905R81014
Fiscal Year 1981
U.S. Environmental Protection Agency - Region V
Illinois Environmental Protection Agency
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State/lEfPTL Tlgreement
Fiscal Year 1981
U.S. Environmental Protection Agency - Region V
Illinois Environmental Protection Agency
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Illinois Environmental Protection Agency
U.S. Environmental Protection Agency - Region V
State/EPA Agreement (SEA)
Fiscal Year 1981
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AGREEMENT
This State/EPA Agreement becomes effective when signed by the Regional Adminis-
trator of the U.S. Environmental Protection Agency (USEPA), Region V, and the
Illinois Environmental Protection Agency (IEPA).
The Agreement identifies eleven environmental or programmatic problems as
"Highlight Issues" and proposes a problem-solving approach for each. The pro-
posed strategies and activities reflected in this Agreement are mutually accep-
table to the parties who agree that all reasonable efforts will be made to
achieve the objectives stated for each highlight according to the implementation
schedule included.
USEPA guidance to the IEPA for the preparation of grant applications for Federal
support and State work programs prepared pursuant thereto will recognize that
the activities specified in this Agreement have funding priority within the
limits of eligible funds allocated to the State of Illinois. The highlights
may be included in the appropriate grant work programs by reference to this
document if the level of detail is considered adequate. Progress on the imple-
mentation of the Agreement will be mutually evaluated in mid-year of the 1981
Federal fiscal year.
This Agreement may be amended at any time, except as limited by applicable laws
or regulations. Amendments shall be made by supplemental Agreement, endorsed
in writing by the parties hereto.
//OohjyMctTuire
Reional Administrator
Environmental Protection Agency
Michael P.
Director
Illinois Environmental Protection Agency
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TABLE OF CONTENTS
I. Introduction Page 1
II. WATER:
Goals and Program Direction for FY 1981 - Page 3
Highlights
#1 Develop a comprehensive strategy for groundwater Page 11
protection in Illinois, as well' as develop a primacy
level Underground Injection Control (UIC) program.
#2 Control the discharge of toxic substances, primarily Page 13
from industrial sources, to surface waters of Illinois
in order to protect human health and improve the
quality of these waters.
#3 Increase the rate of Publicly Owned Treatment Works Page i§
(POTWs) compliance with the requirements of the Clean
Water Act.
III. AIR:
Goals and Program Direction for FY 1981 Page 18
Highlights
#4 Control/reduce excessive levels of Total Suspended Page 24
Particulates in Southeast Cook County.
#5 Control/reduce exessive levels of ozone in the Page 26
Chicago and East St. Louis metropolitan areas.
#6 Improve and simplify U.S. EPA rulemaking procedures Page 28
with regard to Illinois submitted SIP revisions.
IV. HAZARDOUS MATERIALS:
Goals and Program Direction for FY 1981 Page 30
High!ights
#7 Develop a State hazardous waste program, with the Page 33
assistance of U.S. EPA, which is equivalent to the
Federal RCRA program.
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#8 Develop an interagency strategy for coordinated Page 36
dealing with toxic chemical contamination events.
V. MISCELLANEOUS
Overview Page 38
Highlights
#9 Provide for adequate laboratory capability to insure Page 39
the availability of acceptable analytical data
required to support new program efforts.
#10 Allow for more meaningful State input into U.S. EPA's Page 41
development and initiation of new program activities
and directions.
#11 Provide for more efficient oversight of federally Page 43
funded State pollution control programs and delegations.
VI. APPENDICES Page '45
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I. INTRODUCTION
Federal Fiscal Year 1981 marks the second year in the evolution of the
State/EPA Agreement (SEA) in Illinois. This Agreement is intended to be a key
management tool which top managers in the U.S. Environmental Protection Agency
(U.S. EPA) and the Illinois Environmental Protection Agency (IEPA) can use to
focus attention on priority activities and problems. The goal of the SEA
process is to maximize the use of available resources to solve priority envi-
ronmental problems.
The issues which are highlighted in this SEA document are issues determined
to need special priority attention from a program and funding standpoint in FY
1981. Other priority issues, which were identified in the SEA process and are
earmarked for priority funding, are described in the media goals and direction
statements of this document and in the lEPA's FY 1981 program work plans which
are appended to this document by reference.
In delineating Federal and State roles under the Safe Drinking Water Act
(SDWA), the Resource Conservation and Recovery Act (PXRA), the Clean Water Act
(CWA), the Clean Air Act (CAA) and other environmental legislation, Congress
clearly envisioned a Federal/State partnership. The State/EPA Agreement process,
which addresses the above legislation, attempts to make that partnership rea^.
by encouraging the States and the U.S. EPA to negotiate their priorities in
order to maximize the use of available resources.
The SEA development process for FY 1981, in the State of Illinois, began
in January 1980, with the publication of a special issue of Environment Midwest-
U.S. EPA's monthly magazine. This publication described the main issues high-
lighted in the FY 1980 SEAs, explained the process for FY 1981 and solicited
citizen input on issues to be considered as highlights in the FY 1981 SEA
agreement or to be addressed in the appropriate FY 1981 IEPA program work plans.
All public input was considered when developing program strategies for the
coming year and identifying specific issues to be highlighted in the SEA docu-
ment. All of the media specific issues selected as highlights for FY 1981
relate to issues raised by the public in this initial input. Many other issues
raised in this process are addressed in the Illinois EPA's FY 1981 pollution
control work programs, which are appended by reference to this document. There
were a few additional issues raised which do not appear in either the SEA or
the program work programs since they concern issues not under the perview of
U.S. EPA or IEPA.
In March 1980, U.S. EPA and IEPA exchanged lists of issues, covering the
air, water and hazardous/land media, to be given special attention in the
coming year. A negotiation session between U.S. EPA and IEPA in early April
resulted in the selection of those issues to be highlighted in the FY 1981 SEA
document. Others were selected to be addressed in the detailed work programs.
Extensive effort was put into developing problem solving approaches for address-
ing these issues, taking long range goals, available information, and current
resources into consideration.
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This SEA document contains the fruits of the months of discussion and
negotiation between U.S. EPA and IEPA. It is divided into four main sections
— Air, Water, Hazardous Materials, and Miscellaneous issues. Each section,
with the exception of Miscellaneous, contains a broad statement of the overall
goals of that specific media program along with a description of those issues
in Illinois, related to that medium, which need attention in FY 1981. Certain
of these issues have been selected to be given special attention by being
highlighted in the SEA document. Each highlighted issue is accompanied by a
Problem Solving Approach (PSA) which outlines the actions to be taken by U.S.
EPA and IEPA during FY 1981 to deal with this problem. The SEA document is
completed by a list of pertinent back-up materials which are appended to the
document by reference. These materials are available for review in the U.S.
EPA or IEPA offices.
The award of federal grant funds to help the State carry out its pollution
control programs is the final step in the SEA process. The following grant
amounts (estimates) will be made available to the IEPA to support the efforts
outlined in this agreement and the FY 1981 work programs which are appended.
- Clean Water Act
Sections 106 $1,831,000 *.
2D5(g) $3,483,200 (FY'80 funds)
208 $403,000*
314 Fund availability will be identified
in FY'81.
- Clean Air Act
Section 105 $3,532,300
- Safe Drinking Water Act
Section 1443 (a)(l) $1,047,000
Section 1443 (b)(l) $145,600
- Resource Conservation and Recovery Act
Subtitle C Section 3011 $1,403,400
Subtitle D Section 4007-8 $410,720
- Toxic Substances Control Act
Section 28 Grant application is being reviewed by
headquarters. No decision yet on funding.
*Still in negotiation.
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In addition to funding the above grant programs operated by the IEPA, U.S.
EPA will provide the following amounts (estimates) to local/regional units of
government during FY 1981 to assist in the State's pollution control efforts.
- Clean Water Act, Section 208
1) Northeastern Illinois Regional Planning Commission $282,500*
2) Southwestern Illinois Metropolitan and Regional $153,337*
Planning Commission
3) Great Egypt Regional Planning and Development $112,500*
Commission
- Clean Air Act, Section 105
**1) City of Chicago, Department of Consumer Services
**2) Cook County, Department of Environmental Control
**3) Granite City, Pollution Control Agency
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* Amount still in negotiation
** $1,184,000 (Total amount available, individual amounts not yet negotiated.)
II. WATER QUALITY GOALS AND PROGRAM DIRECTION FOR FY T 981
The quality of our State's waters affects us all in many ways. As individ-
uals we rely on supplies of fresh water (surface and/or ground water) as our
source of water for drinking, other daily needs, as well as recreational activi-
ties. Industry also relies upon this water as a basic resource necessary for
many production activities. In an attempt to control the quality of our surface
and groundwater resources Congress passed two major pieces of legislation in
the 1970s. The Clean Water Act (CVJA), passed in 1972 and amended in 1977, and
the Safe Drinking Water Act, passed in 1974 and amended in 1977.
A. The Federal Water Pollution Control Act (FWPCA) Amendments of 1972
(P.L. 92-500) and the subsequent Clean Water Act (CWA) of 1977 (P.L. 95-217)
constitute tv/o of the most complex and far-reaching pieces of environmental
legislation to emerge from the U.S. Congress. They establish highly inter-
related programs for setting water quality goals and standards, planning and
constructing wastewater treatment facilities, awarding grants for design and
construction of municipal sewage facilities, issuing permits for wastewater
discharges and enforcement of the terms of these permits as necessary, and
evaluating effects of diffuse nonpoint sources of water pollution and developing
remedial programs.
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The primary objective of the Clean Water Act Amendments of 1977 is
to "restore and maintain the cherrical, physical, and biological integrity of
the Nation's waters." To achieve this end the CWA set two national goals that
(1) wherever attainable, water quality which provides for the protection and
propogation of fish, shellfish, and wildlife and provides for recreation in
and on the water be achieved by July 1, 1983; and, (2) the discharge of pollu-
tants into the navigable waters be eliminated by 1985.
In attempting to meet the goals of the CWA the U.S. Environmental
Protection Agency (U.S. EPA) and the Illinois Environmental Protection Agency
(IEPA) have been working together in a number of program areas. These programs
can be divided into four main categories. Those related to (1) planning for
the proper management of our water quality resources; (2) management of a
grants program to provide for adequate sewage treatment plant capability; (3)
permitting of sources which discharge into our waterways and enforcement
against violators; and (4) monitoring of the quality of our waterways and the
discharges going into them.
