U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V
FY 1985 ENVIRONMENTAL MANAGEMENT REPORT
Valdas V, Adamkus
Regional Administrator
Alan Levin
Deputy Regional Administrator
September 12, 1985
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Table of Contents
Part Page
I Regional Administrator's Commentary 1
II Regional Environmental Problems 5
A. Hazardous Waste Management and Response 6
1. Hazardous Waste Response 6
2. Hazardous Waste Management 8
B. Contamination of Goundwater 12
C. Discharge of Toxic Materials to Water 15
Contaminated Sludge 17
D. In-Situ Pollutants 18
PCBs 20
E. Violation of Primary Ambient Air Quality Standards 22
F. Synthetic Organic Chemical Contamination of Drinking Water 26
G. Toxic Substances - Existing Chemicals 28
1. Pesticides Misuse 28
2. Asbestos 30
H. Air Toxics 31
I. Great Lakes Areas of Concern 33
J. Nonpoint Source Runoff to Water 35
K. Protection of In-land Lakes 37
1. Cultural Eutroplncation 37
2. Preservation of Wetlands 39
L. Combined Sewer Overflows 41
M. Emerging Problems 43
1. Indoor Air Pollution 43
2. Vehicular and Industrial Emitted Lead in Soil 44
Hi Recommendations for the Agency's Priority List 45
Appendices
A. Environmental Indicators - Southeast Chicago Study
B. Ai r Addendum
C. Great Lakes National Program Office
Areas of Concern - Remedial Action Planning
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Region V FY 1985 Environmental Management Report
Part I - Regional Administrator's Commentary
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2
This Environmental Management Report chronicles not only the major events
of this past year but documents the challenges and changes Region V will face
in the coming year.
The Hazardous and Solid Waste Amendments initiate several entirely new
programs, and mandates some difficult deadlines for their completion.
We are awaiting reauthorizations of several major pieces of environmental
legislation including the Clean Water Act and Superfund. They will bring
substantial changes in our program operations for FY 1986.
Our increased understanding of the groundwater problem in the Region has
caused it to become a significant priority in almost all Regional programs
The Region is facing requirements and statutory timeframes for actions that
will challenge our scientific and regulatory capabilities. A prime example
is corrective actions at solid waste units.
We have limited ability to control several intractable conventional pollutants
which are widespread problems affecting large numbers of people. For example,
particulates are a major air pollution concern, but no progress has been made
on getting full SIP attainment demonstrations because we are still awaiting
the PM-10 standard. Until such SIP demonstrations are made and regulations
developed, there will be no further progress towards attaining the particulate
standard in unattainment areas.
Combined sewer overflows are a major water quality problem, but the Agency
has not yet provided the technical means to set standards for high flow
permit conditions, or criteria for evaluating what construction projects we
should fund to alleviate such problems.
There are special Regional concerns I feel need to be articulated. First, the
Great Lakes National Program Office (GLNPO), with active State involvement, is
participating in an international effort to prepare and update remedial action
plans for 42 Great Lakes areas of concern. This is a significant undertaking
and deserves the support of the national program offices and jurisdictions. In
particular, we need to formulate solutions for in-situ pollutants, toxic air
deposition, combined sewer overflows and non-point source control for the Great
Lakes.
The extent of the issue of in-situ pollutant dilemma is peculiar to Region V and
was highlighted by most of the States. Region V shares this problem with Regions
II and III, and perhaps with some other Regions where these sediments are a
concern. But the extent of the problem in Region V is much greater - virtually
every Great Lakes harbor and stream in industrialized areas have sediments
contaminated by PCBs and other pollutants. There are numerous jurisdictions
involved, and several major actors, including EPA and the Corps of Engineers
(COE). These jurisdictions and the COE are looking to EPA for answers on how
to handle these contaminated sediments when those rivers and harbors must be
dredged. Section D of Part II, the in-situ pollutant problem assessment discusses
some of the more technical aspects of the problem, but it does not portray the
Region's management concerns in dealing with this problem.
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The basic problem we face is to define affordable and environmentally
acceptable alternatives for proper dredge spoil disposal. For example, EPA's
official technical guidance for disposal of contaminated dredge spoils with
PCB concentrations above 50 ppm is to incinerate or landfill them in approved
facilities. The sheer volume and saturation of the dredge spoils make this
technically and economically infeasible. COE has suggested several alternative
disposal methods that have, so far, been unacceptable. To resolve this problem,
Region V will be working to develop disposal alternatives acceptable to both
EPA and COE.
From Subtitle D to Clean Lakes, the States are concerned about funding for
many of the issues this EMR discusses. They are especially concerned about
being asked to expend resources to address some of the noted emerging problems
and programs, while simultaneously being required to continue existing program
activities - all without new funding. Considering that many of these new
problems and programs are complex issues for which there are few accepted
technical answers and little implementation experience, their resolution
will take time and carry a substantial price tag.
the
n
Our State partners have specific concerns about adequate funding for
creasing needs of laboratories. Because so much of our current effort is
related to controlling toxic pollutants, the ability to sample and analyze
for such substances is vital to program success. There are already shortages
of trained personnel, equipment and analysis capacity in each of our State1s
labs. Without appropriate funding and an appreciation of the implications
of this problem by the national program managers, the lack of State lab
capability may become a limiting factor for States in assessing environmental
conditions and meeting program commitments.
I would like to call your attention to another important aspect of this report.
We have made a special effort to focus on environmental indicators in our
Part II Section's, "Expected Environmental Results" narratives. While I feel
we have developed innovative indicators for a number of problems (CERCLA, PCBs,
Asbestos, Nonpoint Source Runoff, Protection of Inland Lakes, CSO), we have
highlighted our Air Management Division's efforts at documenting the environ-
mental results. That documentation is included as Appendix B and is referenced
extensively in Air's Part II problem assessment.
Finally, as part of OPPE's Environmental Indicators development effort, we
have included a case example - Appendix A, Southeast Chicago - a Case Study
of Environmental Planning. This study describes our experiences in trying to
deal with one area's multi-media environmental problems. Environmental indi-
cators played a special role in this study. We are planning to explore ways to
use our experiences there to develop an environmental indicators-based planning
project involving another geographic area with multi-media problems.
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Region V FY 1985 Environmental Management Report
Part II - Regional Environmental Problems
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5
PART II
REGIONAL ENVIRONMENTAL PROBLEMS
Following is a list of what Region V considers to be its most pressing environ-
mental problems. The Region's program managers felt that because of the single
media nature of our environmental laws, inter-media ranking was not really
appropriate. The real ranking came in the selection of our major environmental
problems and the intra-media order of problems. Our overall ranking was done to
agree roughly with the Agency Priority list and partially by intramedia ordering
by the media program managers. That intramedia ordering is based on a number of
factors dictated by experience, including public health threat, potential for
environmental damage, relative intractability of the problem, public interest,
State program priorities, and other related considerations.
RANKING OF REGION V MAJOR ENVIRONMENTAL PROBLEMS
A. HAZARDOUS WASTE MANAGEMENT AND RESPONSE
1. Hazardous Waste Response
2. Hazardous Waste Management
B. CONTAMINATION OF GROUNDWATER
C. DISCHARGE OF TOXIC MATERIALS TO WATER
Contaminated Sludge
D. IN SITU POLLUTANTS
PCBs
E. VIOLATION OF PRIMARY AMBIENT AIR QUALITY STANDARDS
F. SYNTHETIC ORGANIC CHEMICAL CONTAMINATION OF DRINKING WATER
G. TOXIC SUBSTANCES
EXISTING CHEMICALS
1.
Pesticides Misuse
2.
Asbestos
H. AIR TOXICS
I. GREAT LAKES AREAS OF CONCERN
J. NONPOINT SOURCE RUNOFF TO WATER
K. PROTECTION OF WATER QUALITY IN INLAND LAKES
Preservation of Wetlands
L. COMBINED SEWER OVERFLOW
M. EMERGING ENVIRONMENTAL PROBLEMS
1. Indoor Air Polution
2. Vehicular and Industrial Emitted Lead in Soil
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A. HAZARDOUS WASTE MANAGEMENT AND RESPONSE
1. Hazardous Waste
onse
Problem Assessment
Region V has 192 of the 812 uncontrolled hazardous waste sites on the National
Priorities List (NPL). Sixty-one of these sites are in Michigan, 34 in Minnesota,
28 in Ohio, 24 in Wisconsin, 23 in Illinois, and 22 in Indiana. Region V antici-
pates 16 more sites will be added to the NPL in August, 1985. The Region also
has over 4,000 abandoned hazardous waste sites that are not on the NPL, but which
may still threaten human health or the environment. The concentration of heavy
industry and agriculture in the Midwest and the associated number of uncontrolled
hazardous waste sites have raised the public's concern and level of understanding
of the immediate public health threats of Superfund sites. They also understand
many site contaminants are potential carcinogens or mutagens which have the poten-
tial to cause serious long-term health effects. This level of public concern and
awareness of the risks associated with Superfund sites has placed great demands on
our emergency remedial response program.
The primary environmental threat from hazardous waste sites in Region V is
contamination of groundwater wnich the Region relies on for private, municipal,
industrial, and agricultural water supplies. In addition, releases of hazardous
substances by generators or transporters in the Region may cause serious public
health threats in areas without adeauate emergency preparedness measures.
enda
Continue program implementation to focus removal actions at sites posing
the most serious threats and to move current and potential NPL sites
through the "pipeline" so remedial activities can be accomplished through
Fund financed or responsible party actions. Region V expects to undertake
about 30-40 new removals in FY 86, and initiate remedial actions at 15 new
sites. Also planned are about 30 new RI/FS and 20 RDs. Special priority
will continue at sites where groundwater is threatened.
900 preliminary assessments will be conducted in FY 86, with 300 sites
undergoing detailed evaluations, including on-site inspections.
With
the completion of 500 preliminary assessments in the remainder of FY 85
and the 900 scheduled for FY 86, the majority of Region V's identified
potential uncontrolled hazardous waste sites will have had preliminary
assessments.
In addition to the above, other Regional FY 86 priority activities will be to
Pursue responsible party clean-ups and cost recoveries.
- Continue to strengthen our relationships with the States,
encouraging them to take the lead role in site clean-ups.
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Continue implementation of the dioxin strategy through exposure studies,
actions to limit exposure, and evaluation of regulatory alternatives.
If appropriate, the Region may take emergency actions or try to place
additional sites on the NPL.
Continue the Community Relations program to improve Agency credibility
and public understanding.
o
During FY 86, Region V will undertake a special initiative to assist States
and local areas in improving emergency preparedness for accidental releases of
air toxics. To begin this effort, U.S. EPA is developing an "acute hazards"
list to identify those chemicals which would pose the greatest hazard if
accidentally released. Accompanying the "acute hazards list" will be guidance
to assist local communities in assessing the hazards of chemicals handled and
stored at facilities, thus allowing the community to determine the potential
for concern. The acute hazards list, the identification of facilities and
the review of existing safety systems will form the basis for communities to
begin developing or enhancing emergency response plans. To support this
initiative to improve responsiveness to accidental releases of air toxics,
Region V will provide training and technical assistance to States and communi-
ties in emergency preparedness and response planning.
Headauarters Actions Needed
o
Planned increases in the number of sites and investigations will raise the
analytical demands on the contract laboratory program. Headquarters should
continue to explore ways to improve data reliability and turnaround time.
Region V has a number of sites that do not now qualify for the NPL, but may
be environmentally significant. Additional resources should be provided to
further investigate these "middle class" sites to allay public concerns and
see if they warrant inclusion in the NPL.
Region V has potentially uncontrolled hazardous waste sites at 42 Federal
facilities. We need procedures to coordinate with the DOD Installation
Restoration Program for a host of activities in addition to remedial actions,
as well as to clarify the RCRA/CERCLA issues resulting from HSWA.
Region V has experienced late and substandard work from Superfund contractors,
and has been billed for cost and level-of-effort overruns. We realize the
Inspector General is looking at this problem but nothing has yet been resolved.
Headquarters should look at available options for improving contractor perfor-
mance, especially the use of firm, fixed-price contracting with guaranteed work
products.
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ected Environmental Results
Protection of public health and the environment has been achieved by both
Removal and Remedial activities under CERCLA. For example, at Burrows Land-
fill (Hartford, MI) open lagoons of corrosive metal hydroxides were removed
to prevent seepage into the local water supply. The removal protected public
health by preventing contact with and/or ingestion of the substances at this
frequently used recreation area. One definite indicator of our success at
this area was the natural aquatic ecology. The populations of various plants
and animals in this area indicated significant stress due to the contamination,
but they have now been restored to their natural, pre-contamination balance.
Groundwater protection was also addressed recently at the Verona Well Field
site (Battle Creek, MI). Prior to remedial action, drinking water from conta-
minated wells resulted in water being supplied to consumers with concentrations
of Volatile Organic Compounds (VOCs) up to 17 ppb, causing an equivalent cancer
risk of 5 deaths each year per 1,000,000 population. Following the initial
remedial measures, VOCs were at undetectable levels.
Similar measures are planned in Fiscal Year 1986 at the Main Street Well Field
(F.lkhart, IN), where an air stripper will remove 99 percent of the VOCs in the
water supply, lowering the equivalent cancer risk to less than one death per
10,000,000. Planned remedial actions are to pump out, clean, and
to the contaminated aquifer, thereby lowering the VOC concentrations of the
aquifier itself.
retur
water
The Kummer Sanitary Landfill near Bemidji, Minnesota, was found to have VOCs
of various types with concentrations up to 49 ppb, which resulted in a
cumulative excessive cancer risk of 333 deaths per 1,000,000 population.
Remedial actions are being taken to restore the water supply from a new well
Bottled water for drinking and cooking is being distributed by the State as
an interim measure.
can quantify the
These are a few examples at sites in Region V where we
ability of Superfund activities to ameliorate the effects of leaking hazardous
wastes on human health and environmental quality.
