Un,,_, States
                     Environmental Protection
                     Agency
                                            Region 5
                                            230 South Dearborn Street
                                            Chicago. Illinois 60604
Illinois, Indiana, Michigan.
Minnesota, Ohio, Wisconsin
v>EPA
                Region  5
                FY1985
                Environmental
                Management
                Report
Valdas V. Adamkus
Regional Administrator
Alan Levin
Deputy Regional
Administrator
Regional Administrator's Overview Regional Environmental Problems Ha/ardous Waste Management and Response Hazardous Waste
Management Contamination of Groundwater Discharge ot loxic Materials to Water Contaminated Sludge In-Situ Pollutants PCB's
          Primary Ambient Air Quality Standards  Synthetic Organic  Chemical Contamination of Drinking  Water Toxic
             ; Pesticide Misuse Asbestos Air I oxics Q^ggH.akes Areasot Concern Nonpomt Sourct Runoff to Water Protection of In-
                                               ned Sewer Overflows Emerging Problems Indoor Air Pollution
                                                ;ency's Priority List Regional Administrator's Overview Regional
                                                       Waste Management and Response Hazardous Waste
                                                          Contaminated Sludge In-Situ Pollutants PCB's
                                                       lemtcal Contamination of Drinking  Water Toxic
                                                          Nonpomt Source Runoff to Water Protection of In-
                                                          flows Emerging Problems Indoor Air Pollution
                                                                       inistralPr's Overview Regional
                                                             -   —^_^-   ^nse Hazardous Waste

                                                             ****
                                                                                   Pollutants PCB's
                                                                                      Water Toxic
                                                                                    Protection of In-
                                                                              m» InaTTor Air Pollution
                                                                             tralor's Overview Re
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                                                                                 itu
                                                                                rinking
                                                                           noffto Water
                                                                          I'robl
    Regional Administraior'i
    Management
    \'io!ation ol  Pnmar\
    SubstancesChemicals Pesticidi
    Land Lakes Cultural Eutrop
    \ehvcular and lndu>inal E
    Regional Administrator"
    Management Comamm
    \ lolation of  Primary
    SubstancesChemicals Pe:
    Land Lakes Cultural.,
    Vehicular and Indus
    Regional Admmist
    Management Com
    Violation of  Primil
    SubsiancesChemicals
    Land Lakes Cultural EuO
    Vehicular and Industrial Em
    Regional Administrator's Che
    Management ContaminalioftV:
    Violation of  Primary  Am:
    SubstancesChemicals Pesticide
    Land Lakes Cultural Eutrophicai
    Vehicular and Industrial Emitted Lei
                                                                                  rater Toxic
                                                                                 siection of In-
                                                                                 \ir Pollution
                                                                                 few Regional
                                                                                 frdous Waste
                                                                                  utams PCB's
                                                                                  Vater Toxic
                                                                                 btectionol In-
                                                                                 Air Pollution
                                                                             ([Overv lew Regional
                                                                              • Hazardous Waste
                                                                               Pollutants PCB's
                                                                            Wnking Water Toxic
                                                                          'to Water Protection of In-
                                                                        flems Indoor Air Pollution
                                                       unt> KttlWpi^^gsggmsirator's Overview Regional
                                                       Waste Management:**} Response Hazardous Waste
                                                  its'to Water Contaminated Sludge In-Situ Pollutants PCS'-.
                                                Jganic Chemical Contamination ol  Drinking Water Toxic
                                                Sasof Concern Nonpoim Source Runoff to Water Protection ol In-
                                    Wetlands Combined Sewer Overflows Emerging Problems Indoor Air Pollution
                                  nmendations for the Agency's Priority List Regional Administrator's Overview Regional

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  U.S. ENVIRONMENTAL PROTECTION AGENCY

                REGION V


FY 1985 ENVIRONMENTAL MANAGEMENT REPORT
                                    Valdas  V.  Adamkus
                                    Regional Administrator
                                    Alan Levin
                                    Deputy Regional  Administrator
                                    September 12,  1985

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                              Table of Contents
Part

I
II
III
Regional Administrator's Commentary
Regional Environmental  Problems
   A.  Hazardous Waste  Management and Response
         1.  Hazardous  Waste Response
         2.  Hazardous  Waste Management
   B.  Contamination of Goundwater
   C.  Discharge of Toxic Materials to Water
          Contaminated  Sludge
   D.  In-Situ Pollutants
          PCBs
   E.  Violation of Primary Ambient Air  Quality  Standards
   F.  Synthetic Organic Chemical Contaminitlon  of Drinking Water
   G.  Toxic Substances - Existing Chemicals
         1.  Pesticides Misuse
         2.  Asbestos
   H.  Air Toxics
   I.  Great Lakes Areas of Concern
   0.  Nonpoint Source  Runoff to Water
   K.  Protection of In-land Lakes
         1.  Cultural Eutrophication
         2.  Preservation of Wetlands
   L.  Combined Sewer Overflows
   M.  Emerging Problems
         1.  Indoor Air Pollution
         2.  Vehicular  and Industrial
   Recommendations for  the Agency's f-i
Emitted Lead
tority List
                                                           in Soil
Appendices
           A.  Environmental  Indicators -  Southeast  Chicago  Study
           B.  Air Addendum
           C.  Great Lakes National  Program Office
                 Areas of Concern -  Remedial  Action  Planning
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Region V FY 1985 Environmental Management Report
  Part I - Regional Administrator's Commentary

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                                      - 2 -


This Environmental Management Report chronicles not only the major events
of this past year but documents the challenges and changes Region V will  face
in the coming year.

