the repeal for
the 90 day default permit, EPA would be required to assume
authority for the total RCRA program. The environmental
impact of this situation would be a longer period of time
for these TSDF's to be under interim status, because the
permits issuance would be delayed. This could translate
into additional groundwater problems developing as well as
public exposure to air emissions.
(5) Small Quantity Generators
Along with the resource problems at the state level
mentioned above, small quantity generators create additional
problems. The major problems are lack of knowledge about
how much waste is generated and where it is going for
disposal. The disposal of one thousand kg of hazardous
wastes every month by a number of industries into the same
municipal landfill is creating the potential for severe
environmental and human health problems.
All Region IV states feel additional control of the
small quantity generators of wastes is needed. They have
addressed the problem in several ways. All eight states are
using their solid waste laws to control these wastes to the
extent possible under their laws. However, several states
have felt the need for additional control under their
hazardous waste regulations. This ranges from requiring
notification to reducing the small quantity limit to one
hundred kg/month.
(6) Permit Application Quality
Region IV has called 123 storage Part B's and 11
incinerator Part B's as of February 1, 1983. Review accom-
plished to date on these applications has indicated a
substantial lack of understanding of the regulation of lack
of managment emphasis at the corporate level. These appli-
cations have substantial areas where the information is
missing and/or the information is of quality so poor that it
is inadequate for use in issuing a permit.
The net effect is a heavier workload for the Regional
staff through review and response, technical assistance
and/or enforcement to get an application which is of the
quality needed to enable the staff to prepare a draft permit
and fact sheet.
Leadership at the national level is needed to: 1)
impress industry with the need for the type and quality of
information needed in a permit application; and 2) to
11
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impress industry that submission of a complete and adequate
permit application is mandatory and failure to submit an
adequate application is grounds for enforcement action
and/or permit denial.
(7) CERCLA Remedial or Planned Action - RCRA
Permits
CERCLA remedial and planned actions at sites can
involve the same activities which require permits at active
RCRA facilities. Do federally funded, state, or privately
funded activities at CERCLA sites require RCRA permits? The
Agency has not resolved this issue to date.
The implications are significant in terms of workload
for regional and state permitting staff. Conflicts arise
between cost effectivenesss and the RCRA standards. Poten-
tial resource drains, such as responding to public comment
if permits are required, must be considered during policy
discussions.
(8) Permitting Land Disposal Facilities
Although the land disposal regulation went into effect
January 26, 1983, Region IV anticipates significant problems
in getting good quality, complete land disposal permit
applications. The regulated community does not have a good
understanding of these regulations and to date we have not
seen the effort needed from the national program to assist
industry in understanding the requirements so they can
prepare a complete and useable Part "B" Permit Application.
Significant technical and time consuming enforcement
problems with public opposition are anticipated before these
permits are issued. Issuing these permits may be a lengthy
process.
3. Implications for Agency Management
The issues in Region IV are arranged below according to
degree of impact in regional resources and their impact in
human health and the environment. The issues are arranged
in descending order of importance to the region.
a. Barriers
(1) Population and Industrial Growth in the
Region
The predicted increases will necessitate additional
resources. If these resources are not available, the Region
will not be able to handle the additional workload. Work-
load models should reflect growth.
17.8
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(2) Groundwater Data
The Agency needs to develop procedures and regulations
to insure reliable groundwater monitoring data to be col-
lected and reported by the TSD's. Lack of reliable data
will hinder our timely issuance of land disposal permits,
and increase the workload associated with permitting.
Because of the uncertainty of the methodologies used to
determine when a facility caused groundwater contamination
to exceed background levels, enforcement based on the 265
standards which require correction by the facility may not
be timely.
Some states have groundwater standards which can be
independently enforced, but most follow EPA's lead.
(3) Burning Hazardous Waste as Fuels
More emphasis should be put on developing a workable
regulatory definition of a "fuel". The present lack of
regulations forces the regional staff to make time consuming
case-by-case determinations based on best professional
judgment. Recent guidance has helped, but regulations must
be updated.
The" burning of halogenated compounds with no regulatory
controls exposes the public unnecessarily and degenerates
the environment. Region IV recognizes the goal of beneficial
reuse but cannot sacrifice environmental quality for
energy without assessing the cost.
(4) Permitting Land Disposal Facilities
Because of public opposition and industries' lack of
understanding of the land disposal regulations, the regional
permitting workload will be increased. Additional resources
will be needed in the Permitting Section.
(5) State Authorization
The long and difficult process of final authorization
will be very resource intensive at the regional level.
Region IV feels that more resources are needed in this area
to make maximum effort towards meeting the January 1985
deadline for final authorization as provided for in RCRA.
(6) Recycling
The regulations are inadequate in this area to control
recycling activities that have caused problems in the past.
Many recycling activities that are legitimate and beneficial
12.9
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with little potential for damage are being over-regulated.
More Headquarters resources should be devoted to revising
this area of regulation.
(7) Permit Application Quality
Poor quality of the Part "B" application is creating an
additional workload for the regional and state permit staff.
More emphasis needs to be placed on training for industry,
and on impressing upon the regulated community that submit-
ting a good quality Part "B" is mandatory.
(8) Solid Waste (Non-Hazardous) Disposal
The siting of landfills for non-hazardous solid waste
is a drain on regional resources, although the Region has no
resources allocated for this task. Resources should be
shifted to this area.
(9) CERCLA Remedial or Planned Activities
Do activities at CERCLA sites require RCRA permits?
The agency has not resolved this issue. Implications are
significant in terms of workload for regional state permit-
ting staff.
•*
(10) Hazardous Air Emissions
When air emissions occur at hazardous waste facilities,
the current regulations do not provide adequate methods to
establish non-compliance. Headquarters' resources should be
shifted to address this area. Regionally, making case-by-
case judgements is consuming additional resources.
(11) Small Quantity Generators
This regulation can allow large total amounts of
hazardous waste to be disposed of in non-RCRA, inadequately
designed disposal facilities. The regulations should be
modified to provide greater control of these wa.stes.
(12) Synfuel Facilities
Exemptions in the regulation for many of these wastes
may be adding to potentially hazardous situations. Addi-
tional resources to study the hazardous characteristics of
these wastes should be shifted to this area. The exemption
impacts heavily on state resources.
(13) Training of State Personnel
To insure consistency across the Region and the coun-
try, EPA training in all aspects of the RCRA program should
be given to all state hazardous waste personnel. At pre-
-------
sent, the regional staff has to try to coordinate all the
state programs. This is an additional workload where
resources are not allocated.
(14) Annual Report
Retention of the annual report requirement will provide
much-needed data that can be used to allocate resources and
assess needs for new regulations or legislation.
(15) Support of Recycling Activities
The Agency has ceased to provide any leadership in the
area of recycling of solid waste to energy. This is a
fundamental part of RCRA. Region IV is of the opinion that
the impetus for these activities should be at the national
level.
(16) Large Commercial Land Disposal Facilities
Region IV1s two very large commercial hazardous waste
landfills drain the host states'(South Carolina and Alabama)
resources and the regional resources inordinately. The
Subtitle C grant formula should give some consideration to
this resource drain for these states.
b. " General Conclusions and Recommendations
(1) The Agency must continue to stress the
development of additional regulations and the regulatory
amendments needed to implement the program.
(2) The Agency must provide clear and consistent
regulatory requirements.
(3) The Agency should look at growth and growth
potential indication for use in resource distribution among
regions.
(4) The Agency must address the public opposition
to commercial hazardous waste facilities (landfills, incin-
erators, and processing/storage facilities). The economy of
the nation, the health of the population, and the environ-
ment depend upon these facilities.
(5) In support of number 4 above, the Agency
should emphasize recycling and reuse through tax incentive
and publicize good recycling and reuse technology which
results in decreased need for disposal.
-------
(6) The Agency needs to address the training
needs for state programs through the National Governor's
Association and the Association of State and Territorial
Solid Waste Management Officials, and provide national
leadership,
(7) The Agency should decide if RCRA permits are
needed for CERCLA activities.
(8) The Agency should publicize its dissatis-
faction with the quality of the RCRA permit applications
received to date and let industry know this will not be
tolerated.
I3Z
-------
TABLE R-1: GROWTH PROJECTIONS FOR MAJOR HAZARDOUS WASTE
GENERATORS
Projected Growth
(earnings — millions of dollars)
Industry
Chemical and
Allied Products
Stone, Clay, and
Glass Products
Fabricated Metal
Petroleum and
Coal Products
Textile Mill
Products
Primary Metal
j>
1978
2,509
766
1 ,764
124
4,391
1 ,590
2000
5,816
2,941
4,811
412
7,222
3,804
2010
7,738
4,015
6,593
571
8,962
5,095
% Change
1978-2010
+ 208
+254
+ 273
+360
+ 104
+ 220
Calculated from U.S., Dept. of Commerce, BEA, 1980. This
data is'taken from Tables 4-3 and 4-4, Chapter 4, of this
report. Figures are millions of 1972 dollars.
/33
-------
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-------
HAZARDOUS WASTE—SUPERFUND*
1. Site Screening of Inactive Disposal Sites
a. Performance and Trends
The Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA, also called "Superfund")
provides for response to a hazardous substance release in
order to protect the public health, welfare, or the environ-
ment. Either the responsible party or the government will
provide proper response to the release. Identification,
assessment and hazard ranking activities by Region IVs Site
Screening and Engineering Section (SSES) has resulted in
2,978 sites for the ERRIS tracking system (19.3% of the
national total of 15,457), and 48 inactive disposal sites on
the Proposed National Priority List (NPL).
The projected distribution of site assessments in
Region IV for each State is presented in Figure S-1. It is
possible that highly hazardous sites will be uncovered as
on-site inspections are conducted by states over the next
two years. Developing background material on these sites
for the NPL will put a demand on the site screening and
assessment workload. A rough estimate would indicate that
10-12 additional sites are likely to be proposed for the NPL
in FY '84.
b. Emerging or Remaining Problems
(1) State Participation in Program
The management philosophy adopted during implementation
of CERCLA has involved consolidation of decision making
authority at Headquarters, hierarchical review and overview
of Regional recommendations, and direct involvement of
Headquarters Staff in specific activities. This has diluted
the Regional role as principal contact point for the state
agencies, and exacerbated traditional reluctance to partici-
pate compliantly in Federal programs, with the result that
Regional ability to elicit state participation in the CERCLA
progam has been inhibited. Note also that there is no
provision in CERCLA for delegation of the program to the
states, as in other laws administered by EPA. Unless
Regions are delegated greater authority to initiate action,
and a clearer policy of pressing the state agencies to
participate is forthcoming, the reluctance by states to
participate in a non-delegated Federal CERCLA compliance and
enforcement program will be even greater than in the past.
-------
Because of the rapidly developing Superfund policy in
the Agency, many of the suggested changes in this write-up
are now being addressed. This discussion was written prior
to the initiation of the recent Superfund policy changes.
(2) Cost Recovery Action Guidance
In the near future, the pursuit of cost recovery
actions to recover monies disbursed from the Fund for
investigation and remedial action will become a significant
activity. There is, as yet, no adequate guidance defining
(1) the types of costs which are recoverable, (2) how
recovered monies will be distributed between states and the
Fund, (3) how expenditures and environmental improvements
are to be documented in order to demonstrate cost-effective-
ness of remedial work, (4) how costs are to be assigned or
distributed among multiple responsible parties, and (5) what
standards of proof are to be met.
(3) Management Data Collection
Following promulgation of the National Priority List
there has been significant management attention focused on
the "Responsible Party Search" as a measure of progress.
This may not be an appropriate parameter, since the identif-
ication pf responsible parties is a continuing process
through the entire life of the project, and is often most
fruitful after specific compliance actions are initiated.
Virtually every site has a responsible party search initiat-
ed; few are completed at the time management data are col-
lected. Furthermore, management data are presently collect-
ed in a piecemeal fashion by separate staff sections, appar-
ently without use of the ERRIS or PTS Systems developed for
the purpose. This results in redundant reporting by the
regions and introduces the possibility of discrepancies in
data reported to the separate systems.
2. Remedial Action
a. Performance and Trends:
Region IV has 11.5% of the Nation's total 418 inactive
disposal sites on the National Priority List Placement on
the NPL urges a response to every one of the listed sites,
whether by a form of enforcement or fund-financed cleanup.
Of the 48 Region IV sites, enforcment is pursuing cleanup at
30 (or 62.5%) of the sites, while fund-financed cleanup is
being actively pursued at 7 or (14.6%) of the sites.
Because states must provide cost sharing for remedial
activity at a listed site, six of the sites (or 12.5%) are
being held back by the states because of a lack of funding.
The following chart, titled "Action Taken in Region IV NPL
Sites," highlights the activity at each respective site.