2. Hazardous Waste Management
Problem Assessment
Region V is concerned with 2 primary hazardous waste problems. The first
is direct threats to public health; groundwater contamination, acute and
long-term toxicity to humans and the environment, explosions, corrosiveness,
and fire. The second problem is institutional: insufficient disposal capacity
for existing and future amounts/types of wastes, their long-term environmental
persistance and stability, the propensity to control one media's hazard by
transferring it to another (e.g., contaminated waste water being placed in
surface lagoons which may leach into the groundwater), and the widespread
extent of the problem. Region V has 265 land disposal and 47 incineration
facilities (17 and 21 percent respectively of the national total).
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These facilities are not concentrated in a specific geographic area.
The
ready mobility of waste allows them to be easily transported, scattering the
problem throughout many areas in the Region. Therefore, both rural and urban
areas in Region V have been affected.
Despite landfil1 ing1s short and long-term risks, it has been the most often
selected disposal option because of its lower initial costs. While realizing
the grave long-term risks - even the best landfills will eventually leak and
require some remedial actions - EPA has been forced to focus on controlling
short-term risks through permits and enforcement actions. The long-term
solution needed is for alternatives which will simultaneously reduce the
total amount of wastes generated and provide sufficient disposal capacity.
There are several other sources of hazardous waste threats to the environment.
A newly recognized threat to groundwater is from Region V's estimated 150,000-
200,000 underground storage tanks. The number that are now or could soon be
leaking, and the impact of these on groundwater is not yet known. Neither do
we know the groundwater impact of the over 10,000 solid waste disposal sites
without groundwater monitoring wells. Some of these sites may have received
smaller quantities of hazardous wastes and all are receiving some amount of
hazardous substances from normal household refuse. Only new solid waste dis-
posal facilities are required to have monitoring wells. In addition to these
concerns, RCRA's lowered exemption level has added about 30,000 newly regulated
small quantity generators to Region
V's
regulated community.
All of these concerns have created tremendous public attention and apprehension,
which has subsequently made it very difficult to site any type of hazardous or
solid waste facility. This situation - high costs and limited disposal capacity
heightens the danger of illegal, "midnight" dumping.
Regional Agenda
During FY 84, Region V began implementing the national accelerated permit
strategy, but was slowed during FY 85 due to passage of the Hazardous and
Solid Waste Amendments (HSWA). HSWA established a number of new require-
ments for land disposal permitting, including much more stringent permit
requirements, a vast expansion of the regulated community, and a corrective
actions program for active and inactive facilities with prior releases. The
corrective action provision requires identification of all past or present
solid waste management units and all releases, requires clean-up actions for
those releases, and demonstration of financial assurance for the completion
of such actions.
To meet these requirements, the Region has implemented a Facility Management
Planning (FMP) process, which includes extensive permitting and enforcement
coordination, and issuing joint State/EPA HSWA permits. Region V has called-in
Part B permit applications for all land disposal facilities and incinerators, but
no land disposal permits have been issued. However, six land disposal facility
closures have been approved. Region V estimates that HSWA could cause about 50
percent of the land disposal facilities and 10 percent of the incinerators to
close voluntarily or as a result of the permitting or enforcement process. The
primary program barriers for Region V include the large number of land disposal
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facilities on which to act, and the tight time frames for facility screening
and FMP development. These problems are exacerbated by the lack of final HSWA
implementation guidance. The Region will attempt to meet these goals using
internal staff, State programs, and contractors.
In FY 86, the Region V certifications, permitting and enforcement focus will
be to:
Evaluate Part Bs received from land disposal facilities to determine
environmental significance. All land disposal facilities will be screened
by January 31, 1986, with completed FMPs to follow by July 30, 1986.
Schedule implementation of all FMPs developed in FY 85.
Address corrective actions for all facility closures with the States
Assess HSWA-mandated exposure information to determine need for full scale
health assessments.
Attempt to increase the rate of permit issuance, supporting issuance/denial
of all disposal and incinerator permits.
Perform comprehensive compliance evaluations of all significant land disposal
facilities posing immediate threats to the environment, especially to ground
water.
Take enforcement actions against all interim status facilities with groundwater
monitoring problems, and all other high priority and Class I violators.
Issue corrective action orders [under §3008(h)] to abate offsite contamination
at TSDs with Solid Waste Management Units.
Work with Illinois, Indiana, Michigan, Ohio, and Wisconsin to assure final
pre-HSWA authorization in early FY 86 (Minnesota is already authorized).
Continue permitting and enforcement work (States now perform about 75 percent
of permitting, about 90 percent of enforcement) with the States through co-
operative agreement and grants, including joint permitting until State receives
full HSWA authorization - especially at Federal Facilities.
Initiate the UST program by providing State grants to process notifications, and
develop approvable programs.
Continue outreach programs, including Education of Small Generators notification
activities, and educating the public on the proper disposal of hazardous
household wastes.
Headquarters Actions Needed
Development of alternatives to land disposal should be ttie top Agency Research
and Development (R&D) priority.
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Develop and issue final regulations and guidance documents for implementation
of HSWA, including the conduct of Comprehensive Groundwater Monitoring
Evaluations (CMEs), areas of vulnerable geology, and Corrective Action Orders,
standards for small quantity generators, LIST regulations, and tank standards.
To determine SPMS targets for FY 86-88, Headquarters should evaluate the
universe of land disposal facilities in each Region and set targets according
to the number of land disposal facilities that can realistically be addressed.
The large number of such facilities in Region V places a strain on State
and Federal resources, and the quality of the program may suffer in attempting
to meet gross numerical requirements.
OSWER should consider modifying the Subtitle D program to include non-hazardous
waste land disposal facilities, many of which also contain hazardous wastes
and present a significant threat to the environment, especially groundwater.
ected Environmental Results
Currently, the RCRA program has few true environmental indicators, most are
indicators of program results expected in FY 86, such as:
A 20 percenc increase in permitted incinerate^ capacity.
All land disposal facilities will have adequate groundwater monitoring
systems, capable of detecting/assessing groundwater contamination, or be
under formal enforcement to install such systems.
A 25 percent increase in the number of facilities in compliance with the
closure and financial requirements.
A reduction in the volume of wastes disposed of at land disposal facilities
An increase in public awareness of hazardous waste problems, as evidenced
by public participation in permit hearings and household hazardous
waste disposal projects.
The most important and most real program result of RCRA/HSWA will be to discourage
and, wherever possible, prohibit land disposal of hazardous wastes. Also, based
on the expansion of the program due to HSWA, previously unaddressed inactive
facility problems can be corrected.
The environmental effects of changes of disposal practices and the corrective
actions programs will be to prevent groundwater contamination and direct soils
contamination. We are still trying to develop measures to describe such progress
on a larger scale but, so far, can only do it for specific areas (see Part II,
p. 3, "Hazardous Waste Response," Environmental Results Expected.)
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B. CONTAMINATION OF GROUNDWATER
Problem Assessment
Approximately 40 percent of the total population and 95 percent of the rural
area population depend upon groundwater as their prime source of drinking
water. Most of this drinking water is withdrawn from shallow aquifers which
are susceptable to contamination from on-going inadequate land disposal of
hazardous wastes, chemical spills, abandoned hazardous waste sites, leaking
underground storage tanks, and municipal land disposal facilities receiving
nonhazardous wastes. Other sources of contamination include improper agri-
cultural practices, failing septic fields, and unregulated underground
injection control wells.
Groundwater protection is among Region V's highest environmental priorities
for several reasons. First, Region V is underlaid with an extensive and com-
plex groundwater regime - it is a tremendously large and widespread resource.
Second, because of Region V's level of industrialization and agriculture and
resultant production and use of hazardous wastes and toxic substances, there
is a prevalent danger of contamination. Simply put, there is a tremendous
amount of groundwater all over the Region V area; there is also a tremendous
amount of wastes/toxic substances in widespread disposal/use; and therefore,
there is a commensurate potential for groundwater contamination.
Also,
Region V has several unique areas such as Wisconsin's Central Sands and Minne
sota's karst a^ea whose unusual geological/hydrogeological characteristics
make them extremely vulnerable to groundwater contamination.
EPA's authorities to control these contamination sources are almost exclusively
site-specific, in that they do not address multiple contamination sources in
specific geographic areas. There is an exception in that CERCLA can include
the effects of multiple contamination sources in their site ranking criteria.
Region V has already identified several areas where the groundwater contamination
is due to multiple sources - particularly the Grand Calumet Basin in Indiana.
The lack of comprehensive Federal and State groundwater legislation overlooks
longer-range approaches to contamination of large areas that could draw on the
site-specific findings of EPA's and other Agencies1 programs to integrate infor-
mation into a comprehensive multi-contaminant, multi-program response for area!
groundwater protection.
Regional Agenda
The Region has established the Groundwater Coordinating Committee supported by
an Office of Groundwater to address such issues as data sharing, areal contami
nation problems, and oversee the implementation of the National Groundwater
Strategy.
Region V will also continue to use the following ongoing program site-specific
authorities and tools to abate existing groundwater contamination and to prevent
future occurrences:
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CERCLA and RCRA
Under CERCLA, the Region's highest priorities will continue to be taking
removal actions at sites which pose imminent threats to public health,
and taking remedial actions at NPL sites, especially where there is danger
of groundwater contamination.
The Region will continue to implement the RCRA Subtitle C program, where
we will issue permits at land disposal facilities, incorporating the more
stringent requirements of the HSWA. The new law provides for minimum
technology requirements, expands requirements for groundwater monitoring
systems, prohibits certain land disposal practices, bans particular wastes,
and requires retrofitting of some existing surface impoundments with double
1iners.
The first RCRA program priority will be to use HSWA authority to issue
corrective action orders to both regulated facility and solid waste
management units to abate offsite contamination, particularly of groundwater
RCRA enforcement priorities will also be on protecting groundwater.
The
Region will conduct comprehensive compliance evaluations at land disposal
facilities, and take enforcement actions against all interim status land
disposal facilities that have not implemented adequate groundwater monitoring
systems.
During FY 86, the Region and States will begin to develop and implement the
underground storage tanks (UST) program. This program will regulate storage
tanks and require corrective actions for tanks releasing regulated substances
into the environment. The UST program will be a major contribution to the
resolution of the groundwater contamination problem.
Clean Water Act Actions
Provide groundwater grants to the States, after negotiating appropriate
levels of financial and technical assistance, given their groundwater
protection program needs.
Ensure that each State produces a comprehensive ground water strategy.
Manage the implementation of State programs so that area! contamination
problems are addressed.
Develop and implement projects with States on public information and education,
data management, groundwater monitoring.
Safe Drinking Water Act Actions
Implement the Underground Injection Control Program to control previously
unregulated underground injections which have caused significant problems
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J
Coordinate EPA health effects data and provide data to States in a timely
manner.
Implement the Public Water Supply Supervision Program which monitors the
quality of drinking water delivered by public water systems.
Groundwater Coordinating Committee/Office of Groundwater (GWCC/OGW)
In addition to specific program actions, the Region will continue to implement
the National Groundwater Strategy as part of our State program development
multi-media coordination efforts, and focus appropriate Regional program
attention on area! contamination problems.
The Region has established the GWCC and the OGW. The GWCC is being refocused
to serve as a policy body to oversee implementation of the National Groundwater
Strategy, coordinate program responses to such issues as areal contaminations,
and recommend appropriate Regional policies* The OGU will serve as staff to
the GWCC by analyzing issues and making recommendations as required. Also, the
GWCC will perform a variety of coordination functions, the nature and scope
of which will depend on what is needed. Some samples are:
- Assuring that all appropriate Regional programs consider groundwater
protection as an integral part of their program implementation.
Assuring that all Regional program concerns and needs are appropriately
factored into the State workplans and strategies.
Seeing that relevent State data are made available to all the appropriate
Regional programs, and that all Agency technical information, monitoring
data, research developments, and regulatory or policy news is provided to
the State and Regional programs.
Headauarters Action Needed
Implement the National Groundwater Strategy,
o
Provide program and funding guidance for State groundwater grants within
the operating guidance.
Provide the Regions with more timely and consistent health advisories.
Involve the Regions in the various task forces created to establish a
policy framework for EPA groundwater programs.
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Expected Environmental Results
The Region's program activities will help protect groundwater from new
contamination and rectify some amount of past contamination. But, as of
yet, the groundwater data base is insufficient to project exactly what
improvements will be accomplished. In fact, we are just beginning to
develop the ability to map and catalog our groundwater resources and begin
to assess potential threats. The major specific results we expect will be
from implementing existing programs at individual sites - where each will
be quantified separately.
Two major program initiatives will have the greatest environmental effect on
groundwater - the groundwater classification system and the total regulatory
program effect of eliminating land disposal of hazardous waste as a viable
disposal option. Obviously, if the day comes that there is no longer any
hazardous wastes buried, a significant threat to groundwater will have been
eliminated. The groundwater classification system will have more subtle
effects. Mainly, it will allow EPA, the States and other agencies to set
priorities and concentrate on the most important or the the most threatened
water bodies first. An indirect benefit is that, to accomplish the classifi-
cation scheme, significant amounts of monitored data will have to be gathered
This data gathering - in and of itself, and for the processes that must be
established to collect and manage it - can only increase our awareness and
knowledge of groundwater. But these processes must be made as efficient and
effective as possible. Any such monitoring program should be modeled after
the Air Ambient Monitoring program and should avoid the problems of a system
such as STORET.
