903R85002
United States
Environmental Protection
Agency
Region III
841 Chestnut Building
Philadelphia, PA 19107
September 1985
4>ER^\ Environmental
Management
Report 1985
U.S. Er.vi'cnmantal Protection Agency
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PhiijdL'.pina, PA 19107 / . V,:-
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Region 3
1985
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Regional Center for Environmental Informattoo
US EPA Region III
1650 Arch St
PhUaddphia. PA 19103
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION III
1985
ENVIRONMENTAL MANAGEMENT REPORT
James M. Self, Regional Administrator
Stanley L. Laskowski, Deputy Regional Administrator
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Ph;ladiipii,a, PA 19107 '' :^i^
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Prepared by:
Environmental Services Division
Greene A. Jones, Director
Thomas A. Slenkamp, Project Manager
September, 1985
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Acknowledgments
This Report represents the efforts of many individuals and organi-
zations within Region III, and the Region III States, who contributed
generously to the project, even though it was not part of any formal
program plans. It has been a challenging and rewarding activity for
us, and we thank all who contributed ideas, analyses, and effort during
the project.
We would especially like to thank the following individuals:
EMR/MER Task Force: Clerical Support:
James W. Newsom Willa Bradley
Dennis Carney Frances Andracchio
John R. Pomponio
Richard Pepino Editting:
Joseph Piotrowski
E. Dale Wismer Michael Chern
William Belanger Kenneth Andersen
Dennis Zielinski
Michael Vaccaro
Elaine Wright
Henry Brubaker
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Region III
1985
Environmental Management Report
TABLE OF CONTENTS
PART I. REGIONAL ADMINISTRATOR'S OVERVIEW
A. Summary of Significant Regional Problems
B. Managing for Environmental Results
C. Special and Emerging Issues
PART II. SIGNIFICANT REGIONAL ENVIRONMENTAL PROBLEMS
A. Identification and Ranking of Problems
B. Discussion of Problems
1. Hazardous Waste Management
A. Site Cleanup
B. Disposal Capacity
2. Drinking Water and Groundwater Contamination
3. Resource Extraction
A. Acid Mine Drainage
B. Oil and Gas Production
4. Toxic Chemical Mr Releases
5. Ozone Standard Violations
6. Surface Water Toxics
7. Environmentally Sensitive Areas
8. Indoor Air Pollution
A. Radon
B. Asbestos
9. Non-Point Source Pollution
10. Acid Rain
C. Focus on Specific Geographic Areas
PART III. REGIONAL RECOMMENDATIONS FOR THE AGENCY'S 1987-88 PRIORITY LIST
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PART I.
Regional Administrator's
Overview.
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PART I. REGIONAL ADMINISTRATOR'S OVERVIEW
This year's Environmental Management Report (EMR) sets forth
our view of the most significant environmental problems facing the
States of Pennsylvania, Delaware, Maryland, Virginia, West Virginia,
and the District of Columbia. It also outlines actions that EPA and
the States are taking, and will take, to achieve environmental results
on these problems.
Our major purpose in undertaking the EMR process is to make sure
that sufficient attention and resources are directed to attacking the
Region's most significant problems, commensurate with the scope and
severity of those problems. This year's EMR does not attempt to serve
as a State of the Region report or a comprehensive summary of all of
our environmental problems and programs. We will continue to carry
out all of the environmental laws and policies for which we are
responsible. We are using this EMR process, however, to achieve
maximum possible impact in resolving our biggest environmental
challenges. The Region III staff and management represent a wealth
of knowledge and experience in solving environmental problems. We
are anxious to meet the challenges outlined in this year's EMR.
A,, SUMMARY OF MOST SIGNIFICANT REGIONAL PROBLEMS
The Middle Atlantic States of Region III are faced with a variety
of complex, formidable, and often interrelated environmental problems.
Many of these are more difficult to define, and thus control, than
were the broader pollution problems of a decade ago.
Through a collaborative Regional process described in Part II,
we have identified, in order of priority, the following most significant
environmental issues facing Region III today:
1,. Hazardous Waste Management - With 89 uncontrolled hazardous waste
sites on or proposed for the National Priorities List (NPL), and
a widening gap between the volume of hazardous waste generated
versus the available capacity for storage, treatment, and disposal,
it should come as no surprise that hazardous waste management is
our number one priority. The probability of discovering additional
hazardous sites, and new RCRA regulations governing small quantity
generators will further increase the challenges we now face.
2,, Drinking Water and Ground Water Contamination - Drinking water
quality in many areas of the Region is being threatened by (1)
persistent bacterial contamination in small water supply systems,
and (2) increasing levels of unregulated toxic organic chemicals.
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Our ground water resources are of particular concern since
they supply drinking water for 50% of the Region's 24 million
people. The potential for aquifer contamination is of special
concern in Southeastern Pennsylvania; New Castle County, Delaware;
Anne Arundel County, Maryland; and Brooke County, West Virginia.
3. Resource Extraction (Mining) - Environmental impacts resulting
from mining activities represent a significant Regional problem.
We have chosen to focus on the two following areas of concern:
Acid Mine Drainage, frequently caused by improper reclamation
of coal-mined lands, is responsible for approximately 3000 miles
of ecologically impaired streams in Pennsylvania, West Virginia
and Maryland. It represents the most pervasive water pollution
problem in Region III, and includes adverse effects on aquatic
life, water supplies, contact recreational uses, aesthetics, and
man-made structures subject to corrosion.
Oil and natural gas production in western Pennsylvania and
West Virginia is increasingly recognized as the cause of several
environmental problems. Improper disposal of brine (a byproduct
of the drilling operations) has led to degradation of streams,
localized contamination of ground water, and increased levels
of sodium, chlorides, arsenic, cadmium, and other contaminants
in concentrations well above drinking water standards.
4. Toxic Chemical Air Releases - As in other areas of the country,
Region III is increasingly aware of the potential dangers
associated with the release of even trace amounts of toxic
chemicals into the environment. Airborne toxicants represent a
special concern in the Region due to the presence of many heavily
industrialized areas, a variety of possible sources, many areas
of dense population, and the lack of regulation on all but a
few chemicals. Two types of releases are of concern: (1) Routine
releases from both specific facilities and areawide (non-specific)
sources, causing primarily chronic, often insidious, health
effects, and (2) sudden, accidental releases which result in
acute effects, with a Bhopal-type incident representing the
worst possible case.
5. Ozone Standard Violations - The National Ambient Air Quality Standard
(NAAQS) for ozone is still not being attained within several large
geographic areas of Region III. While air modelling predicts
attainment for most of these areas by 1987 assuming continued
program controls, the Philadelphia Air Quality Control Region is
not expected to achieve attainment status unless extraordinary
control measures are taken.
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6. Surface Water Toxics - The 1983 EMR identified toxic substances
as the cause of 16% of use-impaired stream miles in Region III.
Identifying the extent, severity, and impact of toxics in surface
waters remains difficult. However, the 1984 State Water Quality
Reports pointed to a number of problem areas based on data that is
available. These include the Elizabeth River and Baltimore Harbor
in the Chesapeake Bay, and the Beaver, Delaware, Mahoning, and
Shenango Rivers in Pennsylvania. Aquatic life uses appear most
heavily affected by toxics in surface waters However, there is
also some evidence to suggest that there may be potential public
health risks as well.
7. Loss of Environmentally Sensitive Areas - Population growth and
development threaten environmentally sensitive areas throughout
the Region. Particularly susceptible are fragile coastal lands
along the flats of Delaware, Maryland, and Virginia due to
urbanization and drainage for development, and peat bogs in the
Pocono Mountains threatened by mining and recreational development.
8. Indoor Air Pollution - Recent data suggests that indoor exposures
to both man-made and natural air pollutants have an greater affect
on public health than outdoor exposures. Radon, a naturally
occurring radioactive gas, represents a significant public health
threat in certain areas of the Region, including the "Reading
Prong" in Pennsylvania, where 40% of the homes tested by the State
showed unhealthly levels. Asbestos is another indoor air pollutant
which continues to be of concern, especially in many older public
buildings and schools where it has been trowled or sprayed on in
surface coatings and is now friable.
9. Non-Point Source Nutrient Pollution - Nonpoint sources of pollution
are a dominant water quality issue throughout Region III. NFS
pollutant loads are the leading contributor in 54% of the use-
impaired stream miles in the Region. Nutrient contributions
(phosphorus and nitrogen) and associated sediment in runoff,
principally from agricultural sources, are a significant factor
in eutrophic conditions in the Upper Chesapeake Bay, and are
also believed to have greatly reduced the submerged aquatic
vegetation (SAV) throughout the Bay. Excessive nitrogen loads
are also thought to contribute to ground water contamination.
10. Acid Rain - The Middle Atlantic States represented by Region III
are at the center of the acid deposition problem, both as a
receptor of pollution released from neighboring and distant
states, and as a contributor to Regional and external acid rain
effects through emissions of sulfur dioxide and nitrogen oxides
within Region III. Acidification of lakes in the Pocono Mountain
region has been observed, partly through EPA's Survey of Northeastern
U.S. Lakes carried out in the fall of 1984. Forest damage is less
well documented, but still suspected as a result of acid deposition.
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B. MANAGING FOR ENVIRONMENTAL RESULTS
The pilot 1983 Environmental Management Report provided a
comprehensive perspective on the environmental problems within
Region III, and outlined the available tools (and constraints)
for addressing them. The 1984 EMR update identified five priority
environmental issues and eight Regional management themes which
complemented the EMR by orienting planning and program implementation
towards an environmental framework. The 1984 update also described
Region Ill's goal of creating a single comprehensive Regional planning
system for integrating the EMR process into all of our other management
systems, while concurrently attacking our significant environmental
problems.
We have made progress on certain of the environmental problems
and mangement initiatives cited in the first two EMR's, but we have
had less success, in environmental terms, in resolving the most
persistant problems identified. Most problems, of course, such as
the escalating number of uncontrolled hazardous wastes sites, have
evolved over several decades of neglect and will not disappear
overnight. However, in order to make tangible environmental gains
in the coming years and to use the EMR concept to its full advantage,
we need in some cases to modify our management systems approach.
Region III has developed an innovative system for Managing for
Environmental Results which we will begin to implement in FY 86.
Ve believe it may be useful for other Regions as well. It begins by
recognizing that while our National programs, environmental priorities,
and guidance have served the Agency and public well, there are unique
problems within every Region which remain unresolved because most of
our resources are tied to National goals and commitments. This
system could be improved by providing each Region with the flexibility
to make limited adjustments in resource distribution and output
commitments which reflect Regional and State environmental priorities.
The Regional Environmental Management Reports should be used to
define those priorities and then to identify special environmental
initiatives, not possible within Nationally-directed program activities,
which can be implemented to address the problems. In some cases, it
may be necessary to divert resources from ongoing program activities
and request a relaxation in certain program commitments. The environ-
mental initiatives can be incorporated into State grants and State-EPA
Agreements where appropriate, although we have not attempted to
accomplish this for FY 86.
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Region Ill's environmental initiatives for FY 86 were developed
through a rigorous screening exercise following identification of
preliminary priority issues through the EMR process. First,
approximately 65 proposals were developed by senior staff and managers
for special efforts on the priority issues. A review committee
composed of representatives from each Division and Office was formed
to screen and review each proposal. Each proposed initiative was
evaluated by the committee according to a set specific criteria, with
the key consideration being whether the initiative would produce
tangible environmental results. Through consensus, the review group
consolidated a number of proposals and categorized the remaining
proposals according to technical and environmental merit, ability to
provide beneficial results, and funding potential.
The remaining initiatives were factored into the annual Regional
resource allocation process. Overceiling positions were provided for
the high priority initiatives not covered by existing program plans.
The other remaining initiatives were funded, at the discretion of the
Division Directors, from within existing program resources. Where
necessary, adjustments were made to existing SPMS or other programmatic
commitments to reflect the shift of resources. In any case, the Region
will remain accountable for 100% of the resources allocated by
Headquarters.
A summary of the HER process is indicated below. We believe
that this approach will allow us to achieve more significant progress
on our most pressing environmental problems, while still meeting
broad National goals and objectives.
C. SPECIAL AND EMERGING ISSUES
While we intend to devote special attention to the priority
environmental issues discussed in Part II, there are some additional
issues and programs of special interest which deserve mention here.
Enforcement
Enforcement of environmental laws and regulations has been and
continues to be the number one management priority in Region III. As
lead Region for enforcement, Regional management has continued the
emphasis on traditional enforcement activities,, as well as the
development of innovative enforcement initiatives.