During FY 1981 special priority emphasis will be given to certain
activities in each of these general program areas described below:
1. Water Quality Management Planning
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In order to provide a mechanism for integrating all of the water
pollution control related activities into a well coordinated overall program,
Congress stipulated, in Section 303(e) of the Clean Water Act that each state
should maintain a "Continuing Planning Process" (CPP) for establishing and
implementing the State's water quality standards. Section 208 of the CWA also
calls for the development and carrying out of areawide water quality management
plans to control point and nonpoint sources of pollution into our waterways so
that the water quality standards can be maintained.
The water quality management plans for the three designated
areas of Illinois Northeastern Illinois Planning Commission, (NIPC), South-
western Illinois Metropolitan and Regional Planning Commission (SIMAPC), Greater
Egypt Regional Planning and Development Commission (GERPXDC) and the non-
designated portion of the State have been completed. The State's plan and the
NIPC and SIMAPC plans have been certified by the Governor and approved by U.S.
EPA. GERP&DC is undergoing review by IEPA and Region V.
It is now time to refine and begin to implement the solutions
to the water quality problems identified in the initial planning process,
Implementatation, tracking and evaluation of the plans is required in Illinois
in order to keep management, planning and implementation moving in the right
direction and to assess progress in meeting the desired water quality objectives
within the State. Planning efforts will continue to address sources of pollu-
tion not adequately considered in the initial planning programs.
During FY 1981 the designated 208 agencies will continue to
implement their plans, which have been certified and conditionally approved.
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Obtaining adequate funding from local sources to support these activities will
require aggressive planning on the part of the designated agencies.
The water quality management plan for the non-designated portion
of Illinois identified nonpoint source pollution, particularly agricultural
erosion, as a significant contributor to the water quality problems in that
area.
Following additional refinement of the assessment of water
quality impacts and causes, IEPA will narrow and tailor the long list of Rest
Management Practices (BMP) for control of the nonpoint sources of pollution to
fit the particular needs of the affected river basins or segments. Additionally,
in FY 1981 Illinois will develop a priority system for ranking Rural Clean Water
Program projects and other BMP initiatives.,
During FY 1981 revisions are also needed in the State's Continu-
ing Planning Process (CPP) so that it clearly reflects current programmatic
priorities and directions.
Illinois will also be planning for the protection of its pre-
cious groundwater sources during FY 1981. The State of Illinois currently
does not have a unified policy for protection of groundwater resources through-
out the State. Responsibility for groundwater is currently shared by several*
State agencies. During FY 1981 IEPA will be taking the lead to develop a com-
prehensive groundv/ater strategy which will outline the mechanisms to approach
and solve the State's groundwater contamination problems. As part of this
groundwater effort Illinois EPA will make application to assume the primary
enforcement responsibility for the Underground Injection Control Program (DIG),
which is mandated by the Safe Drinking Water Act. This high priority issue
v/as selected to be highlighted in this SEA document. Additional detail on the
scope of this effort and appropriate milestones can be found on page 11.
2. Municipal Facilities/Construction Grants
One of U.S. EPA's major goals is to reduce the pollutants
discharged into waters from municipal wastewater treatment plants and to
eliminate all untreated discharges. To aid in the control of this type munici-
pal pollution U.S. EPA has been assisting communities by making grant funds
available for the planning and construction of sewage treatment facilities.
The operation of this grant program has been delegated to the IEPA.
The Clean Water Act amendments of 1977 provided a great number
of amendments to the process for the planning of municipal sev/age treatment
facilites, all of which are essential for project quality and proper environ-
mental management. Full implementation of these amendments will reap major
environmental benefits, in terms of more efficient use of technology, use of
innovative and alternative technology approaches, water and energy conservation,
reuse of sludge and wastewater, cost savings to small communities, and prevention
of urban sprawl. The environmental review process, including the Environmental
Inventory, Mid-Course Facility Plan Peview and the Environmental Assessment,
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has been established as a critical element in the Facility Plan Review process.
The management of this process continues to be an important priority for FY 1981,
Substantial progress has been made in the State's management of
this grant program through the implementation of the State Management Assistance
Program (SWAP). State resources funded under Section 205(g) have significantly
increased available personnel. In order to optimize the use of available
resources, U.S. EPA, Region V, will maximize the contribution of Regional
resources as well as available personnel from the U.S. Army Corps of Engineers
(COE) to complement State personnel. The top priority for Regional personnel
will be SMAP review, evaluation and feedback, while the COE will provide a
Step 3 assistance function in the State's management of the program. Through
the regularly scheduled delegation reviews, Region V has commented on the
details of the State's review process. In general, the results have indicated
that the project reviews being conducted by the State under delegation are
acceptable.
3. Water Quality Permitting and Enforcement
In order to meet the 1983 goals for improved water quality
U.S. EPA and IEPA have worked to implement the National Pollutant discharge
Elimination System (NPDES) which requires permits for all point sources which,
discharge into our waterways. Point sources are industrial facilities and
municipal wastewater treatment plants which discharge pollutants directly into
the water through pipes and channels. NPDES permits regulate what may be dis-
charged and how much. The permit commits a discharger to reduce or eliminate
his discharges in an orderly fashion. These permit commitments are legally
enforceable.
The permit system also requires dischargers to monitor their
wastes and to report the amount and nature of all waste components. The
State maintains a list of Major Dischargers which prioritizes dischargers
for compliance tracking and possible follow-up enforcement activities. In the
past, major dischargers have been determined soley by size. In FY 1981 pilot
efforts will be undertaken to develop a list which takes the degree of the
problem caused by the discharger into consideration, as well as the size,
v/hen identifying the sources to be included on the Major Discharger's List.
During FY 1931, IEPA will pursue legislative authority to use
general permits, which are permits issued on an areawide basis to certain
categories of dischargers. Some of the categories include: municipally owned
sewage lagoons of less than 2,500 P.E. capacity, all dischargers less than
1,500 gallons per day, which discharge only domestic wastes, sand and gravel
operations which have only run-off discharges, small POTW mechanical plants,
and non-contact cooling v/aters.
In FY 1981 increased emphasis is being put on the control of
discharges of toxicants into surface waters. The Clean Water Act amendments
of 1977 increased the emphasis on the control of toxic pollutants. The States
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and U.S. EPA have a responsibility to protect the public from exposure to
dangerous pollutants by controlling the discharge of toxicants into the environ-
ment. Each year vast quantities of toxicants are generated which enter the
environment. Discharge of toxicants to our waterways directly affect drinking
water supplies, cause fish kills and degrade water quality for other important
uses. Indirect discharges cause upsets in sewage treatment plant operation,
water quality standards violations, render municipal sewage sludge unuseable
for land application and also can contribute to ambient air standard violations.
The number of identified potential adverse health effects from
environmental exposure to toxic chemicals is increasing. Since a large number
of chemical manufacturing sites and a significantly larger number of chemical
processors and user sites are located in Illinois, it is obvious why special
attention is being given to controlling the discharge of toxics into our water-
ways.
In FY 1981 IEPA will develop a strategy and schedule to reissue
effective NPOES permits that emphasize the control of toxicants to primary
industries, major Publically Owned Treatment Works (POTWs), Federal facilities
and major secondary industries. Control of toxicants will also be affected by
Illinois' acceptance of the delegation of the pretreatment program which
seeks to: (1) prevent the introduction of pollutants into POTWs which will ^
interfere with the operation of the POTW or contaminate the sewage sludge; (2")
prevent the introduction of pollutants into POTWs which will pass through the
treatment v/orks into receiving waters or the atmosphere or otherwise be incom-
patible with the work; and (3) improve opportunities to recycle and reclaim
wastewaters and the sludges resulting from wastewater treatment.
The need to control the discharge of toxic substances, primarily
from industrial sources, to surface waters of Illinois in order to protect
human health and improve the quality of these waters has been selected as an
issue to be highlighted in the SEA. Specific details of the activities to be
taken by U.S. EPA and IEPA to address this issue can be found on page 13.
Special emphasis in FY 1981 will also be placed on activities
aimed at increasing the municipal dischargers rate of compliance with permit
requirements. Currently only a little more than one-half percent of the muni-
cipal pernitees in Illinois are meeting their permit requirements. This
issue has also been selected as one to be highlighted in this SEA document.
The joint U.S. EPA/IEPA efforts which will be undertaken in this area are
described in detail on page 16, and will include the initiation of a review
of substantive issues regarding the National Municipal Policy and Strategy and
the implementation of a system to integrate the three major program activities
which relate to POTW/compliance, permits and pretreatment, construction grants
and enforcement.
A high priority effort is needed to continue the operation of
the compliance tracking and inspection program which will surface NPDES permit
violations for appropriate enforcement action.
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4. Water Quality Monitoring :
The intent of the water monitoring program is to provide pro-
gram managers with a valid data base which can aid them in their decision
making, and is responsive to their needs. A most pressing concern is assurance
of the protection of public health through control of toxic and hazardous
sources of pollutants, especially those which have the potential for adverse
impacts on public health.
lEPA's monitoring efforts will include compliance monitoring,
ambient monitoring, intensive surveys, toxic monitoring, biological monitoring,
ongoing Great Lakes monitoring, data interpretation and reporting, operation
and maintenance and training, emergency response and quality assurance. Specific
details on the IEPA monitoring efforts can be found in their FY 1981 Water
Pollution Control Program plan, referenced in the Appendix.
In order to be most useful the samples collected in these various
monitoring activities have to be analyzed in a quality controlled setting, in a
timely fashion. The lack of adequate analytical data is one of the most serious
obstacles facing environmental protection agencies (both federal and state)
in their attempt to properly assess environmental problems.
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New and emerging programs, such as hazardous toxic wastes,
require more complete and costly analytical procedures and equipment to provide
the data needed. It is therefore important to assess the capability and future
needs of the laboratories which will have to provide these services. For this
reason, the FY 1981 SEA includes a highlight issue which addresses the need to
assess Illinois' capability to provide the necessary analytical data, either
by its own laboratory, by contracting for laboratory services, or with the
help of U.S. EPA lab support. More detail on the problem solving approach
developed to address this issue can be found on page 39.