C. DISCHARGE OF TOXIC MATERIALS TO WATER
Problem Assessment
The discharge of toxic materials to water from a variety of industrial and
municipal sources has caused the chemical contamination of fish and aquatic
life. It has also caused direct contamination of surface drinking water
supplies and significant impairment of water uses. The resulting bioaccumu-
lation has caused sport and commercial fishing advisories in 31 of the 42
Great Lakes areas of concern, and these involve all five Great Lakes. All of
the Great Lakes have fish-eating bird populations carrying substantial body
burdens of PCBs and other organochlorines.
Regional Agenda
Work with States to identify key municipal and industrial NPDES permits for
major and significant minor facilities with a high potential for the
discharge of toxicants which need issuance in FY 86/87 and include them in
the FY 86 program plan.
Provide technical assistance to POTWs/States to implement pretreatment
programs.
Work with the States to review and reevaluate water quality standards and
wasteload allocations every 3 years to incorporate specific toxic control
parameters in NPDES permits.
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Assure municipal and industry compliance with pretreatment limits and NPOES
permit requirements for toxicants.
Provide technical assistance on biomonitoring programs to assess the
toxicity of municipal and industrial discharges.
Implement tissue residue monitoring activities to identify presence of
toxic chemicals such as dioxin, dibenzofuran, etc.
Continue to refine standards for issuance of fish consumption advisories
based on toxics levels in fish.
Ensure timely and appropriate State and EPA enforcement response to
instances of significant noncompliance with NPDES permit requirement or
pretreatment standards.
Headauarters Actions Needed
Develop standard sampling and analytical protocols for toxicants,
particularly for short-term testing to surface potential toxicant problems
which affect aquatic-life, human health, and wildlife (e.g., Ames test,
chemical structure-activity, etc.).
Protocols to measure environmental conditions, pollution concentrations,
and biota chemical body burden before and after control actions are taken
should be made standard operating procedures for Federal, and State toxic
programs. Agencies should have to explain why this requirement is inappro
priate to obtain an exception.
Focus resources and direct activities of Headquarters compliance, permits,
and ambient control on improved coordination for toxicant problems.
Provide additional guidance on procedures and requirements to assure
States review and reevaluate water quality standards and wasteload
allocations every 3 years.
Place a higher national priority on continuing pretreatment program operations,
particularly program audits, categorical standards enforcement, and evaluation
of needs for local toxicant limitations.
ORD needs to better coordinate its work with the Regions and provide results,
particularly of field work, in a significantly shorter time.
ected
Environmental
Results
With strong EPA technical and policy participation, the States are expected
to assess the needs for and establish local toxicant limits as part of the
pretreatment and NPDES permit implementation programs. These actions should
also help convince the public that the regulatory process is working to assure
the safety of water resources. The water resources themselves should eventually
be restored to their full designated uses as natural cleansing mechanisms purge
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17
toxics from waters and sediments, or heavily contaminated sediments are dredged.
Meanwhile, NPOES discharge limitations should reduce the reintroduction of toxic
substances to the environment. There will be a lag time between the clean-up or
discharge reductions and corresponding reductions in biota chemical body burden,
but again, as the impact of toxic materials to water bodies decrease, so should
the levels of toxics in aquatic life. So far, EPA has not placed any priority
on such before and after monitoring, so very little data is available. This is
a significant Agency oversight that should be corrected and become standard
procedure.
Contaminated Slud
Problem Assessment
Many Region V waste treatment facilities have reached or exceeded their capacity
to store or properly dispose of contaminated sludge. This problem may be
underestimated because of additional problem sludge management facilities that
have not yet been identified. Runoff from contaminated sludge has deposited
varying amounts of pollutants in ditches, streams, lakes, and surface water
reservoirs. This runoff causes taste and odor problems, as well as toxic sub-
stance contamination in drinking water supplies, toxic levels of pollutants in
surface waters, and hazards to aquatic life and public health.
enda
Provide technical and financial support to the States1 remedial initiatives
to eliminate contaminated sludge sources.
o
Work closely with the States to
of improperly operated sludge management systems.
prepare a strategy for the elimination
Analyze the State inventories of contaminated sludge remedial action plan
to determine if additional sludge management control measures are needed.
Upon promulgation of proposed Part 501 Regulations, work closely with the
States to assure that contaminated sludge remedial action plans are inte-
grated into new State Management Program Plans.
Closely monitor how effective the States are in promoting and sustaining
local agency remedial action initiatives.
Work to develop fully integrated Federal, State, and local contami
nated sludge control programs.
Refine and update the listing of identified "worst case" contaminated
sludge problem areas on an ongoing basis.
Headauarters Actions Needed
Complete the proposed Part 503 Technical Sludge Regulations, and proposed
Part 501, State Sludge Management Program regulations and implementation
guidelines.
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18
Conduct seminars within the Region to allow the States full access to all
available guidance.
Develop and provide information on the best management practices, structures,
and methodologies for the elimination of contaminated sludge sources. Serve
as a clearinghouse of contaminated sludge remedial action information.
Coordinate and encourage participation of other Federal and State agencies
in remedial action initiatives to prevent and eliminate contaminated sludge
Refine and update the national strategy on technical sludge regulations
and contaminated sludge action initiatives.
ected Environmental Results
The remedial action initiatives will redress previously neglected contaminated
sludge problems and restore environmental quality to acceptable levels in
problem areas. In addition, a consolidated strategy will anticipate and prevent
future contaminated sludge environmental problems. The actual improvements in
water quality will be specific to the individual areas where actions are taken.
In some cases where contaminated sludge is threatening or actually causing
problems in water supplies, the improvements may be significant.
0. IN-SITU POLLUTANTS
Problem Assessment
Most of the rivers and streams in industrial areas have varying levels of
contaminants. The number of waterways known to have sediments containing
excessive levels of toxic contaminants has grown rapidly in recent years, and
efforts are continuing to find and evaluate others. Most of the existing data
is on PCB and pesticide contamination, though there is some information on
other organic chemicals such as PAH. Some of the waterways that are known to
contain significant levels of contaminants are:
0
Waukegan Harbor, Illinois
Fields Brook and Ashtabula River, Ohio
Sheboygan River, Wisconsin
North Branch of the Chicago River, Illinois
Grand Calumet River, Indiana, and Illinois
Black River, Ohio
Milwaukee Estuary, Wisconsin
Indiana Harbor, Indiana
Menominee River, Michigan and Wisconsin
Fox River, Wisconsin
St. Louis River, Minnesota
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19
enda:
Although the Region has significant information regarding the extent of
contamination in the areas mentioned and investigations continue on others,
the ability of the Region or States to implement remedial programs is very
limited. Dredging is the most often used remedial action, but with a
few exceptions, the only dredging that has been done is navigation channel
maintenance by the Corps of Engineers (COE). EPA and States advise and
regulate the COE in these activities but generally have not been able to
increase the scope of the COE's navigation projects, to include desirable
clean-up activities. There has been some exceptions, notably the proposed
dredging programs at Waukegan and Ashtabula, and the consent judgment with
U.S. Steel Corporation for dredging of the Black River, Ohio.
Following are some additional Region efforts to deal with in-situ pollutants:
The In-Place Pollutant Task Force will continue to coordinate Regional/
State efforts; to investigate dredging and disposal options, available
treatment technology, and methods of funding; and to develop site action
plans.
The Environmental Review Branch of the Planning & Management Division
is preparing a Dredging/Disposal policy document to clarify the roles
of individual regional programs and criteria for evaluation of dredging
A policy paper is to oe completed in early FY 86
and disposal projects.
The Great Lakes National Program Office (GLNPO) is expecting to fund
a multi-year demonstration program for in-place pollutants.
The GLNPO is assessing sediment contamination in a number of areas to
develop Area of Concern Remedial Action Plans.
The Environmental Services Division is developing a confined disposal
policy for PCB contaminated sediments as a basis for TSCA permits.
The Water Division, GLNPO, and ESD will evaluate coke oven discharges
across the Region to see whether the associated PAH and metals sediment
contamination found in the Black River, Ohio and Grand Calumet River,
Indiana exists elsewhere.
Several programs are working with the COE to evaluate innovative
dredging and disposal approaches. The COE is investigating advanced
design confined disposal facilities (CDF) and other disposal approaches
The Water Division will continue to work with Headquarters to establish
a National strategy for in-situ pollutants.
Headquarters Actions Needed:
Expedite development of sediment contamination and action criteria and
a structured implementation framework.
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20
O
Determine a basis for Agency remedial sediments programs through
Section 115 of the Clean Water Act, modification of CERCLA's hazard
ranking system, use of new RCRA regulatory authorities or other means
o
Analyze existing sediment data nationwide on contamination patterns
to determine if further regulation is necessary.
o
Support Regional investigations of the waterways most susceptible to
contamination.
ected Environmental Results
The discussion immediately below, under Section D., PCBs, Expected Environ
mental Results, covers the improvements expected from clean-ups of in-situ
pollutants, focusing on PCBs. The discussion is applicable to other
as well.
utants
PCBs
Problem Assessment
Polychlorinated biphenyls (PCBs)
waterways and contaminated a number of others to a degree where action is still
have severely contaminated several Region V
necessary
Most of this contamination has been found to be from facilities
located in these drainage areas. An aggressive inspection and enforcement
program has uncovered numerous violations and resulted in a number of enforce
ment actions. This has largely eliminated VOC discharges and spills and
apparently, cleaned-up areas are not being recontaminated.
h
tional
disp
f PCB or oth
taminated
dg
is
f
d f
dredged material
reasons - very difficult
Th
tremend
technic
volume
tit
k
th
prohibitively exp
t
t
or t
P
y a CDF
in an approve
ost always so
t
df
transport very f
Therefore, an al
f wet
ar. t
ternat
h
A CDF is a vessel or enclosed area, usually constructed in or near the waterway
being dredged, built of graded limestone, protected with armor stone on the
outside and lined with silty sand on the inside. CDFs are built to withstand
the largest recorded Great Lakes storm or even collisions with ships. CDFs
are controversial because, while monitoring shows CDFs effectively retain the
sediments and their effluent meets specified discharge limitations, they are
permeable. While permeability is not a severe problem with PCBs, trace quanti-
ties of other contaminants can be released over time. Also, some critics still
question their long-term structural integrity and ability to withstand severe
storms.
Also, beyond the control of discharges and spills to water and contaminated sludge,
we are concerned with the environmentally safe disposal of PCB contaminated sedi-
jients. Additional work needs to focus on alternative disposal technologies.
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21
Regional Agenda
The Regional TSCA program focuses on ending active PCB discharges.
With
approximately 8,000 facilities in the Region subject to the PCB regulations,
Region V projects that approximately 700 facilities will be inspected during
the next year for compliance with these regulations.
The Regional TSCA program has developed a draft Regional PCB cleanup
policy which is being reviewed by the States and by Headquarters.
The
Regional policy will be implemented until a national policy is developed.
Water Division and the Environmental Services Division will jointly determine
the impact of in-place PCB on the attainment of water quality standards that
protect designated uses.
Clean-up of PCB contaminated sediments is being evaluated or conducted by the
Superfund program in a number of Regional areas where the contamination threatens
public health. In other areas, where the contamination is unknown or less of a
direct threat, the COE is the lead agency, involving the Superfund program as
appropriate. Some of the areas EPA and/or COE are addressing contaminated sedi-
ments include:
- Sheboygan Harbor, Wisconsin
- Ashtabula Harbor/Field's Bronx
- Waukegan Harbor, Illinois
- Green Bay, Wisconsin
- Lorain, Ohio
- Chicago, Illinois
Ohio
East
Chicago, Indiana
Headauarters Actions Needed
Develop a uniform National Policy to address clean-up of PCB contaminated
sediments to an acceptably safe level.
Continue funding for research and development of methods for analyzing
sediment samples for PCBs.
Provide R&D projects for methods to break down PCBs in moist sediments, sludges,
and soils into a non-toxic form. This would be most important to treat in-situ
sediment contamination.
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Expected Environmental Results
In some of the most intensively studied areas, such as Saginaw Bay, direct
discharges to tributaries appear to have been eliminated by NPOES permit
limitations, spill controls, and leakage abatement efforts. EPA has not
consistently followed-up on the monitoring of post-activity environmental
conditions, but we can provide some indicators of the results we expect. At
Saginaw Bay, the COE has dredged the navigation channel. Prior to about 1976,
the sediments in the channel averaged 10-20 ppm of PCBs, but there are PCS
contaminated hot spots - in the River but outside the dredged navigation channel
- that far exceed that concentration. Due to continuing projects to dredge
and dispose of contaminated channel sediments, the remaining sediments now
average about 2 ppm, and have maintained this level - they do not seem to be
accumulating any more PCB. Apparently, the discharges have stopped. In time,
the lower levels of sediment and water contamination should restore beneficial
water quality uses and lower the PCB levels in aquatic life.
E. VIOLATION OF PRIMARY AMBIENT AIR QUALITY STANDARDS
Note: There is a separate Air Addendum included as Appendix B, which presents
a great deal of quality environmental indicators and data. This Addendum should
be referred to as it is referenced in this Part II narrative.
Problem Assessment
Region V has experienced numerous violations of ambient air quality standards
for several pollutants. Except for Minnesota, violations of the ozone NAAQS in
Region V have been widespread and persistent, affecting some 31 million people.
Violations were particularly severe in several large urban areas, requiring the
implementation of inspection and maintenance (I/M) programs. Several of these
areas will probably not attain the ozone standard by the Clean Air Act's 1987
deadline.
Monitored ambient S02 violations are much less widespread. Wisconsin is the
only State in the Region which has recently experienced such violations.
S02
remains a pollutant of concern in Region V because of the widespread use of
high sulfur Midwest coal by industries and electric utilities. The use of
taller stacks for pollutant dispersal, modern control technology (e.g., flue
gas desulfurization), and selective use of lower sulfur coal has largely
eliminated ambient monitored violations. However, dispersion modeling analysis
has indicated much remains to be done in Region V's S02 control program. There-
fore, decisions regarding the selection and application of dispersion models can
have major impacts on the S02 control program. These decisions can necessitate
major reanalysis of Region V S02 SIPs, to address such issues as tall stack
regulations, block vs running averaging in modeling, etc. Although SIP limi-
tations are in place for most sources, Wisconsin does not yet have statewide
regulations, and individual sources in other States may require revised
1 imitations.