137
-------
As work on hazardous sites has commenced over the past
years, it has become evident that a great deal depends on
the data gathered at each uncontrolled site. There is a
significant lack of information concerning acute and chronic
hazards of many abandoned chemicals. Further, there is
little correlation between the toxicity of specific chemical
and hazards to the public health. The question of how clean
is clean depends on the interpretation of the data and the
long-term public health effects of residual site materials.
This public health issue can lead to difficulties in public
relation programs. The government is required to deal
effectively with each community for funded site work,
however, private parties are not required to initiate public
relations programs. This has resulted in lack of public
participation in cleanup alternatives and lack of knowledge
regarding progression of work.
b. Emerging or Remaining Problems
(1) State Matching Funds
The cleanup of sites on the National Priority List has
been slowed in Region IV by the requirement for state
matching funds throughout the process.
Currently, five of the eight States in Region IV have
no mechanism to create a fund for use at these sites and,
therefore, must appeal to their legislatures for funding.
Throughout the Region, as well as the Nation, the economy
has made it very difficult for the States to find the
necessary dollars within their limited budgetary con-
straints. The States which have created funds are:
Florida, whose legislature created a $600,000 fund to use as
State match; Mississippi, which has developed a penalty fund
which presently has less than $50,000 available; and
Kentucky, which has collected about $200,000 by taxing
generators. Alabama recently set aside $510,000 in their
FY-84 budget as a contingency fund for cleanup activities.
These schemes are functioning, but appear to be inadequate
in the magnitude of funds which they have yielded.
The states of the Region are not insensitive to the
hazards associated with the listed sites, however, budgets
are planned, other expenditures hold a higher priority.
This dilemma could be alleviated to some degree by removal
of the requirements of matching funds for remedial invest-
igations and/or feasibility studies. This would yield
immediate results in that more sites would proceed through
these preliminary steps. Requests for funds from state
legislatures could then be based on "harder" figures.
Direct taxation and penalties (user taxes) continue to
be viable means of funding, but other states should consider
special bond issues, special tax schemes or any of the other
-------
funding mechanisms available to the states. If Superfund is
to complete its mission, the cooperation of the states is
imperative. They will have to come forward with funding
from some source.
(2) Timeliness of State/EPA Cleanup Agreements
Another problem inherent in all cases is the amount of .
time involved in putting together an enforcement agreement
or the contract between a state and EPA for fundng a reme-
dial activity. Discussions with responsible parties can be
delayed for various reasons, such as additional time for
scope of work preparation, wording of the Order, and the
need for getting together of many generators.
Some of this time could be shortened by concerted
attention to deadlines and up-front negotiations. Remedial
contracts between the state and EPA undergo extensive
reviews at the state, regional, and headquarters level. The
review process takes at least two weeks at each level for
both the draft and final agreement. The time factor is a
pressing issue now that the legislation has less than three
years before sunsetting. On an average, it takes 3-4 years
from project initiation to completion, when all phases of
work are involved. Superfund PERT charts at the end of this
section reflect timelines for fund-financed cleanups at 21
sites. 'Negotiation with responsible parties is not included
and could extend the process significantly.
(3) Groundwater Exposure
Table S-2, entitled "Matrix of Problems at Region IV
NPL Sites," and accompanying map indicate the groundwater
exposure at most of the NPL sites. In the southeast, most
drinking water comes from shallow aquifers, so it is criti-
cal to protect. Also the aquifer characteristics are some of
the criteria used for evaluating cleanup alternatives.
Long-term protection of the groundwater can determine a
choice between on-site containment and off-site action.
3. Classical Spills - Immediate and Planned Removal
a. Performance and Trends
Over 2,000 spills of oil and/or hazardous substances
occur in Region IV annually which must be dealt with by
Region IVs Emergency Response and Control Section. In
addition, four removals - three immediate and one planned -
were completed during the past year. One planned and two
immediate and/or planned removals are projected for the
remainder of FY-83. Figures S-3 and S-4 respectively
reflect the number of spills reported to EPA during the
period 1975 to 1982 and the volume of oil and hazardous
substance spilled for the same period.
139
-------
Emerging and remaining problems for this aspect of the
Superfund program concern (1) resource difficulties for
implementation of CERCLA response requirements, (2) techno-
logical problems (3) inadequate training of local respond-
ers, (4) lack of adequate laboratory support, and (5)
reporting problems.
b. Emerging and Remaining Problems
(1) Resources
Under CERCLA, the Emergency Response Section is mandat-
ed to undertake response activities related to "immediate"
and "planned" removals of hazardous wastes from uncontrolled
sites. Preparation, response and documentation phases of
such activities require intense personnel commitments from
this Section. Figure S-5reflects the significant amounts of
material disposed of during these immediate and planned
removals.
Inspection of oil storage facilities pursuant to 40
CFR, Part 112 currently requires extensive on scene activity
due to more sophisticated and complex engineering plans
developed by owner operators in recent years. In 1975, an
EPA inspector could perform ten inspections per eight hour
day, however, in 1983 he can at best perform 2.5 inspections
per day. Further, there are at least 15,000 facilities in
Region IV that have not been inspected or need additional
inspections.
An emerging problem in this Region has been complex
leaks from networks of underground storage tanks containing
gasoline or certain hydrocarbon related chemicals. It is
estimated that in the state of Florida alone, thousands of
such leaks are in progress. The complexities of these leaks
involve widespread ground and surface water contamination,
as well as the potential hazard of explosion when the leaks
enter the sewer system. Because of their frequent occur-
rence and technically difficult nature, these incidents
require extensive testing, monitoring, eventual corrective
actions and cleanup of contaminated soil and/or ground or
surface waters. Usually a long residence time on scene by
an EPA coordinator is needed to complete monitoring of
testing procedures and corrective action. Further, special
skills such as hydrology, geophysics, geology and structural
engineering are needed to make meaningful responses.
(2) Technology
Increased response work with hazardous waste site
cleanup and classical spills demands essential technology
for each phase of response. Lack of an aggressive research
and development program and budgetary constraints have
/40
-------
severely impaired completion of ongoing projects with direct
relation to emergency response. Such abandoned projects are
development of portable incinerators and off shore platforms
for incineration.
(3) Training of Local Responders
During the past several years, the pressing need for
training of first responders to handle emergency spills/re-
lease of chemical substances has become evident. This
Region receives numerous requests from fire departments and
local government agencies for training on response manage-
ment techniques, safety and other concerns related to
chemical releases. Some Regional program work has been
developed to coordinate, or "package", many of the available
"responder courses" for reference use by interested parties.
In addition, training packages to be developed using Region
IV expertise have been proposed. If first responders are
properly trained and educated, exposure to the public and
the environment can be drastically reduced.
The National Contingency.Plan calls for the development
of state and local contingency plans. The development of
local plans will depend greatly on the training of those
preparing the plan. Anyone not familiar with coordinating
emergency response efforts will experience difficulty in
preparing a complete contingency plan. Again, the training
need in Region IV exists and is definitely increasing due to
federal budget cuts that will ultimately affect state and
local budgets.
(4) Inadequate Laboratory Support
Currently, Region IVs laboratory support program
consists of contract personnel who retrieve proper water
samples and perform limited air monitoring during emergen-
cies. This support, both in-house and by contract, is
inadequate for emergency analytical requirements. An
average turn around time of 45 days is the rule rather than
the exception. This is unacceptable during emergencies.
(5) Reporting Problems
Latest data suggest that during FY 80, 81, and 82,
Region IV was notified of fewer than 50% of the emergencies
which occurred in the eight southeastern states. Although
the National Contingency Plan, the National Response Center
and the Regional Response Center provide smooth and coor-
dinated mechanisms for reporting procedures, failures in
reporting can be attributed to the lack of comprehensive
state and local contingency planning. In an attempt to
remedy this problem, regional personnel have recently
traveled to each state to discuss reporting deficiencies.
-------
Table S-1
Action Taken at Region IV NPL Sites
Site Name
Remedial Feasibility Remedial
Investigation Study Design Action
Triana, AL
Schuylkill Metals, FL
Pickettville Rd .
Landfill, FL
Davie Landfill, FL
Gold Coast Oil, FL
Alpha Chemical, FL
SCRDI, Bluff Rd., SC
A. L. Taylor, KY
N. Hollywood Dump, TN
PCB Spills, NC
Plastifax, MS
Mobray Engineering, AL
Miami Drum, FL
Kassouf-Kimerling, FL
Whitehouse Oil
Pits, Fl
Pioneer Sand, FL
Reeves SE
Galvanizing, FL
Martin Marietta, NC
Z ell wood G/W
Contamination, FL
Taylor Rd. Landfill, FL —
NW 58th St., FL
62nd St. Dump, FL
Velsicol Chemical, TN
Sapp Battery, FL
Murray Ohio Dump, TN
Coleman-Evans , FL
Florida Steel , FL
Brown Wood Preserving, FL-
Hollingsworth, FL
Varsol Spill, FL
SCRDI, Dixiana, SC
American Creosote, FL
Sherwood Medical, FL
Lee's Lane Landfill, KY —
Tower Chemical, FL
Newport Dump, KY
Distler Brickyard, KY
2 _
3
1
3
3
3
5
2
5
1
6
5 _ _ _ __
2
5
3
3
1
3
o ______
o
3 -"-"
1
5
3
2
3
6
3
3
6
4
-3
3
2 — —
3
6
- 2
- 3
. 1 1
- 3
. 3
- 3
. 5 5
__ — 5 — — -
- 2
. 5 5
- 1
- 6
. 5 5
- 2
- 5
- 3
- 3
- 1
3
3
3
3
1
5
3
2
3
6
3
3
6
4
3
3
2
3
6
1
1
5
5
5
c
Key:
1
2
3
4
5
6
Voluntary Agreement
Compliance Agreement
Pursuing Enforcement
Superfund State Contract (EPA Lead)
Cooperative Agreement (State Lead)
Holding for State Prioritization
-------
Cont'd Table S-1
Remedial Feasibility Remedial
Site Name Investigation Study Design Action
ttirco, R.I
Parramore Surplus, FL —
Perdido G/W
-3 _
_ A
-3
-3
6_ _
— 7 — —
1 _
_ 7
o
3___ ___ _ ______
_ _ -3
-3
_ _ "3
-3
__ 1
7
Key: 1 - Voluntary Agreement
2 - Compliance Agreement
3 - Pursuing Enforcement
4 - Superfund State Contract (EPA Lead)
5 - Cooperative Agreement (State Lead)
6 - Holding for State Prioritization
143
-------
Table S-2
Matrix of Problems at Region IV NPL Sites
Ground Surface Fire & Direct Ranking
Site Name Water Water Air Explosion Contact on NPL
Triana, AL 35.92 — 100
Schuylkill Metals, FL - 100 — 21.82
Pickettville Rd. Landfill,
— 18.18
Davie Landfill, FL 100 — 4.36 55
Gold Coast Oil, FL 100 56
Alpha Chemical, FL 96.15 — 5.24 63
*SCRDI, Bluff Rd., SC- 61.22 — 13.99 — 51.15 - 63.33 37.5 78
*A. L. Taylor, KY 28.57 — 10.9 93
*N. Hollywood Dump, TN-26.53 — 10.9 20.8 94
*PCB Spills, NC 25.27 — 12.87 87.5 95
*Plastifax, MS 25.13 — 9.4 29.16 97
Mobray Engineering, AL-92.31 — 10.06 50
Miami Drum, 92.31 8.06
Kassouf-Kimerling, FL—89.8 — 21.82
Whitehouse Oil Pits,
FL 89.45 — 14.55 114
Pioneer Sand, FL 88.45 — 16.08 119
Reeves SE Galvanizing,
FL 88.46 — 16.08 120
Martin Marietta, NC — 69.07 — 57.44 125
Zellwood G/W
Contamination, FL — 89.8
Taylor Rd. Landfill,
FL 88.46 8.58
FL 84.62 — 10.26 144
62nd St. Dump, FL 83.67 — 14.54 37.5 145
Velsicol Chemical, TN- 79.59 — 21.82 25 158
Sapp Battery, FL 79.59 — 21.82
Murray Ohio Dump, TN - 79.59 — 10.91 37.5 177
Coleman-Evans, FL 79.43 — 8.58 178
Florida Steel, FL 77.82 16
Brown Wood Preserving,
FL 76.92
Hollingsworth, FL 76.92
Varsol Spill, FL 76.92
SCRDI, Dixiana, SC 70.0
American Creosote, FL- 69.23
Sherwood Medical, FL - 68.21
Lee's Lane Landfill,
KY 38.78
Tower Chemical, FL — 64.29
Newport Dump, KY
Distler Brickyard, KY- 47.72
Airco, KY 53.88
Parramore Surplus, FL- 58.77
Distler Farm, KY 59.18
Lewisburg Dump, TN 56.91
144
-------
Cont'd Table S-2
Ground Surface Fire & Direct Ranking
Site Name Water Water Air Explosion Contact on NPL
Munisport, FL 53.69 — 15.94 100 362
Carolawn, SC 55.1 — 6.04 368
B.F. Goodrich, KY 53.88 379
Galloway Ponds, TN 52.35 — 9.65 37.5 384
Perdido G/W Contamination,
AL 52.04 — 6.18 37.5 394
Amnicola Dump, TN 52.31 397
Chemtronics, NC 51,02 — 9.65 400
Note: Numbers are based on use of the Hazard Ranking System
criteria
*Classified by the states as their number 1 priority.