The number of formal enforcement actions are continueing in 1985
at levels comparable to 1984, which was a banner year for enforcement
in Region III. For example, we have managed a 156% increase in
numbers of Administrative Complaints, and are ahead of last year's
number of referrals with over 25 to date. We are also concentrating
on following up on actions initiated in 1984 and in continuing to
foster parternerships with our States.
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Region III continues to be in the forefront on geographic
enforcement initiatives (e.g., Kanawha Valley, W.Va) and multimedia
enforcement activities. We are expanding our initiatives on the
Chesapeake Bay and with Federal Facilities, and have begun several
new projects involving wetlands preservation and criminal enforcement
activities.
Risk Assessment/Risk Management
The prevalence of toxic chemicals present in all environmental
media represents the Agency's broadest challenge today. Determining
which chemicals present the greatest relative risk to public health
and the environment is a major purpose of the risk assessment
process recently formulated by the Agency.
Multi-media environmental risk assessment considers all potential
routes of exposure, and therefore cuts across traditional program
boundaries. A recent study concluded that risk assessment requires
"a high degree of information transfer and coordination between
programs", to which "organizational structure is a significant
barrier".
Region III managers have felt a need for increased exchange
of information between programs, with the intent of increasing the
consistency of risk assessments done by different programs. In
order to promote this needed coordination, in July, 1985 the Region
III Toxics Coordinating Committee decided to establish a technical
Risk Assessment Subcommittee to accomplish the following:
(1) study present risk assessment procedures in the Agency
and Region III, (2) recommend a consistent Regional approach to
risk assessment (3) arrange and conduct risk assessment training
for Regional and State staff, and (4) provide technical input to
rulemaking by EPA Headquarters through the Risk Assessment Forum
and other appropriate groups.
Chesapeake Bay Program (GBP)
The Chesapeake Bay Program (CBP) has been established to
improve and protect the water quality and living resources of the
Chesapeake Bay estuarine system, to restore and maintain the Bay's
ecological integrity, productivity and beneficial uses, and to
protect public health. Major accomplishments in FY 85 included:
0 award of FY 84 grants to the Bay States to control
nonpoint sources of pollution in the Bay drainage basin,
0 adoption of a Chesapeake Bay Restoration and Protection
Plan,
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0 establishment of a Citizens Advisory Committee and Science
and Technical Advisory Committee,
0 signing of Memorandum Of Understanding with participating
Federal agencies, and
0 initiation of a program integration assessment to review
other EPA and Federal agency actions in mutual support of
Chesapeake Bay Program objectives.
For FY 86, plans are being developed and implemented to:
0 institute FY 86 State Implementation Grant guidance
0 initiate extramural activities to produce a predictive
mathematical model that addresses both water quality and
hydrodynamics
0 continue Bay-wide monitoring efforts in order to identify
trends in the health of the Bay
0 provide data management support for Federal and state programs
included in the Restoration and Protection Plan, and
0 implement a long-term public information/communication strategy.
Federal Facilities Compliance
The Regional Federal Facilities Compliance Program represents a
fully integrated, multi-media program. Because of the large numbers
of Federal facilities located within Region III, many situated in and
around the Chesapeake Bay, the Region is in a position to demonstrate
leadership in environmental control by ensuring that the Federal
government's activities fully comply with all environmental laws
and regulations.
A number of major activities will be pursued as part of the
Federal facilities program in Region III, including the following:
0 EPA/DOD Joint Resolution on the Chesapeake Bay - Ending our
first year under this resolution, EPA and DOD will be developing
a work plan for FY 86 to detail mutual activities which are
most critical to the Bay's protection.
0 DOD Installation Restoration Program (IRP) - DOD will be
completing all identified confirmation surveys in FY 86 and
initiating remedial actions where warranted.
0 DOD will, be initiating a pilot project to evaluate the Operation
and Maintenance programs at its sanitary sewage treatment
plants which will later be implemented on a national basis
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Quality Assurance/Quality Control
For FY 86, Region III will emphasize the importance of and support
for the Agency's Quality Assurance objectives. These objectives are
essential for making sound scientific judgments in many of our decision-
making processess. We will specifically emphasize the following in
finalizing the Regional QA Program Plan:
1. That QA is to be a distinct activity within each
appropriate program area for which adequate
resources are to be dedicated to accomplish program
and Regional goals.
2. That based on national QA guidelines for estimating
data quality, the Region will adhere to the data
quality objectives established by HQ program offices
for all projects and tasks.
3. That all projects and tasks, intramural and extramural,
involving environmentally related measurements are
covered by an acceptable QA project plan and that plan
is fully implemented.
4. That a management systems auditing process is developed
to evaluate implementation of the QA Program Plan
compliance with QA requirements.
.5. That program specific QA training needs are identified
and provided.
Environmental Services Division will provide the focus for QA
activity coordination and ensure that the Region's QA Plan, to be
submitted the Headquarters in the third quarter of FY 86, contains
each Division's QA program plan. The Regional Plan will be the
basis for full implementation of a rigorous QA program in FY 87.
Municipal Solid Waste Disposal
Many areas throughout the Region are experiencing increased
problems in maintaining or developing adequate capacity for the
disposal of solid waste (i.e. trash). These problems are especially
serious in large urban centers such as Philadelphia, Washington,
Baltimore, Norfolk and Richmond. Specific problems include a lack
of capacity at existing landfills, the need to expand and/or upgrade
existing landfills or incineration facilities to meet currently
acceptable environmental criteria, and the economic impacts associated
with expansion or upgrading. These problems have resulted because
of strong public opposition to the siting of new solid waste management
facilities, as well as inadequate planning at state._and local levels.
10
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Subtitle D of the Resource Conservation and Recovery Act originally
provided Federal financial assistance to state and local agencies to
develop and implement solid waste management plans. However, as
appropriations under Subtitle D have not been available in recent
years, many state and local agencies have not completed and are no
longer pursuing the development of such comprehensive plans. Such
planning could properly address long-term capacity needs and alternate
for meeting those needs. It could also provide a forum for the public
to actively be involved in the discussion of siting options.
11
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PART II.
Significant Regional
Environmental Problems,
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PART II. SIGNIFICANT REGIONAL ENVIRONMENTAL PROBLEMS
A. IDENTIFICATION AND RANKING OF PROBLEMS
We used a collaborative Regional effort led by our Environmental
Services Division to identify the Region's most significant environ-
mental issues. A Task Force with representation from each Division
and Office initially compiled a range of possible environmental
issues and areas for discussion. Several issues from each program
area were then evaluated and rated by the Task Force using a simple
quantitative scoring system which is described below. To emphasize
the Agency's broad mission of improving the condition of the total
environment - both by reducing public health risks and protecting
and enhancing the quality of natural ecosystems - criteria other
than simply public health risks were included.
The issues were then consolidated, ranked, and associated with
geographic areas where the issues are most prevalent. A meeting
was held among senior mangers to discuss the list and to ensure that
an accurate intermedia balance was reflected. Finally, a recommended
list of preliminary issues was presented to the Regional Administrator
for approval. The Region's preliminary list of issues was transmitted
1:0 Headquarters on May 1, 1985.
Subsequently, the preliminary list was provided to our State
Environmental Secretaries for comment. Based on the States' comments
and further Regional discussions, the list was revised further into
the final list of issues as discussed in Section B below.
13
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EMR Issue Ranking Criteria
Weight
20%
30%
10%
20%
10%
10%
Criteria
Population Affected
(Quality of Life)
Public Health
(degree of risk)
Public Concern
Environmental Impacts
Economic Impacts
Intermedia Issues
Description
0 - 10,000 = 1
10,000 - 1000,000 - 2
100,000 - 1,000,000 - 3
1 million - 10 million - 4
Over 10 million - 5
Qualitative Judgement based
on the degree of health risk
to that portion of population
affected.
Based on new media coverage,
Congressional interest,
letters received.
Affects on the environment
other that public health.
Oriented towards long-term
ecological effects.
The cost (to society) of
doing nothing. Does not
include costs of control
strategies which may be
required to address problem.
The extent to which problem
crosses media bounds.
Each environmental issue was scored by assigning a value of from 1-5
for each of the above ranking criteria and them adjusting to scale of 100
incorporating the relative importance (weight) of each criteria.
Score - [Population (Value) X Risk (Value)] X 2
+ [Public Concern (Value) X 2]
+ [Environmental Impact (Value) X 4]
+ [Economic Impact (Value) X 2]
+ [Intermedia (Value) X 2]
Example; Surface Water Toxics
Score = [4 X 3] X 2 + (3 X 2) + (4 X 4) + (3 X 2) + (2 X 2)
24+6 + 16+6 + 4
14
56 points
56 points
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September 3, 198
1985 ENVIRONMENTAL MANAGEMENT REPORT
Region III
Final List of Environmental Priorities
Environmental Issue
1. Hazardous Waste Management
A. Site Cleanup
B. Disposal Capacity
2. Drinking Water and Ground Water Contamination
3. Resource Extraction (Mining)
A. Acid Mine Drainage
B. Oil & Gas Production
4. Toxic Chemical Air Releases
A. Routine Releases
B. Accidental Releases
5. Ozone Standard Violations
6. Surface Water Toxics
7. Environmentally Sensitive Areas
8. Indoor Air Pollution
A. Radon
B. Asbestos
9. Non-Point Source Pollution
10. Acid Rain
16
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B. DISCUSSION OF SIGNIFICANT PROBLEMS
1. HAZARDOUS WASTE MANAGEMENT
PROBLEM ASSESSMENT
Within this overall environmental issue, there are two (2)
specific interrelated concerns, each of which is individually
significant. When considered together, these concerns [site cleanup
(including site discovery and investigation) and lack of disposal
capacity] represent the most significant environmental problem in
Region III.
A. Hazardous Site Cleanup
There are at this time 89 hazardous waste sites within Region III
which are either on, or proposed for, the Nati-onal Priority List
(NPL). The NPL consists of a list of sites which based on National
criteria are considered the highest priority for cleanup. These
sites are contaminated by a variety of substances, primarily organic
chemicals and heavy metals, which are adversely impacting ground and
surface water quality, soils and air quality. These hazardous substances
often result in the contamination of aquifers which are used as a
source of drinking water for public and private supplies. The cleanup
of these sites is conducted under the commonly referred to "Superfund"
Law and is essential to protect the public health and environment of
the surrounding areas.
A specific area which poses serious cleanup issues for Region III
is New Castle County, Delaware. In New Castle County, an area of
approximately 435 square miles and approximately 404,000 people,
there are 7 NPL sites each with its own complex issues surrounding
cleanup. This high concentration of sites in one County results in
public health and environmental impacts on all media (i.e., water,
air and soil) and has resulted in a high level of public interest
and involvement. Of particular concern in New Castle County are the
existing and potential impacts on ground water, as a significant
portion of the County utilizes ground water as a drinking water
source. Contaminants of special concern in New Castle County include:
lead, cadmium, chromium, arsenic, vinyl chloride, PCB, TCE, benzene
and other organic and inorganic compounds.
It is also being recognized that while approximately 2400
sites in the Region have been identified as potential hazardous
waste sites, many additional sites lie undiscovered. These potential
sites remain undiscovered because of a lack of emphasis, guidance
and resources toward discovering new sites. A March 1985 report
prepared by the General Accounting Office (GAO) has identified a
need for EPA to aggressively uncover new potential hazardous waste
17
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sites and improve the current inventory of sites. A review of Region
Ill's inventory has led us to believe that a number of geographic
areas are likely to have additional undiscovered hazardous waste
sites. In particular, the area of southwestern Pennsylvania does
not seem to have the number of potential hazardous waste sites listed
on the national inventory that would be expected based on the past
level of industrial activity.
B. Disposal Capacity for Hazardous Waste
The cleanup of the Superfund wastes results in the need to
dispose of contaminated materials and soils. While often, this
disposal must occur off-site, it should result in treatment and/or
disposal which will not further degrade or contaminate the environment.
Specifically, the disposal should be consistent with the requirements
of the Resource Conservation and Recovery Act (RCRA).