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23
Participate matter has traditionally been Region V!s major air pollution concern.
The high concentration of heavy manufacturing facilities, (e.g., integrated iron
and steel mills) in combination with the general TSP emissions associated with an
urban environment (e.g., industrial fugitive dust, reentrained road dust, etc.),
have caused widespread violations of the TSP standards in Region V. Other than
enforcement, the Region's regulatory program has been held in abeyance by unre-
solved policy issues of an air quality standard for fine particulate matter.
Regional Agenda
Ozone
Region V has initiated a variety of actions to address primary ozone violations,
including a vigorous enforcement program which inspected over 90 percent of the
sources in the nonattainment areas in FY 85, a mobile source control program
which has stressed I/M for all major urban areas with 1987 attainment date
extensions, and an anti-tampering/fuel switching program for several States.
Also, control regulations have been adopted and are being implemented for
numerous categories of stationary sources, with regulations for the remaining
major sources under development for all major urban nonattainment areas.
The
For FY 86, Region V§s ozone control activities will focus on sustaining and
completing current initiatives. The enforcement program will inspect major
sources in accordance with SPMS requirements and take expeditious enforcement
actions as in accord with the State-EPA enforcement agreements (SEEA).
regulatory program's first priority is resolving remaining SIP issues and
getting approved SIPs in place. Other regulatory priorities are developing
anti-tampering/misfueling programs in selected States/local areas, estab-
lishing I/M in the 3 remaining States, and obtaining a suitable enforcement
mechanism for Indiana's I/M program. Federal funding and other restrictions
may have to be placed on areas failing to develop and implement approved
SIPs.
Sulfur Dioxide (S02)
In FY 86, Region V's S02 control programs, while being a lower priority than
ozone, particulates, and air toxics, will focus on resolving SOg SIP issues
in a number of states. The major state-specific efforts will be to:
Illinois and Michigan - review and rulemake on the S02 SIPs for several
small areas that received SIP deficiency notices:
Wisconsin - review and rulemake on the first comprehensive statewide S02
SIP;
Indiana - analyze and address the effects of recent court decisions
on the statewide SO^ SIP;
Ohio
resolve the current interim enforcement policy.
Overall, the Region will be dealing with all the States in implementing
the recently promulgated tall stack regulations, inspecting major sources
according to SPMS requirements, and taking expeditious enforcement actions
in accordance with national guidance and SEEAs. Also, the Region will be
working with the States to revise their S02 monitoring networks and replace
obsolete and worn-out equipment.
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24
Regions V and I will be the lead Regions for development of national policy
and direction for the $02 control program. This initiative will focus on
the resolution of several unresolved rulemaking issues (e.g., block vs running
averaging times, ambient standards, etc.) and enforcement initiatives (e.g.,
use of CENIs, nationally consistent enforcement policies, etc.).
Particulates
The Region will continue to work with Ohio on the development and promul-
gation of an approvable Ohio TSP SIP. Also, recent court decisions will
require Federal promulgation of partial or complete TSP SIPs for Illinois,
Indiana and Michigan. The enforcement program will inspect major sources
in accordance with SPMS requirements and take expeditious enforcement
actions. Enforcement initiatives will include efforts to enforce existing
State fugitive dust regulations. Monitoring activities will focus on
collection of TSP data.
In response to the proposed PM-10 standard, the Region will be working with
the States to develop technical information so they will be able to develop
an approvable SIP when the PM-10 standard is finalized. Monitoring activi-
ties will focus on data collection from existing PM-10 monitors as well as
the siting of additional PM-10 monitors.
Headauarters Actions Needed
Ozone
o
Complete Control Technique Guidelines for Group III source categories.
Provide assistance as necessary on available controls for major non-CTG
sources.
Clarify guidance on requirements for control of major non-CTG sources.
Provide a final decision on Stage II vapor recovery
Provide updated policy on requirements for approvable 1982 ozone SIPs.
Promulgate the Benzene NESHAPS for coke oven by-product plants on schedule
Provide a final national decision on the appropriate legal and technical
means for granting compliance extensions to VOC sources.
Provide Agency policy on implementation of anti-tampering/anti-fuel switch
ing programs
0 SO
2
Resolve outstanding issues effecting establishment of SOg emission
limitations; for example: running vs. block averages, changes to Guide
line on Air Quality Models, sulfur variability in fuel compliance test
method, and averaging time.
Resolve existing inconsistencies in the enforcement of SO? regulations
across the nation.
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25
TSP
Finalize the PM-10 standard.
Provide an updated policy on the requirements for an approvable TSP SIP
for Part D of the Clean Air Act.
Provide technical support for PM-10 attainment demonstrations; for example
emission factors, particle size distributions.
ected Environmental Results
Ozone
Because of its control efforts, the Region expects a continued reduction
in the magnitude and extent of the ozone problem. The maps on pages 1
and 2 of the Air Addendum (see Appendix
illustrates the changes in
designated ozone nonattainment areas between 1979 and 1985. In general,
these maps indicate a shrinking of the nonattainment areas with the
remaining areas centering on major urbanized areas in the Region. While
the charts on pages 3 and 4 demonstrate a diminished geographic extent of
ozone nonattainment, the population exposed to elevated ozone levels has
only decreased 20% between 1978 and 1985. The charts on pages 5 and 6
demonstrate ozone levels and numbers of exceedances for the Milwaukee
nonattainment area. While the design value for the area has not changed
significantly between 1979 and 1983, there is an apparent downward trend
in the number of exceedance days. The graphs on page 7 demonstrates the
projection of reasonable further progress in emission reductions expected
in the Milwaukee area. Since the Milwaukee 1982 ozone SIP is the only
finally approved extension area SIP in the Region, it is the only ozone
extension area with a reasonable further progress (RFP) demonstration.
As other extension area SIPs are approved, similar RFP information will
become available. Finally, the chart on page 8 demonstrates the expected
VOC emission reductions from known violators in the Milwaukee area.
This
chart will change throughout the year as more violators are identified and
existing cases against violators are resolved. Similar charts are included
for the ozone extension areas which summarize the direct environmental
improvement attributable to enforcement actions, as well as graphs showing
trends in number of exceedance days.
SO?
The Region expects that the direct environmental results of its S02 efforts
in FY 36 will be limited. The charts on pages 28 and 29 of the Air Addendum
indicate the change in S02 nonattainment areas between 1978 and 1985. As
graphs show, comparatively little change has occurred in the designated
nonattainment areas. The charts on pages 30 and 31 indicate a relatively
small percentage of the population in the Region is exposed to S02 nonattain-
ment and that level has dropped 23 percent between 1978 and 1985. In FY 86,
the Region expects further reductions in population exposure as resolution
of the Minnesota S02 SIP and designations are completed. However, if
unilateral nonattainment designations by EPA were still allowable under
Section 107 and Part D of the Clean Air Act, the Region would expect the
number of designated nonattainment areas to increase, mainly in Indiana
and Wisconsin.
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26
TSP
The Region expects limited direct environmental effects of its TSP efforts
in FY 86. The maps on pages 32 and 33 of the Air Addendum show the modest
changes in designated TSP nonattainment areas in Region V between 1978 and
1985. The charts on pages 34 and 35 indicate a 33 percent reduction in
the number of people exposed to TSP nonattainment between 1978 and 1985.
The Region expects continued improvement in FY 86 predominately due to re-
designation of nonattainment areas in Ohio and Wisconsin. The charts on
pages 36 to 41 indicate a reduction in the magnitude and frequency of TSP
exceedances in three major metropolitan areas. The Region expects this
trend to continue in FY 86. The Region's FY 86 TSP SIPs development program
will not have direct and immediate environmental results but will establish
regulations which will reduce the pollution in the future.
F. SYNTHETIC ORGANIC CHEMICAL CONTAMINATION OF DRINKING WATER
Problem Assessment
Historically, groundwater has been viewed as a relatively pristine resource,
and has generally been used as a drinking water source without major treatment
other than disinfection. However, the 1981 National Groundwater Survey, which
provided a random sampling of groundwater systems across the country, indicated
that a significant number of drinking water sources had measurable levels of
contamination from synthetic volatile organic chemicals (VOCs). Those findings
have effected the current systematic efforts of Region V's Drinking Water
Program to achieve complete VOC monitoring in Indiana and the primacy States'
commitments to VOC monitoring. To date, Region V State and Federal drinking
water programs have cumulatively analyzed approximately 6,872 out of 15,634
(44 percent) community water wells for VOC compounds. The current totals
indicate that at least 440 (6.4 percent) of those tested wells have been shown
to contain some VOCs. This sampling program has a high priority in the Drinking
Water Program to detect VOC contamination before they become serious public
health problems.
VOC contamination involves two major concerns that have not yet been fully
addressed. The first concern is the existing health risk to people using a
contaminated source of drinking water. With the increasing number of VOC
detections, it is essential that more health advisory information be provided
to the Region to better evaluate the risks. The other major concern is the
potential for future/further contamination of groundwater sources of drinking
water. The fact that these contaminants are all synthetic, indicates that
contamination is due to human activities. The levels of health risk and the
activities causing the contamination can both be best assessed through a
consistent synthetic volatile organic chemical testing program in all States.
Regional Agenda
Continue the VOC monitoring program in Indiana and on all Indian
lands to complete sampling all community water system wells by the
first quarter of FY 87 .
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o
Assure that the public is notified by water suppliers if contamination
is found.
Continue to encourage primacy States to complete all VOC monitoring,
consistent with this strategy within four years.
Compile all quarterly monitoring program findings into an automated
data system for future tracking and reporting.
Routinely alert the Regional Superfund program if high levels of
contamination are found.
Correct drinking water problems when VOC's are found, including use
of the Superfund program.
Re-test systems that have been found to be contaminated with VOC's
on a regular basis.
Provide State program grants to increase laboratory capacity and
capability.
Provide information and technical assistance to States, and other
Federal Agencies.
Coordinate closely with the Superfund and RCRA programs to ensure
that drinking water technical and health effects considerations are
properly addressed at all sites.
Participate on the Regional Ground Water Coordinating Committee to
address synthetic volatile organic chemical concerns.
Headauarters Actions Needed
Increase research and development efforts to:
Develop surrogate methods of detecting VOCs in drinking water.
Reduce the costs of testing samples (current average cost is
$300/sample).
Promulgate regulations concerning VOC maximum contaminant levels
(MCLs) and monitoring requirements on schedule.
Provide the Regions with comprehensive health advisory information
which includes a broader spectrum of synthetic volatile organic
chemical contaminants and multi-route exposure scenarios.
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28
ected Environmental Results
Actual environmental results (as opposed to program actions) are difficult
to quantify due to the lack of federal regulations and consistent State
reporting requirements. With about one-half of the Region V water supplies
tested, an estimated 4.5 million people depend in some part on water supplies
that have detectable VOCs. Thus far, contaminations estimated to be greater
than the 1x10-6 excess lifetime cancer risk have been confirmed in about 237
(3.4 percent) of the tested wells and greater than the 1x10-5 excess risk in
104 (1.5 percent) of the wells. The current VOC findings have led to the
removal of at least 60 public drinking water wells from routine service. At
other sites, VOC removal treatment systems has been installed. And at the
remaining locations, the options of either treatment or providing new water
sources is being studied by State and local authorities.
The Region V Superfund program is routinely alerted if unexplained high
contamination levels are found in a water supply. Several of Region V's
largest Superfund sites were initially discovered by the drinking water
program through their monitoring.
G. TOXIC SUBSTANCES
EXISTING CHEMICALS
1. Pesticide Misuse
Problem Assessment
Because of extensive agricultural production, the Region v area is among
the highest pesticide users in the country. About 20 percent of the
national total (one hundred and eighty million pounds) of pesticides are
used in Region V annually. Region V also has 26 percent of the pesticide
producing facilities, which manufacture about 280 million pounds of
pesticides annually.
The highest rates of violations have been found among the following user
groups: aerial application (40%), agricultural ground application (30%),
and nonagricultural application structural usage (25%). These rates
may not reflect true environmental exposure because most use compliance
monitoring data is tabulated from citizen complaints and other "for cause"
investigations. Nevertheless, pesticide use violations can and must be
reduced and vigorous enforcement taken in cases where there is the poten-
tial for environmental damage. State/EPA enforcement agreements negotiated
yearly will be the primary tool for shaping program direction and pesticide
use enforcement programs.
The greater sensitivity of new analytic tools has recognized an increasing
problem of groundwater pesticide contamination even with properly applied
pesticides. Aldicarb, a systemic carbamate insecticide used in Wisconsin,
has been detected in groundwater at 1 ppb up to 111 ppb. Triazine-type
herbicides have been detected in Ohio and Wisconsin at low ppb levels.
Even though groundwater contamination can result from proper use, additional
use compliance activities are needed to minimize the problem wherever
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29
Reaio
enda
The EPA/State pesticide use and marketing enforcement agreements, funded
partially by EPA, are the cornerstone of a coordinated enforcement program
directed at use compliance programs.
Continue to upgrade State programs to train and certify applicators
in the proper use of pesticides.
Priorities are set for use compliance programs by the cooperative
agreements in accordance with the annual National Pesticide Guidance
Region V's current use compliance priorities are:
pesticide drift and overspray violations for both ground and
aerial applications,
structural/urban pest control application violations
a. exposure to humans and domestic animals
b. damage to gardens and trees/shrubs
pesticide and pesticide container disposal,
pesticide runoff from storage and handling facilities,
other general use inconsistent with label practices violations, and
Headquarters Actions Needed
Establish standards for consistent label directions and precautions
abel Improvement Program).