145
-------
TABLE A
REGION IV DISTRIBUTION OF =REL:MINARY ASSESSMENTS
i o /,
PERCENT
BASED ON
COMPLETED
SITES
STATE
TOTAL
P. A. '5
COMPLETED
REMAINING
PRELIMINARY
ASSESSMENTS
AL
127
83
FL
176
21
GA
171
7
KY
105
16
MS
• 85
16
NC
127
69
SO
131
13
TN
189
12
TOTAL
1111
237
THE ABOVE BAR GRAPH REPRESENTS THE NUMBER OF PRELIMINARY ASSESSMENTS COMPLETED OUT Oc
THE TOTAL NUMBER OF SITES REPORTED UNDER §103(c).
EACH COMPLETED P.A. HAS AN ESTABLISHED PRIORITY FOR SITE INSPECTION AS FOLLOWS:
= NO ACTION NEEDED — NO PLANNED INSPECTION.
Z LOW — INSPECTION PLANNED, BUT NO DATE ESTABLISHED.
~ MEDIUM — INSPECTION PLANNED WITHIN ONE YEAR.
' IB -IGH - IMMEDIATE INSPECTION PLANNED
-------
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'^K/^^VrTTT<^< '
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NUMBER OF SPILLS
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14-5?
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VOLUME (GALLONS)
p
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149
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ui
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O
> _
BRICKYARD
— _ ro ro
o> O 01 O ui
O O O O O
O O O O O
1 1 1 1 1
450 YD3
SOLIDS
26,500 GAL.
ORGANIC LIQUIDS
| 6,500 GAL
CO
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61
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1,228 YD3
SOLIDS
52,000
ORGAN
GAL.
1C LIQUIDS
280.000 GAL. \
INORGANIC LIQUIDS \
lioo
YD3
(SOLIDS
9,000 GAL.
INORGANIC LIQUIDS
2 CD
m 33
CO O
o
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2
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-n
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33
C
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INORGANIC LIQUIDS
m
m
rn
3J
390 YD3
SOLIDS
20,000 GAL.
ORGANIC LIQUIDS
IS
m m
o a
3 -n
m ID
CO
^,780 GAL.
INORGANIC LIQUIDS
290 YD3
SOLIDS
35,000 GAL.
INORGAN 1C LIQUIDS
2,140 YD3
SOLIDS
48,000 GAL
ORGAN 1C LIQUIDS
10,000 GAL
INORGANIC LIQUIDS
-------
21 Superfund PERT Charts
AMERICAN CREOSOTE WORKS, PENSACOIA, FLORIDA
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
7-82 10-82 2-83 6-83 7-83 2-85 2-85
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
2-85 5-85 6-85 8-85 12-85 2-86
Briefly, the hazard is creosote, pentachlorophenol and wood preserving by-
products in the groundwater.
BROWN WOOD PRESERVING, LIVE CAR, FLORIDA
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
7-1-83 1-17-83 7-1-83 8-1-83 11-1-83 8-1-84 9-1-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
9-1-84 11-1-84 12-1-84 2-1-85 2-1-86 5-1-86
Brown Wood Preserving is an abandoned wood treatment plant which used creosote
and pentachlorophenol in its processes. Wastewater was stored in a 5 acre
surface impoundment. Residences in the area are on private wells which may be
subject to an impact.
15.1
-------
GOLD COAST OIL, MIAMI, FLORIDA
Concurrence RAMP Action Coop. Agreement RIPS Public Decision
of State Memo or St. Contract Meeting Memorandum
12-82 (Expect generators to do RI/FS) 2-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
2-84 3-84 5-84 1-85 3-85 3-85
Gold Coast Oil was used as a solvent reclamation and bulk storage area from
the early 1970's to 1982. Before the July 1982 voluntary cleanup by the
property owners, approximately 2,500 corroded and leaking drums were located
on the property. Slowdown from past operations sprayed directly on the
ground. Approximately 50 drums of contaminated soil were removed. Since only
obviously contaminated soil was removed, a thorough evaluation of soil
contamination must be done. Further, a FIT team resistivity study identified
a plume underneath the property. This needs to be investigated. The site
overlies the Biscayne Aquifer, the sole source of drinking water for the area.
HOLLINGSWORTH SOLDERLESS, FORT IAUDERDALE, FLORIDA
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
12-82 11-83 8-83 (g/w) 1-84 12-84 1-85
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
1-85 2-85 6-85 7-85 12-86 8-86
Hollingsworth made electrical terminals. Effluent from their plating (copper,
nickel, lead and tin) flowed into a drainfield and contaminated the soil.
Some trichloroethylene went into a well into the groundwater. A public water
supply wellfield is approximately 1/2 mile away.
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MIAMI DRUM, MIAMI, FLORIDA
Concurrence
of State
RAMP Action
Memo
6-2-82
Coop. Agreement RIFS Public Decision
or St. Contract Meeting Memorandum
9-29-82 2-83 10-83 11-83
Dec. Memo Action Coop. Agreement
Memo or St. Contract
Design &
Construction
Cleanup Recovery
Documentation
11-83
11-83
1-84
3-84
5-85
4-85
Drum recycling company. The county cleaned up the surface drums, etc., and
removed the contaminated soil (12-81 - 1-82) at a cost of approximately $1.6
million. A Remedial Investigation is currently underway to determine the type
and extent of groundwater contamination.
N.W. 58th STREET LANDFILL, MIAMI, FLORIDA
Concurrence RAMP Action Coop. Agreement
of State Memo or St. Contract
RIFS
8-82
Public
Meeting
8-84
Decision
Memorandum
12-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
12-84
2-85
5-85
4-87
4-87
Contamination detected in groundwater plume from landfill. Biscayne Aquifer
Study is sampling in that plume. Results delayed by contract labs. When
results received, decision will be made on what to do next. Until sampling is
complete from Biscayne Aquifer Study, cooperative agreement process will not
begin. It is possible that a Suparfund cleanup will not be necessary.
153
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SAPP BATTERY, COTTONDALE, FLORIDA
Concurrence
of State
12-10-81
RAMP
N/A
Action
MenD
4-27-82
Coop. Agreement
or St. Contract
6-21-82
RIFS
Public
Meeting
12-82 5-84
Decision
Memorandum
6-84
Dec. Memo Action Coop. Agreement
Memo or St. Contract
6-84
9-84
10-84
Design &
Construction
1-85
Cleanup Recovery
Documentation
1-86
7-86
Lead and nickel on/in soil, sulfuric acid in surface water as are the lead and
nickel. Groundwater not substantiated but possible.
SCHUYLKILL METALS, PLANT CITY, FLORIDA
Concurrence
of State
7-1-83
RAMP Action
Memo
12-8-82 8-1-83
Coop. Agreement RIFS Public
or St. Contract Meeting
9-1-83
12-1-83 9-1-84
Decision
Memorandum
10-1-84
Dec. Memo Action Coop. Agreement
Memo or St. Contract
10-1-84 11-1-84
12-1-84
Design &
Construction
4-1-85
Cleanup Recovery
Documentation
4-1-87
8-1-87
Schuylkill Metals, an active facility, recovers lead from storage batteries.
Leachate containing heavy metals and sulfuric acid has been discovered
migrating from unlined impoundments into an adjacent drainage ditch. The
company has modified its operations to help eliminate some of these problems.
The company is being investigated as to its application to RCRA Part B.
I 54
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TOWER CHEMICAL, CLERMONT, FLORIDA
Concurrence
of State
3-14-83
RAMP
Action
Meno
Coop. Agreement RIFS Public
or St. Contract Meeting
1-17-83 5-30-83
6-15-83
7-15-83 2-84
Decision
Memorandum
3-84
Dec. Memo Action Coop. Agreement
Memo or St. Contract
Design &
Construction
Cleanup Recovery
Documentation
3-84
3-84
3-31-84
5-84
6-85
9-85
Pesticide manufacturer's poor housekeeping resulted in high concentrations of
DDT and other by-products in soil and surface water. Possible contamination
of the Floridan Aquifer exists.
VARSOL SPILL, MIAMI, FLORIDA
Concurrence
of State
RAMP Action
Memo
Coop. Agreement
or St. Contract
100% Federally
Funded
RIFS Public
Meeting
8-82
8-84
Decision
Memorandum
12-84
Dec. Memo Action Coop. Agreement
Memo or St. Contract
2-85
5-85
Design &
Construction
1-86
Cleanup Recovery
Documentation
4-87
6-87
Sampling in suspected area of contamination under way as part of the Biscayne
Aquifer Study. Results delayed by contract labs. When results received
decision will be made on what to do next.
Until sampling from the Biscayne Aquifer Study is complete it is not certain
that Superfund cleanup will be necessary.
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WHITEHOUSE WASTE OIL PITS, WHITEHOUSE, FLORIDA
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
2-3-82 6-25-82 2-24-82 6-1-82 9-1-82 1-1-84 2-1-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
2-1-84 4-15-84 5-15-84 7-1-84 5-31-85 N/A
The pits are composed of a waste oil sludge that is toxic to aquatic life and
contains several toxic organic compounds. The toxic leachate may cause
serious skin irritation because of eroded dikes, and the release of toxic
leachate into the surrounding surface waters.
A. L. TAYLOR, BROOKS, KENTUCKY
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
* 5-11-83 7-29-83 8-23-82 FS 4-20-83 5-11-83
3-30-83 GS
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
5-11-83 5-11-83 7-29-83 9-29-83 3-1-84 4-1-84
Substantial volumes of buried waste remain on the site. Surveys estimated
that as much as 12,500 cubic yards of material including 18,500 drums may be
located in burial areas of the site. Chemical analyses of soil and water
takne indicate the presence of a wide variety of organic compounds and heavy
metals. Potentially hazardous substances detected included heavy metals,
ketones, phthalates, polychlorinated biphenyis (PCBs), chlorinated alkanes and
alkenes, aromatics, chlorinated aromatics, and polynuclear aromatics.
* Generator negotiation
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DISTLER BRICKYAED, WEST POINT, KENTUCKY
Concurrence
of State
9-1-83
RAMP Action
Memo
3-1-83 10-1-83
Coop. Agreement
or St. Contract
11-1-83
RTFS
Public
Meeting
3-1-84 11-1-84
Decision
Memorandum
12-1-84
Dec. Memo Action Coop. Agreement
Memo or St. Contract
12-1-84 2-1-85
3-1-85
Design &
Construction
7-1-85
Cleanup
Documentation
7-1-87
Recovery
10-1-87
The Brickyard site is an abandoned brick manufacturing facility which was used
as an industrial waste disposal area. In February, 1982, EPA removed all
drummed wastes, but prior spillage has contaminated the groundwater beneath
the site. FIT will install some groundwater wells at the site during March
1983.
DISTLER FARMS, BROOKS, KENTUCKY
Concurrence
of State
3-83
RAMP Action
Memo
11-8-82 4-83
Coop. Agreement
or St. Contract
5-83
RIFS Public
Meeting
7-83
2-84
Decision
Memorandum
3-84
Dec. Memo Action
Memo
3-84
3-84
Coop. Agreement
or St. Contract
4-84
Design & Cleanup Recovery
Construction Documentation
5-84
9-85
10-85
Unknown number of drums of chemicals to be determined. Thought to be mostly
solvents. Danger to groundwater not established by 3/10/83.
-------
LEE'S LANE LANDFILLS, LOUISVILLE, KY
RAMP
Concurrence
of State
9-1-83
Action Coop. Agreement
Memo or St. Contract
12-8-82 10-1-83
11-1-83
RIFS Public
Meeting
3-1-84 3-1-85
Decision
Memorandum
4-1-85
Dec. Memo Action Coop. Agreement
Memo or St. Contract
Design & Cleanup Recovery
Construction Documentation
4-1-85 5-1-85
6-1-85
10-1-85
3-1-88
6-1-88
Lee's Lane Landfill is located along the Ohio River and it received wastes
from domestics, commercial and industrial sources. Methane gas was detected
in the subsurface, and a gas venting system was finally installed in October
1980. By October 1981, surface drums were pumped out and the liquid disposed
of properly. Well drilling is being done to determine groundwater contamina-
tion.