There are currently serious problems regarding the number of
RCRA regulated facilities which have the capacity to handle wastes
from Superfund sites and which are operating in accordance with
their interim status requirements (i.e., an existing facility
operating under certain standards until final disposition of its
permit application). As a result of the November, 1984, Amendments
to RCRA, it is expected that the current shortage in available capacity
will become critical during 1986 and 1987. Specifically, the amendments
include provisions which are going to increase the need for capacity
at treatment, storage and disposal (TSD) facilities at the same time
that many interim status facilities may be forced to close due to
their inability to meet specific mandates regarding ground water
monitoring and financial responsibility. In addition, the lack of
commercial disposal capacity is a concern for the Region beyond the
disposal of Superfund wastes. The shortfall in TSD capacity will
also impact active facilities generating hazardous waste and may
result in increased cases of illegal dumping with a potential for
significant environmental damage. While the lack of capacity is a
Reglonwide concern, it is expected to be particularly serious in
heavily industrialized areas, such as western Pennsylvania and metro-
politan Baltimore.
REGIONAL AGENDA/BARRIERS
A. Hazardous Site Cleanup
The Region intends to continue its current efforts to clean up
NPL sites through either enforcement actions against responsible
parties or by using the Superfund monies where responsible parties
cannot be identified or are recalcitrant in taking steps to accomplish
the cleanup. For the period October 1985 through September 1986 the
Region intends to initiate remedial investigations at 14 sites and
18
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remedial design or cleanup at 13 sites. In all cases, the Region,
through the implementation of project-specific community relations
plans, will involve the surrounding community in the decision making
process. Furthermore, where a state desires to take the lead in
directing remedial cleanup efforts, the Region is proceeding with
the development of specific Cooperative Agreements with the State.
Regarding site discovery, the Region working with the State of
West Virginia recently completed an effort to discover new sites in
the Kanawha Valley. Through extensive research of available records,
the use of aerial mapping, and interviews with State and local officials,
the Region and State were able to identify 84 new potential hazardous
waste sites. The inventory of sites for the area prior to this effort
listed 56 sites. The Region in coordination with the Agency's Environ-
mental Photographic Interpretation Center, intends to conduct a
similar site discovery effort in the Monongahela-Ohio River Valley
in southwestern Pennsylvania during 1985-86.
B. Disposal Capacity for Hazardous Waste
The Region has outlined some steps which could be used to facili-
tate discussions on the problem of a shortfall in hazardous waste
disposal capacity. This approach would involve first, an assessment
of the actual shortfall in capacity. This would include a comparison
of the actual capacity available (adjusted for capacity likely to be
lost due to a loss in interim status) against the annual hazardous
waste generation rate in the Region. Secondly, by developing a task
force composed of representatives from EPA, State, industry and the
public, it is hoped that a strategy could be developed to either
increase disposal capacity, or, possibly through the identification
of alternative technology, decrease the volume of waste requiring
disposal. A problem with this approach is that it places EPA in the
forefront of an issue which has traditionally been a State/local
responsibility, and EPA has no legislative authority to actually
take a lead on siting hazardous waste disposal facilities.
REQUESTED HEADQUARTERS ACTION
Specific EPA-Headquarters actions if taken, could broaden the
Region's capability to address the issues associated with site cleanup,
site discovery and disposal capacity. These actions include:
0 EPA's Office of Solid Waste and Emergency Response (OSWER)
should consider a modification in the national policy which currently
limits EPA enforcement actions to sites listed on the NPL. The
policy requires some relaxation to provide Region III more flexibility
to pursue enforcement actions on selective sites. These sites would
be those which have serious environmental impacts and have generated
19
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a high degree of interest within the Region and a State, but which
due to the nature of the Hazard Ranking System and its emphasis on
public health impacts, have scored below the 28.5 NPL cutoff. A
limited number of such enforcement actions each year (i.e., 1-2 per
State and/or 5-10 per Region) could further the goal of CERCLA while
improving State/EPA relations.
0 OSWER should provide guidance and resources to the Region to
direct efforts towards the discovery of new potential hazardous waste
sites. The guidance should provide direction on whether the site
discovery efforts should have a geographic focus or some type of
categorical focus (i.e., municipal landfills).
0 EPA-Ueadquarters needs to develop a policy which outlines the
Agency's position on the acceptable level of Regional involvement in
the siting of new TSD facilities, in particular, commercial facilities.
ENVIRONMENTAL RESULTS
Current efforts on site cleanup are expected to result in an
increase in the number of remedial actions initiated and completed
both through enforcement lead and fund lead efforts.
The implementation of the site discovery effort in southwestern
Pennsylvania is expected to result in the identification of a signifi-
cant number of new potential hazardous waste sites. Once identified,
those sites will be entered into the national inventory of potential
hazardous waste sites, and priorities and a schedule developed for
the accomplishment of future preliminary assessment and site investi-
gations.
Due to the contraints on the Region, it is not expected that
significant environmental gains will be achieved by EPA in the near
future regarding the shortfall in disposal capacity. A tangible
result which may be achieved will be an identification of the potential
shortfall in capacity by State.
20
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2. DRINKING WATER AND GROUNDWATER CONTAMINATION
A. DRINKING WATER QUALITY
PROBLEM ASSESSMENT
A problem of major environmental management importance is the
provision of safe drinking water to the consumers in Region III.
Challenges in this area are to improve the rate of compliance
among small public water suppliers and to protect the public from
the growing list of presently unregulated organic chemicals and
biologic organisms which are being found in water supplies. The
scarcity of data on unregulated contaminants is a serious problem.
Also, the voluminous number of organic compounds prevents the
formulation of health advisories' and treatment data for every
compound. This in turn makes Agency response to each incident very
difficult.
In addition to inorganic contaminants (e.g., lead, nitrates,
etc.) and radionuclides, the Safe Drinking Water Act (SDWA) regulates
six pesticides/herbicides, trihalomethanes and collform bacteria.
Yet, many monitoring surveys and contamination incidents are showing
the presence of more and different pesticides/herbicides and volatile
organic chemicals in drinking water sources. This is particularly
true for ground water supplies, a drinking water source previously
believed to be pure and immune from contamination.
Another unregulated contaminant of concern in Region III is the
parasite, Giardia lamblia. In 1983/8A, major outbreaks of
giardiasis occurred in Pennsylvania at three public water supplies.
Thousands of consumers were potentially at risk from the gastroenteric
effects of this disease and hundreds of cases were actually reported.
Along with the unregulated contaminants, compliance of public
water suppliers with the SDWA continues to be a concern in the Region.
The elimination of violations in small drinking water systems
represents the major portion of this concern. Of the 5,853 community
water systems in the Region, 5,254 are classified as small water
systems (i.e., one which serves less than 3,300 people). Small
systems account for the great majority of non-compliance with the
national drinking water standards (approximately 98 per cent of the
persistent violations).
Small systems' non-compliance involves failure to meet the
monitoring and reporting (M/R) requirements or failure to comply
with a Maximum Contaminant Level (MCL) requirement of the SDWA.
Although the microbiological and turbidity requirements are most
frequently violated, other parameters such as lead, nitrates,
fluorides and radium are also of concern.
21
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REGIONAL AGENDA/BARRIERS
The Agency is addressing these problems in a number of ways.
MCL's are being proposed for the nine most frequently occurring
volatile organic chemicals in water supplies. Associated monitoring
with these proposed regulations, possible future requirements
under the SDWA to monitor for nearly 50 unregulated organic chemicals
and data received from the CERCLA/RCRA and Pesticide programs
should significantly improve the data base on organic chemicals in
drinking water sources. In the area of health advisories and
treatment, the Office of Drinking Water will shortly have available
a Health Effects Registry wihich will provide guidelines on health
effects and treatment for many unregulated organic chemicals.
To diminish the problem of increasing waterborne disease
associated with Giardia Iambiia, water suppliers will be informed
of the effectiveness of Giardia lamblia removal by properly operated
and maintained filtration processes. This information will be
provided through technical assistance programs (e.g., Regional
seminars on giardiasis and technical assistance to the states,
including laboratory support). Region III will continue to support
the State of Pennsylvania's Giardia Monitoring Survey.
Proposed amendments to the SDWA call for mandatory filtration
of surface water supplies. If enacted, this Region will work
closely with the states to implement this provision. The most
serious limitation of a mandatory filtration requirement will be
the capability of most small water systems to finance construction.
The Region will develop action plans to assist the water suppliers
and the states in securing financial aid from other Federal agencies,
State and local agencies, Public Utility Commissions and private
funding institutions.
To improve compliance rates among the small water systems, EPA
Region III will initiate a technology transfer program for the
public and the water suppliers. The technology transfer program
will consist of the dissemination of information to assist water
purveyors to seek financial assistance, improve their management
skills, understand the regulations and how and when to collect
samples, etc.
The Region and the states will also focus more aggressively on
those systems which present the greatest public health threats or
are recalcitrant and persistent violators. Each State's existing
compliance strategy will be revised to include a compliance
improvement work plan. The Region will be more aggressive in taking
Federal actions in states which request EPA support and intervention.
22
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Limitations to Federal intervention in a primacy state are the
lack of administrative order authority in the SDWA, and the regulatory
process for taking Federal actions in a primacy state without its
consent. Both of these limitations result in inordinate time
requirements for Federal intervention.
REQUESTED HEADQUARTERS ACTIONS
Headquarters needs to expeditiously continue with the revision
of the drinking water regulations. These planned revisions will
set standards for volatile organic chemicals, which would help
Regions, States and public water suppliers to focus on the severity
of the problem and the degree of treatment necessary and associated
costs. Other revisions are needed to reduce the monitoring require-
ments for low priority water quality parameters. This would allow
water systems to concentrate resources on meeting the requirements
for the priority parameters and newly established standards.
Headquarters also needs to continue to support research in
drinking water treatment technology for small water systems. The
emphasis should be on development of technology which is financially
attainable, technologically feasible and energy efficient.
Small water system operators also need opportunities to receive
technical information and assistance. The Office of Drinking
Water should allocate funds and resources towards development and
dissemination of technology transfer material. When the efforts
of our technology transfer initiative prove successful it could
prove to be a prototype for other Regions to use to reduce the
National levels of non-compliance.
ENVIRONMENTAL RESULTS
States have been giving priority to the larger water systems
which affect the greatest number of consumers. Continued decreases
in state program funding and increasing regulatory responsibility
in areas more complex than what is currently being controlled will
continue to force the states to appropriately devote their resources
to the larger systems. Region Ill's technology transfer effort will
complement the states' efforts in providing technical/administrative
assistance to small water systems to obtain their compliance with
the existing regulations.
A major objective of this effort is to attain a level of only
4% persistant non-compliers and 4.5% intermittent non-compliers.
It is hoped that the objective will be met by the end of fiscal
year 1987. Attainment of the objective will result in significant
improvement in the number of systems meeting drinking water standards.
This will cause a resultant decrease in the population exposed to
excessive levels of health related contaminants. '
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B. GROUND WATER CONTAMINATION
PROBLEM ASSESSMENT
Reports of existing and potential ground water contamination
problems are increasing thoughout the Region. Areas of significant
ground water resources that are susceptible to contamination, and
known or suspected contamination sources, need to be identified and
investigated.
Region Ill's ground water compendium, which lists ground water
contamination problems reported to the Regional Office, shows a
significant increase in reports in the 1980's. During the 1970's,
there were 53 reported incidences of ground water contamination.
In contrast, in 1980-1985 more than 225 concerns were reported.
Highly significant is the fact that the reporting of these
incidents is not the result of a rountine monitoring program.
With increasing data collection, more evidence of ground water
contamination is found. This is of great concern as many of the
more highly populated areas of the Region use ground water as a
principal source of public and private drinking water. More
importantly, these highly populated areas are where the contaminants
of greater concern are being discovered, and they contain aquifers
that are highly vulnerable to contamination. The potential for
aquifer contamination has been shown to exist in southeastern
Pennsylvania (comprised of Chester, Bucks and Delaware Counties),
New Castle County in Delaware, Anne Arundel County in Maryland,
and Brooke County, West Virginia.
In the past, the Region has found ground water contaminated by
nitrates, microbiological organisms and other inorganic compounds.
More recently, volatile organic chemicals (V.O.C's), which are highly
toxic and thought to be highly prevalent in aquifers, have become
contaminants of major concern. For instance, in 1984 there are a
number of public water supply wells in southeastern Pennsylvania
that remain closed due to the high levels of TCE (a V.O.C.) in the
ground water. Ground water contamination from septic tanks and drain-
fields and shallow water-table aquifer contamination from gasoline
and other petroleum products are also being found more frequently.