Continue funding and national direction to promote State use compliance
programs and certification programs.
Implement the National Pesticide Monitoring Plan to collect pesticide
data on groundwater, surface water, soil and air.
ected Environmental Results
Reduced levels of pesticides in human tissue.
Resurgence of wildlife populations previously suspected of being
endangered/threatened by pesticides in the environment.
Reduced pesticide contamination of groundwater, surface water, soil, and
air.
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30
2. Asbestos
Problem Assessment
There are 2 primary EPA asbestos related programs. The first and largest
is the Asbestos-In-Schools program. In this program, EPA is concerned with
the disease-causing potential of intermittent low-level exposures to asbestos.
The durability, small size, and fiberous shape of asbestos fibers, allow them
to remain airborne for long periods of time. Under section 6A of TSCA, the
Agency has taken steps to minimize the exposure of school children to asbestos
by mandating that both public and private schools perform inspections for
friable asbestos-containing materials. EPA then requires school officials to
notify other school employees and parents of the dangers of that school. While
we have no further authority to require corrective actions, public concern and
pressures on the school systems usually results in corrective actions.
The second, smaller EPA program is the air media's NESHAPs, which limits
airborne emissions from manufacturing use, demolition, renovation, and waste
disposal of asbestos.
Regional
enda
Region V, using the American Association of Retired Persons (AARP) and
Regional personnel, will accelerate the compliance monitoring inspections
of schools as well as disseminate technical information and guidance.
Region V projects that approximately 400 local educational agencies will be
inspected during FY 86 for compliance with the Asbestos-in-Schools Rule.
Wisconsin will be awarded a grant to conduct school asbestos compliance
inspections which will continue as long as Federal funding is available
This active program should bring noncomplying facilities into compliance
with the regulation, as well as provide technical assistance to school
officials on abating asbestos problems.
Under the Asbestos School Hazard Abatement Act (ASHAA), approximately
$45 million in Federal grants and loans will be available in FY 86 to
help abate asbestos in schools with potential health hazards. In
Region V, approximately 75 schools may receive Federal funding for
asbestos abatement projects.
The Air Management Division will provide 105 grant funding for and
assure State program workplans address asbestos NESHAPs activities.
This program focuses on minimizing asbestos fugitive emissions during
demolition of asbestos containing structures.
Headauarters Actions Needed
Headquarters needs to evaluate the risks, costs, and benefits of expand-
ing the asbestos program to other public buildings. Appropriate technical
and operational guidance must be developed and sufficient implementation
resources provided if this program is undertaken.
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31
EPA needs to continue funding the ASHAA program to correct the asbestos
problems.
Headquarters should assess the overall national compliance inspections
progress and success rate of the existing regulatory process in resolving
school asbestos problems.
Expected Environmental Results
The NESHAPs asbestos program should help limit the public's exposure to
fugitive asbestos particulates in the ambient air. The actual environmental
improvement would be very site-specific, but - as anyone who has observed
building demolition without dust suppression measures can attest - the
improved protection can be significant.
An EPA report entitled, "Airborne Asbestos Levels in Schools" documents
the higher levels of airborne asbestos particles in schools with friable
asbestos containing materials. The mean levels of airborne asbestos at
all the schools tested prior to remedial actions was about 179 ng/m^.
After corrections, studies of airborne asbestos at these same schools
showed a reduction of airborne asbestos to about 6 ng/m^, about the
background level of asbestos in outdoor air. While individual schools
in Region V may have higher or lower levels than the study mean, we can
expect similar improvements in the quality of the air in those schools -
that is, almost the complete elimination of any excess exposure or risk.
H. AIR TOXICS
Problem Assessment
The toxic air pollutants problem in Region V is currently difficult to assess.
Because of the type and extent of industrialization within Region V, a multi-
tude of potentially toxic chemicals are emitted into the air. Since so few
chemicals are regulated under existing air programs, no recordkeeping is
required for thousands of these chemicals. Therefore, the quantity, type, and
extent of the problem is largely unknown.
Air toxics are also a threat to other media, since the atmosphere acts as a
pathway between the contaminant source and the water and soil. This is of
particular importance to the Great Lakes, which receive up to 55 percent of
their PCB and essentially all of their toxaphene loading from the atmosphere.
The regulatory program is an issue in itself. Of the thousands of potentially
toxic air emissions, the National Emissions Standards for Hazardous Air Pollutants
(NESHAPS) program has promulgated regulations for only five source categories and
has listed only seven pollutants. The USEPA has been promoting various activities
at the Regional level to encourage States to initiate programs within their own
authorities. Further, the Agency is presently exploring an alternate approach to
NESHAPS by placing State and local agencies in the lead to make technical assess-
ments and decisions to regulate pollutants with a low national incidence but high
local risk. But as of yet, EPA has not defined the characteristics of a base
State air toxics program.
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32
enda
The Regional program in FY 86 will continue to focus on improving State
and local capabilities to characterize, monitor, and control hazardous
air pollutants. Regional plans include efforts to improve stack and
ambient monitoring capabilities through technical assistance and imple-
mentation of pilot toxic air pollutant monitoring projects at selected
locations. The Region will continue to conduct and manage risk assess-
ments to determine whether control is appropriate. Further, the Region
will work closely with State and local agencies, especially in Ohio,
Michigan and Illinois relating to acrylonitrile, the first air toxic
chemical to be addressed using the State/local option. The Region will
encourage programs under State authority by providing Section 105 grant
resources and technical assistance, as well as issuing a regular air
toxics newsletter to share experience and information on toxic air
pollutant problems, sources, and remedies. States will be encouraged
and assisted to evaluate possible monitoring sites, conduct source
surveys, review emissions inventories, perform risk assessments, develop
permit programs, and take compliance actions. The Region will continue
analyses of the air toxics problem in Southeast Chicago, focusing on
estimating the extent and magnitude of the air toxics problem, estimating
emissions for specific toxic compounds, performing dispersion modeling of
sources of these compounds, and conducting exposure risk analyses.
Headauarters Actions Needed
Provide information on health effects, emission sources, monitoring methods,
and acceptable risks.
Decide what actions are needed to implement the results of the national
e United
study, The
States.
Problem in
nitude
the
Toxic
Nature
u Define the National/International nature of the air toxics deposition
problem.
Further guidance on control procedures and other possible candidate pol
lutants to effectively implement the State/local approach to air toxics
Define characteristics of a base State Air Toxics program
Environmental Results
ected
Since the Air Toxics program is still relatively under-developed, specific
environmental indicators do not yet exist. Certainly, the Region believes
tnat analysis, regulatory decisions, and aggressive enforcement of existing
NESHAPS standards can mitigate risks in some cases. However, given the broad
array of potential air toxics compounds, complete risk analyses for every
area and every chemical in Region V is not feasible. The Region believes that
consistent with Agency's "six months study", the best indicators of general
air toxics risks are the conventional pollutants, TSP and VOC. Therefore, the
Region expects that continued improvement in TSP air quality and reductions
in VOC emissions will reduce the Regional air toxics problem. In specific
area studies, such as Southeast Chicago, it may be possible to better charac-
terize ambient levels of specific toxic compounds. That study may lead to a
better understanding of appropriate methods for characterizing and tracking
air toxics problems.
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33
I. GREAT LAKES AREAS OF CONCERN
Problem Assessment
in the
The Water Quality Board of the International Joint Commission (IJC) has iden
tified 42 localized "Areas of Concern" (see Figure 1, Appendix
Great Lakes Basin where environmental quality is degraded or beneficial water
uses adversely affected beyond guidelines established by the Great Lakes Water
Quality Agreement. Of these, 30 are located (wholly or partially) within the
United States. Although these areas constitute only a relatively small portion
of the total area of the Basin, they contain a large percentage of the Basin's
population and industry and are concentrated loading points for many pollutants.
Over the past 10 years, the environmental quality in the Areas of Concern (AOCs)
have improved considerably, particularly problems associated with conventional
pollutants (such as BOD, suspended solids, and oil and grease) and some heavy
metals such as mercury. While 27 of the 42 areas still have some problems
associated with conventional pollutants, remedial actions have reduced the
severity and extent of these problems.
In these AOCs with remaining conventional problems, control measures currently
in place are inadequate to solve some or all of the following problems:
municipal and industrial discharge control, leachate from waste disposal sites,
combined sewer overflows, urban land and agricultural runoff, and in-place pol-
lutants. For example, municipal and industrial dischargers are not adequately
controlled in the Grand Calumet River/Indiana Harbor Canal; pretreatment pro-
grams are inadequate at the Black River in Ohio, the Buffalo and Niagara Rivers
in New York, and at Massena, New York. Unsecured waste disposal sites ara
leaching toxic suostances into the Grand Calumet River/Indiana Harbor Canal
areas, the Black and Cuyahoga Rivers in Ohio; and the Ashtabula, Niagara and
St. Lawrence Rivers, and the Massena area of New York.
various pollutant
Several areas need construction projects to reduce
emanating from combined sewer overflows and urban 1
Rouge River Basin, the Detroit area, and the Grand Calumet River/Ind
d
ff
loadings
ding the
iana Harb
Canal area. Environmental improvements that cou
of specific CSO and urban runoff sources are not
d b
pected f
t
pleted identified
d
correcting these sources is an expensive,
gthy p
I
some oth
areas.
agricultural runoff is the major water quality problem
initiated in the Saginaw Bay/River Basin to demonstrat
reduction techniques, but continued funding for th
and no other long-term programs are in
Project
h
b
t-effect
ace t
t
proj
1 ag
is not
ff
ed
ff
Most of the remaining problems are non-conventional problems of toxic sediments
contaminated by past discharges. Their effects on water quality, aquatic life
and overall environmental integrity vary by site and are often not well under-
stood or documented. Although GLNPO is studying whether natural processes will
eventually restore the ecosystem in the Great Lakes connecting channels, it is
doubtful whether some areas, including the Grand Calumet River/Indiana Harbor
Canal, the Rouge and Raisin Rivers in Michigan, the Cuyahoga and Ashtabula Rivers
of Ohio, and the Buffalo River in New York can be fully restored to the quality
levels called for in the 1978 Great Lakes Water Quality Agreement without
additional remedial efforts. Even if all practical controls are implemented in
these areas, sediments will remain degraded, and will require special programs
for remediation.
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34
enda
The GLNPO does not implement any control programs of its own. Instead, it acts
in concert with the IJC as a research and coordinative body that advocates and
directs actions by other regulatory control programs. Obviously, coordinating
the multitude of activities by all the various actors is a tremendous task, and
the IJC has recently revised its approach to the AOCs. All the Great Lakes
jurisdictions have agreed to prepare Remedial Action Plans, which the IJC Water
Quality Board will subsequently review to assess their adequacy. Because the
AOCs are not located on free flowing streams, standard problem assessment methods
are often not applicable. The new Remedial Action Plan process to assess and
evaluate the actual results of the remedial actions taken should provide better
estimates of the relative benefits of various control activities. While several
plans are completed, all Plans are expected to be completed and submitted by the
end of 1986.
The Remedial Action Plans describe environmental conditions, identify sources,
detail needed corrective actions, specify roles, delineate implementation actions
and schedule needed activities. The plans also describe surveillance and monitoring
to track program effectiveness. If it is deemed infeasible to restore all water
quality uses, then the Plan will identify the quality and uses which can be achieved
Some of the activities GLNPO and cooperating programs will be implementing in FY 86
include;
Implement specific portions of the Great Lakes National Program Office
five-year strategy that support AOCs, including preparation of Remedial
Action Plans to specify environmental conditions and sources of
contamination: detail corrective actions, responsibilities, schedules;
and establish mechanisms to monitor plan effectiveness. (See Appendix C
for complete description)
o
Complete prototype plans for the Rouge River and Indiana Harbor, and initiate
plans for Lower Fox/Southern Green Bay; Waukegan Harbor, Saginaw Bay, Detroit
River/Lake St. Clair/St. Clair River, Black River, Raisin River, and the
Buffalo/Niagara area.
Track the environmental effects of remedial plans in Waukegan Harbor (through
fish flesh monitoring), and all other areas where feasible.
Finalize draft Lake Erie/Saginaw Bay Phosphorus Load Reduction plan.
Extend the "Master Plan" for the Grand Calumet River/Indiana Harbor Canal to
nearby Lake Michigan.
Implement the recommendations of the "Report on Lake Michigan Total Maximum
Daily Loads", that specify actions that must be taken by U.S. EPA and the
States to ensure that Great Lakes water quality standards are not violated.
Expedite water quality standards reviews associated with AOCs and ensure
that special attention is given to toxicants.
Ensure that States rigorously review permits that impact AOCs prior to
permit reissuance, and that pretreatment programs are incorporated into
those permits.
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35
O
Provide guidance to Regions and States to develop the Regulatory Authority
to control atmospheric deposition under the State/Local option: (See H,
Air Toxics) Focus this authority on those lake contaminants whose primary
source is air deposition.
Headquarters Actions Needed
Develop national standards and methods for removing, containing, or
stabilizing in-place pollutants.
Continue to refine standards for issuance of fish consumption advisories
based on toxics levels in fish.
Funds and advocate research on and development of estuarine and
large lakes computer models to aid remedial efforts*
Complete all effluent guidelines with special emphasis on toxicants
Environmental Results
ected
Major water quality improvements have come from compliance with basic
require
ments for best practical treatment for industry and secondary treatment for
municipal discharges. However, with minor exceptions, little further improvement
can be expected without additional pollutant reductions.
While the Remedial Action Plans may provide emphasis and importance for
actions, the real environmental improvements will come only with the
implementation and success of other programs, such as CSO reductions,
NPDES permitting, and Superfund.