PIASTIFAX, GULFPORT, MS
Concurrence
of State
8-23-82
RAMP Action
Memo
Coop. Agreement
or St. Contract
RIFS Public
Meeting
(a)10-19-82 N/A
(b) 4-15-83
Decision
Memorandum
10-1-83
Dec. Memo Action Coop. Agreement
Memo or St. Contract
Design &
Construction
1-1-84
Cleanup Recovery
Documentation
3-31-84
N/A
* Private response: (a) phase I, (b) phase II field investigation activities
only, feasibility study proposed 8-1-83, public meeting under private clean-
up not recommended, RIV/RC
**Due to the release of hazardous chemical compounds such as hydrochloric,
sulfuric and nitric acids on to the ground surface, environmental contamina-
tion of the shallow groundwater and surface soils exists.
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N.C. PCB ROADSIDE SPILLS
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
4-23-82 5-7-82 N/A 1-4-79
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
5-20-82 5-25-82 6-25-82 ongoing 1-26-83
action
filed
The intent of this project is to clean up approximately 40,000 cubic yards of
PCB (polychlorinated biphenyl) contaminated soils located along the shoulders
of 211 miles of North Carolina roadways. The proposed remedial action will
accomplish the removal of contaminated soils from along fifteen segments of
highway and the placement of these soils in a PCB disposal site in Warren
County, North Carolina.
There is a serious need to dispose of the contaminated soils, since PCBs are
very stable compounds that will remain unchanged in the environment for an
excessive amounj: of time. Studies using laboratory animals have shown
potential chronic effects such as cancer induction, pigmentation, and behav-
ioral changes after ingesting PCBs. Accordingly, the reason for the removal
of the PCB contaminated soils to a secure landfill is to prevent the future
redistribution of the soils which could increase the chance of PCB exposure to
humans and animals.
CAROLAWN, FT. LAWN, SOUTH CAROLINA
Concurrence RAMP Action Coop. Agreement RIFS Bublic Decision
of State Memo or St. Contract Meeting Memorandum
7-1-83 3-1-83 9-1-83 10-1-83 2-1-84 8-1-84 9-1-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
9-1-84 11-1-84 12-1-84 3-1-85 9-1-85 12-1-85
The Carolawn site is an abandoned waste storage and disposal facility west of
Ft. Lawn, SC, that has several hundred drums of chemical wastes, including
acids, bases, and organic solvents. Superfund money was used to remove all
drums, dispose of all liquids and solids, drain the diked lagoon, and remove
the sludge from the lagoon. Possible groundwater contamination needs to be
investigated.
i era
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SCRDI BLUFF ROAD, COLUMBIA, SOUTH CAROLINA
Concurrence RAMP Action Coop. Agreement RIFS Public Decision
of State Memo or St. Contract Meeting Memorandum
5-6-82 2-16-82 6-28-82 7-83(g/w) 12-83 5-17-82
1-84(g/w)
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
1-84(g/w) 8-83 2-22-83
The site has an estimated 2300 drums remaining. These remaining drums account
for 1/4 of the surficial waste left at the site by a generator sponsored
cleanup. Based on the initial findings by the contractor for the generators,
the site contains various kinds of explosives and an undetermined number of
gas cyclinders.
The remainder of the wastes at the site is presently being cleaned up by a new
contractor under a state/EPA Cooperative Agreement. The present contractor
(Defender Vac, Inc.) has been on site since 2-22-83. It is anticipated that
the present contractor will finish his phase of the cleanup by June 6, 1983.
GALLOWAY POND, GALLOWAY, TENNESSEE
Concurrence RAMP Action Coop. Agreement RTFS Public Decision
of State Memo or St. Contract Meeting Memorandum
3-7-83 6-1-83 9-1-83 10-1-83 1-1-84 9-1-84 10-1-84
Planned
Removal
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
10-1-84 12-1-84 1-1-85 4-1-85 10-1-85 1-1-86
The Galloway Pits are a series of old gravel pits used for disposal of
municipal and industrial wastes. A company from Memphis is suspected of
dumping pesticide wastes in one of the ponds. The types and quantities of
waste at this site indicate a potential for groundwater contamination.
Governor Alexander has written a letter requesting planned removal.
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NORTH HOLLYWOOD DUMP, MEMPHIS, TENNESSEE
Concurrence RAMP Action Coop. Agreement
of State Memo or St. Contract
6-80 8-1 1-81 (MOU)
RIFS
Public
Meeting
12-80 12-79
Decision
Memorandum
1-84
Dec. Memo Action Coop. Agreement Design & Cleanup Recovery
Memo or St. Contract Construction Documentation
1-84
1-84
2-84
6-84
3-80
6-85
As we can best determine, the N. Hollywood Dump was used for both municipal
and industrial waste disposal. At the present time, the true hazards at this
site are unknown. However, data is being generated by the TAG to assess the
dangers at the site. As it now stands, the data presently being generated
will be handed over to a subcontractor who will determine the hazard and
subsequently offer corrective alternative measures that will be considered in
mitigating any identified environmental hazards.
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RADIATION
1. EPA Authority
a. Statutory Authority: AEA 274(h)
Reorganization Plan No. 3 of 1970, 42 USC 202(h),
tranferred to EPA the authorities of the Federal Radiation
Council, which includes authority to develop guidance for
other federal agencies to follow in limiting radiation
exposures. Additionally, EPA was given authority, under the
Atomic Energy Act, to establish generally applicable envir-
onmental standards to protect public health from exposure to
radiation. Guidance and Standards being Developed:
(1) Occupational Radiation Exposure
(2) Transuranic Elements Guidance
(3) Radiofrequency Radiation Guidance
(4) Environmental Protection Standards for High-
Level Radioactive Waste
" (5) Environmental Protection Standards for Low-
Level Radioactive Waste
b. Statutory Authority: UMTRCA 206 AEA275/42 USC 2022
CFR: 40 CFR 192
1. Remedial Action Standards for Inactive Uranium
Processing Sites
2. Environmental Standards for Active Uranium Mill
Processing Sites
c. Statutory Authority: CAA Soc 112/42 USC 7412 CFR
40 61
NESHAPS Airborne Radionuclides - Radionuclides are a
hazardous air pollutant. EPA is determining from which
source categories of radionuclide emissions create a signi-
ficant health risk. The Agency will issue standards for
each category named.
d. Statutory Authority: SDWA SCC 1412/42 USC 3009-1
Safe Drinking Water Act - The Safe Drinking Water Act
of 1974 requires EPA to establish primary and secondary
drinking water regulations for public drinking water sup-
plies. Primary regulation are aimed at protecting public
-------
health. They establish maximum allowable contaminant levels
in drinking water, provide for water treatment technologies,
and water supply system operation.
EPA is also developing regulations for clean up and
disposal of uranium mill tailing piles under the Uranium
Mill Tailings Radiation Control Act of 1978.
2. Region IV Major Radiation Sources
a. Listing
SOURCE NO.
(1) Nuclear Power Plants (Commercial, 36
LWR) (20 operating)
(2) Research Reactors 3
(3) Production and Research 7
(4) Radioactive Waste Burial 2
(5) Nuclear Fuels Reprocessing 1
» (6) Nuclear Submarine Bases 2
(7) Phosphate Mining and Milling . 2*
53-Total
*Florida and North Carolina - many large milling
operations
b. Discussion
As of December 31, 1982, there were 20 operational
nuclear power plants in Region IV with the available capa-
city of 18,591 megawatts of electrical power generation.
This represents 28 percent of the present U.S. capacity of
nuclear generated electrical power. The average plant
capacity of the operational plants in Region IV is 930
megawatts electrical, with a range of 728 to 1220 megawatts
electrical for the individual plants.
There were 16 nuclear power plants, under construction
as of December 31, 1982, in Region IV. These plants will
provide an additional available capacity of 17,707 megawatts
of electrical power generation. The average plant capacity
of the plants under construction is 1,107 megawatts of
electrical power generation. Also, as of December 31, 1982
there was an additional plant capacity of 5,036 megawatts
electrical power on order by utilities in Region IV with an
indefinite status for construction and operation.
I / 2
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3. Fundamental Issues
a. Waste Management:
At the present time, there are only three burial
facilities in the United States that are utilized for low-
level radioactive waste disposal: Barnwell, South Carolina;
Richland, Washington; and Beatty, Nevada. Because of the
shortage of disposal capacity and the lack of national
policy, Congress passed the Low-Level Radioactive Waste
Policy Act in December, 1980. The Act encourages states to
form regional compacts to manage low-level wastes. It
further provides that a host-state burial facility can
exclude the receipt of any waste generated outside a region-
al compact after Januray 1, 1986.
A Southeast compact is under development with the
states of Alabama, Florida, Georgia, Mississippi, North
Carolina, South Carolina, Tennessee and Virginia. The
present compact language provides for the use of the
Barnwell, South Carolina burial facility until 1992 at which
time it will be closed. The intent of the Southeast compact
is to have another site operational by that date to serve
the regional party states. Wastes generated by federal
government defense, research, and development activities are
not included as state responsibilities under the compacts.
The proper management of Low-Level Radioactive Waste
(LLW) has become a major concern of governmental agencies.
This intense interest has been exhibited by the public in
general, by the Congress through the introduction of various
bills relating to LLW, and, in particular, by the passage of
the Low-Level Waste Policy Act of 1980.
Intense interest in LLW issues has been generated in
individual state and local governments as existing commer-
cial sites begin to close or reduce the volume of waste
being accepted. This situation, which became critical in
1979-1980, has made government officials and waste generat-
ors recognize the potential unavailability of facilities to
dispose of their radioactive waste, and the consequences
that would result.
The major environmental concern is the potential for
radionuclide contamination of man's environment from dis-
posal of such waste, and, in particular, groundwater contam-
ination at the state and local community level. Safeguard-
ing the public health by protecting the quality of ground-
water, and in turn the radiological (DWS) quality of surface
water, especially during low-flow periods, is dependent upon
groundwater quality protection. Another major concern is
the potential nonavailability of shallow land burial sites
-------
for disposal of the wastes, which would significantly
curtail, if not prohibit, the beneficial use of radioactive
material.
Problems have occurred at most existing sites. One of
the major causes for these problems has been the lack of
national criteria and guidelines in the proper design and
operation of shallow land disposal sites. For future sites
for disposal of LLW - without clear, comprehensive and
nationally accepted criteria, standards and guidelines -
decisions will be fragmented, nonuniform, and will probably
result in much slower desicion-making processes for the
proper management of Low-Level Radioactive Waste.
b. Spent Nuclear Fuel Storage
Operating commercial nuclear power plants have the
primary responsibility for providing interim storage of
spent nuclear fuel by maximizing to the extent practical,
the effective use of existing storage facilities on-site and
by adding new on-site storage capacity. This is being
accomplished through the use of high-density fuel storage
racks, fuel rod compaction, and the transshipment of spent
nuclear fuel to another power reactor within the same
utility system. Also, the construction of additional spent
fuel pool or dry storage capacitiy, or other storage means
at the sites of nuclear power plants is often needed to
assure the continued orderly operation of the reactors to
supply base load electrical power generation.
Under the Nuclear Waste Policy Act of 1982, the federal
government has the responsiblity to provide up to 1900
metric tons of capacity for interim storage of spent nuclear
fuel for the commercial power reactors that cannot reason-
ably provide adequate storage capacity on-site when needed
to assure the continued orderly operation of power genera-
tion .
In conjunction with DOE actions to alleviate the spent
nuclear fuel storage problem under the Nuclear Waste Policy
Act of 1982, EPA has the responsibility to set generally
applicable environmental radiation standards for radioactive
wastes. In December 1982, EPA issued proposed Environmental
Standards for the Management and Disposal of Spent Nuclear
Fuel, High-Level and Transuranic Wastes under 40 CFR 191.
c. Radiation Emergency Planning and Response
The air, water, drinking water, and toxics acts all
have emergency sections which give EPA authority to deal
with immediate dangers to the public, including exposure to
radioactive materials. EPA may issue orders and file for
i / c
-------
injunctions to regulate any emission, storage, transport, or
other activity posing an imminent and substantial danger to
public health.
Specifically, the Agency is charged with the following
responsibilities:
o Identifying and diagnosing radiological hazards
in the environment as a result of an accident.
o Assisting in the development and coordination of
federal, state and local plans to prevent or
minimize long-term ecological impacts from
emergencies and to preserve resource quality
during an emergency.
o Developing protection action guides for use in
emergencies which would estimate radiation doses
which may result from radiation incidents and
recommend specific emergency actions.
The Region IV Environmental Radiation Program is a
charter participant in the Federal Interagency Radiation
Emergency Radiation Assistance Committee. The committee is
chaired by the Federal Emergency Management Agency (FEMA)
and also includes the Nuclear Regulatory Commission (NRC),
the Department of Transportation (DOT), the Food and Drug
Administration (FDA), the Department of Energy (DOE), and
the Department of Agriculture (DOA). State and county
emergency plans are reviewed and exercises of those plans
are evaluated by representatives of the federal agencies,
with written comments submitted. The EPA representatives
particularly evaluate how the EPA protection action guides
are implemented.