The sources of ground water contamination vary by area. In
many cases, the direct correlation between specific sources and the
contaminants is hard to establish. For some existing ground water
contamination, the sources are unknown. However, contamination in
the Region does result from sources such as septic tanks and
drainfields, drainage and disposal wells, RCRA/Superfund sites,
dumpsites and contamination incidents. Shallow water-table aquifer
contamination from gasoline and other petroleum products are
suspected to come from underground storage tanks (USTs) and spills.
Nonpoint sources, such as urban runoff and agricultural/animal
wastes are also known causes of contamination.
24
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REGIONAL AGENDA/BARRIERS
Region III currently has a two-pronged approach to deal with
ground water contamination. The first is preventative; the second
is remedial. The Regions's emphasis on preventing ground water
contamination relies on:
(1) The "sole-source" aquifer designations to protect unique sources
of drinking water. There are three aquifers in the Region that have
been designated as sole-source aquifers. The Region is currently
reviewing a petition for a fourth designation in Clarke County,
Virginia. In these areas, construction projects with polluting
potential which receive Federal financial assistance are subjected
to a special EPA review to ensure that ground water contamination
will not occur.
(2) Permitting and monitoring activities under the Resource
Conservation and Recovery Act (RCRA) to ensure that ongoing activities
in generating and storing hazardous wastes will not contribute to
future ground water contamination. A ground water monitoring
network is required as a permit condition at active solid and
hazardous waste facilities that might impact ground water.
(3) Water quality management planning under Section 106 and
205(j) of the Clean Water Act to assist in identifying and solving
primarily nonpoint source related problems.
(4) Solid waste planning and management as conducted by State
agencies. The Region relies on the States' solid waste management
programs to anticipate and prevent ground water contamination form
solid waste handling.
(5) The underground injection control (UIC) program, which is
in its second year of operation. Because there are more than 24,000
Class V (unregulated) wells in the Region, their potential for
ground water contamination is of concern. The Region has delegated
the UIC program to West Virginia, Delaware and Maryland, and is
directly implementing UIC programs in Virginia, Pennsylvania and
the District of Columbia.
(6) Region III has an active Office of Ground Water that is
designed to serve as the focal point for all multi-program responses
to ground water issues within the Region. The office has developed
a Regional ground water work plan based on the National Ground
Water Protection Strategy developed by EPA Headquarters.
In terms of remedial actions, the Region relies on investigations
with limited site-specific monitoring to identify problems. Once
contamination has been documented, the Region initiates follow-up
either under Superfund or other statutory authority. When
appropriate, the Superfund program pursues either enforcement
25
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action or Superfund remedial action to correct the problem. EPA
works closely in all cases with local and State agenices to develop
cooperative agreements to ensure adequate protection of public health
and to find additional sources of drinking water where shortages
may occur as a result of well closures. Intensive monitoring and
cooperative investigations involving local health departments,
State agencies and EPA have been conducted in Pennsylvania, Virginia,
Maryland and Delaware.
The Implementation of an effective ground water protection
program faces several barriers that require concentrated effort to
overcome.
Prevention:
0 Available staff expertise in ground water hydrology and geology
at the Federal and State levels only permits response to the most
pressing clean-up issues rather than to prevention of problems
through resource protection.
0 Reductions in funding levels and priority of water quality
management planning hamper the states' ability to develop site-
specific plans and nonpoint source controls for important ground
water areas.
0 The absence of specific programs to control pits, ponds, and
lagoons hinders Federal control of these potential sources of
contamination.
Remedial:
0 The sources of pollutants are difficult to trace and to link
to aquifer contamination. Additionally, the costs of exploration,
well monitoring, case development and enforcement are high.
Activities to determine the source of pollutants and develop remedial
actions can cost more than State and local agencies can afford.
In addition to actively fulfilling its responsibilities under
Superfund, RCRA and the Safe Drinking Water Act, Region III intends
to implement the following special initiative.
0 For each county in the Region, significant aquifers that are
currently being used as an underground source of drinking water, or
have the potential as a water supply base, are to be defined.
The vulnerability to contamination (i.e., low, medium, high) of
the aquifers will also be determined. The total county population
using ground water as a water supply (both private and public) will
also be determined. Based on this information, the counties will
be prioritized, with the highest rated counties being examined in
greater detail (i.e., on a county-scale basis).
26
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0 For the highest rated counties, hydrogeologic base maps will
be developed. The county hydrogeologic maps will also illustrate
the vulnerability to contamination of the aquifers in the county.
0 Overlayed on the hydrogeoglogic base maps will be the location
of RCRA and Superfund sites, dumpsites, USTs and contamination
incidents to determine potential aquifer pollution problems.
0 Water supply wells (both public and private) that are located
near the potential contamination site(s) will be identified and
information obtained on depth of well, aquifer characteristics
and recharge area.
The intended end products are a series of overlay maps for
each area in the Region that is identified as having ground water
resources vulnerable to contamination, having a large population
using the resource as a water supply, and having known or suspected
sources of contamination located near the aquifer. These areas
will be targeted for monitoring compliance and enforcement activities
where possible under RCRA, UIC, PWSS and NPDES. For remedial
actions, the Region will rely on CERCLA to clean-up known existing
contaminated areas.
REQUESTED HEADQUARTERS ACTIONS
No EPA Headquarter actions are required at this time.
ENVIRONMENTAL RESULTS
Previous actions involving ground water contamination issues
have been handled on a case-by-case basis after the contamination
has been discovered. The EMR initiative brings together all the
ongoing efforts that address ground water contamination, and develops
a consolidated strategy for assessing the problem. It establishes
a mechanism for protecting the Region's ground water through strict
compliance of the various permit programs under the SDWA, CWA, and
RCRA. Remedial action is handled under CERCLA.
The environmental objectives are as follows:
0 Identify ground water resources that are vulnerable to contami-
nation.
0 Identify, located known or suspected sources of ground water
contamination in these vulnerable areas.
0 Prioritize these areas by incorporating into the Region's
compliance enforcement actions.
0 Use the UST Notification List to prioritize UST/ground water
follow-up activities.
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3, RESOURCE EXTRACTION (MINING)
A. ACID MINE DRAINAGE
PROBLEM ASSESSMENT
Acid mine drainage (AMD), mainly from active and abandoned mines,
is the cause of roughly 3000 miles of ecologically impaired streams
ia Pennsylvania, northern West Virginia, and western Maryland.
Adverse effects associated with AMD include: impacts to aquatic life,
contact recreation, water supplies, aesthetics, and man-made concrete
and metal structures. In addition, the relationship between mining
activities and sensitive habitat, such as wetlands, needs further
characterization regarding potential impacts. Table 1 summarizes
Regional stream impairment in terms of pollution sources.
REGIONAL AGENDA/BARRIERS
Two Federal laws require that permits be issued on mining activities.
(1) The Clean Water Act (CWA) requires mine operators to have
a National Permit Discharge Elimination System (NPDES) permit which
limits the following pollutants: pH, iron, manganese and sediment.
The NPDES permit program has been delegated to all of the the states
in Region III.
In addition, the CWA also covers dredge and fill permits for
wetlands protection and coal fines dredging.
(2) The Surface Mining Control and Reclamation Act (SMCRA),
under Title V, requires permits to be issued for pre-mine plans,
overburden analysis, runoff control, reclamation, and bonding. The
bond is required in order that incomplete or inadequate reclamation
is avoided. Title IV also imposes a fee on every ton of coal extracted.
This fee is used in part for reclamation of abandoned lands. These
unreclaimed mines appear to be the primary source of AMD in Region III.
An important objective of SMCRA is to reinforce water pollution
control measures, and for this reason, efforts are being made at
the headquarters level to combine the two permit systems.
As part of the Regional EMR initiatives, Region III has formed
a Mining Task Force to assess mining problems and make recommendations
for improving water quality attributable to mining sources. Previous
Regional efforts have identified five areas that demand immediate
attention.
28
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1) Water quality improvement at abandoned sites using the SMCRA funds.
0 EPA and West Virginia are negotiating the use of SMCRA funds
for water quality improvement at abandoned mining sites.
The Region's Task Force will support this effort and make
recommendations.
2) The environmentally unacceptable use of instream sediment ponds
in steep slope country.
0 Regional Counsel is reviewing regulations covering sediment-
ation ponds. The Task Force will work with Regional Counsel
to implement their legal opinion into the NPDES system.
3) Wetlands are not adequately protected by effluent guidelines
or Section 404 permits. Also, water quality standards do not
protect sensitive areas, such as low buffered streams.
0 The Task Force will complete a monograph on the subject. The
Task Force will also initiate negotiations with the Corps
of Engineers (COE) to better define permit limitations and
potential mitigations.
0 The Task Force will develop guidelines to protect low buffered
streams.
4) Regional oversight with regard to the delegation process must
be reexamined, especially in the area of mine closure policies.
0 The Region's task Force will review oversight policies,
closure practices, and make recommendations.
5) Industry wants to reopen unreclaimed mines without responsi-
bility for treating current drainage.
0 The Task Force will review the potential adverse impacts
associated with this action and evaluate alternatives.
REQUESTED HEADQUARTERS ACTIONS
1) Headquarters should work with the regions in helping to resolve
regulation and policy inconsistencies needed for the mining/wetlands
issues.
2) Headquarters should coordinate with other agencies in resolving
issues surrounding the use of SMCRA abandoned lands funds for
water quality improvement.
3) Headquarters should review the need for personnel devoted to the
long range resource extraction problem.
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ENVIRONMENTAL RESULTS
1. The Mining Task Force will prepare a report by September 30,
1986, including recommendations regarding the five activities presented
in the Regional agenda. The report will include:
0 Required institutional changes to improve water quality at
abandoned sites.
0 Legal resolution and strategy to combat the usage of the
instream sediment control ponds.
0 Mining/wetlands issues will be advanced using both the tech-
nical information of the Wetlands Monograph and appropriate
404 permitting procedures.
0 Evaluation of Regional oversight for the NPDES permits system
and recommend changes, where necessary. This will extend to
the issues surrounding close-down procedures.
0 Evaluation of the pros and cons of regulation relief regarding
reopening abandoned mines.
2. The Mining Task Force will develop a 3 year/5 year EMR initi-
ative to significantly reduce stream impairment in Region III. These
long range plans will estimate the required resources to ensure
implementation.
3. Under the direction of the Deputy Regional Administrator,
a Regional conference will be held on The Reclamation of_ Disturbed
Lands. The conference will include representatives from the Federal
and State sectors, the regulated community, and environmental interest
groups. Proceedings from the conference will be prepared for general
distribution.
4. Coordination meetings will be aranged with Pennsylvania and
West Virginia to discuss Task Force recommendations and long range
planning.
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TABLE 1
SUMMARY TABLE: WATER USE IMPAIRMENTS - REGION III *
STREAM MILES OF USE IMPAIRMENT (SEVERE (S), MODERATE (M), POTENTIAL (P)
Region I
PROBLEM
PARAMETERS
pH, Iron,
Sediment
Nutrients
Sediment
Dissolved
Oxygen
Toxics
Organic/
Inorganic
Bacteria
PA
S-1815
M-0
P-0
S-0
M-233
P-0
S-0
M-271
P-434
S-195
M-170
P-35
S-0
M-0
P-0
MD
S-74
M-0
P-0
S-4
M-430
P-10
S-13
M-18
P-0
S-0
M-0
P-0
S-44
M-171
P-0
WV
S-238
M-748
P-54
S-0
M-112
P-0
S-0
M-lll
P-0
S-5
M-336
P-0
S-0
M-0
P-0
VA
S-245
M-20
P-0
S-28
M-67
P-107
S-91
M-25
P-0
S-138
M-102
P-33
S-250
M-147
P-64
DE
S-0
M-0
P-0
S-3
M-17
P-0
S-3
M-0
P-52
S-3
M-23
P-0
S-119
M-31
P-0
DC
S-0
M-0
P-0
S-8
M-ll
P-0
S-8
M-ll
P-0
S-0
M-8
P-0
S-8
M-19
P-0
Taken from 1983 Region III EMR
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B. OIL AND GAS RELATED POLLUTION
PROBLEM ASSESSMENT
The Region III States of West Virginia and, in particular, Pennsyl-
vania, are producers of oil and natural gas. Ever since the Colonel
Drake well was drilled in 1859, hundreds of thousands of producing
wells have been drilled in Pennsylvania and West Virginia. Several
environmental problems occur related to oil and gas production.
Foremost among these problems is the disposal of brine that is pro-
duced as a natural by-product along with the oil or gas. Brine is the
pre-historic deep ground water which is present in the oil and gas
bearing zones. The brine contains contaminants such as sodium, chlorides,
barium, arsenic, strontium, cadmium, iron and sulfate in concentrations
up to several thousand times higher than drinking water standards.