J. NQNPQINT SOURCE RUNOFF TO WATER
Problem Assessment
Farming is a major industry in Region V, and improper management of agricultural
land has created extensive nonpoint source (NPS) water quality problems - many
of which could be prevented or corrected through proper soil management techniques
without hindering crop production. Runoff from agricultural lands transports
varying amounts of agriculturally-related NPS pollutants (nutrients, pesticides,
and organic and inorganic particulate material) which are deposited in ditches,
wetlands, streams, lakes and reservoirs. Excessive erosion and runoff containing
animal wastes often cause dissolved oxygen reductions, accelerated sedimentation,
along with high levels of nutrients and residual pesticides in those water bodies.
Nutrients, especially phosphorus, adhere to eroded soil particles, causing excess-
ive algae growths and other undesireable aquatic vegetation. NPS runoff can cause
problems with almost all uses of water, including taste and odor problems, oxygen
depletion, and toxic levels of chemicals. These problems can cause direct harm
and loss of habitat for aquatic life, detrimentally affect drinking water, and
cause sufficient bioaccumulation of toxic chemicals in fish to pose a hazard to
to consumers.
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36
ional Agenda
Provide technical and financial support through Sections 106, 108, and
205j of the Clean Water Act to strengthen the States1 role in NFS water
pollution control, and assure that Regional NPS control needs are fully
considered during program grants negotiations.
Provide technical assistance to GLNPO to assure the Section 108 projects
benefit NPS water quality problems.
Work with GLNPO and the States to develop and implement water quality
based herbicide-free and herbicide-reduced agricultural NPS abatement
strategies and projects to minimize herbicide loadings and correct
other identified water quality problems.
Work with GLNPO to assure that the NPS strategies and programs in Indiana,
Michigan and Ohio reflects their roles in the Great Lakes Phosphorus
Reduction Plan.
Document, evaluate, and analyze existing data to define the water quality
impacts of agricultural NPS pollution. Where data are inadequate to do this,
develop plans to obtain the appropriate information.
Assist States and other Federal agencies in evaluating and analyzing
State control strategy implementation, including NPS project plans and
individual Best Management Practices.
Initiate or follow-up contacts with other Federal agencies and private
organizations to support both group's participation in NPS prevention
and control programs.
Either independently or in coordination in EPA Headquarters, provide
direct support and assistance to innovative State or local NPS projects
witn the potential to mitigate newly identified or emerging NPS-related
problems.
Work with water quality control and soil conservation agencies to establish
jointly funded projects that serve both soil conservation and water quality
management.
Headauarters Actions Needed
Implement the USEPA Nonpoint Source Policy and Strategy in its entirety,
based on existing authority under the Clean Water Act.
Develop and provide technical guidance and data on analytical methodologies,
best management practices, management structures and financing.
Provide a central clearinghouse for NPS water quality information.
Coordinate/encourage participation through programs of other Federal agencies
in State-selected projects.
Refine and update National NPS Policy and Strategy as needed.
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37
Environmental Results
ected
The water quality benefits of erosion, pesticide, and nutrient loss control
are well documented and measured by the reduction of use impairments. State
strategies to reduce erosion and agricultural chemical discharges to water
bodies will reduce nuisance vegetation, turbidity, and pesticide levels,
and improve the quality of fisheries and surface water supplies. The actual
amount of improvement is site specific and depends on the extent and success
of individual projects.
Indicators of expected environmental results can be drawn from such examples
as the Blue Creek Watershed Project. The main water body, Pittsfield City
Lake, had identified drinking water supply and recreational use impairments
due to agricultural runoff and sedimentation. Over a 3-year period, USEPA
and the Department of Agricultural implemented a joint demonstration project
with local farmers and others, implementing erosion control practices. These
practices reduced soil erosion by over one-third, which reduced sedimentation
in Pittsfield City Lake by 25 percent and phosphorus by 17 percent. There
were significant improvements in recreational use due to the decreased rate of
sedimentation and levels of in-lake turbidity.
Over the next years, sixty-one watersheds have been targeted to receive accelerated
technical and cost-sharing assistance to correct NPS problems. We expect the
implementation of nutrient management, terraces, vegetative coverages, conservation
tillage, and best pesticide management practices on critical lands within these
watersheds will reduce pollutant and sediment loadings by an average of 60 percent.
We have calculated the following ranges of water quality improvements from imple-
menting these practices in various areas:
60-95 percent phosphorus reduction
55-90 percent nitrogen reduction
75-95 percent sedimentation reduction
50-90 percent pesticide reduction
While these improvements will take some time to actually have their effects,
they will eventually have benefits on groundwater, wildlife habitat, and water
quality uses.
K. PROTECTION OF WATER QUALITY IN INLAND LAKES
1. Cultural Eutrophication
Problem Assessment
Most of Region V's 25,000 lakes are located in Minnesota, Wisconsin and
Michigan, and they provide drinking water and recreational opportunities
for millions of people each year. Although most of the Region's lakes are
not covered by lake classification surveys funded under the Clean Water Act,
lakes in the southern portions of Minnesota, Wisconsin, and Michigan have
been analyzed and found to be undergoing long term degradation from such
processes as runoff from agricultural and urban areas, leaching from septic
fields, destruction of adjacent wetlands, and interference with stream flow.
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38
In spite of these findings, watershed management plans for these lake
areas have never been developed or implemented. Historically, the Clean
Lakes program has focused on structural changes, such as dredging and weed
harvesting, to rehabilitate lakes. While these solutions enhance short-term
recreation potential, they are costly and often ignore the basic causes of
eutrophication. The Clean Lakes program has received low levels of funding
over the past several years and, therefore, very few lakes have been rehabil-
itated. Basically, the problem is less one of not having the technical tools
to understand or resolve the environmental threats, but instead the problems
appear to be more of priority, funding, and institutional ennui.
ional Agenda
Prepare State applications for Section 314 funding.
Develop State-specific strategies to fund necessary revisions to
Classification Surveys, and assure their consistency, where appropriate,
with the Regional NPS strategy.
Ensure each new Phase 2 grant provides for two years of environmental
results monitoring to encourage States with watershed management concerns
to update or develop lake classification surveys.
Encourage development of Federally-funded watershed management projects
prior to initiation of in-lake work.
Prepare nonconstruction projects for State funding (approximately 2 per
State per year).
Develop State funding sources for nonstructural solutions.
Facilitate the transfer cf technology on lake and watershed management
techniques between Regions and States.
Develop a general nonpoint source program directed at protecting inland
lakes.
Provide technical assistance on watershed management classification
systems, and other lake projects.
Headauarters Actions Needed
Provide a definitive national statement on how the Clean Lakes program
should be managed over the next five years.
Request that Congress reauthorize the Clean Lakes Program.
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39
O
Specify ample lead time (at least 6 months) for State preparation and
Regional review of candidate projects.
Implement the National Nonpoint Source Strategy
ected Environmental Results
For the past 3 years, Region V has advanced a watershed management approach
aimed at protecting and improving the water quality of surface impoundments
and natural lakes. The elimination or reduction of nonpoint source and
point source contributions will benefit water quality, enhance recreational
opportunities, and provide higher quality drinking water supplies. Lake
aesthetics would improve because of reduced growth of nuisance algae.
Structural changes, such as dredging, can restore high priority lakes within
the context of an overall watershed management plan.
The Region can project specific environmental results based on experience
with several project types that have been conducted within watershed manage-
ment plans. The Clearwater River (Minnesota) Chain of Lakes Clean Lakes
Project emphasized agricultural erosion reduction practices. Even in 1984
a year of heavy rainfall with runoff rates 2 to 4 times the norm - the total
external phosphorus load to that watershed was reduced by 39 percent, from
86,000 Ibs. to 52,000 Ibs. One part of the project was particularly success
ful, accounting
for
the vast bulk of the total reduction. In that area, the
reduction was from 35,000 Ibs. per year to less than 1,000 Ibs. We expect
further reductions as the watershed management plan continues. During normal
rainfall/runoff years, we estimate remaining phosphorus loadings to vary
between 20,000-40,000 Ibs., and the anticipated watershed erosion reduction
practices yet to be implemented will reduce this to about 5,000 Ibs.
The
prog
the
tons
Lak
k
Le-Aqu
1th in
s wate
. for
Na Clea
ake str
qua!ity
Lak
Project combined a
t
dredging
point source
ae harvesting
t
S
f
a tot
d
soil loss h
n reduction
b
f
y
E
though th
is a
tively new project
Igae
n reduced f
7560 tons/y
it has alr
t
5.12 t
tor
2.0
t
3000 tons/
dy produced a
gnificantly improved, quality
t
resource.
2. Preservation of Wetlands
Problem Assessment
Agricultural, urban, and transportation developments have resulted in the
loss of well over half of the known Region V wetlands, and their destruction
continues at an alarming rate. This destruction of wetlands systems means
loss of important wildlife habitat; reduced natural protection from floods;
increased need for costly, man-made flood control systems; increased levels
of conventional and hazardous pollutants in the Region's waterways (partic-
ularly from non-point sources); and, an increased need for remedial pollution
control programs. Several factors contributing to the continued loss of
wetlands remain unchanged:
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40
Ideological perceptions that wetland issues are solely matters of land
use and property ownership, without regard to ecological consequences.
Legal and economic policies at all levels of government encourage
wetland losses. Agricultural price support systems, flood insurance
programs, and inequitable taxation policies make development of
cheap, "worthless" wetlands a profitable enterprise.
Inconsistent and uncertain administration of regulatory programs has
hampered efforts to control losses and encourage responsible wetland
use.
Current wetland protection regulations do not adequately address
harmful practices such as wetland drainage or piecemeal destruction
Inability to conduct and maintain an accurate wetland inventory has
hindered attempts to protect existing wetland areas.
Reqi
enda
Expand and emphasize the Advanced Identification of Disposal Sites
program to protect important wetlands. Such advance designation will
help avoid permit issuance by designating, in advance, which wetlands
suitable for various purposes and what activities should be prohi
bited.
Utilize existing regulatory and management tools to minimize wetland
degradation or destruction.
Develop and implement the Section 404 enforcement strategy.
Develop an audit strategy to evaluate the Michigan Section 404
delegation.
Work with the States to:
Establish water quality standards for wetland areas, to assist
EPA, the States, and the Corps of Engineers in assessing the
effects of discharges and other activities on wetlands physical
characteristics.
Develop water quality management plans that recognize and encourage
the protection of natural wetlands.
Adequately reflect the status and importance of wetlands in the
305(b) water quality reports.
Assure coordination between the Regional offices developing the in-situ
pollutant policy and the 404 Dredge and Fill program.
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41
Headauarters Actions Needed
Renegotiate the MOA between EPA/COE to establish better procedures
to enhance the environmental aspects of the 404 program.
Assess options to protect wetlands against harmful but currently
unregulated practices.
Develop and implement regulatory programs to encourage and facilitate
wetlands preservation in project planning.
Environmental Results
ected
A wetlands treatment system, part of the Long Lake Project, expects to reduce
internal phosphorous loadings to Lake Josephine by 57 percent (about 668 Ibs.
per year). That wetlands treatment system has consistently achieved about 60
percent removal efficiency for phosphorous, about 30 percent for nitrogen and
about 80 percent for sediments.
If the Agency can continue to use environmental indicators such as the one
above to quantify specific benefits of wetlands preservation, we can make a
much more convincing case as to the value of wetlands. With this information
and an expanded Advanced Identification of Disposal Sites program, the
Region and States will be able to identify and protect the highest quality
wetlands from fill activities which reduce wetlands surface area and
contaminate surface and groundwaters. This will improve recreational
activities along many of the Region's rivers and streams. Slowing the
rate of wetlands loss will protect groundwater recharge areas and improve
habitat for fish and wildlife.
COMBINED SEWER OVERFLOWS
Problem Assessment
A problem for many of the older municipalities is controlling and treating
combined sewer overflows (CSO). The CSO problem is complicated by its
site specific nature, and that CSO impacts are often masked by nonpoint
source impacts.
Larger storm events cause bypasses from the combined sewers to protect
treatment plants or because of inadequate sewer system capacity. These
overflows cause several problems: 1) the immediate contamination of
surface waters from untreated sewage; 2) the long-term pollution in the
receiving water because solids settle to the bottom and form sludge
deposits; (3) lost recreational potential; and (4) aesthetics degredation
The Agency's bi-annual needs survey in 1984 estimated a need of $6.4
billion for construction of CSO abatement projects in the Region.
represents 28 percent of the total national CSO need.
This
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42
Part of the Regional and National dilemna in assessing controlling CSOs is the
difficulty of establishing water quality standards applicable to wet weather
flows. Water quality standards generally allow standards exceedances under
unusually low flow conditions. It may be equally logical to establish unusually
high flow conditions relief, as during a 100 year storm, for CSO* There has been
no comprehensive policy for issuing NPDES permits dealing with CSO discharges.
Those permits issued have been done on a case-by-case basis, frequently emanating
from controversial situations. While existing permits recognize CSO discharges,
the permits have no specific limits. Therefore, enforcement actions against local
communities to require management or control cannot be taken.
Since many CSO abatement activities are primarily initiated for other objectives
The
(e.g., basement flooding), they frequently result in multi-purpose projects.
complexity of EPA's multi-purpose funding policy has many implementation pitfalls
EPA's lack of a comprehensive policy has resulted in Region V's delegated States
making case-by-case decisions by default. Therefore, project solutions, effects,
and costs vary considerably from State to State.
o
end a
Control
priority
tions
are
CSO pollut
municipal
1 inked t
by c
facilit
CSO ev
pleting the identificat
f th
highest
f
hich
t
qua Iity
dards viola
t
d develop appropriat
dit
d
controls in NPOES permit
o
Complete water quality standards reviews/revisions and identify priority
water bodies. The priority water bodies in turn must be compared against
CSO discharge points to determine the contribution of CSO to the problems
in a given area.