The Three Mile Island accident was a unique event in
the context of emergency management. The conditions it
imposed were new and there was inadequate understanding of
potential radiation amounts and effects, and there were
problems in understanding the technology of events trans-
piring at the site. These factors have been addressed at
the federal, state and local events in present emergency
response plan development so that future emergency condi-
tions at fixed nuclear facilities will adequately provide
for the risk to health and safety of the public. The
federal responsibility mandates a level of emergency plan-
ning and coodination that will meet the strictest guide-
lines, to provide timely, clear-cut guidance applicable to
state plans and to give needed support to states in the
event of an evacuation or protection action. The states
should rely on continually updated plans for at least a
ten-mile radius for all fixed nuclear sites.
-------
All Region IV states now have Radiation Emergency
Response Plans and all plans have been exercised at least
once. The large number of radiation sources in Region IV
add considerably to this workload.
d. Phosphates
Phosphate lands are located in large areas of central
Florida and the coastal areas of South Carolina and North
Carolina. Containing Radium-226, they are a source of
increased exposure to radiation for area residents, and
thus, an increased risk of developing cancer. Such risks
exist in undisturbed phosphate lands and in mined phosphate
land, both reclaimed and unreclaimed.
Radon, a radioactive gas, is emitted by Radium-226 in
the soil and may seep through the foundations of houses. If
present in sufficient concentration, it can produce carcino-
genic effects in people residing in those houses. EPA has
developed remedial prevention techniques for controlling
radon, including both structural and in-house reduction
methodologies.
In the future, the EPA Region IV office, in conjuntion
with EPA/ORP Headquarters, will continue to work with the
states in the interpretation and implementation of the EPA
radon exposure recommendations and remedial prevention
techniques.
4. Primary Sites Using Radioactive Materials
a. Savannah River Plant
The Savannah River Plant (SRP) facilities were esta-
blished in the early 1950's to produce nuclear material for
national defense requirements, principally plutonium and
tritium. The site is 150 kilometers (94 miles) from
Savannah, Georgia, on an 800 square kilometer controlled
area along the Savannah River in South Carolina. The major
operating facilities include three isotope production
reactors, two chemical separation plants, a fuel and target
fabrication plant, a heavy water production plant and the
Savannah River Laboratory. These facilities are the princi-
pal sources of radioactive liquids and airborne emissions.
Since opening, SRP has generated more than 265,000
cubic meters of high level radioactive liquid waste, and
continues to generate between 5,700 and 7,600 cubic meters
per year. The volume is being reduced by more than 60
percent through evaporation. The waste is stored in tanks
underground with capacities for 2,800 to 4,900 cubic meters.
From 1966 to 1982, DOE has constructed 27 high-integrity,
double-shell storage tanks to replace the older tanks, and
to store new waste. This construction was completed in
-------
1982. These tanks have a combined capacity of 132,000 cubic
meters. The high-level waste is being transferred from the
old tanks to the new tanks and prepared as feed material for
the Defense Waste Processing Facility (DWPF).
The DOE plan is to remove the waste from tanks,
immobilize it, and dispose of it in an off-site geologic
repository. Borosilicate glass was selected as the waste
form in 1982. The current engineering projections for the
DWFP are to process about 1250 cubic meters of sludge and
produce approximately 500 canisters of borosilicate glass
per year.
The SRP also generates about 10 percent, by volume, of
the defense transuanic (TRU) waste. This share is envi-
sioned to increase to about 15 percent by 1989-90.
In August 1982, DOE issued an Environmental Assessment
on the proposed restoration and operation of the L-Reactor
at SRP. DOE issued a FONSI indicating that an Environmental
Impact Statement would not be required, as the restoration
of L-Reactor was not a major federal action. In this
report, DOE acknowledges there are environmental issued
related to:
» a) Cooling water withdrawal, including increased
usage from the Savannah River and increased
impingement and entrainment of fish, b) thermal
discharge as a result of heated effluent to be
discharged directly to Steel Creek, c) flood-
plain/wetland impacts of direct discharge of
cooling water to Steel Creek, which has been
undergoing post-thermal recovery since 1968, d)
1000 or more acres of wetlands of Steel Creek
and Savannah River are impacted, and additional
wetland habitat is expected to be eliminated or
modified at the rate of approximately seven to
ten acres per year, e) Radiocesium transport
and remobilization in the Steel Creek -
Savannah River System, and f) Radiological dose
commitments to the public.
Should the determination be made that this is a major
Federal action significantly affecting the human environ-
ment, an Environmental Impact Statement (EIS) should be
prepared. The purpose of the EIS is to fulfill the require-
ments under Section 103 (2) (c) of the National Environ-
mental Policy Act of 1969 (NEPA), by providing environmental
inputs to the decisions regarding the proposed action and
its reasonable alternatives.
This is not a new source, much operational data are
available, and the cumulative radiological impact, including
the radiocesium transport in the liquid pathway, has been
-------
studied extensively. The radiological impacts of the
proposed action are based on projections of the current
operational releases on the environmental baseline. . The
environmental assessment provides the maximum individual and
population dose commitments resulting from radioactive
releases from the L-reactor and its supporting facilities.
This issue must continue to be monitored by the Region
IV Environmental Radiation Program as well as the impact of
new facilities which are under consideration for construc-
tion within the Plant complex.
EPA Region IV testified before the Senate Armed Ser-
vices Committee February 9, 1983 regarding environmental
impact issues, danger or hazards to the public from the
restart of the L-reactor.
b. Maxey Flats Low Level Radioactive Waste Disposal
Facility
Maxey Flats, which was established in 1962, was ini-
tially plagued by poor management and poor- operation.
Current hydro-geological knowledge of the site is insuffi-
cient to develop a model capable of predicting future ground
water behavior. The primary radiation control problem at
the site involves water management, which includes carryover
into the Evaporator Stack Effluent and surface transport of
radioactive liquid.
Most of the waste disposed of appeared to be readily
degradable and poorly packaged so that large voids existed
or developed between the waste and packaging. Contact with
water caused additional voids. This led to settlement of
the trench contents followed by slumping and subsidence of
trench covers. This in turn allowed enhanced percolation of
water through the trenches.
In addition, control of liquid accumulation in the
trenches constitutes a major problem and expense. The site
evaporator has been operating since 1973 with the processing
rate of contaminated liquid exceeding the accumulation.
Basic work to accomplish eventual decommissioning of
the site is in progress. The old tank farm and the small
pond, both areas for accumulation and contamination of
rainwater, have been eliminated, and water infiltration into
the trenches has been diminished by the re-working of trench
covers, recontouring, drainage improving, and the protection
of some 20.5 acres of trenches by plastic cover. The
evaporator will continue to be operated through at least
1983 due to the backlog of contaminated water onsite.
. . r\
-------
An EPA/ORP study on the Maxey Flats operations was
conducted with a report issued in January, 1976 which
focused on waste management and migration of radioactive
materials at the site. The concern is with any insult to
the environment outside of the plant boundaries and availab-
ility of technical assistance to the state should such be
requested. Surveillance of the site by the state and
analysis of the environmental data by appropriate organiza-
tions will be necessary in the foreseeable future.
c. Oak Ridge Nuclear Facility (DOE)
The Oak Ridge DOE Reservation is located in northeast-
ern Tennessee, approximately 35 kilometers west of
Knoxville, Tennessee. It is in a valley between the
Cumberland and Great Smokey Mountains and consists of
aproximately 150 square kilometers. The major facilities at
the Oak Ridge site include the Oak Ridge National Laboratory
(ORNL) which is a multi-discipline research laboratory with
nuclear research reactors, chemical pilot plants, research
laboratories, radioisotope production laboratories and
support facilities including the High Flux Isotope Reactor
and the Transuranic Processing Plant. About one percent of
DOE's Transuranic (TRU) waste is produced and stored annual-
ly at ORNC.
/•7A
-------
d. Oak Ridge Gaseous Diffusion Plant
This consists of a complex of production, research,
development and' support areas to provide enrichment of the
Uranium-235 isotope. Still another major facility is Oak
Ridge Y-12 Plant which has four primary purposes: (1)
production of nuclear weapon components; (2) fabrication
support for weapons design; (3) support for the ORNL; and
(4) support and assistance to other government agencies.
Smaller facilities located at the reservation are the
comparative animal research laboratory and the Oak Ridge
associated universities.
The primary areas of environmental concern at the site
include radioactive airborne emissions, on-site radioactive
waste disposal areas, the impact of radioactive material
released in the liquid effluent (White Oak Creek to the
Clinch River to the Tennessee River), and dredging operations
in preparation for the construction of the Clinch River
Breeder Reactor at Oak Ridge, TN.
.Radioisotope concentrations in the Clinch River are
within the allowable limits of the EPA drinking water
standards. A substantial amount of the radionuclides are
absorbed by the river sediments and transported by diffu-
sion, with sufficient dilution as to present no significant
health risks to off-site individuals and populations. EPA,
in conjunction with DOE and the state of Tennessee, will
continue to monitor Oak Ridge's operation for any off-site
environmental impact which may affect the public health and
safety.
The Clinch River Breeder Reactor Plant (CRBRP) is the
demonstration project proposed by DOE (TVA and nuclear
industry participation) under its Liquid Metal Fact Reactor
Program. The licensing activities were suspended in 1977
but resumed in September, 1981. The 1981 total plant cost
estimate was about $3.2 billion dollars. EPA has been
involved with this project since the early 1970's to assist
DOE under the authority of the Second Memorandum of Under-
standing between EPA and NRC regarding implementation of
certain NRC and EPA responsibilities (Federal Register 40
40115) pursuant to NEPA regarding issuance of licenses for
nuclear power plants and certain other facilities.
Since the FEIS was issued in 1977, additional data
relative to the site and its environs have been collected,
several modifications were made to the plant design and its
fuel cycle and the timing of plant construction and opera-
tion have been affected. NRC and EPA summarized these
damages, and their environmental significance was assessed
the in the July, 1982, draft supplement to the 1977 FEIS.
In December, 1982, Region IV issued to all interested
agencies, public groups and citizens the Record of Decision
-------
on the CRBRP and Notice of NPDES permit determination for
the proposed DOE demonstration project. The agency's
decision and summary of its EIS (CAA Section 309) review
responsibility was presented. The mitigative measures
adopted to minimize adverse environmental effects of the
action were identified. Region IV will continue to cooperate
with NRC as the lead agency on the NEPA issues, and assist
DOE with their implementation actions during proposed
construction and operation of the CRBRP.
e. Kings Bay Submarine Base
In 1977 the Department of Defense (DOD) and the U.S.
Navy proposed major federal action for the construction and
operation of a fleet ballistic missile submarine support
base at Kings Bay in Camden County, GA. Disclosure of the
project description, existing environmental base, probable
impacts and mitigating measures, and alternatives to the
proposed action were presented in a DEIS. The Navy recog-
nized that the establishment of the Kings Bay Submarine
Support Base, expandable to become the major East Coast
future Trident base, involved a complex, interactive rela-
tionship in the environment. EPA Region IV, the state of
Georgia, in conjunction with the Navy, planned a preopera-
tional radiological baseline to measure all important
components of the background radioactivity currently present
at Kings Bay site beginning in May 1978. EPA participated
in the monitoring survey, and performed laboratory analysis
of duplicate sites of environmental samples. Air, soil
harbor water, groundwater, harbor sediments and core samples
of the St. Mary's River proposed turning basin areas,
adjacent (marsh) wetlands, marine life and Cumberland Island
shallow water areas were included in these samples. Results
of the monitoring survey were published by Navy, EPA, and
the state of Georgia (DNR). Quality assurance of the
radiological data base was enhanced by the individual
laboratory analysis.
The Department of Defense, under the present
administration, envisions up to 20 Trident class submarines
to be based at the Kings Bay site. The state of Georgia
(DNR), Environmental Protection Division, is continuing with
the operational monitoring program under the state Fixed
Nuclear Facility Environmental Radiation Surveillance Pro-
gram. EPA is providing technical assistance and monitoring
equipment to DNR, quality assurance crosscheck, review of
the surveillance monitoring data, and cooperation with the
federal facilities' regional coordinator to assure that any
off-site environmental radiation impacts are minimized.
-------
Exposure From
Environmental Sources
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Contribution
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6.0 Million
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Internal to
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5.3 Million
3erson-flems
per Year
Unknown
Contneution
6.5 Million
Person-flems
per Year
Sum of Known Environmental Sources
is 19.9 Million Person-flems oer Year
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PESTICIDES
1. Overview of Status and Trends
The use of pesticides (both insecticides and herbi-
cides) is proportionately greater in the South than other
areas of the country. By the mid-to-late 1970's the South
accounted for nearly sixty-six percent of the 86 million
pounds of insecticides, and twenty six percent of the 98
million pounds of herbicides, used nationally. Attendant
with this significant use are the potential problems of
residues of pesticides in food commodities and groundwater,
as well as bioaccumulation (real or perceived) resulting
from the persistence of certain of these chemicals.