Historically, brine disposal has occurred by methods such as discharge
to pits, streams, or roads. In addition, in Pennsylvania many gas
producers dispose of their brine by using "blow, boxes", which are
shallow in-ground basins that allow the percolation of the brine into
the ground water. (Attached is a map of the Pennsylvania oil and gas
fields where blow boxes have been used). These brine discharge practices
have led to degradation of streams throughout Western Pennsylvania,
localized contamination of ground water in many areas, and increased
sodium levels in some public water systems.
A second problem that has occurred is contamination of drinking water
supplies due to oil and gas drilling practices. It has been estimated
that the drinking water for 10,000 people has been fouled by oil and
gas drilling related contamination. Hydrofracking the formation has
often been blamed as the cause of contamination of drinking water aquifers.
Third, oil spills can occur on the ground surface as the result of
production activities. If not quickly controlled, the spills threaten
local streams, affecting both aquatic life, water supplies and other
stream uses.
A particular problem area regarding oil spills is in northwestern
Pennsylvania centered around the Allegheny Reservoir and Allegheny
National Forest. The Allegheny Reservoir and its tributary streams
currently support a diverse range of gamefish including bass, walleyes,
pike and several species of trout. However, as a result of oil spills,
in particular, spills resulting from past operations or abandoned
wells, the potential for water quality impacts on the Reservoir is
significant. Field Investigations have identified serious problems
along tributary streams and in forest areas. These problems include
destroyed vegetation and polluted streams which can no longer support
trout population or in some cases appear totally devoid of aquatic
life.
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REGIONAL AGENDA/BARRIERS
The Region is undertaking a number of initiatives which are expected to
j'ield significant progress on the problems described above.
The disposal of brine into blow boxes is now regulated under the Federal
Underground Injection Control Program. The Region's Water Supply Branch has
begun implementation of an aggressive blow box compliance strategy. Using
this strategy, the Region will integrate a public information initiative, an
independent surveillance effort, and ultimately a legal enforcement presence
to attain the closure of blow boxes. It is estimated that there are 3,000
or more blow boxes in Pennsylvania. Through implementation of the blow box
strategy, the Region projects to achieve closure of over 90% of the blow
boxes by 1987.
The management of brine discharge to streams has been lax in Pennsylvania
clue to lack of priority by the PA Department of Environmental Resources. For
FY 86, the Region has listed State issuance of oil and gas brine discharge
permits as a high priority item for the NPDES Section 106 workplan. Under
the performance based grant concept, this will commit the State to addressing
this issue in FY'86. Regarding West Virginia, the State has recently proposed
use of a general permit for oil and gas brine discharges.
Recognizing that our efforts are changing the brine disposal practices
that many oil and gas operators have used for many years, the Region will be
preparing public information on the brine disposal options available, inclu-
ding the growing areas of deep well injection and use of centralized treat-
ment plants. The Region plans to participate on Oil and Gas Advisory Groups,
and to undertake technical reviews of the available options.
The PA DER's new Oil and Gas Act will give citizens more protection
against contamination of their drinking water from oil and gas well drilling.
DER is currently involved in writing the regulations and hiring staff.
A concern is whether DER will receive adequate funding to properly run the
program. The Region will monitor State activities under this statute to
assess their effectiveness.
In an attempt to clean up in particular past oil spills, EPA's Emergen-
cy Response Section (ERS) has solicited assistance from the Regional Response
Team (RRT). The RRT is composed of a number of Federal Agencies, plus in
this situation the Commonwealth of Pennsylvania and was created under the
auspices of the National Oil and Hazardous Substances Contingency Plan. The
RRT, under the lead of EPA and the U. S. Coast Guard, has agreed to develop
a plan for accomplishing a cleanup. The plan will include: identifying the
location of spills and setting priorities, education and promoting responsi-
ble party cleanup through meetings with the oil industry, vigorous spill
prevention control and countermeasure (SPCC) inspections and enforcement,
and where necessary, funding Federal cleanup actions and aggressively
pursuing cost recovery. This plan is being developed and implemented under
the leadership of an on-scene coordinator from the ERS Section.
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REQUESTED HEADQUARTERS ACTION
Continued Headquarters support is needed in the area of setting work-
able limitations for brine discharge to streams. The zero discharge require-
ment is based on the concept that the brine can be put in a pit and evapora-
ted, which is not a feasible concept for Eastern states. Realistic brine
discharge limits will allow states to move forward with the permitting pro-
cess, thereby gaining some control over the discharges that are occurring.
The blow box problem is specific to only two States in the country -
Pennsylvania and New York. Therefore, it is important that Headquarters
recognize the workload involved in locating, documenting, and achieving clo-
sure of blow boxes.
ENVIRONMENTAL RESULTS
The Region expects to achieve significant results in the area of brine
discharge. Blow boxes will be eliminated, stream discharges will be con-
trolled, and more environmentally sound brine disposal methods will be used
by the oil and gas industry. As a result, stream and ground water quality
will be better protected. Drinking water quality will be more effectively
safeguarded by the new PA Oil and Gas law, and residents will have more
chance for resolution if a problem does occur.
Initial results expected from the vigorous implementation of the RRT's
Plan will include an identification and prioritization of existing spills,
an increase in the number of oil spill cleanups in Northwestern Pennsylvania
both by responsible parties and the EPA, and additional emphasis and
compliance with existing SPCC regulations. Enforcement actions (including
cost recovery of Section 311 funds expended) will be taken as appropriate.
34
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4. TOXIC CHEMICAL AIR RELEASES
A. ROUTINE RELEASES
PROBLEM ASSESSMENT
Toxic pollutants are found in all environmental media. It is
now understood that traditional methods to remove such pollutants
in accordance with requirements of any individual media-oriented
statute may merely transfer such substances to other media. Despite
the usually low ambient air concentrations of these toxicants,
there is concern with both long and short-term public health effects,
most of which are only understood to a very limited extent. Furthermore,
projections of such effects are often controversial as they usually
are based upon extrapolations of laboratory data, since acceptable
human epidemiological information is sparse.
Recent studies have concluded that area-wide as well as specific
point sources contribute to the air toxics problem and that routine
releases from these area sources appear to be responsible for the
majority of aggregate cancer incidence.(D The highest individual
health risks seem to be posed by releases of substances from point
sources, primarily routine releases but potentially by (however small)
accidental releases. The point sources primarily identified by the
previous studies are those related to various chemical processes with
the air medium being the prime exposure pathway.
Concern in Region III is focused primarily upon concentrated
industrialized areas such as Philadelphia, Baltimore, New Castle
County, Delaware and the Kanawha Valley area of West Virginia. The
Kanawha Valley is one of the most heavily industrialized chemical
complexes in the nation. The sources and chemical processes throughout
the Valley, directly or indirectly, are the cause of more organic
compound air emissions, with potential toxic effects, than most
heavily populated metropolitan areas. Because of the complex terrain
that characterizes the Valley, many of these compounds are not readily
dispersed and may remain entrapped for long periods of time.
The major point sources of toxic air releases in these areas are
chemical manufacturing facilities. Subtances such as methyl isocyanate,
chloroform, arsenic, ethylene oxide, benzene, carbon tetrachloride,
acrylonitrile and many other known or suspected toxic pollutants are
routinely emitted by these facilities. These pollutants, in large
quantities, are often produced in areas where populations reside
adjacent to chemical manufacturing facilities and are exposed daily
to different concentrations of the chemical compounds.
36
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Other major sources include industrial and manufacturing facilities,
hazardous waste sites, municipal landfills, incinerators, sewage treatment
plants, motor vehicles, and gas stations.
BLEGIONAL AGENDA/BARRIERS
EPA Administrator Lee M. Thomas announced on June 4, 1985, a five-
step National Strategy to reduce the risks from toxic air pollutants.
Region III will direct its programs to implement all applicable portions
of the National Strategy.
One of the National Strategy steps is "Multi-Media Methods to
Control Toxic Pollutants". Region III is engaging in several
activities to improve mutual understanding of multi-media/multi-source/
multi-pollutant interactions which pose risks to public health and the
environment.
Integrated Environmental Management Plans (lEMP's), which investigate
the environmental risks present in all media simultaneously, are well
underway for the Philadelphia and Baltimore metropolitan areas.
The Philadelphia study is scheduled for completion this fall.
Preliminary findings indicate that air toxics emissions originate
principally from about a dozen sources (both point and areawide), and
that some non-traditional sources such as sewage treatment plants, may
be major contributors.
The Baltimore study is entering the detailed evaluation phase
focusing on the following five issues:
0 Metals in the environment
0 Toxic air pollution
0 Baltimore Harbor
0 Indoor Air Pollution
0 Underground Storage Tanks
Another Regional effort involves supporting the State of West
Virginia in evaluating the risk posed by toxic chemicals in the Kanawha
Valley. Initially, Region III and Headquarters program offices involved
will perform a screening analysis of potential health risks associated
with toxic releases in the Valley. At the present time, the Agency is
working with the State of West Virginia to determine the scope and
magnitude of this study.
Additionally, the State of Delaware will initiate a $550,000
effort later this year to monitor the ambient air for possible toxic
pollutants. A tentative list of 50 monitoring locations has been
established, concentrated in New Castle County where many chemical
processing facilities are located.
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REQUESTED HEADQUARTERS ACTION
Headquarters has committed to fund extensions of multi-media work
presently on-going in Philadelphia and Baltimore to address specific
air toxic issues. Additionally, funds have been provided to enable
the aforementioned screening analysis in the Kanawha Valley to proceed;
but the possibility exists that some additional funds may be needed
to complete the screening analysis. If future work is required to
determine specific control measures needed, costs for same can be
considerable and this possibility should be factored into long-range
budgetary considerations.
Other Headquarters support which will be needed specifically for
the Kanawha Valley study include:
1. Review, comment, and concurrence with proposed protocol
for meteorological monitoring, dispersion modeling and data processing
for the screening phase.
2. Guidance by OR&D, OAQPS, and IEMD on data reporting
techniques and prioritization of toxic pollutants listed in West
Virginia's emission inventory.
3. Guidance by OR&D on techniques for monitoring of toxic
air pollutants.
ENVIRONMENTAL RESULTS
The multi-media studies currently being performed in Philadelphia
and Baltimore are designed to provide additional decision-making
tools for optimal control of toxic pollutants. These will facilitate
adoption of appropriate regulatory measures that will minimize levels
of population exposure to those pollutants whether or not the most
critical receptor medium is air.
The Kanawha Valley study is designed to provide for a screening
analysis of human health and environmental risks present as the
result of the release of various pollutants in the Kanawha Valley.
The study will also include defining potential sources for control.
(1) The Air Toxic Problem in the United States: An analysis of
Cancer Risks for Selected Pollutants, US EPA Office of Air and
Radiation and Office of Policy, Planning and Evaluation document,
May 1985.
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4. TOXIC CHEMICAL AIR RELEASES
B. SUDDEN ACCIDENTAL RELEASES
PROBLEM ASSESSMENT
In addition to concern over ambient levels of toxic chemicals
from routine releases, Region III is concerned with the possibility,
however remote, of a sudden, major chemical accident such as that
which occurred in December, 1984, at Bhopal, India. That tradegy
was caused by a massive air-bourne release of methyl isocyanate
(MIC) from a chemical plant storage tank, and resulted in the loss
of over 2,000 lives and thousands of disabling injuries.
We believe that a tragedy of that magnitude is much less likely
to occur within the United States. Because of more rigorous safety
precautions and emergency preparedness plans, sudden accidental
chemical releases which have occurred in the U.S. have been infrequent
and noncatastrophic. However, since there are numerous large
industrial facilities in this country which manufacture, handle,
store, or dispose of significant quantities of potentially toxic
chemicals, serious consideration must be given to improving emergency
preparedness and response capabilities for potential major chemical
releases wherever possible.
While the issue is of concern nationally, Region III is especially
sensitive to the possibility of a major release because of the presence
of a number of industrial facilities located in densely populated areas
within the Region. Although this issue is raised under the heading of
toxic air releases, other possible pathways of exposure are of equal
concern.
REGIONAL AGENDA/BARRIERS
Control strategies for addressing a potential Bhopal-type catas-
trophic release fall into two broad categories: (1) those actions
designed to prevent a major incident from occurring, and (2) those
actions designed to improve our preparedness to respond, if necessary,
and to minimize the impact on human health and the environment, once
a major incident does occur.