Finalize a Regional CSO policy that includes specific actions for con
sistent implemention by the States.
Ensure CSO problems in all GLNPO-areas of concern are addressed as the
remedial action plans are prepared.
Identify all dry weather overflows in the Region and ensura controls
are implemented via permit enforcement or judicial orders.
Work with the States to improve sewer system maintenance projects that
will control inflow and infiltration.
Work with the States and municipalities to ensure that there is adequate
sewer capacity that will prevent overflows and environmental degradation
Headauarters Actions Needed
Provide more explicit National policy direction on criteria for NPDES permits
dealing with CSO discharges, and on setting water quality standards for high
flow conditions.
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43
Expected Environmental Results
CSO projects vary tremendously - from those at such cities as Minneapolis/St.
Paul and Detroit to one at Boonville, Ohio (pop. 1500). The Region and States
are now developing a CSO policy which will eventually lead to strategies and
projects with quantifiable environmental results, from reduction of suspended
solids and floatable materials which cause aesthic impairments, to reductions
of nutrients such as phosphorus which upset natural water ecological balances.
The Region has implemented several CSO remedial actions, primarily through
construction of retention basins and in-line storage. However, these con-
struction solutions have been extremely expensive to build and maintain. A
new project that may provide dramatic environmental benefits at lower costs
is being tried at the City of Saginaw. Beginning in 1979, the Region and
the City modified 13 combined sewer regulation chambers and constructed one
new in-line control chamber to maximize temporary storage of wet weather
combined sewerage that could be held for later treatment at the City!s
treatment plant. These innovative changes have incrementally reduced suspended
solids loadings to the Saginaw river by 16 percent, BOD by 20 percent, and total
phosphorus by 8.5 percent.
As the States finalize their own CSO policies in FY 86, the mechanisms will be
in place to plan for future strategies and projects that will have similar or
greater environmental benefits.
M. EMERGING ENVIRONMENTAL PROBLEMS
1. Indoor Air Pollution
Problem Assessment
As more information becomes available, the problem of exposure to indoor air
pollution such as passive exposure to tobacco smoke, exposure to radon, and
exposure to formaldehyde have all stimulated public concern that indoor air
pollution may be a serious health problem. In Region V, the emphasis on
energy conservation has led to a lowering of the air exchange rate of a
typical home, and subsequently to potentially greater accumulations of indoor
air pollutants. Even now, the Region routinely receives calls regarding
indoor radon concentrations in private residences. With the increase in
data and public awareness, Region V expects a commensurate increase in
program demands for information and some Agency response.
Regional
enda
Establish and maintain an indoor air pollutant contact person to provide
informed and factual responses to citizen concerns.
Provide information to State Air and Radiation agencies on indoor air
pollution, including a regional workshop on the indoor radom problem.
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44
Headauarters Actions Needed
Headquarters should continue reseach into the problem of indoor air
pollution and provide technical information as it becomes available
Headquarters should consider guidance on possible Agency responses
to requests for action.
2. Vehicular and Industrial Emitted Lead in Soil
Problem Assessment
The City of Chicago Health Department recently performed a survey of public
playgrounds and parks to determine the soil lead content. These analysis
indicated significant soil lead concentrations in areas near major highways,
which prompted public concern regarding lead in playground soils. As a
consequence, the State of Illinois is currently undertaking a broad state-
wide analysis of lead in the soil of playgrounds in the state. The most
obvious source of this lead is motor vehicles using leaded gasoline. Since
there are other major metropolitan areas in Region V which have very signi-
ficant levels of motor vehicle traffic, the Region expects that this will
become a broad Regional concern.
An additional concern with elevated soil lead levels is in the proximity
of lead point sources. Recent soil analyses near two lead sources in North-
western Indiana have indicated significantly elevated lead levels in off-plant
property - one of which was a residential area near the plant. It is reasonable
to expect elevated off-plant property lead levels around other major lead
point sources in Region V and other areas of the country.
ional Agenda
Continue to work with Illinois to characterize the extent and magnitude
of lead in soils.
Inform other states in the Region of this potential problem.
Continue to work with states and local agencies to develop misfueling
programs to limit the lead from motor vehicles as much as possible.
Explore potential clean-up of the most polluted areas contaminated by
vehicular lead.
Continue to work with Indiana to develop an acceptable lead SIP for point
sources.
Explore potential clean-up of polluted areas contaminated with stationary
source lead emissions.
Headauarters Actions Needed
u Define available resources which could be used to pay for clean-up
Define appropriate action level for clean-up of lead in soil.
Establish Agency policy on requiring implementation of anti-tampering/
anti-misfueling programs.
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45
Part III
COMMENTS ON AGENCY PRIORITY LIST
Region V feels that the Agency's overall priority list should be limited
to about 10 items, 15 at the most. Beyond that number, they lose their
effectiveness and cease to be priorities - if everything is a priority,
then nothing is a priority.
If additional priorities are desired, they should be included by the indivi
dual national programs. There need be no such numerical limit for those.
So, Region V's comment on the Agency Priority List is to keep the first 10
priorities as ranked and written, except for number 10 which we suggest
be rewritten as follows:
10.
"Implement the national municipal policy to achieve municipal compliance
with final effluent limits no later than 1988 or as soon as practicable
with or without Federal funding." This will help ensure timely and
appropriate enforcement response to instances of significant noncompliance
with MPDES permit requirements (including requirements for pretreatment
development) and of pretreatment standards to achieve compliance as
soon as practicable.
-------
Appendix B - The Air Addendum
Note: The Air Addendum covers page 1-41, pages 42-59 describes a proposed
geographic-specific enforcement coordination effort which has some
very interesting environmental planning and environmental indicators
implications.
-------
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444
Environ
Protection
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-------
Draft Geo
or
erne
Sources,
hio
River
Basin
Dioxide
fur
Attached is an outline of suggested activities for implementing a geographic
enforcement initiative (GEI) directed at insuring continuous compliance of
major sulfur dioxide emitting sources in the Ohio River Basin. A major sulfur
dioxide emitting source (MSDES) is defined as one which emits 50,000 tons of
sulf'jp dioxide ($03) or more per year or which causes or substantially con-
tributes to a violation of the $02 National Ambient Air Quality Standards
(NAAQS). This draft GEI proposal specifically addresses those MSDESs
emitting 50,000 tons S02 or more. Later drafts will include an inventory
of those MSDES emitting less than 50,OCO tons S02 per year yet significantly
impacting ambient S02 air quality.
The basic thrust of this proposal is to use present authority to insure
strict and consistent compliance of all MSUES's with their existing emission
limits. Those limits were established to either protect ambient air quality
standards or to reflect emission levels associated with tne best available
technology
for
new sources. Because of a lack of reported continuous
compliance data and
the
existence of conflicting interpretations of the
applicable compliance averaging times for S02 emissions, the EPA cannot say
with certainty that these sources are in continuous compliance with their
established emission limitations. Tnis lack of certainty is serious because
the Ohio River Basin has the highest concentration of S02 non-attainment areas
Consequently, the EPA is concerned that without close monitoring of compliance
of these MSOES's, ambient S02 "evels: 1) will not soon improve in those areas
not meeting the NAAQS,
maybe in excess of the standards in unclassified
areas, and
merit.
could increase to exceedance levels in areas of marginal attain
The Ohio River Basin was chosen for an air pollution GEI~because that area
has a lingering amoient S02 problem and has been extensively characterizec in
the past by a joint Department of Energy and Environmental Protection Agency
research and development program (see "Ohio River Basin Energy Study (ORBES):
Main Repor
January 1981, EPA-6QO/781-008). The ORBES report provides
sufficient background information on the re^tionship of MSOES's and environ
mental qualtty in the basin. The report clearly projects the effect of high
S02 ambient concentrations due to
emsson
from MSOES's on crop losses and
public health effects (increased mortality and morbidity).
The area chosen for the
(*** T
Gel
is a portion of the ORBES region.
It
encompasses
GEI
those Air Quality Control Regions (AQCRs) directly bordering on or containing
portions of the Ohio River (see Figure 1). The proposed boundaries of the
include 11 AQC/Ts and 153 counties in six different states. Seven of the
11 AQCRs cross state and EPA regional boundaries. Intaragency cooperation
and coordination is a necessary component of any strategy for solving tne
ambient S0£ problem in the Ohio River valley. The boundaries of the G
are preliminary and could be changed based on input from Regions III or IV.
Ci
42
-------
Though the proposed GEI area is approximately a third of the QRBES area,
it contains a significant number of MSDESs. The preliminary count of
MSDESs indicates 33 individual electric utility plant sites, all of which
were listed in the top 100 power plants nationwide in terms of $03 emissions
in 1980 (see Figure 2). Twenty of these plants are located directly on the
Ohio River. Other than power plants no other type of stationary source
has been identified in the proposed
/"**" T
Gel
area that emits 50,000 tons or
more of $02 per year. An inventory would be conducted after the GEI
boundaries are finalized in order to identify other major sources of sulfur
dioxide that cause or significantly contribute to the elevated SOg ambient
air quality levels in the Ohio River 3asins' non-attainment areas,
Our
oncern with the current status of the S02 air quality levels in tne
study area is illustrated by the following statistics:
In 1985 there are 16 counties designated as non-
attainment or unclassified in regards to the $02
NAAQS within the proposed GEI area. Nine of the
11 AQCRs within the area have at least one non-
attainment area.
In 1983 and 1984, 23 of the total of 120 ambient
monitors located in the proposed GEI area recorded
violations or marginal compliance with the primary
$02 NAAgS. This is particularly significant in
light of the recognized deficiencies in the existing
ambient monitoring networks to effectively measure
maximum $03 impacts from MSOES. There are on average
less—thaivjar.e monitor-per county with an average of
el even ~per~AQCRr~ Some of the AQCRs have only three
or four monitors total
The existence of so many
monitored exceedances with so poor a monitoring net-
work indicates that there is a larger air quality
problem than what is currently being seen.
E
missions from the 33 power plants have remained fairly
stable over the past six years
Thus, we Deli eve that the overall air quality levels in the proposed GEI
area are currently showing a problem that has been lingering
for
many years
Ensuring that the MSOESs are at least meeting the existing federally approved
emission limitations on a continuous oasis would be a
elimination of the public nealth problem in this area.
irst step in expediting
43
-------
The proposed mechanisms for insuring effective enforcement of the applicable
emission limitations, and thereby insuring continuous compliance are:
Determine the current applicable $03 emission limits
(or sulfur-in-fuel limits) for each MSDES. Establish
a hierarchy of those applicable $03 regulations using the
classifying criteria of
numerical stringe
of the emission limit,
stated or understood compliance averaging cime,
stated or understood compliance testing methodology,
stated or understood compliance testing frequency,
enforcement authority at the Federal, State and local
levels.
Identify the S02 emission limitation chat best protects trie
3-hour and 24-hour SO? NAAQS around each MSOES.
Identify any special enforcement or permitting programs that
could effect the interpretation of the $03 emission limitations
or attempts to enforce
hem.
This may include factors such as:
stipulated penalty program based on continuous emission
monitoring
permit-to-operate
PSO/NSR/8U8BLES/GfF-SETS/8ANKING/TRAOES
Environment Auditing
Site specific SIP revisions
Enforcement Orders and Consent Decrees
Enforcement Policies.
fcr
that
Identify for each MSDES the air pollution control agency with
the primary responsibility for ensuring compliance
MSOES with the SO? emission limitation that best protects against
short-term ambient excaedances.
Establish commitments through AMAS, SPMS and performance based
grants for those specific lead agencies to require and evaluate
emission information
from
those sources, to verify compliance
with applicable limits using shortest applicable averaging time
if the source is not in compliance
in accordance with the EPAs timely and appropriate enforcement
and to initiate enforcement
'
policy.
44
-------
Utilize discretionary authority (§114 OP State authority) to
require a uniform minimum level of source-generated emissions
monitoring and reporting - GEM, FSA, intermittent monitoring,
scheduled compliance test at each MSOES.
Establish schedules for installation of monitoring equipment
and initiation cf reporting. Allow approximately 6 months
for initiation of reporting from sources installing and
utilizing coal sampling and analysis (CSA) procedures for
computing emissions on a 24-hour basis. Allow approximately
18 months for sources not presently equipped with Sl)2 CEMs to
install such equipment and begin reporting of $03 data. CE
is tne preferred means of generating continuous compliance data
In the interim period, prior to installation of CEMs sources
should be required to supply available CSA information. MSDESs
with S02 CEMs or CSA systems already in place would be required
to begin reporting witnin 2 months of initiation of the program
Establish and implement a consistent approach for the review ana
use of continuous emission monitoring data and emission averaging
times, for evaluating the compliance status of MSOESs in the GEI
area.
Establish an interayency pool of technical and enforcement expertise.
Also attached is background information on the area, ihe sources and the
regulations. These areas would need to be further researched and detailed.
It is expected that personnel in Regions III and IV and in the state agencies
would be very active in all decision making associated with preparation of the
final
draft
proposal,
45
-------
GEOGRAPHIC ENFORCEMENT INITIATIVE (GEI)
1.
Puroose:
Insure continuous compliance of major sulfur dioxide emitting sources
2
3
Ma.ior Source:
Emitting in excess of 50,QOC tons S02/year
Selected Area Must:
o
O
how significant dec Line
show lack
improvement
be a threat to health
have multi-media violations
have cross-boundary impacts
have enforceable regulation
Area Selected
h
Ohio River Basin (area has serious SO? problems')
a
Without close monitoring
Area will not improve
NAAQS will not be achieved
5
Area Covers
o
o
o
o
111inois
Indiana
Ohio
Pennsylvania
West Virginia
Kentucky
11 Air Quality Control Regions (AQCRs)
163 Counties
o
Plants In Each State
o
o
* • *
Illinois
Indiana .