The percentage use of chemicals is not expected to
decrease in the future since the Region contains more than
one fourth of the total number of farms in the United States
and the number of acres to which pesticides are applied
continues to increase (Figure P-1). In addition, some
300,000 private and 50,000 commercial applicators in the
Region hold valid certification, and are all potential
sources of continuing future pesticide application.
While it may be tempting to visualize the magnitude of
the problem by tracking the actual pounds of pesticides
applied, the introduction of new chemical compounds has made
such an analysis misleading. New chemicals such as synthe-
tic pyrethrin require a much lower volume of application,
and hence the loading to particular acreage may be reduced.
However, the actual number of acres to which pesticides are
applied is increasing as demands for crop production cause
more land, presently in unmanaged forest and rangeland, to
be converted to intensively managed cropland.
Managing the pesticide program (registration, training,
inspection, investigation and enforcement) to minimize the
risk and increase the benefits of pesticidal use is a
challenging job. Pesticide poisoning cases involving
children are one of the documented risks (Figure P-2). The
switch from long-lived chlorinated hydrocarbons to shorter-
lived substitutes with greater acute toxicity to people has
aggravated this problem, and demonstrates the need for
greater safety consciousness among the general public
(pesticide applicators in particular). This is one of the
challenges for the future.
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Region IV
ENVIRONMENTAL MANAGEMENT REPORT
Pilot Project
Attachment B
Detailed Analysis of Significant Environmental Problems and
Special Projects
AIR QUALITY
1. There is a rising public concern and awareness regard-
ing the impact of pollution (air, water, hazardous waste,
etc.) on our lives. The need exists to identify those
problem areas, understand the causes, and ultimately estab-
lish measures to eliminate these concerns. There are
numerous nonattainment areas in the Region for total sus-
pended particulate, ozone, carbon monoxide, and sulfur
dioxide, that will require a concerted effort by Federal,
State, and local control agencies to resolve the environ-
mental problems. This Region has identified five (5)
geographical locations with nonattainment problems in which
a detailed analysis of the problem should be addressed.
These areas are: (1) Ashland, Kentucky; (2) Birmingham,
Alabama; (3) Southeast, Florida; (4) Louisville, Kentucky;
and (5) Knoxville, Tennessee. Addressing these environ-
mental concerns in these areas may give insight to help
solve the many other nonattainment areas in the region.
In addition, thoughout Florida there is a growing
desire of power companies to convert power plants from oil
to coal. The impact of increased air pollutants from these
conversions could be significant. This concern will be
addressed in this appendix also.
a. Ashland, Kentucky - Total Suspended Particulates
(TSP) Nonattainment
Ashland, Kentucky is a highly industrialized nonattain-
ment area for particulate emissions and the state's submit-
ted SIP revision does not demonstrate attainment by the
statutory attainment date. The area is on the Tier II list
of areas subject to sanction. The Ashland area has four
monitoring sites which are exceeding the primiary (health-
related) National Ambient Air Quality Standard (NAAQS) for
particulates. The most recent year with complete data
available is 1981; the annual geometric means were 100, 77,
87, 94 ug/m at the four sites. The primary NAAQS for
particulate is 75 ug/m . These values appear to be fairly
stable over the past three years, although the maximum 24
hour averages have decreased. The state feels that fugitive
dust emission from unpaved roads may be the major contribut-
or to the TSP nonattainment problem.
-------
Because Ashland has continued to exceed the NAAQS for
TSP for the past ten years and the areas"s air quality
appears to have stabilized but is still nonattainment, it
has been selected by the Region to be the subject of a pilot
audit program for environment results. The Ashland area has
several advantages over other TSP nonattainment areas in the
Region for this type of program. For example, the non-
attainment area is reasonably small in size; the source
inventory is small enough to be manageable; and historical
ambient data is available back to 1965. The pilot audit
program will be designed to determine the magnitude, possi-
ble causes of the particulate problem, and potential solu-
tions. The audit will address considerations such as siting
and operation of monitors, nearby source emsission and their
degree of control, compliance with regulation, and operating
characteristics. Fugitive dust emission from unpaved roads
will be addressed as part of the program audit, and new
source growth impact will be considered when formulating
final corrective action.
The study will require the efforts of several program
groups within EPA, cooperation by the affected community,
and the services and expertise of an outside contractor.
EPA's activities will include: (1) conducting emissions
inventories for ther study area; (2) identifying all violat-
ing facilities; (3) profiling the chronology of abatement
equipment installation; (4) providing a meteorological
profile of the Ashland Area; (5) conducting air quality
modeling; (6) developing a microinventory of each monitor;
(7) evaluating the Ashland ambient monitoring sites and (8)
recommendation for additional contacts. Regional Counsel's
Office will be required to provide legal services regarding
confidentiality of the data obtained during the study. The
contractor will need to provide approximately 1600 manhours.
Based on the audit results, the Regional Office and
State will formulate corrective actions for the major
problems. These actions could include, but are not limited
to: (1) enforcement in the case of violations of emission
limits in the vicinity of the ambient violations; (2)
improved regulations on source operation or emission limits
that would have to be included in SIPs as a regulatory
revision or operating permit; and (3) improvement in moni-
toring practices or relocation of monitors.
It is anticipated that once this pilot audit program
has been completed, the results obtained may be utilized to
help eliminate other similar TSP nonattainment areas in the
Region.
b. Birmingham, Alabama
(1) Total Suspended Particulate (TSP) Non-
attainment
131
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As a result of a suit by U.S. Steel, Birmingham's
(Jefferson County) particulate nonattainment area was
redesignated on June 10, 1980, the changes to the boundaries
made on June 24, 1981. The due date for submittal of the
Part D plan for attainment of the particulate standard was
June 10, 1981. The Alabama Air Control Commission submitted
a draft Part D SIP for Jefferson County on July 14, 1982.
EPA responded with comments on that draft on August 20,
1982, identifying the plan an unapprovable. Recently, the
newly established Alabama Department of Environmental
Management has agreed to submit a revised attainment plan
with changes identified by EPA. The New Source construction
moratorium presently applies in Jefferson County and has
been in effect since December 10, 1982. The area is on the
Tier II list of areas subject to sanctions.
The air quality in Birmingham has improved steadily
over the last few years and is a vast improvement over the
levels recorded there in the early 1970s. Violations of the
ambient standard still exist despite the fact that several
large industries, especially the iron and steel industry in
Birmingham, have temporarily closed down most operations in
the last couple of years due to poor economic conditions.
With the projection of improved economic conditions and
recovery starting in FY 83 and FY 84, the upturn in industr-
ial activity and associated increase in emissions are
expected to reverse the trend of improving air quality data
in Birmingham. Unless the industry has perfomed maintenance
or takes adequate precaution with the startup of their indu-
strial operation and associated control equipment, there
could be an acute air quality problem until the production
and control equipment stabilize into normal operating
conditions. EPA has recently obtained a contractor to
assist EPA and the state in completion of the Birmingham and
Etowah TSP Part D plans. It is anticipated that this effort
will be completed with the state adopting or EPA promulgating
a plan by the end of 1983.
(2) Ozone Nonattainment
Birmingham was designated nonattainment for ozone in
March 1978 and required to develop and submit a plan for
attainment of the ozone standard. The State of Alabama did
develop and submit an attainment plan for ozone projecting
attainment by December 31, 1982. Due to the elevated values
of ozone recorded during 1982, EPA, Region IV does not
anticipate that Birmingham can make the demonstration of
attainment. The area is on the Tier II list of areas
subject to sanctions.
Because Alabama has already adopted regulations for the
control of major sources of VOC covered under Groups I and
II of the CTG documents, a more in-depth analysis will have
to be done in order to determine additional control require-
-------
ments required to attain the ozone standard. A thorough
investigation of the sources controlled and not controlled
and their corresponding emissions must be prepared. The
analysis to determine the most cost-effective emission
reductions should include possible reductions from tran-
sportation control measures and a vehicle inspection and
maintenance program. After a National policy is established
for this type of situation, EPA Region IV can initiate work
with the State to evaluate and develop the most cost-
effective plan to bring about attainment of the ozone
standard in Birmingham as expeditiously as practicable.
c. Southeast Florida - Ozone Nonattainment
Southeast Florida has a history of violating the ozone
standard. Generally, ozone concentrations in the South
appear to be declining at many ambient monitoring sites. In
southeast Florida, the trends are downward, but ambient
levels are still well above the standard in Dade County. In
1978, the three county area (Palm Beach, Broward and Dade)
was designated nonattainment for ozone. Palm Beach and
Broward Counties have sufficient data to demonstrate attain-
ment, if considered separately. Since EPA policy is to
consider an entire urbanized area as a single unit, ambient
ozone violation of the NAAQS in Dade County would mean the
entire three county area remained nonattainment. This area
in on the proposed Tier II list of areas subject to sanc-
tions.
One of the major contributors to the formations of
ozone in the Southeast is emission from automobiles. Exces-
sive rates of tampering/fuel switching contribute to this
problem by introducing additional pollutants to the atmos-
phere. An EPA national survey has indicated Dade County has
the second highest tampering/fuel switching rate of ten
locations surveyed (22.3% compared to 16.7% national aver-
age), in recognition of this concern, EPA has awarded a
grant to Dade County to investigate the tampering/fuel
switching problem. The grant will provide assistance in (1)
documenting tampering/fuel switching by taxicabs and private
school buses; (2) assessing options in strategies to reduce
tampering/fuel switching including development of a local
ordinance prohibiting such action if the problem is verified
by the study; and (3) increasing public awareness of the
problems resulting from tampering/fuel switching. EPA will
be assisting the County by providing technical expertise
during the grant period. EPA Headquarters has announced
recently that DIP credits and possible Section 105 grant
monies will be available to State/local agencies for anti-
tampering/fuel switching efforts.
-------
The efforts in Dade County will be looked upon by EPA
as a "pilot" program which may develop into a region-wide
effort where high ozone levels are attributed inpart to tam-
pering/fuel switching.
d. Louisville, Kentucky
Louisville is nonattainment for the following National
Ambient Air Quality Standards:
National Ambient Air
Pollutant Quality Standards
Total Suspended Particulates Primary and Secondary
Sulfur Dioxide Primary and Secondary
Carbon Monoxide *Primary
Ozone *Primary
*Secondary standard same as primary standard.
(1) Ozone and CO Nonattainment
As a condition of EPA's approval of Louisville's Part D
plan as part of the Kentucky SIP, Louisville was required to
implement an I/M program to reduce hydrocarbon and carbon
monoxide emissions. The program was not in place as of
December 31, 1982. The local agency adopted vehicle inspec-
tion and maintenance regulations in January 1983 and has
scheduled startup for July 1, 1983 (although January 1, 1984
is more likely.) Vehicle inspection maintenance is neces-
sary to attain standards by 1987 for both carbon monoxide
and ozone and thus Region IV will make every effort to
ensure the startup of the I/M program in a timely fashion.
The 1981 monitored carbon monoxide concentrations were
approximately equal to the 1977 figures, further emphasizing
the need of the vehicle inspection program. The ozone
analysis indicates ambient monitoring figures slightly below
the standard, but this is not considered part of a downward
trend, since in previous years the maximum readings have
fluctuated up an down in alternate years.
(2) Total Suspended Particulate Nonattainment
The County is on the Tier II list of areas not expected
to have attained the TSP standard by December 31, 1982.
The total suspended particulates emissions inventory
and attainment strategy for Jefferson County should be
updated. The 1981 Reasonable Further Progress report for
this are does not indicate Reasonable Further Progress
toward attainment. The total suspended particulates emis-
sions line is above and diverging from the Reasonable
Further Progress line. The emissions inventory and control
strategy update must be planned in light of the impending
114
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change to the particulate ambient standard. Resources
required to perform the update may differ considerably,
depending on which standard is targeted, the present total
suspended particulates standard or the impending inhalable
particulate standard.
(3) Sulfur Dioxide Nonattainment
The nonattainment problem in Jefferson County is mostly
due to emissions from Louisville Gas and Electric coal-fired
power plants. The plants account for 91% of the total
sulfur dioxide emissions. The 1981 report for this area
does not indicate Reasonable Further Progress toward attain-
ment. The total sulfur dioxide emissions line is above and
diverging from the Reasonable Further Progress line (1981)
total emissions 141,600 tons per year; attainment at 90,200
tons per year. Each unit should be in compliance by January
1, 1985. The area will probably be attainment before 1985
due to installation and startup of two retrofitted flue gas
desulfurization units in 1982.
The Air Pollution Control District of Jefferson County
is considering the possibility of redesignating portions of
the County to attainment for total suspended particulates
and sulfur dioxide in areas where ambient monitors indicate
attainment. The remaining portions which are nonattainment
are unlikely to attain the standards without additional
measures taken, such as installation of Flue Gas Desulfuriz-
ation.