Quality controlled data obtained from the various State and
Federal monitoring activities is used to provide information on the current
status of v/ater quality so that it can be seen whether the quality has improved,
remained the same, or degraded. In some instances different agencies interpret
the same data in different ways, resulting in confusion over the actual water
quality. A standard, consistent type of v/ater quality index is needed in
order to show that we are accomplishing the national program for v/ater pollu-
tion control. During FY 1981 U.S. EPA will be working with the states in
Region V, including IEPA, to develop a consistent method for translating water
quality data into a meaningful index of water quality.
B. The Safe Drinking water Act of 1974 (SDWA) amends the Public Health
Service Act and is established to assure that the public is provided with safe
drinking v/ater. The Safe Drinking Water Act provides the legislative initiative
under which Primary and Secondary Drinking Vfater Regulations are promulgated
by EPA. These regulations which apply to water after treatment by all public
drinking water systems are standards of purity, established to protect the
public health. IEPA has assumed the management for the implementation and
enforcement of the public water system supervision program.
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The SDWA also (1) provides for the protection of underground sources
of drinking water, (2) assures that there will be adequate supplies of chemi-
cals needed to treat public water systems, and (3) establishes the National
Drinking Water Advisory Council to make recommendations to the EPA about matters
relating to this act.
The Safe Drinking Water Act marks the first time a truly national
commitment was made to safeguard public drinking water supplies. The drinking
water supplied to most American homes today is generally considered safe.
However, at least 4,000 known cases of waterborne illnesses occur each year in
this country. The actual total may be ten times greater. Further, medical
science has not yet determined the effects on people of long-term, low-level
exposure to contaminated drinking water. The Nation's water supplies are
also being threatened by careless use of hundreds of chemical compounds and
the improper disposal of toxic wastes.
The Interim Primary Drinking Water Regulations, established under
the SDWA, require all public water systems to regularly monitor their v/ater
for various health-related contaminants, and to maintain concentration of
these contaminants below specified levels, called maximum contaminant levels,
or MCL's. The top priority for the Illinois Public Water System Supervision
Program in FY 1981 is to assure that the community public water systems in ^
Illinois are substantially in compliance with these regulations.
In Illinois 52 community v/ater systems are known to exceed a chemi-
cal MCL -43 fluoride, 9 barium — and approximately 75 systems are suspected
of violating the MCL for radium. It should be noted that the radium violations,
most of which are found in the northeastern part of Illinois, to the best of our
knowledge are due to naturally occurring radioactivity in the areas geological
formations. There were also a large number of bacterial MCL violations identi-
fied in Illinois during FY 1979. Bacterial contamination is usually transitory
in nature, and normally poses a less severe long term or chronic health hazard
than chemical or radiological contamination; however, if the safety of drinking
water is to be better assured, the number of bacterial violations must be
significantly reduced, and the public nust be made aware of the violations
which do occur. Illinois will be ensuring that all monitored violations at
community systems will be followed up with the required public notices.
Another major concern this year is the presence of trihalomethanes
in drinking v/ater. Regulations governing monitoring and MCL requirements
for trihalomethane will begin to take effect in November, 1980. IEPA, however,
has already begun to monitor v/ater systems that serve over 10,000 people, for
the presence of trihal omethane violations.
U.S. EPA has determined that injestion of these synthetic organic
chemicals, which are commonly formed when water is chlorinated, pose a risk to
human health.
During FY 1981 IEPA will work to bring the mobile home park program
up to par with the program for all other community water systems. Non-community
water supply systems' compliance with the drinking water regulations will also
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he emphasized. In Illinois the Illinois Department of Public Health (IDPH) is
responsible for non-community supplies. IEPA has a cooperative agreement with
the IDPH v/hich outlines the work the IDPH will do in support of the IEPA
responsibilities assumed as a result of accepting delegation of primacy for
the public water system supervision program.
Probably the greatest overall problem with relation to public health
is the contamination of groundwater and surface-waters with toxic or carcino-
genic compounds. A source of groundwater contamination of significant concern
is the underground injection of fluids. Improper injection activities pose a
direct threat to groundwater. All States including Illinois, have potentially
large numbers of uncontrolled facilities, such as clandestine shallow injection
wells, drainage wells and abandoned wells, all of which may pose a potential
danger to underground sources of drinking water.
The abandoned wells will look particularly attractive as injection
sites as land disposal restrictions are tightened. The severity of the hazard
posed by these unsound practices is yet unknown. One thing is certain however,
that there is a strong link between the Resource Conservation and Recovery
Program (RCRA) and the Underground Injection Control (UIC) program, since
wastes that are being tracked under RCRA may find their ultimate destination
to be an injection well regulated under UIC. The necessity for coordination*.
and consistency between the two programs is critical, so that no loopholes
exist for the improper disposal of waste materials, whether it be above the
surface or below.
In an effort to protect underground sources of drinking water from
contamination, IEPA will be applying, in FY 1981, for primacy to operate the
Underground Injection Program (UIC). IEPA will also be developing a comprehen-
sive statewide strategy for groundwater protection which will outline the
mechanisms needed to approach and solve the State's groundwater contamination
problems. These groundwater protection activities were selected to be high-
lighted in this SEA document. Specific details can be found on page 11.
10
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HIGHLIGHT ISSUE #1
Develop a comprehensive strategy for groundwater protection in Illinois.
DISCUSSION
The State of Illinois does not currently have a unified policy for protection
of groundwater resources throughout the State. • Responsibility for ground-
water is currently shared by several State agencies, fostering a fragmented
and incomplete approach to groundwater protection.
This highlight acknowledges the need to expand upon and meld the various ground-
water protection components, ensuring consistency with requirements established
under the Safe Drinking Water Act (SDWA), the Resource Conservation and Recovery
Act (RCRA), the Clean Water Act (CWA), and other Federal legislation.
The problem solving approach for this highlight should result in the completion
of a comprehensive strategy for groundwater protection in the State. This
strategy, which will be developed on an intermedia basis, should result in the
identification of aquifers to be protected, the sources to be controlled, the
methods for regulation, and a systematic approach for detection and resolution
of groundwater contamination cases. As a part of the groundwater strategy,.^
IEPA will develop a program for seeking and maintaining primacy enforcement
responsibility for the Underground Injection Control (UIC) program.
PROBLEM SOLVING APPROACH
1. Illinois' ground water task force composed of — Illinois State
Geological Survey, Illinois Department of Mines and Minerals, Illinois Depart-
ment of Public Health, Illinois Environmental Protection Agency, Illinois
Department of Agriculture, and Illinois Department of Transportation-Division
of Water Resources will meet by November 1, 1980, to establish coordination
channels and responsibilities relative to implementation of the various State
and Federal programs designed wholly, or in part, to protect groundwater.
2. The task force, under the leadership of the IEPA, will develop a compre-
hensive statewide groundwater protection strategy which will outline the mecha-
nisms to approach and solve the State's groundwater contamination problems.
The scope of work, to be completed by January 1, 1981, will include the following
items at a minimum:
A. Identification of existing programs that involve groundwater manage-
ment and an evaluation of their effectiveness at preventing or resolving ground-
water pollution problems, by January 1, 1981.
B. Identification of necessary intensive investigations to document
specific problems and solutions by March 1, 1981.
C. Compile a statewide inventory and assessment of available hydro-
geologic information and prioritize additional data needs by July 1, 1981.
11
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This should Include projects currently and previously developed under the CWA,
SDWA, PsCRA, etc.
D. Development of a comprehensive list of known or suspected areas of
groundwater contamination by August 1, 1981.
E. Development of a prioritization and prioritize the list (See D
above) to identify the most important groundwater contamination problems by
area and by source. This should be completed by September 1, 1981.
F. Develop and conduct a public participation program.
G. Conduct a resource analysis to specify the comprehensive groundwater
management strategy that can be accomplished within the existing resources and
programs; and identify additional legislative, programmatic and resource needs
that would improve groundwater protection. Prioritize the identified additional
needs. These efforts are expected to be completed during the first quarter of
FY 1982 (October - December, 1981).
3. Illinois will assume primary enforcement responsibility (primacy) for
the Underground Injection Control (UIC) program by July, 1981, provided the
State's financial resources are sufficient. Information developed by this *^
program will be used in defining additional data needs in the comprehensive
strategy document.
4. Illinois will prepare the following:
A. A first year status report by September 30, 1981
B. A final comprehensive strategy for groundwater protection in Illinois
by December 31, 1981 (FY 1982)
RESOURCES
Section 208 grant, Clean Water Act; UIC grant; Section 1443, Safe Drinking
Water Act; State funds.
Responsible Program Managers/Staff Contacts:
U.S. EPA: Joseph Harrison, Michael Phillips
IEPA: John Moore
12
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HIGHLIGHT ISSUE #2
Control the discharge of toxic substances, primarily from industrial sources,
to the surface waters of Illinois.
DISCUSSION:
The Clean Water Act of 1977 directed U.S. EPA and Illinois EPA to focus special
attention on the control of toxicants which may cause harm to human health or
the environment. Progress needs to focus on directing attention to the control
of toxicants in the NPDES permit program and supporting surveillance and
other activities. Illinois and Region V have in FY '80 started to consider
toxicant monitoring and limitations in NPDES permits. Work also commenced to
increase and integrate toxicant surveillance activities into the permit activi-
ties. Illinois and U.S. EPA agree to jointly work to resolve the prioritized
implementation of this program issue to control toxicants of national and
local concern.
The toxic substance control program is primarily in the problem assessment
stage in Illinois. The major emphasis of the program involves efforts by both
the State and U.S. EPA along with special monitoring and evaluations by select
industries. The general program contains: ^
1. The implementation of existing or, where needed, development of reliable
and accurate methods for measuring the level of toxic substances in the environ-
ment either directly by chemical analysis or indirectly by examining the toxic
impact on indicator organisms, and
2. Development of appropriate and enforceable monitoring requirements and
limitations for toxic substances believed to be a problem in Illinois or down-
stream waters.
To supplement existing monitoring procedures for conventional and toxicant
pollutants, the IEPA has developed specialized equipment for collection of
water samples which will be subjected to analysis for organic compounds present
at trace levels. IEPA is also developing a comprehensive, statistically-based
quality control program.