At the Regional level, our agenda for addressing potential
major incidents is directed at improving our preparedness and response
capabilities. We have more experience as well as broader statutory
authority for emergency responses as oppossed to emergency prevention,
and can more easily implement response activities with currently
allocated resources. Implementation of a preventive strategy, while
also important, would likely require considerably .greater resources,
including the committment of significant senior level management
time, and additional statutory authority.
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Region III will accomplish this agenda both through ongoing
programs and new initiatives. The Region will continue to maximize
the use of available existing authority to address accidental chemical
releases. For example, spills or releases of hazardous substances
in excess of defined Reportable Quantities (RQ's) must be reported
in accordance with Section 103 (a) of CERCLA (Superfund). Also,
certain spills or releases are enforceable under Section 311 of the
Clean Water Act if the spill reaches a navigable waterway, or under
the Clean Air Act (Section 112) if the release is one of seven currently
designated hazardous air pollutants. In the absence of agency rulemaking
which particularly regulates a specific substance regarded as an
"air toxicant," the agency's best authority to deal with such releases
comes from the emergency provisions of the various statutes.
The Region has recently reviewed procedures used in handling spill
and release reports received, focusing on internal coordination and
enforcement follow-up actions. The review, while finding that proper
and timely actions are taken when spill reports are received, did
identify some areas where more formal procedures could enhance the
Region's internal coordination and follow-up action. Formal Regional
procedures in the form of Regional Orders are currently being developed
and are expected to be in place by October 1985.
Region Ill's strategy also includes strengthening emergency
preparedness and response capabilities by improving the adequacy of
Contingency Plans developed by State and local governments. Using
the framework outlined in the National Contingency Plan (NCP), the
Region will work through the Regional Response Team (RRT) to ensure
that each Region III State, and local areas, where necessary, have
comprehensive written Contingency Plans, which address the wide
range of possible accidental hazardous chemical releases. We will
focus our review during FY 86 on State Contingency Plans and on
those local geographic areas with prominent chemical processing
facilities. For example, Contingency Plans for the Kanawha Valley
in West Virginia were updated during this past year as a result of
the RRT reviewing the State and local plans for that area. Our goal
is to have acceptable plans in place for all local, state, and Regional
areas by the end of FY 87. We also hope to develop a computerized
data base of contingency plans to assist in monitoring and updating
plans in the future.
REQUESTED HEADQUARTERS ACTIONS
While the Regional agenda focuses on response capabilities, we
recommend that Headquarters continue its efforts to improve both
preventative and response measures. The Region supports the Head-
quarters' ongoing activities and new initiatives outlined in the
June 1985 National Air Toxics Strategy. We particularly encourage
the following:
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0 Office of Solid Waste and Emergency Response (OSWER) should
allocate additional resources to each Regional Office for improving
state and local governments' preparedness activities, including
contingency planning, training, exercises, and simulations.
0 OSWER should expedite issuance of a List of Acute Hazards
which will represent EPA's advice to the public, State and local
governments, and emergency officials, on which chemicals could lead
to accidents resulting in serious acute exposures.
0 OSWER should continue coordinating Federal preparedness
activities with private sector initiatives such as those by the
Chemical Manufacturers Association and the American Institute of
Chemical Engineers.
ENVIRONMENTAL RESULTS
Implementation of the above Regional and Headquarters actions
will result in (1) a reduced likelihood that a major chemical release
incident will occur, and (2) improved capabilities at all levels of
government to respond to any emergencies which do arise.
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5. OZONE STANDARD VIOLATIONS
ENVIRONMENTAL PROBLEM
PROBLEM ASSESSMSNT
The ozone National Ambient Air Quality Standard (NAAQS) is not
being attained over large geographic areas within Region III. However,
for most of these areas, modeling has predicted attainment of the
NAAQS by 1987. The most notable exception to this is the Pennsylvania
portion of the Philadelphia Intrastate Air Quality Control Region,
where existing modeling predicts a 5.5% volatile organic compound (VOC)
emissions reduction shortfall, leading to a predicted inability to
attain the ozone standard in this area. There are many contributing
factors to the ozone nonattainment problem in the Philadelphia area;
namely, its location within the Northeast Corridor for ozone transport,
meteorological conditions, the sheer volume of point sources in this
area including several of which have not yet complied with existing
VOC regulations and the delayed implementation of the automobile
inspection and maintenance program.
REGIONAL AGENDA/BARRIERS
Major (greater than 100 tons per year) VOC sources are subject
to existing Federal and State regulations. In addition, the automobile
inspection and maintenance (I/M) program has been implemented in the
Philadelphia area which should contribute to reductions in the ozone
levels.
The Commonwealth of Pennsylvania and EPA Region III are examining
extraordinary VOC control measures, such as controls for the wood
furniture coating industry, the automobile refinishing industry and
barge loading operations, that could be implemented to provide for
ozone attainment by 1987. The Commonwealth is also preparing an
updated, comprehensive VOC emissions inventory which is expected to
show lower VOC emissions for 1985 through 1987 than originally predicted.
The revised State Implementation Plan (SIP) is expected to be submitted
to EPA by September 30, 1985.
One barrier to timely ozone attainment is the Commonwealth's
reluctance to adopt and implement an automobile antl-tamperlng program.
We will continue to work with Pennsylvania, including securing their
participation in a study of possible tampering and misfueling problems
in the Philadelphia area during the summer of 1985, and to develop an
acceptable anti-tampering program in FT 1986.
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Another potential problem could be a delay in the adoption of
certain extraordinary VOC control measures while additional source
specific and technological data is gathered.
REQUESTED HEADQUARTERS ACTIONS
None required at this time.
ENVIRONMENTAL RESULTS
The general trend in ozone levels in Region III has been a
gradual reduction in violations over the years, except for 1983 which
showed an unusual number of violations during the very hot, dry
summer months.
The revised VOC emissions inventory and the implementation of
the extraordinary VOC control measures should result in the elimination
of the VOC emissions reduction shortfall and may provide for attainment
of the ozone NAAQS by 1987. However, due to the widespread ozone and
transport problems in the Northeast Corridor, there are no assurances
of attainment by 1987.
A3
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6. SURFACE WATER TOXICS
PROBLEM ASSESSMENT
Identification of the extent, severity, and impact of toxics
substances in surface waters has proven to be difficult. However,
the 1984 State 305(b) reports have identified a number of streams
with known or suspected toxics problems based on available water
quality data. The 305(b) reports indicate that the most significant
toxics problems in Region III are: Baltimore Harbor and Elizabeth
River in the Chesapeake Bay and the Beaver, Delaware, Mahoning and
Shenango Rivers in Pennsylvania. Many of these waterbodies are
affected by both point and non-point sources from an urban/
industrialized center. Aquatic life uses are most heavily affected
by toxics in surface waters. Due to the proximity of large population
centers to these toxics problems, there is a high level of public
interest and concern about these problems. This is particularly true
for the Chesapeake Bay where contact recreation and shellfishing are
important water uses potentially impacted by toxics pollution.
There may be potential problems associated with public health
in several areas of the Region. As additional data are developed
and analyzed, especially with regard to public health concerns, we
anticipate some change in the priority geographic areas identified
above.
REGIONAL AGENDA/BARRIERS
Region III continues to implement the Regional Surface Water Toxics
Strategy that was established last year. As part of this effort the
Region has commitments from all NPDES-delegated states to develop
procedures for addressing toxics in the NPDES program. It is anticipated
that all five Region III States will complete this effort in 1986.
The Region will monitor state implementation through in-depth reviews
of a sample of major permits issued by the states. The implementation
review will be coordinated with the water quality standards program
so that potential problems may be addressed in the triennial review
of standards.
In addition, the Chesapeake Bay Program will address the toxics
problems in the Elizabeth River and Baltimore Harbor areas of the Bay.
A plan of action for the Elizabeth River area will be completed early
in FY 1986. The Region will conduct intensive chemical and biological
effluent analyses* These analyses will result in recommendations
concerning NPDES limits for the priority dischargers. A plan of
action for the Baltimore Harbor study will be developed after completion
of the IEMP study.
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The Region will continue to encourage States to adopt appropriate
toxics criteria in their water quality standards programs. One barrier
to this initiative is reluctance of State agencies to apply laboratory
derived criteria to field situ ations. The Region plans to implement
a new, risk assessment/risk management initiative in FY86. This
involves the selection of several priority sites where carcinogens or
other toxics may pose public health problems. Additional field
studies will be conducted to establish contaminant levels evaluated
through a risk assessment approach and risk management alternatives
will be developed for consideration by State and Federal decision makers.
In FY86, Region III plans to complete the field work and conduct the
risk assessments at 4 sites. An additional 4 sites are scheduled for
FY87. The effort will be coordinated with appropriate Federal and
State agencies.
REQUESTED HEADQUARTERS ACTIONS
o Accelerate development of scientifically sound water quality
criteria for toxic pollutants - OWRS
o Establish a national policy on an acceptable carcinogen level
for protection of human health. This should be' implemented
consistently through all EPA programs, i.e., WQS, PWS, RCRA,
ORS, ODW, OWRS, etc.
o Insure consistent implementation across Regions of the Policy
for the Development of Water Quality - Based Permit Limitations
for Toxics Pollutants - OWEP
o Develop improved bioassay tests for human health impacts of
toxics pollutants - ORD.
o Finalize monitoring program guidance which emphasizes the
importance of scientifically sound toxics data gathering,
management and evaluation - OWRS.
o Provide workshop for Region III States on interpretation
and application of human health criteria - ORD.
ENVIRONMENTAL RESULTS EXPECTED
We expect to obtain agreements with all Region III States on toxics
permitting procedures which will result in accelerated implementation of
point source controls. The State procedures and EPA review of a sample
of proposed permits in NPDES delegated States will insure that toxics are
properly addressed in all permits issued in the future. Since there are
a large number of point sources with potential toxics concerns, this will
go a long way toward controlling surface water problems in the Region.
i
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The control programs under development in the two geographic
problem areas of the Chesapeake Bay will result in NPDES limitations for
all significant dischargers and recommendations for non-point source load
reductions. Implementation of the permit requirements and NFS controls
will result in reduction of the existing documented toxics problems.
The risk assessments will address human health concerns in selected
priority areas and identify, to the extent possible, the pollution sources.
Management options will be developed for consideration of State and
Federal decision makers. Implementation of management recommendations
will provide greater public health protection in these geographic areas.
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7. LOSS OF ENVIRONMENTALLY SENSITIVE AREAS
PROBLEM ASSESSMENT
Historically, the attempt at the preservation of enviromentally
sensitive areas (i.e. - wetlands, floodplains, farmland, etc.) has
been ineffective. For example, since the 1950's over nine million
acres of wetlands have been lost in the United States. By the year
2010, urban and other non-agricultural uses will claim 25 to 30
million acres of the nation's farmland. The impacts associated with
these losses and conversions are significant.
The impacts associated with the loss of agricultural land could
result in a decline in food production, the conversion of new land
to agricultural use, or the intensification of farming practices.
Both of these activities will contribute to water quality degradation.
The impacts of agriculture, aside from pestici.de regulation, have
until recently been largely ignored. Soil losses have been estimated
by SCS to be 3 million tons per year, and these soil losses have been
identified as a major source of water pollution due to the high
content of chemical and animal waste. With the intensification of
agricultural activity, and the conversion of new land to agricultural
use, an increase in the use of fertilizer, pesticides, and herbicides
can be expected. Therefore, it is critical for Region III to develop
initiatives that will preserve existing agricultural land, and to
control nonpoint source pollution which is often due to poor agricultural
practices.
Wetland areas are interspersed between the aquatic and terrestrial
environments and are of critical importance in maintaining and improving
water quality by reducing erosion and filtering both land runoff and
sediments already in the water column. Wetland areas also assimilate
various pollutants including nutrients. These nutrients support the
growth of plants which provide organic matter that is the basis of the
aquatic food web. In Region III, preliminary studies have found an
annual loss of 8700 acres of freshwater wetlands, and a net loss of
14.9Z of the wetlands in the Gulf-Atlantic Coastal Flats of Delaware,
Maryland and Virginia. These losses must be curtailed if EPA is to be
successful in its mission of protecting the environment and in main-
taining or improving water quality.
REGIONAL AGENDA/BARRIERS
Administrative procedures are in existence that could and should be
used to protect environmentally sensitive areas. The expertise is
available within the Agency for greater application of comprehensive,
ecosystem-oriented evaluations in sensitive regions (e.g. Chesapeake Bay,
Poconos) or in generic systems (e.g. agricultural land use patterns and
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practices, floodplains, wetlands). However, losses have been occurring
due to the fact that the National Environmental Policy Act, Executive
Orders, Agency policies, and Agency guidelines are not uniformly applied.