Resolution of the nonattainment strategy for Jefferson
County will require Headquarters aid in securing contractual
assistance for portions of work. Achieving the National
Ambient Air Quality Standards for the four applicable
pollutants will require considerable Regional resources to
ensure attainment of the standards in an expeditious manner.
Region IV must be prepared to provide technical assistance
to the local agency and to provide review and approval of
proposed attainment strategies.
e. Knoxville, Tennessee - Carbon Monoxide Nonattain-
ment
Knox County has been designated nonattainment for
carbon monoxide with a 1970 Census under 200,000, the State
was not required to submit control measures in 1979 under
the Clean Air Act requirements. Monitoring data indicate
that reliance on the Federal Motor Vehicle Control Program
will not bring Knox County into attainment. The area is on
the Tier II list of areas subject to sanctions.
Under the new census, Knox County is now over 200,000
population and thus the State may be required to prepare and
submit a State Implementation Plan revision pending guidance
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from EPA and/or Clean Air Act revisions. Guidance on the
exact State Implementation Plan requirements and schedule of
activities will be necessary from Headquarters. Without
guidance, the State will be hesitant to develop an action
plan. The State has expressed an urgent need for guidance,
particularly in light of the proposed sanctions for this
area.
f. Coal Conversions at Florida Power Plants
Florida is highly dependent upon fuel oil for genera-
tion of electricity. Fifty percent of the generating
capacity in the State uses heavy fuel oil as the primary
fuel. Due to uncertain supplies and prices, the two largest
electric utilities in Florida, Florida Power and Light and
Florida Power Corporation, are evaluating conversion of at
least eleven units, totalling 4000 MVm from oil to coal
fuel. These units consume about 24 millions barrels per
year of No. 6 fuel oil. Present actual sulfur dioxide
emissions from the eleven units are approximately 231,000
tons per yer. After conversion to coal, the actual emis-
sions could be over 700,000 tons per year depending on
interpretation of present State law, 1981 capacity factors
and the State Implementation Plan limit of 6.17 Ib/MM BTU.
This increase would create a tremendous burden on Florida's
air quality. This burden is in addition to that created by
a recent State Implementation Plan relaxation allowing a one
and one-half times increase in oil-based sulfur dioxide
emissions from most of Florida Power and Light's generating
units.
Region IV, in conjunction with the Florida Department
of Environmental Regulation, will be deeply involved with
this project. In the beginning stages, a number of policy
questions concerning regulatory applicability must be
addressed. Resolution of Prevention of Significant Deteri-
oration and New Source Performance Standards applicability
has already begun. As applications are being prepared and
submitted by the utilities (one permit application is under
review now), EPA will concurrently review each permit
application with the State. There will probably be public
hearings associated with many of the conversions. Florida's
reliance on tourism as a major industry and its large
population of elderly people, cause public participation in
an any environmental relaxation to be greater than in most
States. Florida is planning to adopt a fuel conversion rule
to accomodate the coal conversions. Significant resources
will need to be devoted to rule preparation and review,
evaluation of environmental impacts and participation in
public hearings. Four of the units will impact Everglades
National Park, and conversion will necessitate coordination
with the National Park Service. If Florida Power and Light
-------
applies to increase emission at those units it can be
expected to apply for Class I variance, creating additional
public involvement.
The Department of Energy is studying these plans for
possible issuance of fuel conversion orders. If this
occurs, experience has shown that EPA will be extensively
involved in negotiating the conditions needed to insure
compliance with National Ambient Air Quality Standards,
Prevention of Significant Deterioration increments and
emission standards.
Under any scenario for fuel conversion, EPA will need
to devote significant technical resources to the overall
project, including air quality modeling, air monitoring
plans, control equipment specification review, determination
of appropriate emission limits, and assurance of compliance.
in
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SYNTHETIC FUEL FACILITIES
1 . Introduction
Region IV is expected to continue to be one of the more
active areas of the country for the proposed development of
synfuel facilities. Presently there are 12 projects in
Region IV under active consideration for financial assist-
ance of the Syntethic Fuels Corporation (SFC). (Figure SF-1)
There is no typical synfuel project and indeed many of
the processes used with the synfuel proposals are not new.
The problem is that the processes are being used and con-
nected together in new ways such that the operation and
waste emissions are not reliably known. This causes an
uneasy feeling on a large part of the public that waste
emission from synthetic fuel projects may cause irreparable
harm to people and the environment.
The Energy Security Act (ESA) established the U.S.
Government policy to support development of a U.S. Synthetic
Fuel Industry. The EPA role in support of this policy is to
insure, through consultation with SFC and their applicants,
that the industry develops in an environmentally safe
manner. The mechanism for this consultation is Section
131(e) qf the Energy Security Act which calls for SFC
applicants to prepare environmental monitoring plans (EMPs).
The conference committee report describes the EMP as helping
to characterize and identify areas of concern and develop an
information data base for the mitigation of problems asso-
ciated with the replication of synthetic fuel projects.
2. Active Projects in Region IV are:
a. Peat Methanol Associates (PMA)
The sponsors propose to initially harvest peat
from 15,000 acres on the Pamlico-Abermarle penin-
sula of North Carolina and will use a KBW gasifier
to produce 4600 BPD of methanol in 1985.
b. North Alabama Coal Gas
This coal liquefaction project to be located at
Murphy Hill, Alabama was orginally developed by
TVA. The sponsors expect to produce 28,000 BPD of
methanol in 1986.
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c. Kensyntar
This tar sands project has mineral leases for
17,000 acres near Mammoth Cave National Park,
Kentucky., A pilot project is in operation now;
however, full scale production of 10,000 BPD of
heavy oil would not be achieved until 1987.
d. Mid South Synfuels
This industrial fuel gas project would convert
3100 tons of coal to 167 MCF gas per day at
Memphis, Tennessee.
e. Breckinridge
This H-coal facility was mainly sponsord by
Ashland Oil Company at Breckinridge County,
Kentucky. Coal would be converted to 25,000 BPD
of oil equivalent products.
f. W. R. Grace
This coal liquefaction project at Baskett,
Kentucky would convert 7700 TPD to 12,500 BPD
, gasoline beginning in 1988.
g. SRC-1
This direct coal liquefaction facility at Newman,
Kentucky would convert 6000 TPD coal in the
equivalent of 20,000 BPD oil derived fuels and
energy products.
h. American Syn-Crude Project
This oil shale project, located in Olive Hill,
Kentucky, is proposing to produce shale oil using
the "Petrosix" technology. Construction would
begin in 1985, with start-up scheduled for 1989.
i. Means Oil Shale Project
This oil shale project is located in Montgomery
County, Kentucky. Southern Pacific Petroleum and
Central Pacific Mineral are joint sponsors who
propose to extract oils from eastern shale to
produce 13,440 barrels of upgraded shale oil per
day. Full operation of the plant is scheduled for
the second quarter of 1988.
j. Tennessee Synfuels Associates Projects
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This coal liquefaction project is located in Oak
Ridge, Tennessee. Koppers Synfuels Corporation
proposes to convert coal to gasoline using KBW
gasifiers, M.W. Kellog methanol synthesis an the
Mobile MTG catalytic process to produce gasoline.
The project will produce 10,000 BPD oil equivalent
product. Initial production is scheduled for
1987.
k. Falcon Sciences Project
This tar sands project in Butler County, Kentucky
will produce 2000 barrels of oil per acre per
year.
1. Kentucky Tar Sand Project
This tar sands project in Logan County, Kentucky
is sponsored by Texas Gas Development Corporation
and will produce 5000 BPD of heavy crude oil.
Construction is shceduled to begin in October 1983
with start up in late 1986.
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REGION IV
ACTIVE SYNFUEL PROJECTS
Falcon Sciences Project
Kensyntar
Breckinridge Project
WR Grace
SRC-1
American Syn-Crude Project
Means Oil Shale Project
Kentucky Tar Sand
Mid South
Svnfuels
'Peat
Methanol
Associates
Svnfuels
North Alabama Coal Gas
Figure SF - 1
IQI
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ELECTRIC POWER GENERATION
1. Introduction
Between 1970 and 1981, Region IV led all other Federal
Regions with just over 20 percent of the nation's total
electric utility net generation. During this time period,
the Region also had over 20 percent of the nation's total
generating capacity. In the region, net generation grew by
64.3 percent and plant capacity by 95.3 percent between 1970
and 1980 (See table below) compared to the nation's 49.3 and
79.9 percent, respectively.
The net generation by fuel source mix in Region IV
reflects the reliance on coal and nuclear power plants and
is shown in Figure EP-1. Region IVs net generation by oil
is influenced by Florida's heavy use of fuel oil, which
represents about 88 percent of the Region's net generation
by oil.
Fossil fuel consumption (primarily coal) in Region IV
increased between 1970 and 1980, as shown on Figure EP-2.
Figure EP-3 shows the projected power plant capacities
in 1990 for Region IV. The extraordinary increase in
nuclear .capacity relates to its operating cost advantage
over the fuel sources in the region.
Coal
Oil
Gas
Nuclear
iyvu
Capacity
65,096
26,823
5,639
15,908
19bU
Capacity
99,483
28,313
°1
47,770'
% Increase
52.8
5.6
0
200.3
Adjusted for nuclear plant cancellation or deferment.
The increasing use of coal in Region IV will compound
the acid deposition problem. Limited research of acid
deposition's effect on coniferous trees indicates that the
extensive acreages of pine forests in the Region can suffer
damages; if true, this will create far-reaching impacts on
the Region's pulp and paper industry.
2. Intake and Thermal Impacts
More than 100 thermal impact studies (conducted under
Clean Water Act, Section 316(a), and applicable Water
Quality Standards) and/or entrainment/impingement studies
[conducted under CWA Section 316(b)] have been conducted at
power plants in Region IV. With a few exceptions, environ-
-------
mental impacts associated with these facilities have been
found to be within an acceptable range. In general, plants
with the most significant impacts are found at shallow
estuarine sites as compared to fresh water or open ocean
locations. Considering the projected capacity increases,
thermal pollution and intake effects will be of continuing
concern unless plants are carefully sited to avoid impacting
critical estuarine environments.
3. Selenium
The selenium "problem" has become apparent at two
existing p^ant where fly ash is sluiced to an ash pond,
which discharges to a small cooling lake. Since the source
of ash sluice and cooling water at each plant is its cooling
lake, considerable recirculation occurs with limited outflow
from the lake. Because of the intake and discharge of ash
sluice water from the lakes, lake water has increased in
selenium (also arsenic and metals ) concentration. Company
data indicate that continuous exposure to extremely low
levels of selenium (significantly less than 0.01 mg/1)
results in a buildup of selenium in fish tissue through the
food chain to a point where fishery reproduction is serious-
ly reduced or eliminated. Steps to reduce this problem are
underway at one of the plants. Continuing studies are
underway, at the second plant, and were recently instituted
at another similar plant when it became operational. Region
IV and state agency representatives have been involved in
development and implementation of these studies.
Note: The Electric Power Research Institute also has
similar studies underway (and is participating in those in
Region IV), since the problem is surfacing elsewhere in the
U.S. (particularly in Region VI) where ash sluicing and/or
air fallout of selenium from burning lignite coal is causing
similar problems in adjacent small lakes.
-------
UJ
cr
UJ
Q.
70
65
60
55
20
10
Percent of Net Generation by Fuel Source. Region IV
1970 - 1980
COAL
OIL
I970 I97I I972 I973 I974 I975 I976 I977 I978 I979 I960
Figure EP - 1
Fossil Fuel Consumption , Region IV, 1970 - 1980.
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1970 197! 1972 I973 1974 1975 I976 1977 I978 I979 I960
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THE BISCAYNE AQUIFER
1. Description
The Biscayne Aquifer,'a designated Sole Source aquifer,
underlies the southeastern tip of peninsular Florida includ-
ing Dade, Broward, and the southeastern tip of Palm Beach
County. It is a wedge shaped body of highly permeable
limesto'ne and sand which extends from land surface to a
depth of more than 200 feet along the coast and thins out
completely 40 miles to the west under the Everglades. The
aquifer is unconfined and is recharged primarily by rain-
fall. Water levels in the aquifer, which are close to the
surface, respond to and are in direct connection with suface
water bodies such as canals and lakes.
A combination of factors has combined to create a
drinking water quality dilemma in the Biscayne Aquifer: a
groundwater table several inches to several feet below the
surface; a thin aquifer resulting in shallow water supply
wells, large amounts of rainfall to transport surficial
contamination and a relatively flat, porous ground surface
with several million people and associated domestic, commer-
cial and industrial activities at its surface. This area is
one of the most vulnerable to groundwater contamination in
the Region, and is the most significant problem in terms of
the number of people impacted. Prevention of groundwater
contamination and clean-up of existing contamination in the
Biscayne Aquifer are difficult problems with no easy solu-
tions; however, the high stakes involved in terms of public
health impacts warrant serious consideration and action by
the agency.