IEPA has proposed two related efforts to U.S. EPA for funding under Section 28
of TSCA. The major effort is an epidemiological investigation of excess cancer
rates in certain parts of Illinois. The second effort is measuring the uptake
and excretion in mammals of compounds, specifically (at this time), phenols
identified in Illinois waters. This work will extend to similar studies of
pollutants identified in the epidemiology study. A specific objective of the
uptake v/ork is to validate a model which relates the uptake in mammals to the
potential uptake in humans. Implementation of these two programs is contingent
upon receiving Federal funding under Section 28 of TSCA.
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PROBLEM SOLVING APPROACH
1. In order to establish priorities for staff effort and U.S. EPA overview,
the IEPA will have completed prior to FY 1981 a draft listing of those industrial
facilities that: (1) have the highest potential for the discharge of toxicants;
and, (2) should be evaluated as to the need to conduct process evaluations.
The basis for this listing will be U.S. EPA's list of October, 1977, Illinois
EPA's list of June, 1979, and U.S. EPA's NEIC SIC code categories IV-VI. U.S.
EPA will have reviewed and provided comments on the listing within 30 days of
receipt. Within an additional 30 days IEPA and U.S. EPA staff will jointly
agree upon a priority listing.
2. During FY 1981, IEPA will monitor at least 8 municipalities for the
pr°^ence of toxic pollutants as well as several public water supplies and
incustrial sites in conjunction with the instream bioassay work.
3. By December, 1980, the State will develop a fish and other tissue
broad chemical analyses program as part of an ongoing toxicant surveillance
support program. U.S. EPA has provided laboratory analyses for limited State
collected fish in FY '79 and part of FY '80. Additional special Federal fund-
ing is not available for non-Great Lakes waters so the State needs to integrate
the continuation of this high priority work into their ongoing program. They.
will do this as resources can be made available. This program is to be imple-
mented in spring-summer 1981.
4. By December, 1980, U.S. EPA, Region V, will develop and begin to imple-
ment a plan to work with other U.S. EPA organizations such as Effluent Guide-
lines, Research and Development, etc., to obtain industrial toxicant data
within the Federal system that would be of use to the State in its toxicant
control effort. (An example is the ongoing ORD analyses of Effluent Guidelines
industrial samples for additional toxicants beyond the 129 priority pollutants.)
EPA will also seek to obtain technical assistance, including technical expert
witnesses, needed by the State. A progress report will be prepared by April,
1981.
5. IEPA and U.S. EPA, Reagion V, will jointly agree upon a pretreatment
program which meets at least the minimum national requirements, as well as
addresses specific State concerns, by November, 1980. Programmatic considera-
tions will be based upon technical data obtained from the statewide industrial
survey and the nation-wide study of POTW effluents due to be comleted in the
fall of 1980.
6. By November, 1980, IEPA will have incorporated pretreatnent compliance
schedules into 80 percent of all applicable major permits. By the end of
December, 1980, IEPA and U.S. EPA will agree on a strategy for addressing the
remaining 20 percent of all applicable permits.
7. By November 1, 1980, IEPA and U.S. EPA permits, construction grants
and surveillance staff will agree on criteria for the creation of regional
laboratory facilities with GC-MS or similar capabilities and will identify
candidate POTWs for regional laboratories v/here possible.
14
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8. Throughout FY 1981 IEPA will provide guidance to and work with POTWs in
developing and implementing their pretreatment programs. This work will receive
high priority for all of FY 1981.
9. Throughout FY 1981, IEPA will review pretreatment elements, submitted
by municipal grantees, which will allow the processing of Step 2 and Step 3
construction grants per the requirements of 40 CFR 35.920 3(b)(9) and 3(c)(4),
or as otherwise required by applicable NPDES permits.
RESOURCES
Sections 106 and 208 grants, Clean V.'ater Act; State funds.
Responsible Program Managers/Staff Contacts:
U.S. EPA: Dale Bryson, Glenn Pratt, James Hanlon
IEPA: Roger Kanerva
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HIGHLIGHT ISSUE #3
Increase the rate of Publicly Owned Treatment Vlorks (POTWs) compliance with
the requirements of the Clean Water Act.
DISCUSSION:
Publicly Owned Treatment Works (POTWs) treat wa&tewater from our homes, busi-
nesses, schools, etc. One of U.S. EPA's major goals is to reduce the pollutants
discharged into our waters from POTWs and to eliminate all untreated discharges.
The POTWs are granted National Pollutant Discharge Elimination System (NPDES)
permits which regulate what and how much may be discharged. A permit commits
the discharger to reduce or eliminate the discharges in an orderly fashion.
Currently only a little more than one-half the major municipal permitees in
Illinois are meeting their permit requirements and schedules. Improvement of
compliance in many cases requires completion of the construction already funded
or funding for the initiation of construction.
During the coming year U.S. EPA and IEPA will be reviewing the National Municipal
Policy and Strategy and will be coordinating the activities of the three major
water programs that relate to the control of municipal point source discharges:
construction grants, permits and pretreatment, and enforcement. These efforts
should alleviate some of the inconsistencies apparent in past dealings with
municipalities and should provide for a more efficient attack on the sources
of municipal pollution.
PROBLEM SOLVING APPROACH:
1. A task force of IEPA and U.S. EPA upper level staff members will address
the substantive issues regarding the National Municipal Policy and Strategy
which were raised by the State in the negotiation of the April 22, 1980,
Advanced V/aste Treatment (AWT) Settlement Agreement. The task force will
identify where amendments are necessary to promote a more workable policy and
will produce a draft amended policy by December 31, 1980. Concurrence in the
amended policy will be sought from U.S. EPA Headquarters by April 30, 1981.
2. IEPA will implement a system to coordinate the three major water pro-
grams of permits (including pretreatment), construction grants, and enforcement
which stresses accountability but retains flexibility. The system will be a
written procedure which reflects the substance of the U.S. EPA's Municipal
Management System yet is in a form most useful for IEPA. The written system
is expected to be in place by October 1, 1980, at which time a "shake down"
period will begin. By December 31, 1980, an evaluation of the system's effec-
tiveness will be made and any necessary changes will be made by March 31,
1981.
3. IEPA will upgrade the quality of the Operation and Management (O&M)
manuals required in the construction grant program in order to improve their
usefulness, by May 1, 1981. U.S. EPA will provide technical assistance as
requested by the State.
16
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4. IEPA will complete a draft assessment of operator manpower and training
requirements to assure the availability of the necessary skilled personnel to
operate the POTWs by March 31, 1981. A complete assessment will be finished
by September 3, 1981.
5. U.S. EPA and IEPA will work to evaluate treatment technology in order
to reach an understanding of the technology needed to reach Advanced Secondary
Treatment (AST) and Advanced Waste Treatment (AWT) effluent limitations. It
is anticipated that mutual agreement on this issue can be reached by December
31, 1980.
RESOURCES:
Section 106 grant, Clean Water Act; Section 205(g), Clean Water Act; State funds,
Responsible Program Managers/Staff Contacts:
U.S. EPA: John Kelley, Charles Sutfin, James Hani on
Ken Fenner, Arnold Leder
IEPA: Roger Kanerva
'•* -.
17
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III. AIR GOALS AND PROGRAM DIRECTION FOR FY 1981
The atmosphere has never been completely pure. It always contains contami-
nants from windblown dust, forest and range fires, gases emitted by organic
decay, and other natural sources. But man-made contaminants have contributed
thousands of tons per day from industrial smokestacks, automotive exhausts,
waste incineration, fertilizer and pesticide applications, aerosol sprays, and
innumerable other sources.
In sufficient concentrations, airborne pollutants increase the incidents of
respiratory and heart diseases and can increase fatality rates. Acid and
corrosive rains from an atmosphere polluted by sources hundreds or even thou-
sands of miles away can damage our property and have adverse effects on our
food and water supplies. The effects of unchecked air pollution are a clear
and present threat to the public health and economic vitality of our region,
our nation, and the entire world.
In order to accelerate the program of air pollution control and abatement,
Congress passed the Clean Air Act (CAA) in 1970. The CAA directed U.S. EPA to
develop and achieve acceptable air quality standards. Primary National Ambient
Air Quality Standards (NAAQs) were set to provide for the protection of health.
Secondary standards were set for the protection of welfare, which in the wor.ds
of the Act, "included, but was not limited to, effects on soils, water, crops",
vegetation, manmade materials, animals, wildlife, weather, visibility, and
climate, damage to and deterioration of property and hazards to transportation,
as well as effects on economic values and on personal comfort and well being."
Pollutants for which NAAQS have been established may be referred to as "criteria
pollutants." Criteria air pollutants are those substances in the air which
are reasonably anticipated to endanger public health or v/elfare and which are
released into the air by numerous or diverse sources. The NAAQS promulgated
under the CAA address particulate matter, sulfur dioxide, carbon monoxide,
photochemical oxidants, hydrocarbons, and nitrogen dioxide. A primary standard
for lead was added in 1978, and the standards for photochemical oxidants were
amended in 1979. Other standards are currently under review by U.S. EPA and
decisions on the appropriate levels of protection will be made over the next
few years.
In addition to providing for health related standards, the law also laid the
foundation for a strong, cooperative Federal-State program to clean-up the
Nation's air. In response to the standards Illinois prepared a State Implemen-
tation Plan (SIP) which defined the process by which the air pollution standards
would be met in Illinois. The original Illinois SIP v/as submitted to the U.S.
EPA in 1972. Air quality improved as a result of this plan but the improvements
fell short of the goals in many areas of the State. This was the case in most
areas of the country. Therefore, Congress found that changes were needed to
bring the CAA up-to-date -- to better cope with the realities and the problems
encountered in implementing the 1970 law.
18
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The result of the congressional reappraisal was enactment of the Clean Air
Act Amendments of 1977. These new amendments required the States to update
their SIPs. The revised SIP describes measures that will be implemented in
Illinois to provide for the attainment of the primary National Ambient Air
Quality Standards for sulfur dioxide (S02), participates (TSP and oxides of
nitrogen (MQX) by December 31, 1982; and for the attainment of the ozone (03)
and carbon monoxide (CO) standards by December 31, 1987, in those areas unable
to meet the December 31, 1982 date. The main portion of the revised Illinois
SIP was conditionally approved by U.S. EPA in February 1980. A notice of
proposed rulemaking on that portion of the SIP which addressed the control of
particulates in those non-atttainment areas where the problem is caused by
iron and steel industries was published in the Federal Register on July 31,
1980.
r
The SIP addresses the control of pollution from two major categories of
sources -- Mobile and Stationary. Mobile sources, cars and trucks, account
for virtually all of the carbon monoxide related air quality problems in our
urban centers and are major contributors to the areawide ozone nonattainment
problem. In Illinois, Cook, DuPage, Kane, Lake, McHenry and Will counties are
not attaining the carbon monoxide standards, or the ozone (03) standards.