Illegal dredge and fill activities are also occurring throughout
the Region that cannot be addressed with current manpower and financial
resources. Many of these unauthorized activities are occurring due
to a lack of identification of these areas and communication by the
resource agencies to the public. EPA guidelines provide a tool for
"advanced identification" but it has not been utilized by the Regions
on a large enough scale to have significant benefits due to other
resource commitments.
In order to achieve significant environmental results in terms
of protecting environmentally sensitive areas, the Region intends to
undertake a number of initiatives. The Environmental Impact and
Marine Policy Branch will establish formalized interagency coordination
efforts with cooperating Federal agencies (COE, SCS, DOT) for NEPA
and 404 reviews. Similarly, the Assistant Regional Administrator for
Policy and Management (ARAPM) intends to review construction grants
and remedial actions undertaken within the Region to ensure application
and/or equivalency with NEPA mandates, as well as conformity with
wetlands policies, Executive Orders, guidelines, and Agency policies
relevant to the protection of sensitive areas. In-house training
will also be provided to these programs (CERCLA, Construction Grants)
on NEPA and 404 responsibilities, ecosystem ecology and comprehensive
environmental assessment.
Interface with the Chesapeake Bay Program Implementation Committee
is also planned to ensure that sensitive habitat issues are incorporated
into the Bay's implementation program. In addition, the Region will
develop a "wetlands prioritization" program to be incorporated into
the Regional decisionmaking process, and a number of "advanced identi-
fication studies" will be undertaken to improve Section 404 permit
reviews and enforcement.
Finally, the Region will specifically advance its enforcement
efforts in the Pocono Region of Pennsylvania where unauthorized
dredge and fill activities have resulted in significant impacts to
wetland areas, especially peat bogs. These enforcement activities,
along with the advanced identification studies discussed above, will
provide protection to thousands of acres of wetlands and associated
ecosystems, and reduce the ecological losses that have been occurring,
especially to freshwater wetlands.
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REQUESTED HEADQUARTERS ACTION
"Headquarters should formally recognize these activities as
critical to the Agency's mission in protecting the environment and
reward these activities during the budgetary process.
"Headquarters should provide assistance by encouraging Agency
construction grants and remedial programs to better utilize the
knowledge and experience of the NEPA and 404 program offices. This
would facilitate the acquisition of external permits and/or external
Agency approvals by assuring that Agency actions are undertaken in
the most environmentally acceptable manner and by assuring that all
external coordination requirements are achieved.
"Headquarters should serve as a liaison with other Federal, State
and Local agencies to assure that NEPA and Wetland Policies are
applied uniformly.
"Headquarters should revise EPA's Section 404(c) guidance to
facilitate decisions. For instance, Section 404(c) veto/restriction
authority should be delegted to the Regional Administrator.
ENVIRONMENTAL RESULTS
With these initiatives in place, we project a minimum increase
of 25% in Section 404 enforcement actions, and the protection of at
least 1,500 acres of wetlands during FY86. This is,in addition to
the protection that is currently afforded through our normal NEPA
compliance and §404 review procedures, and will be in addition to the
resource savings that will accrue from our coordination and training
efforts described above.
Our coordination efforts, both internally and with other agencies,
will also result in the protection of environmentally sensitive areas.
Coordinating activities will ensure that proper environmental consider-
ations are being put into the early planning stages of project develop-
ment, which will both benefit the environment and facilitate permitting
actions occurring in later phases of their project development. This
will result in fewer wetland impacts associated with Federal projects.
Finally, EPA will undertake "Advanced Identification Studies" in
the Region and develop a "wetlands priority list" that will result in
the initiation of at least two advanced 404(c) actions. These actions
will restrict or deny dredge and fill activities in at least two
environmentally sensitive wetland areas in the Region.
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8. INDOOR AIR POLLUTION
INTRODUCTION
Recent data has begun to indicate that indoor exposures to both
man-made and natural pollutants may be more important than outdoor
exposures in terms of public health. Region III has chosen to focus
its attention on two Indoor air pollution problems, radon gas and
asbestos.
PROBLEM ASSESSMENT
A. Radon
Radon is a naturally-occurring radioactive gas that results from
the radioactive decay of uranium in the soil. It is not uniformly
distributed so there are geographic "hot spots." Radon has been found
to be a significant problem in an area of Pennsylvania known as the
"Reading Prong," with about 40% of homes tested by the State having
unhealthful levels. Radon is a suspected problem in some areas of
Region III, but an equally important concern is often the lack of a
data for most of the Region. EPA estimates that 5000 to 20,000
deaths occur each year in the United States from radon exposure.
This estimate is based on the range of estimates made by independent
U. S. and world radiation experts from epidemiological data from
uranium miners.
B. Asbestos
Asbestos has been used extensively in trowled-on or sprayed-on
surface coatings, in public builings and schools. Region III has
operated an asbestos-in-schools program for several years. The
primary concern over exposed surface coatings is because of the high
potential for human exposure. This initiative would continue the
completion of the asbestos-in-schools program.
At the current rate of inspections of Local Education Agencies
(LEA) for asbestos, it is projected that it may take in excess of 20
years to complete the 3500 public and private LEA's in Region III.
Furthermore, one friable asbestos is identified in schools, the LEA's
often are recalcitrant in solving the problem unless parents become
aware and demand correction.
50
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REGIONAL AGENDA/BARRIERS
A. Radon
The main barriers to the solution of the radon problem are the
lack of legal authority to conduct a regulatory program and lack of
funds for remedial measures or a large-scale monitoring effort. The
Regional agenda consists of an effort to identify the problem areas
in the Region using radiographic data from USGS. We will also do
limited spot-checks based on that data in cooperation with the state
having jurisdiction. Sampling equipment to do these measurements is
already on hand in the Regional Office and the USGS data is on order.
We will also conduct an outreach program to assist in informing
homeowners how to fix their own home and to inform builders on radon-
resistant construction techniques. A massive radon monitoring program
has been initiated by the Pennsylvania Department of Environmental
Resources in Eastern Pennsylvania. The Region III efforts will
complement this monitoring program.
B. Asbestos
The main barriers to solution of the problem include lack of
financing in local school districts to remove the asbestos and lack
of sufficent EPA resources to implement the inspection and enforcement
program. Region III intends to continue its asbestos-in-schools
program at approximately the same level as it did in the past which
involves performing approximately 125 inspections of LEA's per year.
American Association of Retired Persons (AARP) personnel are being
used to supplement EPA personnel to meet this projection. Furthermore,
through the use of grant funds a couple of Region III States will be
performing additional inspection during FY'86.
REQUESTED HEADQUARTERS ACTION
A. Radon
A radon program was recently proposed for the consideration of
the Administrator. Region III endorses this program. We also plan
to utilize ORP Headquarters and the ORP field facilities in Las Vegas
and Montgomery, Alabama to assist in our program.
B. Asbestos
Headquarters should review the progress currently being made on
the Asbestos-In-Schools program and consider atternatives for accelerating
the completion of the inspection effort.
51
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ENVIRONMENTAL RESULTS
A. Radon
1. Identification of potential radon hot spots in Region III.
An added benefit of this effort would be identification of areas with
potential radium-in-drinking-water problems.
2. Outreach sessions and/or seminars with at least three groups
of contractors/builders or with affected members of the public.
3. Monitoring of radon in at least 3 buildings from each potential
hot spot, but as many as possible will be monitored, contingent on
availability of travel funds.
B. Asbestos
Where inspections identify friable asbestos, the Region will
continue to pursue the enforcement actions necessary to eliminate the
problem and provide for a reduction in the long-term health risks of
school-age children.
52
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9. NON-POINT SOURCE POLLUTION - NUTRIENTS
PROBLEM ASSESSMENT
Nonpoint source (NPS) pollution is a dominant water quality issue
in Region III and impacts all areas of the Region. Four Region III
states list nutrients as a major water quality problem; three list
animal wastes as a major problem; and three list sediments as major
problems. This, along with the fact that 54% of the stream miles
and 66% of the lake acreage in the Region are reported as not meeting
designated uses because of NPS, points to the breadth of the problem.
In addition to the lakes and rivers, the upper Chesapeake Bay receives
48.6% of its phosphorus and 76.9% of its nitrogen from nonpoint
sources. Also, since agricultural lands provide most of the driving
force for ground water recharge, nutrients, primarily nitrogen, are
transmitted into the aquifer, thereby degrading this important source
of domestic water in the Region.
Nutrients accelerate algal growth, which along with suspended
sediments, reduce light penetration believed to be the major cause
of loss of submerged aquatic vegetation (SAV) in the Bay. Algal
blooms and the resultant die-off produces low dissolved oxygen condi-
tions in many water bodies throughout the Region. Also, nutrient
rich sediment deposits are responsible for large areas of zero
dissolved oxygen in the deeper portions of the Bay.
Nutrients in NPS runoff can be traced to three distinct sources:
animal wastes, commercial fertilizer, and naturally occurring nutrients
in the soil. The transport of nutrients from each source presents
a slightly different problem and therefore requires a different
solution. Animal waste nutrients can enter surface water by direct
discharge from the animal standing in the stream, by runoff from
barn lots and manure piles and by runoff from fields with manure
applied on the surface. Commercial fertilizer usually leaves the
field with runoff water and the sediment carried in the runoff.
Natural soil nutrients follow the same path as commercial fertilizer.
Surface runoff from agriculture usually does not carry large amounts
of dissolved nutrients, but does carry large amounts of absorbed
nutrients on the sediment. Nitrogen, being soluable will follow the
path of the first movement of water in the soil and this is usually
downward. Therefore, nitrogen either moves into the groundwater or
moves to surface waters being interflowed below the soil surface.
In the Chesapeake Bay, the early spring runoff events moves large
amounts of phophorus into the Bay, followed a few weeks later by
nitrogen carried by high base flows in the rivers.
53
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REGIONAL AGENDA
The efforts to control NFS nutrient problems have several defined
goals:
1. Reduce NFS phosphorus Induced aquatic impacts in lakes,
rivers and Chesapeake Bay.
2. Decrease nitrogen loads to both surface and groundwater
resources.
3. Improve water quality in the Chesapeake Bay and other
water bodies in the Region.
4. Restore the living resources and aquatic habitat in
the Bay.
5. Reduce erosion and sediment transport to protect both
the soil and water resources of the Region.
Virginia, Pennsylvania and Maryland have operating cost share
and technical assistance programs that are addressing urban and
agricultural NFS problems in the Bay watershed through the installation
of best management practices (BMP). All programs are using both
state and federal funds to accomplish their goals. Also, USDA through
its normal conservation program, is working with the states on this
task.
In order to reach the above stated goals many activities must
happen at the same time. Through the use of Clean Water Act grants
(205g and 106) the states must increase their technical assistance
staff to insure effective use of the implementation funds. An expanded
NFS monitoring program is needed, utilizing the grant process (205j
and 106). This will provide information on the effectiveness of the
installed BMPs as well as provide data for overall program evaluation.
In order to provide the states with assistance and guidance on NFS
programs, EPA is hiring a full time NFS specialist to work in the
Region with the major effort directed to the Bay. In order to assure
coordination and cooperativeness with USDA programs, a staff person is
being assigned to work in this area. The Region has MOUs with SCS,
FWS, COE, NOAA, and USGS concerning the Bay Program and is working on
others to insure coordination of programs, projects and day to day
activities.
The Regional NFS program is stressing the concept of using NFS
funds only where the most benefit can be derived. This concept of
targeting NFS funds is being encouraged at all levels of planning in
state grants and in ongoing conservation programs. This includes
targeting basins and sub-basins, targeting critical areas within these
54
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areas, and targeting at the farm and field level. Also, a progress
tracking system is being developed for the Bay to assist in management
of the grants and evaluations of program effectiveness. Another
benefit of tracking will be to assist in determining load reductions
accomplished through implementation of BMPs.
The states have the lead role in developing and implementing
the NFS program for the Bay and Region. They are responsible for
the coordination with local and federal programs in their states.
Much of the assistance needed for the NFS program will come from
other federal agencies with ongoing programs. This is ensured through
MOUs, with EPA. EPA must also provide assistance for all phases of
this effort. The Region will be responsible for most of the activity,
but will rely upon Headquarters to assist as needed.