2. Drinking Water Dilemma
In 1974 EPA conducted a National Organics Reconnais-
sance Survey (NORS) which analyzed water in 80 cities for
organic constituents. Miami, which was one of the cities
chosen, had the highest level of chloroform (311 ppb) of any
city, in addition to detectable levels of 34 other volatile
organic compounds. A total of 76 organic compounds of all
types were detected. The samples which yielded these
results were taken from the Preston well field, one of the
major water supplies in Dade County. A follow-up study
which was performed by the Region confirmed the findings of
the NORS. The results showed that some of the organics were
formed in the treatment process (trihalomethanes) but also
that many organic compounds were present in the raw water
and passed through the treatment process with little or no
change in concentration.
These findings prompted the County to use part of their
208 grant money to conduct an area-wide survey of drinking
water supplies. Raw water was collected from 216 wells
-------
across the county representing approximately 66 different
water supplies. The samples were analyzed for 15 different
volatile organic chemicals; a number of them are known or
suspected animal carcinogens. The results demonstrated that
widespread, low level contamination exists across much of
Dade County. Only 10% of the wells were completely free
from contamination. Traces of contamination (less than 1
ppb) were found in approximately 50% of the wells. While
these levels are not of an immediate health-related concern
they do indicate the susceptibility of this aquifer system
to man-made domestic, industrial or commercial contaminants
and the potential for higher levels of contamination depend-
ing on the activity at the surface.
The results of the survey also demonstrated that
significant contamination existed in certain wellfields or
individual wells. Forty percent of the wells studied
contained between 10 ppb and 223 ppb for the combined total
of all 15 volatile organic chemicals. The Preston/Hialeah
system was determined to be one of the most contaminated
water supplies. The Preston and Hialeah wellfields, which
are located in the same general area of Miami, are connected
to two separate water treatment plants, but the plants are
interconnected and are considered as one unit. This system
supplies water for approximately 750,000 consumers. All of
the wells in the Preston wellfield and 15 out of 23 wells in
Hialeah contained between 10 and 175 ppb total of the 15
volatile organic chemicals. The results of the survey also
demonstrated that 11 out of 20 wells supplying the Sunny
Isle water treatment plant in North Miami Beach contained
totals between 10 and 223 ppb. At least 5 other water
systems were shown to have significant contaminations and a
number of single wells included as a part of a larger water
supply system demonstrated levels of concern. It is impor-
tant to note that these samples were raw water samples which
did not reflect the total trihalomethane (THM) concentra-
tions. In many cases in Dade County, the total THM would
increase significantly the total volatile organic concentra-
tion occurring in the water supply.
A follow-up study implemented by Dade County on the
Preston/ Hialeah area demonstrated that land uses character-
ized as industrial or commercial are associated with higher
levels of synthetic organics in the underlying groundwater.
In the case of Preston, Hialeah, North Miami Beach, and
probably many of the impacted wells, this observation may
explain the occurrence of these chemicals in the ground-
water.
A more recently discovered contaminated well supply is
the Medley wellfield which is located to the north of the
Preston wellfield and on the edge of an industrial/commer-
cial area, as well as directly west of a listed Superfund
site. It is used to supplement water supplies at the
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Preston water treatment plant, In the first half of 1982,
Medley wells #3 and #2 together were pumped an average of
408 hours per month or 17 full days per month. In May,
1982, Medley 13, which is pumped most frequently, contained
210 ppb volatile organic chemicals, and in September it
contained 122 ppb including vinyl chloride, dichloroethylene
and dichloroethane. (The September data may not include a
complete survey of all volatile organic chemicals). Water
from the Medley wellfield is mixed with water at the Preston
Plant before it is distributed. At one point, complaints by
consumers of taste and odor problems coincided with the
introductions of Medley water into the system. This event
generated local press coverage and prompted the Region to
write the Florida Department of Environmental Regulation
requesting that Medley be taken off-line as soon as pos-
sible .
In September of 1982, finished water from the Preston
water treatment plant contained levels of vinyl chloride,
dichloroethylene, tetrachloroethylene and dichloroethane in
excess of the one in a million cancer risk for lifetime
exposure to these chemicals. But even though county offi-
cials are concerned about the health implication of these
chemicals, they do not have the luxury of abandoning a
wellfield or even the most contaminated wells such as those
in Medley. Water shortages occur during dry periods which
require'the use of most water supply wells. The only option
they have is to drill new wells to replace the contaminated
supply wells. A new wellfield containing approximately 15
wells, which is located in a presently undeveloped portion
of the county, is in the final stages of construction and
should be on-line this year. At that time, they will reduce
their dependence on the Preston/Hialeah wells (and reported-
ly discontinue the use of Medley). While this is seen as a
major remedial action that is urgently needed, it is not
seen as the end to the problem. Growth in the area will
demand that more and more water from the Preston/Hialeah
wellfields be provided. Also, intense commercial and
industrial development pressure for land within the cone-
of-influence of the new wellfield is occurring which may
result in degradation of the new supply.
Last year, an EPA contractor sampled and analyzed
approximately 13 water samples from the Biscayne Aquifer as
part of the national Groundwater Supply Survey. All six
community water supplies in Broward County were found to
contain traces of contamination, but only one, the City of
Hallandale, contained levels of volatile organics which
prompted EPA to notify the community that use of two of the
wells should be discontinued and another monitored on a
frequent basis. All six supplies in Broward County con-
tained total THM concentrations above 100 ppb, the EPA
standard. Of the five community supplies sampled in Dade
County, only one was found to contain significant contamina-
-------
tion to prompt EPA to recommend that two of the wells be
monitored on a frequent basis. The one supply in Palm Beach
County within the Biscayne Aquifer was free of contamina-
tion. The Groundwater Supply Survey is discussed in more
detail in a discussion of organic contamination in the
Drinking Water Section of this report.
Recent data obtained by the Region indicate that the
City of Ft. Lauderdale's water supply is threatened by vinyl
chloride contamination. Use of several wells in the most
eastern part of the wellfield has been discontinued due to
levels of vinyl chloride as high as 554 ppb. The City is in
the process of addressing remedial measures at this time.
Synthetic organics are not the only type of contamina-
tion occurring in the Biscayne Aquifer. Bacterial and viral
contamination of the groundwater can occur in localized
areas. Two epidemics, typhoid and gastroenteritis, were
reported in 1973 and 1974, respectively. Also, agricultural
practices have contaminated the groundwater with nitrate in
portions of the agricultural region of South Dade.
3. Sources of Contamination
Sevjen hazardous waste sites listed on the National
Superfund Priority List are located on top of the Biscayne
Aquifer. All have contaminated the groundwater to varying
degrees. Four of these, Gold Coast Oil, Miami Drum, the
Varsol spill and the 58th Street Landfills are located in
the immediate vicinity of the Preston/Hialeah wellfields. A
Superfund study is in progress to determine the full extent
of the impact on the groundwater system from three of these
sites. One of the other hazardous waste sites, Hollings-
worth Solderless Terminal Company, is located within the
cone of influence of Ft. Lauderdale's wellfield where use of
several wells has been discontinued due to vinyl chloride
contamination.
Other hazardous waste sites not occuring on the nation-
al Priority List such as a wood preserving facility and a
battery recycling facility have contaminated the ground-
water. Other sites are just being discovered such as the
Pepper Steel and Alloy Company that disposed of used trans-
formers on the ground resulting in suspected PCB contamina-
tion of the groundwater.
There are a total of 265 hazardous waste facilites in
Dade and Broward County which notified the Agency in
response to the RCRA requirements. Only 9 of those are
disposers; however, any facility handling hazardous waste
holds the potential to contaminate the groundwater as a
result of spills and leaks.
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Areas of concentrated industrial and commerical estab-
lishments are another source of contamination to the
aquifer. These areas are characterized by many different
types of activities ranging fom manufacturing plants to
laundromats to automobile salvage operations. While most of
these facilities probably do not use large quantities of
hazardous or toxic chemicals, many of them may use small
quantities of a variety of chemicals, solvents being one
class most commonly used. Some of these areas are unsewered
and use septic tanks or french drains for their wastewater
disposal. This type of disposal mechanism provides the most
direct path of contamination into the aquifer system.
Contaminated surface drainage from production areas onto the
ground, or spills and leaks, or leachate from solid waste
disposal areas could also result in introduction of contami-
nants into the aquifer.
Outside of the industrial and commercial areas, sources
of groundwater contamination may include wastewater disposal
in the form of septic systems, percolation ponds or spray
irrigation fields. Stormwater runoff could potentially
enter the aquifer through rock pit lakes or (borrow) ponds
and cause quality degradation. Use of agricultural chem-
icals has caused problems in certain areas. Any spill or
leak is likely to cause some degradation of the groundwater.
4. A Step Toward Unified Action
Continued assaults on the Biscayne Aquifer threaten its
usefulness as a drinking water supply. While federal, state
and local governments have taken steps individually to
reduce these attacks, the continued viability of this sole
source of fresh water for over 3 million people cannot be
entrusted to a splintered approach. The affected counties
and all branches of state and federal government must have a
common plan to guide their actions. The stakes are too
critical to allow piecemeal actions to alternately protect
and degrade the aquifer. Recognizing that this situation
cannot be allowed to continue, Region IV proposes (subject
to Headquarters approval) to develop a management plan for
the protection of the Biscayne Aquifer. Several federal,
state and local agencies have agreed to join in this task.
The final report would present a preventative action program
with specific guidelines for the protection of the Biscayne
Aquifer potable water supply.
PESTICIDES
1. Pesticides Contaminating Groundwater
Emerging problems may be identified in a number of
areas. The inability to be able to perfectly forecast
biological degradation and movement of pesticidal compounds
200
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under all environmental conditions (soil type, moisture,
temperature, light, etc.) could lead to these compounds or
the metabolites showing up in unexpected places. Certain
organophosphates may be found to appear in groundwater where
applications were assumed to be made with very little such
risk. The same may be said for chlorinated hydrocarbons and
carbamates. Consequently, the contamination of groundwater
and drinking water is a valid concern of everyone and Region
IV has not escaped this problem. A program of groundwater
monitoring conducted by industry and various departments of
state government was implemented recently in Florida when
residues of aldicarb showed up in water samples. While no
residues of aldicarb have been found in citrus products
entering commerce, contamination has been found in drinking
water wells surrounded by citrus groves that had received
treatments with the chemical. The findings led to a state-
wide ban on TEMIK use, pending more extensive testing and
analysis.
Groundwater contamination and monitoring issues were
also the basis of the DBCP Section 18 exemption request and
ultimate request for withdrawal in South Carolina. The
Agency refused to withdraw its approval of the exemption.
The State identified its inability to perform the proper
groundwater monitoring program (certain State and private
individuals had voiced concern over leaching and contamina-
tion) as justification for withdrawal request action.
Major concerns were raised for some individuals in
isolated areas of North Carolina with regard to contamina-
tion of water supplies from picloram. Because much of the
reporting of these incidents involved unsubstantial claims
of health effects, no new formal action has been taken by
any governmental body regarding the compound. However, it
is viewed as a problem for Region IV in the entire context
of groundwater contamination. Pivot irrigation utilizing
chemicals (chemigation) is a new potential source of ground-
water problems. This is particularly so because even though
the practice is becoming more common, only one state
(Georgia) has a requirement that anti-siphon devices be made
a part of the irrigation system.
2. No Till Cropping and Payment in Kind - Changes in
Pesticide Use Patterns
This pesticide use is balanced by a benefit to the
environment. Reduced erosion saves both the nutrients
applied as well as the cropland, giving rise to both imme-
diate and long-term savings to the farmer. In addition,
minimizing erosion reduces the greatest quantity of pollu-
tants in surface water, namely sediment. It is estimated
that by the year 2000, 65% of all major crops will be
produced utilizing a no till farming system. The payment-
in-kind (PIK) acreage diversion plan announced by the U.S.
201
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Department of Agriculture could also lead to increased uses
of herbicides and possibly insecticides. One industry
expert forecasts participation in PIK at 20-23 million acres
in 1983. In part, participation in PIK requires that weeds
be controlled on the diverted acres and that sufficient
cover be allowed to prevent loss from erosion. Specifying
weed control on the diverted acres is sound business.
Vegetation growing on the non-cropped land provides a good
habitat and alternate host for insects or potential crop
diseases. Consequently increased herbicide use for weed
control may necesarily be accompanied by increased use of
insecticides or fungicides.
The use of herbicides may be expected to increase
markedly in the near term. If used properly and in accord-
ance with label direction, the use of these herbicides
should show a considerable benefit to the environment. No
till crop production is expected to increase by several
hundred thousand acres in Region IV. No till cropping may
reduce sheet and rill erosion by 50-90%. Sheet and rill
erosion is responsible for the majority of soil erosion in
Region IV. To achieve this reduction through no till
cropping could result in a 20 to 35% increase in herbicide
application.
202-
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