Madison and St. Clair counties are classified as non-attainment for ozone.
An extension has been granted, until 1987, to allow these counties to attain--*.
these standards.
Programs to reduce emissions from mobile sources include the imposition of
the Federal motor vehicle emission standards on new autos, State development
of auto inspection/maintenance programs for the Chicago and East St. Louis
metropolitan areas, efforts to hold down fuel switching and tampering, and
the development of transportation systems management, all of which are included
in the Illinois SIP.
There are approximately 1326 major sources of air emissions in Illinois.
The recently revised SIP established new requirements for some additional
sources and tightens requirements for many sources which are presently in
compliance.
Sources which emit hydrocarbons are expected to be most significantly affected
by changes in the revised SIP. Efforts to control S02 and TSP will be directed
tov/ard power plants and iron and steel making facilities. The S0£ and TSP
NAAQS are currently being reviewed by U.S. EPA.
The primary goal of the joint Illinois-U.S. EPA air pollution control program
in the State is the protection of the health of Illinois' 11 million citizens.
Over 9 million people in Illinois live in areas that exceed the health-related
Federal air quality standard for ozone. Most of these people live in the
Chicago and the Illinois portion of the St. Louis metropolitan areas. More
than 4 million people live in areas which do not meet the National Ambient Air
Quality Standards for particulates. The priority air quality goals identified
for FY 1981 in Illinois are the reduction of the number of people exposed to
unhealthy levels of ozone (03) and Total Suspended Particulates (TSP). These
two issues have been selected as Highlight issues (Highlights #4 and #5) and
additional details can be found on pages 24-27.
19
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Activities to be undertaken in FY 1981 to address the ozone and TSP problem
can be divided into four major areas:
1. Air Quality Monitoring and Analysis
Air quality monitoring provides the underlying basis for determining an
areas attainment status and for analyzing trends in ambient air quality. There
are 55 national air monitoring systems (NAMS) sites and 160 State and local
monitoring systems (SLAMS) sites in Illinois. The acquisition and analysis of
quality assured data from these stations will be a major task in FY 1981.
Illinois will also be implementing the Pollution Standard Index (PSI) method
for reporting air quality information to the public in the Chicago and East
St. Louis areas in FY 1981. Both adequate monitoring and the public notifica-
tion programs are essential ingredients in achieving the ozone and TSP priority
air quality goals.
2. SIP Development
Several SIP development activities will be carried out by Illinois in
FY 1981. They include: working toward the development of the 1982 ozone SIP
in accordance with their approved work/study plan which can be found in Illinois'
FY 1981 air pollution control work program; developing further stationary *.
source hydrocarbon controls for additional industrial categories; working
toward the implementation of the auto inspection/maintenance program in the
Chicago and East St. Louis metropolitan areas; and, working on the development
of a lead SIP.
U.S. EPA and IEPA recognize that the SIP development/revision process
is very time-consuming. In an attempt to make this process more efficient it
v/as agreed to highlight the SIP revision process in this SEA document. In FY
1981 U.S. EPA and IEPA will work together to improve and simplify U.S. EPA's
rulemaking procedures with regard to Illinois submitted SIP revisions. Addi-
tional detail on this issue (Highlight =6) can be found on page 28.
3. Source Compliance and Enforcement
In Illinois, 95 percent of the najor emission sources are currently in
final compliance with emission requirements or on compliance schedules, which
will be completed prior to 1982. In FY 1981 a large number of additional
sources will become subject to new or tightened hydrocarbon control regulations.
This will result in an increase in source non-compliance and may necessitate
accelerated enforcement effort to insure achievement of the priority air quality
goal of reducing ambient ozone levels. Increased surveillance and the instal-
lation of in-stack monitoring in certain major sources will be key elements in
assuring that the TSP control equipment mandated for major sources of this
pollutant is maintained and operated to achieve design removal efficiencies
and thus will directly impact the achievement of the high priority air quality
goal related to particulates.
20
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4. New Source Review
All major new sources seeking to locate in Illinois in FY 1981 will be
subject to review under one of two sets of regulations. Prevention of signifi-
cant deterioration (PSD) regulations and the SIP govern in attainment areas.
The requirements of Section 173 of The Clean Air Act, including lowest achieva-
ble emission rate (LAER) and offsets, apply in the priority standard ozone and
TSP non-attainment areas. Insuring that all new major sources of these pollu-
tants that locate in nonattainment areas meet the requirements of Section 173
is vital to the achievement and maintenance of the ambient standards.
U.S. EPA has targeted Final Action of the applicable Illinois SIP New
Source Review (NSR) components for within 6 months after receipt of the final
Illinois submittal. (Submitted June 19, 1980)
For selected categories of new industrial plants and for those that are
substantially modified, the CAA mandates U.S. EPA set emission limits for
certain designated pollutants. These limits—called "new source performance
standards" (NSPS), not to be confused with the national ambient air quality
standards—are specific to each industry. U.S. EPA has set NSPS for 28 indus-
trial categories to date. They set the maximum amounts of each kind of pollu-
tant (Sf)2, TSP, HC, etc.) that can be emitted from that new plant's stacks •«.
for each unit of the plant's production. The limits are based on the best
engineering knowledge of the industry's processing methods.
IEPA has identified 48 facilities subject to NSPS. During FY 1981
IEPA will be inspecting each identified NSPS facility for compliance at least
two times a year, taking enforcement action where necessary. Determinations
will also be made as to which proposed sources will be covered by the NSPS.
Section 112 of the CAA requires the setting of standards, called
National Emission Standards for Hazardous Air Pollutants (MESHAP). Final
standards have been adopted for asbestos, beryTium, mercury and vinyl chloride.
A proposed standard for benzene has also been issued. IEPA has identified 35
facilities in Illinois which are subject to these standards and during FY
1981, IEPA will be continuing its efforts to inspect these sources, at least
four times per year, taking enforcement action as necessary. IEPA will also
be reviewing any plans for construction or modification of sources subject to
NESHAP.
In addition to the problems and activities previously mentioned, U.S. EPA
and IEPA will be directing some attention to areas which historically have
not been included in the basic pollution control efforts but are becoming
increasingly important. These include the problem of interstate air pol-
lution, the relationships between energy and air quality and the control of
toxicant emissions.
21
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1. Interstate Air Pollution
Interstate air pollution problems fall into three broad categories.
The first is the direct impact of emissions from a source in one State on the
attainment of an ambient air quality standard in an adjoining State. In addi-
tion to the obvious health implications of nonattainment the impacted State
must also concern itself with the the potential restriction of its economic
growth as a result of any resulting nonattainment designation. A subset of
this issue is the question of the setting of equitable emission limits for
sources whose emissions affect interstate air quality. While the Clean Air
Act does not require equality of emission limits, the U.S. EPA is concerned
that the consumption of available air quality within an interstate air shed
not be done in a discriminatory manner.
The long range transport of pollutants beyond the State in which they
originate will be an increasingly important issue in FY 1981. This issue has
special importance in Illinois because sources in the Midwest are believed to
contribute to the acid rain problem in the northeastern United States and
Canada. It is important to get more information on this question so that the
problem can be properly assessed and to begin to implement policies aimed at
addressing the problem.
One important factor which will become increasingly apparent is that
the U.S. EPA cannot itself solve many of these air quality related interstate
problems but instead must serve a facilitator role to aid the involved States
themselves in reaching solutions acceptable to all parties. Action to develop
interstate mechanisms to deal with these types of problems is already underway
and will continue to receive increased emphasis.
The second issue is associated with the development of new sources in
clean areas and the attendant consumption of the available air quality increment
under the prevention of significant deterioration regulations. The question
of how to allocate the available increment between States has already arisen
several times and will remain a significant cause of controversy into the
forseeable future. As one part of this effort Region V in cooperation with
other U.S. EPA Regions is to actively promote a dialogue between affected
States to aid in resolving these problems.
The third and more generalized concern is the long-range transport of
the precursors of ozone and acid rain.
2. Energy and Air Quality Relationships
The use of the Region's abundant reserves of high sulfur coal in an
environmentally sound manner is the single most important issue linking energy
and the environment in Illinois, as well as in Region V. Given the slow rate
of growth in electrical generating capacity and the continuing reluctance on
the part of the utility industry to retrofit sulfur dioxide control technology
(scrubbing) on existing generating capacity it does not appear that there will
be significant increases in the use of high sulfur coal in Illinois in FY 1981.
22
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U.S. EPA is exploring the opportuniiies that coal washing and other coal pre-
paration techniques may provide for increased high sulfur coal use under
current air quality requirements. It must be understood that burning high
sulfur coal and meeting environmental health related standards are not mutually
exclusive.
3. Toxicant Emissions
Recognition is given to the need to control hazardous air pollutants
in Section 112 of the Clean Air Act. However, to date only four National
Emission Standards for Hazardous Air Pollutants (NESKAPs) have been established
and therefore only a small fraction of the thousands of potential toxicants
which are emitted in a highly industrialized area such as Region V are subject
to the direct regulatory control of the Federal air quality program. Stationary
sources of the four designated NESHAPs pollutants (Asbestos, Mercury, Beryliurn
and Vinyl Chloride) have been identified in Region V. Virtually all of these
sources are in compliance with emission requirements and enforcement actions
are actively being pursued against all known violators.
A major challenge to the Region's air quality program is the need to
develop a strategy, in concert with State officials, to minimize the emission
of toxicants by agressively monitoring those source categories of particulata.
and hydrocarbon emissions which also are likely to be significant toxicant
sources. In addition, the setting of emission limits to meet the requirements
of Lowest Achievable Emission Rate (LAER), Best Available Control Technology
(BACT) or Reasonable Available Control Technology (RACT), should be done with
the full knowledge and active technical consideration on a case by case basis
of potential toxicant emissions.
Finally, non-regulatory measures to reduce toxicant emissions in advance
of the standard setting process should be developed.