Ohio ....
Pennsylvania
West Virginia
Kentucky
* «
9
* • *
2
7
OTAL
• * * •
33 °1ants (All among the too inn plants
in the nation.)
46
-------
The
ram will
o
J
o
require emissions information
evaluate emissions information
verify compliance with applicable limitations
initiate enforcement
utilize Section 114 or State authority to require
compliance test
monitoring data
intermittent monitoring
CEM installation
o
o
establish schedules for CEM installation
establish procedures to rev low and use CEM data
establish an inte^agency pool of technical and
enforcement expertise
require coordination of twenty requlatory agencies
Steos Reouired To Develoo GEI
Discuss the problem area using geographic orientation.
Coordinate with Region I and prepare a joint proposal
Coordinate with Regions III and IV.
0
Identify available enforcement requirements.
o
Develop a list of minimum criteria for enforcing
existing emission limitations.
o
Identify all sources which emit significant quantities
o
SO?.
Identify actual emissions of each source.
Identify allowable emission limits for each source.
Develop a compliance and enforcement plan.
Develop better, more effective-cooperative relationships
with States.
0
Develop performance based grants and S?MS commitments.
o
Set overview procedures to track State and Federal progress
Initiate Federal enforcement action if States do not oroce°d
^^^^^^^ ^^^^^^^
satisfactory.
47
-------
Geographic Enforcement Initiative
Addressing Major Sulfur Dioxide
Emitters in the Ohio River Basin
David Kee, Director
Air Management Division
Region V
Ray Cunningham, Director
Air Management Division
Region III
and
and
Lou F« Ritto, Director
Air Management Division
Region I
vlames T. Wilburn, Chief
Air Management Branch
Region IV
Attached is a draft proposal for a Geographic Enforcement Initiative
that we would like to develop and present as a joint proposal to
the Administrator for his consideration. This proposed GEI was prepared
in line with the guidance in the memorandum of May 24, 1985, from Courtney
Price. The main ?ocus
the GEI would he to utilize present authority
• ^^ *
and assure continuous ccmoliance with sulfur dioxide emission limitations
at all major sources located inTfte most environmental iy stressed norcion
of the Ohio River Basin. We ask for your consideration and cooperation
in the preparation of a final proposal.
Region V's Environmental Services Division is in the process of generating
plots fron MEDs and SAROAD data to graphically portray the status of emis-
sions and air quality in
the
air quality control regions comprising the
Ohio River Sasin. .Cooies of those plots will be sent
to this draft as soon as they are available.
to
you as supplements
This project will definitely require interregional cooperation and coordin-
ation. We ask that you review this initial proposal and send your comments
Mr. Peter B. Spyropoulos in Region V, Air Compliance Branch (5AC-26-II).
to
I
you, we would suggest you have personnel responsible for sulfur dioxide
this coordinated sulfur dioxide enforcement strategy appears viable to
compliance issues in your Region contact
proposal can be exoeditiously prepared.
Spyropoulos so that a joint
"hanking you in advance for your consideration
Attachments
c
Kertcher
Paisie
Czerniak
Spyroooulos
Goranson
AMO:ACS:SECTION 11:MCCOY:3-2086:ram:3-12-85
ram
McCoy
Sect. Sec.
Spyropoulos
Gingher
Kertcher
Geisler
Kee
48
-------
OUTLINE FOR DEVELOPING A SO? GEOGRAPHIC ENFORCEMENT
INITIATIVE ACTION PLAN
Phase 1
Select an area for pilot sturfy with thp most environmental benefits
Areas .nust:
3.
o
O
O
show significant decline
show lack of improvement
be a threat to health
have multi-media violations
have cross-boundary (Governmental) impacts
have enforceaDle regulations
2. Identify and discuss the problem area using geographic orientation.
Coordinate with Reqicns III & IV and prepare a draft proposal.
Identify available enforcement requirements.
Identify lacking (deficiencies) enforcement requirements.
Develop a list of minimum criteria for enforcing existing emission
limitations.
5.
Identify all sources which emit significant Quantities of
Phase 2
6. Identify actual emissions of each source.
7. Identify allowable emission limits for each source.
8.
Compile a comprehensive compliance and enforcement plan
Identify cross-media impacts of violating sources
Identify remedies sought.
49
-------
Phase 3
9. Develop better, more efficient-cooperative relationships with States.
10. Develop performance based grants and SPMS commitments.
11
12
Set overview procedures to track State and Federal progress
Take Federal enforcement action if States do not proceed satisfactorily
50
-------
STATE: ILLINOIS
No.
Plant
1
EEI Joppa
STATE: INDIANA
No.
Plant
3
4
5
6
7
8
33
IPL Petersburg
PSI Gallagher
PSI Gibson
SIGECO Warrick/Culley
IKEC Clifty Creek
IMEC Creed
IMEC Tanners Creek
HE Ratts
STATE:
OHIO
No.
Plant
9
10
11
12
13
H
15
16
17
8P Cardinal
CG&E Seckjord
CG3.E Miami Fort
OP&L Stuart
OE Surger
OE Sammis
OVEC Kyger Creek
OP Muskingum River
OP Gavin
ATE:
No
PENNSYLVANIAN
Plant
13
19
20
21
22
23
WPP Hatfield
PP Mansfield
PE Conemaugh
PE Homer City
PE Keystone
PE Seward
51
-------
STATE: WEST VIRGINIA
NO
Plant
24
25
OP Mitchell
OP Kammer
STATE: KENTUCKY
No
Plant
26
27
28
29
30
31
32
BREC Coleman
8REC Henderson II
KU Ghent
LGE Mill Creek
TVA Paradise
TVA Sna^nee
KP Big Sandy
52
-------
53
Table 3.6
Ohio River Steam-Electric Power Generating Plants
1975 - 1983
Mile Point
15.6
33. S
32.3
34.5
$5.0
59.1
74.5
75.0
101.9
102.5
111.1
160.3
160.5
260.2
405.7
453.3
471.4
490.3
494.5
558.5
604.0
616.6
752,8
755.3
773.0
773.0
793.5
803.6
946.0
958.0
Station
J. H.
F. PHILLIPS
BOO MANSFIELD
SHIPP!NG?ORr
3EAVER VALLEY
W. H.
TCRCNTO
CARDINAL
KAM4ER
PLEASAtfTS
WILLS* ISLAND
5HIU? SPORN
GAVIN
J. M
W. C. 3EOJORD
WEST EM)
MIAMI FOTT
TANNER
MILL
PACDY'S SUN
CANE 3JN
' HJN II
ELMER
WARRIOC
WARRICX 14
OJLLET
OHIO
HENDERSON
SiAHNES
JOPPA
Installed Generating Capacity 0*0
1975
411.2
2202.5
175.8
226.2
1220.5
1622.6
712.5
1105.5
1200
1086.3
240C
1220.3
219.
892.3
1100.3
559.9
1203.6
321.1
337,5
1016,7
52.5
149.7
in,s
225,2
1750
1100.3
411.2
1650
2202.5
175.8
226.2
1845.5
1622.6
712.5
110S.5
260C
1086.2
2400
1220.2
219.3
1293.3
1100.3
1113.8
1302.6
746.1
327.5
1016.7
340
$2,5
I I
149.7
121.5
225.2
1750
1100,3
1983
1650
1712
1845
1632
1650
uos.s
1086.3
2400
2028
1220.3
219.3
1393.2
1100.2
1112.8
1302.6
1171.1
327.5
1016.7
52.5
300
149.7
121.5
225.2
1750
1100.3
F«d*nl Pew CaMttiiicn
-------
54
i ^ TL** f
* ^ • \ A ^^
il ^
-------
REGULATORY AGENCIES
1. U.S. EPA Region III
2.
U.S. EPA Region IV
3.
U.S. EPA Region V
ACB
4
Illinois EPA Region 3
5
Indiana Air Pollution Control Division (State Board of Health)
6.
City of Evansville, Indiana Air Pollution Control Office
7.
Ohio EPA Southwest District Office
8.
Ohio EPA Southeast District Office
9.
Southwestern Ohio Air Pollution Control
Cincinnati
10. Regional Air Pollution Control Agency - Montgomery County
11. Air Pollution Unit - Portsmouth City Health Department
12
13
North Ohio Valley Air Authority - Steubanville
Mahoning - Trumbull Air Pollution Control
14. Air Pollution Control Division - Canton Health Department
15. Pennsylvania Bureau of Air Quality Control
16. Allegheny County Bureau of Air Pollution Control
17.
West Virginia Air Pollution Control Commission
18. Wheeling Air Pollution Control Department
19.
Kentucky Dept. of Environmental Protection - Division of Air Pollution Control
20.
Jefferson County Air Pollution Control District
55
-------
c
56
-------
LJ
r-r ;
^•i ***
-rt
57
-------
r: i
\ *
-------
-------
Appendix C - Great Lakes National Program Office
Areas of Concern and Anticipated
Availability of Remedial Action Plans
-------
*%& •.*-,«--jwtpfli»*"*ltfirJ,^fet • •*> - *t.**ws
^ ^ •-'% ^C':'^'- +-- - ? * * • • ' -^
-v'r
t*/
\
-------
o
UJ
1
-------
' * *
If- hi tjP fcH ±
"V.
' ' !
**
t •*
** -
f
i *
\ +1 rb
r *
m t
i\
v h
,J t
-> '
r
u*
^if v '^K1 ^ -v ^ *• v V
-------
MAP
REF.
TABLE 4
AREAS OF CONCERN IN THE GREAT LAKES BASIN
LAKE BASIN/AREAS
CONCERN
JURISDICTION
Lake
nor
eninsula Harbour
Jackfisft
N1 pi gon
Thunder Bay
:. Louis River
Torch Lake
Deer Lake-Carp Creek-Carp River
Ontario
Ontario
Ontario
Ontario
Minnesota
Michigan
Michigan
Lake Michi
iver
Menominee River
River/Southern Sreen
Sheboygan
Milwaukee Estuary
Waukegan Harbor
Grand Calumet River/Indiana Harbor
Kalamazoo River
Muskegon Lake
White Lake
Canal
Michigan
Michigan/Wisconsin
Wisconsin
Wisconsin
Wisconsin
Illinois
Indiana
Mi chi gan
Michigan
Mi chi gan
Lake Huron
ver/Saglnaw Bay
Collingwood Harbour
Penetang Bay
Sturgeon
Spanish River Mouth
Lake Erie
ton River
Rouge River
Raisin River
Maumee River
Black River
Ashta
ga River
ula River
Wheat lev Harb
Lake Ontario
iver
Eighteen Mile Creek
Rochester Embayment
Oswego River
of Quinte
Port Hope
Toronto Waterfront
Hamil ton Harbour
Michigan
Ontario
Ontario
Ontario
Michigan
Michigan
Michigan
Ohio
Ohio
Ohio
Ohio
Ontario
New York
New York
York
New York
Ontario
Ontario
Ontario
Ontario
Connectinq Channels
iver
Clair River
Detroit River
Niagara River
Lawrence River
Ontario/Michigan
Ontario/Michigan
Ontario/Michigan
Ontario/New York
Ontario/New York
a.
See Figure 1
2
-------
**
I-1
t
*"
-.* *
r
t,
^ I
1, .
f
*
* *
'V
A1
w
A !
c
ri ->
*• '
, 4
, -
r -
f *.
* *
a .
4 '** "4*
bf
• t
-------
TABLE 5
NUMBER OF AREAS OF CONCERN ASSIGNED IN EACH CATEGORY
BY THE JURISDICTIONS
TOT
nta
a. Six of the 42 areas of concern are shared by two jurisdictions, .
NUMBER
DESCRIPTION
1.
Causative factors are unknown and there is no investigative
program underway to identify causes.
2.
Causative factors are unknown and an investigative program is
underway to identify causes.
3
Causative factors
known, but
Remedial Action Plan not
developed and remedial measures not fully implemented.
4
Causat
but re
fact
k
d Remed
Act
P
dial measures not fully implemented
developed
5.
Causat
all re
been i
fact
k
Remed
Act
P
di
P
measures identified
ted.
developed
d
Remedial Act
Pi
h
6.
Confirmation that uses have been restored and deletion as an
area of concern (in the next Board report).
3
-------
itr
***-,
* *.+ ^
j.
"**3 &* r
r
Vfc
*-*
j*,*
^ -»
* *
f c
3'
, B.
rt V
-------
TA8U
ANTICIPATED AVAILABILITY Of REMEDIAL ACTIOII PLANS
JURISOtCTIOM/AREA OF CONCERN
CATEGORY
JUNC 35
JlWt 96
DEC
Peninsula Harbour
Jackflsh Bay
Thunder Bay
Comngwood Harbour
Penetang 8«y/Sturgeon
Bay
Spanish River Mouth
Wheat Uy HarDoar
Bay of Quinte
Port Hoot
Toronto Waterfront
Haul!ton Haroour
St. Marys
St. Ciair River
Oetrott River
Niagara River
St. Lawrence River
IlLitiOtS
Waukeoan Harbor
6r»nd Calunet/lndlana Harbor
Torch Lake
Oeer Lake-Carp River
Man1st1que River
Henoialnee River
Kaiaaazoo River
Huskeaon Lake
Wftlte Lake
Saglnaw
Clinton River
Bay
Rouqe River
Raisin River
St. »*arys River
St. CUIr River
Detroit River
St. Louis River
8uf
aia River
Eighteen Nile Creek
Rochester
Osweoo River
Niagara River
Lawrence River
St.
aua
H«umee River
Black River
Cuvanoga River
AsfttabuU River
Harbor
AH
Henominee River
Green Bay
Fox River/Southern
Sheboyaan
Milwaukee Estuary
TOTAL
t
H-
4
------- |