HEADQUARTERS ACTION NEEDED
1) Continued support in areas of policy and guidance reflecting the
needs of the Region and Chesapeake Bay from both the Office of
Marine and Estuarine Protection and the Office of Water Regulations
and Standards.
2) Assure that the Chesapeake Bay Program interests are included
when cooperative efforts with other agencies are developed.
3) Utilize the Chesapeake Bay drainage basin as the test area develop-
ment of point and nonpoint source load evaluations using "Reach
File" programs, as this system is modified to include NFS information.
4) Provide NFS effectiveness data, including information from the RCWP
evaluation program and the CTIC data sets.
5) Provide assistance in obtaining data and information regarding
NFS implementation within the Bay drainage basin from other
agencies (USDA) for use in implementation tracking and NFS
effectiveness evaluations.
ENVIRONMENTAL RESULTS
Reducing the nutrient loads will reduce the number of river
miles and acres of lakes that are not now meeting designated uses.
Also, reduced loads will greatly help the restoration of Chesapeake
Bay, although the Bay will react slower that the lakes or rivers.
55
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For Chesapeake Bay, control of nutrients and sediment will mean an
improvement in the living resources of the Bay (SAV, striped bass, and
shellfish), an improvement in the commercial and recreational interests
on the Bay, a stabilization of the land resources in the drainage basin
of the Bay, and an economic improvement for the agricultural community
in the basins.
56
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10. ACID RAIN
PROBLEM ASSESSMENT
Region III believes that acid deposition is a real and serious
environmental problem. The Middle Atlantic States covered by Region
III are at the center of the controversey. Because the States in
Region III are heavily populated and industrialized, the emissions
of sulfur dioxide and nitrogen oxides within the States are major
contributor to the local acid rain problem. Pollution released from
neigboring and more distant States contributes to the problem, because
much of the pollution is transported through the air over long distances
before being brought to earth by rain and by fallout of aerosol.
We know from the Survey of Northeastern Lakes carried out in
fall 1984 that some of the lakes in the Pennsylvania Pocono mountains
are not healthy, because they are too acidic, and other lakes would
be damaged if more acid is introduced, which may occur because of
acid deposition. The Survey did find that most of the lakes appear to
be resistant to acidification.
We know less about the damage being done to the forests.
Serious forest damage in Europe has been attributed to Acid Deposition,
as has more limited damage in the Northeastern United States. Research
in this area is just beginning with the first results not expected
for 3 years.
REGIONAL AGENDA
The Middle Atlantic State Air Pollution Control Agencies and
EPA Region III are playing a major role in the National effort concerned
with acid deposition. Most of this effort involves two vital activities:
1. State Acid Rain Program (STAR)
The STAR program is approximately 30 projects that are being
carried out by the State Air Pollution Control Agencies. These
projects taken together represent a practical review of the
administrative and managerial steps that EPA and the States
would employ if legislation is passed to control acid deposition.
A $3 million dollar supplementary appropriation was provided in
FY 85 to support these efforts.
57
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In Region III, the Washington DC Council of Governments,
State of Maryland, and State of Pennsylvania have agreed to
undertake projects in the STAR program. The projects will be
completed during the 4th quarter of FY 86.
Region III will monitor and administer these projects as
part of its overview of the 105 Air Grant programs.
2. National Emission Data System (NEDS)
National Emission Data System is the EPA operated computer
based emission data base used by the State 105 Grant Agencies
to record the emission data that they collect each year for
all major industrial sources across the country. These updated
emission Inventories are due each year by July 1st. In the
past NEDS was not a high priority activity; therefore, extra
effort is required this year to obtain the best possible
inventory.
Region III will be putting additional effort into assisting
the States in preparing their annual emission inventory. This
is reflected in the change of approach that Region III will be
following:
During previous years Region III waited until the submittal
were received and processed before beginning the work of
verifying that all the emission sources were included and
beginning the work of correcting the coding errors.
During FY 86 more effort will be put into correcting and
rectifying omissions in the 1984 emission inventories.
- This will include use of non-NEDS information to verify
that all industrial sources are included in NEDS 1984.
This effort will produce 1985 inventories that will be
complete when they are submitted.
- Also, Region III personnel will work with and, if
necessary, train the State personnel in coding the NEDS
information with the errors in the 1984 submittal
identifying where the efforts should be directed.
After this effort, few coding errors should be found in
the 1985 submittal.
- Also, Region III personnel will review the inventory
information at the State offices sufficiently in advance
of the FY 85 submittal to EPA to allow corrections and
to collect missing information.
58
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REQUESTED HEADQUARTERS ACTION
L. State Acid Rain Program (STAR)
The STAR program is being directed by the EPA Acid Rain
Office, AR-445, at EPA Headquarters. We are satisfied with the
approach and schedule described below that the Acid Rain Office
has established for the STAR program, and we are not not requesting
additional Headquarter's assistance.
EPA Acid Rain Office, AR-4A5, will monitor the technical
performance of the individual STAR projects and identify the
need for redirection of tasks. Where appropriate EPA Acid Rain
Office is expected to request Region III to take formal action
under the Region's role of administrator of the 105 grant program.
EPA Acid Rain Office will evaluate the findings of the STAR
projects and formulate from the findings a prototype regulatory
program for implementing controls for acid deposition. A
description of this prototype program is expected to be available
about 6 months after the STAR projects are completed, probably
Spring 1987.
2. National Emission Data System (NEDS)
In the past NEDS was not a high priority activity.
Headquarters has identified NEDS to be a high priority program
in 1985, because it is the Industrial source emissions data base
that will be used for studying the acid deposition problem.
Headquarters has stressed the importance of the 1985 inventory
by (1) including NEDS in the Strategic Planning and Management
System, (2) identifying NEDS as high priority in the 1986/87
Operating Plan, (3) including Acid Rain Inventory (meaning NEDS)
among the special Initiatives in the Performance Grants Program
for the FY86 105 State Grants, and (4) the Administrator's June
11, 1985 letter to the State Secretaries for Environmental
Affairs in which he dlscussies and stresses the importance of
obtaining the best possible acid rain emission inventory.
The effort that will be required at the working level to
obtain the best 1985 inventory has not been emphasized by Head-
quarters, nor has Headquarters identified intermediate and final
goals nor have the promised additional funds been identified.
Headquarters must provide the guidance, arrange for distribution
and feedback of information and identify the funds that are
available before the States and EPA Regional make their plans to
collect the best inventories.
59
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ENVIRONMENTAL RESULTS
1. State Acid Rain Program (STAR)
The STAR projects will produce a detailed plan that the
regulatory agencies will follow to control the emissions of
pollution that cause acid rain. Because the State and Local
Air Pollution Agencies played a major role in the STAR projects,
the plan will incorporate a balance of environmental, social,
and economic considerations.
2. National Emission Data Base (NEDS)
The 1985 NEDS will provide the inventory of industrial
emissions that will be used in studying the acid deposition
problem and to plan for its control.
60
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II.C. FOCUS ON SPECIFIC GEOGRAPHIC AREAS
Region III has long been an advocate of the geographic integra-
tion concept. That is, a large proportion of environmental problems
nationally are concentrated in a relatively few geographic areas,
where populations or sources of pollution are so concentrated that
total environmental risk remains high,even after the application of
broad national control requirements. These problems are most effec-
tively addressed by focusing attention on the geographic areas of
concern on a selective basis where environmental concerns have been
identified. Region III has been in the forefront of applying the
geographic concept, through our experiences with the Philadelphia
and Baltimore Integrated Environmental Management Projects.
In developing a preliminary list of environmental issues for
this year's EMR, an attempt was made to associate discrete geographic
areas with each of the identified environmental issues. The geographic
focus was intended to pinpoint some areas within the Region where
these issues are of special concern. For example, under the issue
of hazardous waste management, we listed New Castle County, Delaware
as one geographic focus becasue that area includes a cluster of
seven hazardous waste sites listed on the National Priority List for
cleanup. This does not mean that the scope of the issue is limited
to only New Castle County. Nor was it meant to imply that hazardous
waste management is not of concern elsewhere throughout the Region.
Hazardous waste management is, in fact, a Regionwide concern, especi-
ally in regard to need for disposal capacity.
For each of the EMR priority issues discussed in Part II B. of
this Report, geographic focuses were incorporated as appropriate into
the discussion under problem assessment. In some cases (e.g., drinking
water contamination), no particular geographic area was identified and
the issue was considered to have a Regionwide focus. The following page
includes a summary of the final list of issues and the associated
geographic focuses.
61
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1985 ENVIRONMENTAL MANAGEMENT REPORT
Region III
Final List of Environmental Priorities
Environmental Issue
1. Hazardous Waste Management
A. Site Cleanup
B. Disposal Capacity
2. Drinking Water and
Ground Water Contamination
3. Resource Extraction (Mining)
A. Acid Mine Drainage
B. Oil & Gas Production
4. Toxic Chemical Air Releases
5. Ozone Standard Violations
6. Surface Water Toxics
7. Environmentally Sensitive Areas
8. Indoor Air Pollution
A. Radon
B. Asbestos
9. Non-Point Source Pollution
10. Acid Rain
Geographic Focus
Regionwide
New Castle County (Del.),
S.W.Pa, S.E. Pa., N.E. Pa.,
Regionwide, especially
Baltimore SMSA and W.Pa.
Regionwide,
Southeastern, Pa.
West Virginia, Western Pa.,
and Western Maryland
Northwestern Pa.
Kanawha Valley (W.Va), Upper
Ohio River Basin, New Castle
County (Del.), Philadelphia SMSA
Pennsylvania, especially
Philadelphia; 1-95 Corridor
Elizabeth River (Norfolk),
Baltimore Harbor; Shenango
River, Pa.
Chesapeake Bay; Coastal
Flats of Delaware, Maryland,
and Virginia; Pocono Mts.
Reading Prong (Reading-
Allentown area of Pa.)
Regionwide
Chesapeake Bay, from
sources in Md., Va., Pa.
Regionwide
62
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PART III.
Regional Recommendations
For The Agency's 1987-88
Priority List.
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PART III. REGIONAL RECOMMENDATIONS FOR THE AGENCY'S 1987-88 PRIORITY
LIST
Regions III believes that the current priority list included in
the FY 86-87 Agency Operating Guidance is for the most part adequate
for the purposes of directing attention to the Agency's most important
National environmental problems. We do, nevertheless, suggest the
following revisions, based largely on our discussion of Regional pro-
blems contained in Part II. We agree with the recent Headquarters
suggestion that the list be limited to about twenty major items.
Suggested Revisions
1. Increased emphasis should be placed on those actions which
will facilitate state and local development of.new hazardous waste
disposal capacity. In this regard, current Priority #6 dealing with
RCRA regulated hazardous waste disposal alternatives- should be streng-
thened to emphasize the need for National guidance for the Regions and
states on development of new treatment, storage, and disposal facili-
ties.
2. Implementation of the National Air Toxics Strategy announced
1 in June, 1985 should be reflected on the list. Planned Strategy ac-
tions such as issuance of a List of Acute Hazards, strengthening
Reportable Quantities regulations and enforcement, and improving
state and local contingency planning should be included. Current
Priority #15 dealing with NESHAPS should be included as part of this
emphasis, and the entire air toxics issue should be listed as priority
t #9. Current Priority #9 which addresses compliance with the NAAQS's
can be reduced in priority to #15 to accommodate the air toxics
emphasis.
3. Promulgation of drinking water standards for currently unregu-
lated contaminants (Priority #13) should be elevated to somewhere in
' the top ten priorities. Standards for volatile organic compounds
should be emphasized.
4. Current Priority #17, which addresses the need for toxics
control in water quality criteria and standards, should be considered
< in the context of Priority #11, which deals with NPDES permit issuance.
Priority #17 should be elevated, perhaps, if appropriate, by combining
it with Priority #11.
5. Federal Facilities compliance (Priority #23) should be elevated
somewhat to reflect its multi-media, cross-program application.
67
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6. Under Priority #24 which deals with PCS compliance, the phrase
"and eliminating the use of PCB transformers in high voltage applica-
tions" should be added to reflect new PCB removal regulations.
7. Priority #14 dealing with wetlands protection should include
emphasis on the Advanced Identification of Disposal sites program.
8. Language should be added to Priority #7, which calls for reducing
risks from existing chemicals, which emphasizes the need for improved
risk assessment and management techniques, and the identification of
risk reduction controls, through studies such as the Philadelphia and
Baltimore Integrated Environmental Management Projects (lEMP's).
68
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