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HIGHLIGHT ISSUE #4
Control/reduce excessive levels of Total Suspended Particulate (TSP) in South-
east Cook County.
DISCUSSION
More than 4 million people in Illinois live in areas which do not meet the
health based National Ambient Air Quality Standards for Total Suspended Parti-
culates (TSP). Most of these people are located in the southeastern portion
of Cook County, an area whose heavy industry contributes to this problem. TSP
is a measurement of particles in the air (such as soot, flyash and smoke) and
includes non-toxic materials (dust and dirt) as well as more toxic substances
(lead, asbestos, sulfates). Manmade sources contribute to TSP which can affect
our respiratory systems in varying degrees depending upon particle size and
chemical composition. During the coming year U.S. EPA and IEPA will be working
tov/ard reducing the levels of TSP in southeast Cook County.
PROBLEM SOLVING APPROACH
A. U.S. EPA/IEPA enforcement activities to address this problem will include:
^ m
1. U.S. EPA and IEPA recognize the need to install continuous monitors
in alt major stack sources emitting TSP in southeastern Cook County, except
those in which installation is impractical or those whose nature of operation
does not lend itself to continuous monitoring techniques. By mid-November
1980, U.S. EPA and IEPA will agree on a list of candidate sources which will
be required to install continuous monitors. U.S. EPA and IEPA will then agree
on a division of the sources identified and each agency will proceed with
requiring installation for their respective portion of the list.
2. IEPA will maintain a high rate of compliance inspections for major
sources of TSP in southeastern Cook County in accordance with the inspection
schedule contained in their approved FY 1981 air pollution control program plan.
3. U.S. EPA and IEPA will continue to coordinate enforcement action
strategies for major TSP sources in southeastern Cook County on a 4-week to
6-week basis throughout FY 1981.
4. U.S. EPA and IEPA will monitor and expedite, where possible, any
initiated enforcement actions taken against TSP sources in southeastern Cook
County. Any newly identified violators will receive prompt, appropriate action.
B. TSP State Implementation Plan SIP activities to address this problem:
1. IEPA will devote high priority management attention and appropriate
resources to achieve the TSP SIP schedule commitments and to complete the TSP
SIP related studies related to Cook County (SIP approval issues).
24
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2. IEPA will implement a program to assure that all new major TSP
sources In southeastern Cook County meet the requirements of Section 173 of
the Clean Air Act (New Source Review) upon final U.S. EPA approval of the
applicable Illinois SIP components. U.S. EPA Final Action on the Mew Source
Review SIP elements is targeted for within 6 months after receipt of final
Illinois submittal. (Submitted June 19, 1980)
C. Monitoring activities to address this problem:
1. IEPA will resolve any remaining problems involved in the imple-
mentation of the National Air Monitoring System (NAMS) in southeastern Cook
County.
2. IEPA will carry out any remaining activities necessary to implement
public reporting of the Pollution Standard Index in Chicago.
RESOURCES
Section 105 grant, Clean Air Act; State funds
Responsible Program Managers/Staff Contacts:
;* ^
U.S. EPA: David Kee, Tom Mateer, John Doolan, David Ullrich
IEPA: Dan Goodwin
25
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HIGHLIGHT ISSUE #5
Control/reduce excessive levels of ozone in the Chicago and East St. Louis
metropolitan areas.
DISCUSSION
Over nine million of Illinois' eleven million citizens live in areas that
exceed the health related Federal air quality standard for ozone (03). Most
of these people live in the Chicago metropolitan area and in the Illinois
portion of the St. Louis metropolitan area (East St. Louis). Ozone is the
principal constituent of modern smog and serves as an indicator of all the
other photochemical oxidants. It is a highly reactive form of oxygen that
irritates the mucous membranes of the breathing system, causing coughing and
impaired lung function. It aggravates chronic respiratory diseases like asthma
and bronchitis. All oxidants are formed by the chemical combination of nitrogen
oxides and hydrocarbons induced by sunlight. Emissions from motor vehicles
contribute heavily to this problem.
Illinois has been given until 1987 to meet the National Ambient Air Quality
Standard for ozone. During the coming year increased effort will be directed
toward trying to reduce the excessive levels of ozone in the Chicago and East.
St. Louis metropolitan areas.
PROBLEM SOLVING APPROACH
1. U.S. EPA and IEPA have agreed to the following schedule for reducing
hydrocarbon (HC) emissions in the Chicago and East St. Louis metropolitan
areas.
Objectives
A. IEPA will identify all major HC stationary emission sources and com-
pliance schedule date requirements, and provide information to U.S. EPA.
B. IEPA will establish a tracking mechanism with U.S. EPA assistance
to identify sources not meeting schedules.
C. IEPA and U.S. EPA will develop procedures to insure that action is
taken against violating sources promptly.
D. Insure high compliance rates by pursuing appropriate remedies for
all violations with IEPA in the lead.
Implementation Milestones
A. October 1, 1980 - Tracking procedure in place with all schedule
dates identified;
B. January 1, 1981 - All violators identified;
26
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C. April 1, 1981 - Enforcement action, as appropriate, commenced
against all violators within 3 months of identification.
2. IEPA will work toward the development of the 1982 ozone SIP in accord-
ance with their approved work/study plan which can be found in their approved
FY 1981 air pollution control work program.
3. IEPA will devote high priority management attention and appropriate
resources to resolve conditional ozone SIP approval issues.
4. IEPA will implement an Inspection/Maintenance program in accordance
with the federally approved SIP schedule, or an approved revision submitted
by the IEPA. (See FY 1981 air pollution control work program for additional
details.)
5. IEPA will implement a program to assure that all new major hydrocarbon
stationary sources in the Chicago and East St. Louis areas meet the requirements
of Section 173 of the Clean Air Act (New Source Review) upon final U.S. EPA
approval of the applicable Illinois SIP components. U.S. EPA approval of the
New Source Review SIP elements is targeted for within 6 months after receipt
of final Illinois submittal. (Submitted June 19, 1980)
6. IEPA will carry out any remaining activities necessary to implement "**
public reporting of the Pollution Standard Index in the Chicago and East St.
Louis areas.
RESOURCES
105 grant, Clean Air Act; 175 funding, Clean Air Act; State funds.
Responsible Program Managers/Staff Contacts:
U.S. EPA: David Kee, Tom Mateer, John Doolan, David Ullrich
IEPA: Dan Goodwin
27
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HIGHLIGHT ISSUE £6
Improve and simplify U.S. EPA rulemaking procedures with regard to Illinois
submitted SIP revisions.
DISCUSSION
The State Implementation Plan (SIP) for air pollution control is a complex,
technical blueprint for restoring and preserving a healthy atmospheric environ-
ment in Illinois. The SIP which is mandated by the Clean Air Act, defines the
process by which air pollution goals will be achieved, explains why certain
air pollution goals were selected over alternatives and describes the relation-
ships among the organizations involved in restoring and maintaining a healthy
environment in Illinois.
The Illinois SIP, which was recently revised to set emission limitations needed
to achieve attainment of the primary National Ambient Air Quality Standards
(NAAQS) by December 31, 1982, is a dynamic document. In order to insure that
additions to and modi fi cat "Tons of the SIP are approved as quickly as possible,
U.S. EPA and IEPA have agreed to work toward improving and simplifying U.S.
EPA's rulemaking procedures with regard to Illinois SIP revisions, during the
coming fiscal year. *.
PROBLEM SOLVING APPROACH
A. U.S. EPA agrees to process Illinois SIP revisions in the priority
order mutually agreed to by the IEPA and U.S. EPA and to honor IEPA requests
for expedited processing when special circumstances warrant.
B. U.S. EPA, Region V, will attempt to provide coordinated Agency input
into the Illinois SIP rulemaking process prior to final State action.
C. U.S. EPA and IEPA agree to jointly investigate possibilities for making
the total State/U.S. EPA SIP rulemaking process more efficient.
1. A work group to look into this problem will be named by U.S. EPA
and IEPA by November 1, 1980.
2. The work group will prepare a list of recommendations by February 1,
1981.
3. The recommendations will be forwarded to the appropriate parties.
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RESOURCES
105 grant funds, Clean Air Act; State funds.
Responsible Program Managerstaff Contacts:
U.S. EPA: David Kee, Gary Gulezian
IEPA: Dan Goodwin
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-.'ZAjrOUS WASTE GOALS AND PROGRAM DIRECTION for FY 1981
Hazardous wastes are unavoidable by-products of our technology which, if
improperly managed, can pose a serious threat to our health and the environment,
particularly since many of them are not readily neutralized or destroyed.
"Thasa wastes are generated by many segments of our society—industry, hospitals,
research laboratories, and all levels of government. For years the disposal
of hazardous wastes was largely unregulated, resulting in thousands of abandoned
and "Inactive disposal sites that now threaten to contaminate our air, water
and food supplies.
In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA)
in order to insure that hazardous wastes would be properly managed and would
be regulated from "cradle to the grave." One of the major goals of this legisla-
tion is to protect the public health and the environment from the mismanagement
of hazardous wastes during its generation, transport, treatment, storage and
disposal. Working toward the achievement of this goal has become one of U.S.
EPA, Region V's top priorities.
RCRA charged the U.S. EPA with the responsibility to implement and administer
the program, including the development of a regulatory framework to identify*.
hazardous wastes and properly manage their disposal. The first phase of U.S.
EPA's RCRA regulations were promulgated on February 26, 1980, and provided
standards for generators and transporters of hazardous waste under Sections
3002 and 3003 of RCRA. The main part of the RCRA Subtitle C regulations were
prcnulgated on May 19, 1980. These voluminous regulations contain the permit
procedures and guidelines for the approval of State hazardous waste programs
irnder Sections 3005 and 3006 of the Act. These regulations also provide the
first phase of the RCRA Section 3001 hazardous waste list and characterics and
the Section 3004 facility standards. U.S. EPA plans to amend its Sections
2001 and 3004 regulations later in 1980 to bring additional wastes into the
baza-dous waste management system and to add additional facility standards.
~hese regulations will become effective on November 19, 1980, and will create
s. rew framework which will fundamentally change the v/ays in which industry
r-.anages its wastes. These regulations are not the final solution to the problem
but just the first step toward preventing the creation of new hazards to the
public health and the environment.
A successful hazardous waste management program will take close cooperation
between the States and the Federal government. Illinois had been actively
pursuing a program to insure the proper management of hazardous wastes in the
State prior to the promulgation of the RCRA regulations. We are firmly com-
ritted to attain the primary goal of the joint State/ Federal hazardous waste
nsnagenent program in Illinois which is the protection of the environment and
the health of the State's 11 million citizens. A major hazardous waste goal
in Illinois in FY 1981 is the reduction of the number of people unnecessarily
exDcsed, through assuring an environment free from improperly managed and
dis rosed hazardous wastes.
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The State of Illinois ranks second among all States nationally by generating,
as well as we can estimate, anywhere from .8 to 2.6 million tons per year of
hazardous wastes; this is approximately 6.7 percent of the estimated national
total. It is estimated that there are anywhere from 2,700 to 3,900 hazardous
waste generators in the State. These facts place Illinois high in national
ranking with respect to the magnitude of hazardous waste which must be managed.
Illinois has been in the forefront in developing a hazardous waste management
regulatory program (and authorization plan) toward the level necessary to
qualify for Federal authorization to deal with this problem. Some additions
to the State program will be necessary to assure the implementation of a
regulatory program which is substantially equivalent to that defined in the
Federal hazardous waste regulations and standards. The State-wide and inter-
State nature of the hazardous waste management problem raises significant
issues with respect to required State Program equivalence and consistency
determinations leading to authorization. Situations must not exist where it
is "easier" to dispose of wastes in one State than in another.
The operation of a State hazardous waste management program that is substan-
tially equivalent to the Federal RCRA program is included as a highlight issue
in this SEA document. Additional details on the implementation of this program
can be found on page 33. *,.
Proper management of hazardous wastes demands a sufficient number of properly
designed and operated disposal sites. Currently our Nation lacks sufficient
hazardous waste management facilities. Establishment of new facilities almost
always results in intense opposition by local citizens. Current public hosti-
lity to new waste disposal facilities is understandable; people are afraid.
But industry can't properly manage v/astes without sites at which improved
nanagement can take place. Hence every citizen has a personal stake in the
resolution of the siting issue. Our society needs new processes and procedures
whereby sites can be selected at which the best technologies can be applied to
assure the safe management of hazardous v/astes. During the coming year U.S.
EPA will be developing a policy which articulates U.S. EPA's position on loca-
ting hazardous waste disposal sites. During the coming year Illinois will
also continue to examine the State's role in the area of siting. They have
been considering the various aspects of this issue for the past few years.
U.S. EPA and IEPA are also seeking new solutions to the problems created by
hazardous wastes. One v/ay to reduce our dependence on land disposal is to
increase the development of waste exchanges. This is based on the principle
that one company's waste may be another's raw material. IEPA plans to act as
a focal point for companies on the exchange of information on wastes which can
then be physically exchanged. This waste exchange effort should be in opera-
tion early in FY 1981.
The increasing incidence of toxic contamination is another major environ-
rental concern. Toxic substances, are regulated by the Toxic Substances Control
ret (TSCA) of 1976. TSCA specified that: (1) an inventory be compiled on exist-
ing commercial chemicals; (2) manufacturers submit to U.S. EPA a pre-manufacturing
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notice 90 days prior to producing any chemical not listed in the inventory;
ar,d (3) U.S. EPA's Administrator may prohibit or limit the manufacture, proces-
sing, distribution, use, or disposal of a chemical substance or mixture if he
finds that it presents or may present an unreasonable risk of injury to health
or the environment.
Throughout the United States increasing occurances of toxic chemicals con-
taminating our environment have been reported. Often these incidences have
posed a threat to human health. While programs are being developed to deal
vrith hazardous wastes, toxic air and water discharges from industries and
municipalities, the contamination of drinking water and the manufacture and
distribution of chemicals, a need remains to effectively manage contamination
fron these and other sources. The primary goals of any Federal or State toxic
chenical control program is the protection of human health from environmentally
related exposure to toxic chemicals at unsafe levels as well as protecting the
environnent from contamination. The development of State programs for inter-
agency coordination in dealing with toxic contamination episodes and improving
the Federal/State interaction on these issues is necessary.
During FY 1981 U.S. EPA and IEPA will be working to improve inter and intra-
agency coordination on toxic contamination events at the Federal and State
levels. This effort is highlighted in the FY 1981 SEA and additional details,.
can be found on page 36. Basically, the goals of this Federal/State inter-
action will be the establishment of (1) management procedures among all appro-
priate State agencies to ensure that coordinated action is taken on identified
environmental toxic contamination problems and (2) procedures for responding
to possible health effect problems attributed to environmentally related expo-
sure to toxic chemicals.
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-IGHLIGHT ISSUE |7
Drotect hunan health and the environment from potential exposure to hazardous
wastes during its generation, transport, treatment and disposal.
DISCUSSION
Hazardous wastes are by-products of our chemical and industrial society. If
improperly managed these wastes can result in serious damage to human health
and the environment. It is estimated that only a small percentage of the
hazardous waste generated in our country is properly managed, although this
varies from State to State. U.S. EPA has promulgated regulations dealing
with the proper management of these wastes.
Illinois has been in the forefront in developing a hazardous waste management
program. During FY 1981 U.S. EPA and IEPA will be working together to reduce
the number of people unnecessarily exposed to mismanaged hazardous wastes. A
nain means to that end is the development of a state program which is substan-
tially equivalent to that defined in the Federal hazardous waste regulations
and standards.
PROBLEM SOLVING APPROACH
---'' --.--.r_--_. -.. . - •___-!—_ .^ ^
A. Objectives
1. During FY 1981, IEPA with assistance from U.S. EPA, will develop a
State hazardous waste program that is substantially equivalent to the Federal
P.CRA Program.
2. If necessary, prior to the granting of interim authority, U.S. EPA
and the State may develop a cooperative arrangement for the IEPA to implement
those portions of the Federal program that the State can carry out.
3. U.S. EPA obtains from Illinois a complete, approvable request for
Dhase I interim authorization and U.S. EPA expeditiously grants that authority.
4. U.S. EPA obtains from Illinois a complete, approvable request for
Phase II interim authorization and U.S. EPA expeditiously grants that authority.
5. U.S. EPA and Illinois continue to conduct a joint program to effec-
tively deal with instances of mismanaged hazardous wastes which pose a substan-
tial endangerment to human health and the environment. This program will be
integrated into the RCRA regulatory program in Illinois.
6. Illinois develops a strategy to reduce waste of energy and material
resources, and creation of hazardous waste by encouraging resource recovery/
recycling.
7. The State develops a strategy for siting new facilities and for
increasing capacity of existing facilities for disposal of hazardous wastes,
if needed.
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B. Implementation Milestones
The letter-number following each milestone refers to the appropriate
objective listed above.
9/80 Illinois submits a final application for interim authori-
zation. (A-3)
10/80 The cooperative arrangement, if determined to be necessary,
nay be implemented and operated until the State fully implements a substantially
equivalent program. (A-2)
12/80 U.S. EPA expeditiously processes a complete, approvable
request for Phase I interim authorization and makes a positive determination.
(A-3)
1/81 State submits hazardous waste facilities assessment as element
of State Solid Waste Management Plan. (A-l)
1/81 State submits strategy for the maximization of resource con-
servation and recovery from solid and hazardous waste, specifically addressing
front-end consideration by generators of recycling options, as element of *,
State Solid Waste Management Plan. (A-6)
2/81 U.S. EPA provides the State with a determination of statutory
and regulatory changes needed for the State to qualify for final full authoriza-
tion. (A-l)
2/81 State submits a draft Phase II interim authorization applica-
tion. (A-4)
2/81 State establishes data base, including notifictions, Part A
oernit applications, and other pertinent State regulatory program information.
(A-5)
2/81 State and U.S. EPA design a strategy for the enforcement and/
or clean-up on inactive sites not under the purview of the RCRA hazardous
waste management regulatory system. (A-5)
3/81 State compares sites identified through uncontrolled sites
program to this data base. Active sites on uncontrolled sites' list will be
incorporated into hazardous waste management program enforcement effort. (A-5)
3/81 State submits a legislative package prepared January, 1981,
to provide the State with the authority to conduct a program equivalent to
RCRA. (A-l)
4/81 State submits a complete, approvable Phase II interim authori-
zation application. (A-4)
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7/81 *U.S. EPA makes a final determination as to the approvability
of the State's Phase II interim authorization application. (A-4)
7/81 *State commences formal regulatory process to effect regulatory
changes needed in order to qualify for final authorization. (A-l)
RESOURCES
Section 3011, RCRA; State funds.
Responsible Program Managers/Staff Contacts:
U.S. EPA: Bill Constantelos, Karl Klepitsch, Joel Schaffer
I EPA: John Moore
* Dependent on legislation being passed and signed by the Governor, action on
Interim Authorization and federal resources.
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HIGHLIGHT ISSUE $8
Develop inter-agency (and intra-agency) coordination for dealing with toxic
chemical contamination events.
DISCUSSION
The primary goals of any Federal or State toxic .chemical control program is
the protection of human health from environmentally related exposure to toxic
chemicals, as well as protecting the environment from contamination. While
programs are being developed to deal with hazardous wastes, toxic air and
water discharges from industries and municipalities, the contamination of
drinking water and the manufacture and distribution of chemicals, there still
remains a need to effectively manage contamination from other sources and to
effectively and efficiently deal with toxic chemical contamination events when
they occur.
Although the State of Illinois has already devoted effort to control environ-
mental contamination and the subsequent human exposure to toxic chemicals,
there remains a need to establish a single State coordinating mechanism to
clarify roles, jurisdictions and relationships between State agencies in dealing
with toxic chemicals. During FY 1981 U.S. EPA and IEPA will work toward im-^
proving inter and intra-agency coordination at the Federal and State levels
for dealing with toxic contamination events. Attention will also be directed
at improving the Federal/State interaction on these issues as necessary.
PROBLEM SOLVING APPROACH
1. In November, 1980, IEPA will establish a formal State plan identifying
appropriate Illinois State agencies and contacts to ensure coordinated response
to identified toxic chemical contamination problems. The plan will identify
both health and environmental agencies, as well as a single focal point (person)
for the implementation of the plan.
2. The State of Illinois will implement this plan, as necessary throughout
the year, in order to respond to toxic chemical environmental contamination
problems which may effect the health of humans, wildlife, or domestic animals.
3. Prior to the beginning of FY 1981, U.S. EPA staff developed a mapping
program using data compiled from the Chemical Inventory under the Toxic Sub-
stances Control Act. Data relative to the Illinois chemical industry by geo-
graphic area, specific chemical and production quantity will be displayed.
During October, 1980 - January, 1981, IEPA will evaluate these data and ini-
tiate appropriate action with respect to specific industries or geographic
areas where toxic chemical contamination has occurred or is likely to occur.
This information will be used to help guide the activities of existing programs
(e.g., NPDES, Air, etc.), to focus available resources on areas of greatest
ootential concern.
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Aopropn'ate follow-up activity which may include inspections, environmental
r-onitoring, or regulatory activity will be initiated during the remainder of
FY 1981 and FY 1982. lEPA's plan for these follow-up activities will be
reviewed by U.S. EPA during February and September, 1981.
RESOURCES
Section 1M3, Safe Drinking Water Act
Section 105, Clean Air Act
Section 106, Clean Water Act
Section 4008, Resource Conservation and Recovery Act
Other Federal grant sources as applicable
State funds
Responsible Program Managers/Staff Contacts:
U.S. EPA: Bill Constantelos, Karl Bremer
IEPA: Michael Mauzy
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V. MISCELLANEOUS
In addition to the issues identified in the media specific portions of
this agreement—Water, Air and Hazardous Materials—issues were identified
that affect all of the pollution control programs and therefore do not con-
veniently fit under one of the three categories. Three of these so-called
miscellaneous issues were felt to be of sufficient importance to be included
as highlights in the FY 1981 SEA. This is to insure that they receive the top
level management attention necessary to address them.
Although these issues may not be directly related to the solution of speci-
fic environmental problems, actions to address these issues should result in
rore efficient, responsive programs to deal with specific environmental pro-
blems. Resources to accomplish the problem solving approaches for these issues
will come from all of the various pollution control programs. Specific deter-
mination of costs to be assigned each program will be made by the State.
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'-'IC-HLIGHT ISSUE *9
Provide *or adequate laboratory capability to insure the availability of accep-
table analytical data required to support program needs.
DISCUSSION
An environmental protection agency needs an adequate analytical data base in
order to properly identify and solve the problems with which they are confronted.
The lack of adequate analytical data is the most serious obstacle to these
agencies discharging their duties and protecting the health and welfare of
their citizens. New and emerging programs, such as hazardous/toxic wastes,
require even more complex and costly analytical equipment to provide the data
needed to identify problems and take necessary corrective actions.
In order to assure that the necessary analytical data is available, careful
assessment of future analytical needs by the environmental program offices is
required, since a one to two year lead time is often needed for a laboratory
to develop new and expanded analytical capability, the availability of
Qualified contract laboratories is limited, and U.S. EPA presently can pro-
vide only minimal laboratory support.
*.
During FY 1981 U.S. EPA and IEPA will be working together to identify Illinois'
projected program needs and laboratory capabilities.
PROBLEM SOLVING APPROACH
1. IEPA, with assistance from U.S. EPA, will project program needs for
analytical data for at least three years. This projection will be updated
and finalized by December 1, 1980.
2. IEPA, with assistance from U.S. EPA, will develop a multi-year imple-
mentation plan to bridge the gap between projected program data needs and
lEPA's laboratory capabilities. This implementation plan will be completed by
April 1, 1981.
3. U.S. EPA will incorporate the appropriate elements of the multi-year
implementation plan into the FY 1982 State Specific Guidance by May 15, 1981.
This practice will be continued in future years.
P.ESOURCES
Section 106, Clean Water Act
Section 105, Clean Air Act
Section 1443, Safe Drinking Water Act
Sections 4008 and 31, Resource Conservation and Recovery Act
State Funds
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Responsible Program Managers/Staff Contacts
U.S. EPA: Curtis Ross
IEPA: John Anderson
;* ^
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HIGHLIGHT ISSUE #10
Allow for more meaningful State input into U.S. EPA's development and initia-
tion of new program activities and directions, which may have the potential
for significant resource implication, by providing for advance consultation
on such issues to the maximum extent possible.
DISCUSSION
The operation of effective pollution control programs, to protect public health
and welfare from pollution and environmental hazards, requires constant re-
evaluation. Expanding data bases, new legal mandates and day-to-day experiences
often result in the need for modifications to existing programs and/or more
precise descriptions of program thrusts, which will impact implementation.
These changes do not necessarily coincide with established planning schedules.
As a result, State programs often have to be modified during the program (fiscal)
year. This can necessitate the reprogramming of existing resources, requests
for additional appropriations, etc.
State and Federal dollars for pollution activities have tended to remain con-
stant over the past few years, due to the state of the economy. Even where
dollar amounts have remained constant or have increased slightly the net res.ult
is less "buying power" due to the high rate of inflation.
State and Federal funds to support pollution control efforts in Illinois are
appropriated by the Illinois General Assembly. These appropriations cannot be
made without sufficient lead time which allows the General Assembly to review
the proposed program and request, and take action, in light of their existing
schedule.
In order to operate a pollution control program which is responsive to the
needs of the citizens of Illinois, the IEPA must be made aware of the possi-
bility of new program directions and activites, as soon as possible. There-
fore, they will have adequate opportunity to comment on these from the State's
perspective, and to initiate any actions necessary to insure that the necessary
resources are made available either by reprogramming existing resources or
requesting an additional appropriation of Federal and/or State dollars from
the General Assembly.
State input on such possible program modifications at an early stage should
enable the U.S. EPA to more thoroughly review the State's comments and to
provide program guidance/direction which more clearly reflects the State's
needs.
PROBLEM SOLVING APPROACH
1. U.S. EPA will notify IEPA through personal or telephone contact of
potential/possible changes in program direction or scope, as soon as it is pos-
sible. Care will be taken to prevent "false starts" or premature notification.
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2. U.S. EPA will transmit the appropriate memos, policy papers, Head-
c-jarters guidance to IEPA for review and comments as soon as they are received
~cr distribution. IEPA will provide comments where appropriate in timely
-ashion.
.-^SOURCES
Section 105, Clean Air Act
Section 106, Clean Water Act
Section 1443, Safe Drinking Water Act
Sections 4008 and 3011, Resource Conservation and Recovery Act
State funds
Responsible Program Manager/Staff Contacts
U.S. EPA: Mary Canavan
IEPA: Michael Mauzy
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HIGHLIGHT ISSUE #11
Provide for more efficient oversight of federally funded State pollution control
programs and delegations.
DISCUSSION
A Federal-State partnership is at the base of our Nation's pollution control
efforts. A concerted effort is needed to make sure this partnership works.
Both parties must constantly strive for good communication and inter-action.
This Federal-State partnership should result in more effective, non-duplicative
programs.
U.S. EPA has pursued a policy of supporting State pollution control efforts
through direct financial support and through delegation of certain Federal
responsibilities to the State. U.S. EPA supports State pollution control
programs with grants to share in the cost of these activities. U.S. EPA pro-
vides grant support to the IEPA for the following programs:
1. Water Pollution Control Program
2. Air Pollution Control Program ,«
3. Public Water System Supervision Program
4. Construction Management Assistance Program
5. Solid and Hazardous Waste Management Programs
6. Water Quality Management Planning Program
7. Clean Lakes Program
8. Underground Injection Control Program
Due to the nature of the program grant and delegation mechanisms, U.S. EPA is
responsible for insuring that federally supported programs and delegations are
consistent with the Congressional mandate. Overview of State efforts should
not result in duplication of efforts at the Federal/or State levels, but should
provide necessary direction and assessments of efforts to result in more effec-
tive, efficient programs.
With limited resources available at the Federal and State levels, it is neces-
sary to make the best use of them. Effective oversight of State programs and
delegations should result in more efficient use of State and Federal person-power
and resources.
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During FY 1981 the U.S. EPA and IEPA will jointly review the existing oversight
mechanisms, identifying those program areas where oversight can be improved
and to what extent. Based on this review U.S. EPA and IEPA will identify any
areas where changes in the existing procedures would be beneficial. Modifica-
tions will be made in the current overview approach where appropriate.
PROBLEM SOLVING APPROACH
1. U.S. EPA and IEPA will independently identify the following by December
1, 1980.
a. Current oversight functions by program/delegation.
b. Basis (legal/policy/etc.)/rationale for oversight.
c. Frequency of oversight (actual vs. recommended).
d. Positive and negative aspects of oversight.
e. Suggested modifications to existing oversight activity.
2. U.S. EPA and IEPA will exchange the information prepared according tp,^
to milestone #1 above, by January 1, 1981.
3. U.S. EPA and IEPA will arrange a meeting to discuss the current process
and any changes/modifications which should be made in the existing system.
4. U.S. EPA, with the assistance of IEPA, will produce a revised overview
strategy of federally supported IEPA pollution control programs by April 1, 1981,
RESOURCES
Section 105, Clean Air Act
Sections 106, 205(g), 208, 314, Clean Water Act
Section 1443, Safe Drinking Water Act
Sections 3011 and 4008, Resource Conservation and Recovery Act
State funds
Responsible Program Managers/Staff Contacts:
U.S. EPA: John McGuire, Mary Canavan, Laird Starrick
IEPA: Michael Mauzy
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VI. APPENDICES
The following documents are appended to this Agreement by reference.
Copies of these documents are available for review at the U.S. Environmental
Protection Agency, 230 S. Dearborn Street, Chicago, Illinois 60604, or the
Illinois Environmental Protection Agency, 2200 Churchill Road, Springfield,
Illinois 62706. Individual copies of some of the documents are available
upon request.
1. Region V Guidance for the development of grant applications under:
Section 106, Clean Water Act
Section 314, Clean Water Act
Section 208, Clean Water Act
Section 205(g), Clean Water Act
Section 105, Clean Air Act
Section 1443, SDWA
Section 1421, SDWA
Section 3011, RCRA
Section 4008, RCRA
2. State grant work plans developed for the above listed grant applica-
tions, effective upon grant award.
3. EPA Operating Year Guidance - February, 1980
4. EPA Handbook for FY 1981 - State/EPA Agreements
5. EPA Profile of Environmental Quality, Region V, 1979
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