  0  The Hazardous and Solid Waste Amendments initiate several  entirely new
     programs, and mandates some difficult deadlines for their completion.

  0  We are awaiting reauthorizations of several  major pieces of environmental
     legislation including the Clean Water Act and Superfund.  They will  bring
     substantial changes in our program operations for FY 1986.

  0  Our increased understanding of the groundwater problem 1n the Region has
     caused it to become a significant priority in almost all Regional  programs.

  0  The Region is facing requirements and statutory timeframes for actions that
     will challenge our scientific and regulatory capabilities.  A prime  example
     is corrective actions at solid waste units.

  0  We have limited ability to control several intractable conventional  pollutants
     which are widespread problems affecting large numbers of people.  For  example,
     particulates are a major air pollution concern, but no progress has  been made
     on getting full SIP attainment demonstrations because we are still awaiting
     the PM-10 standard.  Until such SIP demonstrations are made and regulations
     developed, there will be no further progress towards attaining the particulate
     standard in unattainment areas.

  0  Combined sewer overflows are a major water quality problem, but the  Agency
     has not yet provided the technical means to  set standards for high flow
     permit conditions, or criteria for evaluating what construction projects we
     should fund to alleviate such problems.

There are special Regional concerns I feel need to be articulated.  First,  the
Great Lakes National Program Office (GLNPO), with active State involvement, is
participating in an international effort to prepare and update remedial action
plans for 42 Great Lakes areas of concern.  This  is a significant undertaking
and deserves the support of the national program  offices and jurisdictions.  In
particular, we need to formulate solutions for In-situ pollutants, toxic  air
deposition, combined sewer overflows and non-point source control  for the Great
Lakes.

The extent of the issue of in-situ pollutant dilemma is peculiar to Region  V and
was highlighted by most of the States.  Region V  shares this problem with Regions
II and III, and perhaps with some other Regions where these sediments are a
concern.  But the extent of the problem in Region V is much greater - virtually
every Great Lakes harbor and stream in industrialized areas have sediments
contaminated by PCBs and other pollutants.  There are numerous jurisdictions
involved, and several major actors, including EPA and the Corps of Engineers
(COE).  These jurisdictions and the COE are looking to EPA for answers on how
to handle these contaminated sediments when those rivers and harbors must be
dredged.  Section D of Part II, the in-situ pollutant problem assessment  discusses
some of the more technical aspects oT~the problem, but it does not portray  the
Region's management concerns in dealing with this problem.

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                                    - 3 -


The basic problem we face is to define affordable and environmentally
acceptable alternatives for proper dredge spoil disposal.  For example, EPA's
official technical guidance for disposal of contaminated dredge spoils with
PCS concentrations above 50 ppm is to incinerate or landfill them in approved
facilities.  The sheer volume and saturation of the dredge spoils make this
technically and economically infeasible.  COE has suggested several  alternative
disposal methods that have, so far, been unacceptable.  To resolve this problem,
Region V will be working to develop disposal alternatives acceptable to both
EPA and COE.

From Subtitle D to Clean Lakes, the States are concerned about funding for
many of the issues this EMR discusses.  They are especially concerned about
being asked to expend resources to address some of the noted emerging problems
and programs, while simultaneously being required to continue existing program
activities - all without new funding.  Considering that many of these new
problems and programs are complex issues for which there are few accepted
technical answers and little implementation experience, their resolution
will take time and carry a substantial price tag.

Our State partners have specific concerns about adequate funaing for the in-
creasing needs of laboratories.  Because so much of our current effort is
related to controlling toxic pollutants, the ability to sample and analyze
for such substances is vital to program success.  There are already shortages
of trained personnel, equipment and analysis capacity in each of our State's
labs.  Without appropriate funding and an appreciation of the implications
of this problem by the national program managers, the lack of State lab
capability may become a limiting factor for States in assessing environmental
conditions and meeting program commitments.

I would like to call your attention to another important aspect of this report.
We have made a special effort to focus on environmental indicators in our
Part II Section's, "Expected Environmental Results" narratives.  While I feel
we have developed innovative indicators for a number of problems (CERCLA, PCBs,
Asbestos, Nonpoint Source Runoff, Protection of Inland Lakes, CSO),  we have
highlighted our Air Management Division's efforts at documenting the environ-
mental  results.  That documentation is incl.uded as Appendix B and is referenced
extensively in Air's Part II problem assessment.

Finally, as part of OPPE's Environmental Indicators development effort, we
nave included a case example - Appendix A, Southeast Chicago - a Case Study
of Environmental Planning.  This study describes our experiences in  trying to
deal with one area's multi-media environmental  problems.  Environmental  indi-
cators played a special  role in this study.  We are planning to explore ways to
use our experiences there to develop an environmental  indicators-based planning
project involving another geographic area with multi-media problems.

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Region V FY 1985 Environmental  Management Report
   Part II - Regional  Environmental  Problems

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                   PART II - REGIONAL ENVIRONMENTAL PROBLEMS

Following is a list of what Region V considers to be its most pressing environ-
mental problems.  The Region's program managers felt that because of the single
media nature of our environmental laws, inter-media ranking was not really
appropriate.  The real ranking came in the selection of our major environmental
problems and the intra-media order of problems.  Our overall ranking was done to
agree roughly with the Agency Priority list and partially by Intramedia ordering
by the media program managers.  That intramedia ordering Is based on a number of
factors dictated by experience, including public health threat, potential  for
environmental damage, relative intractability of the problem, public Interest,
State program priorities, and other related considerations.

                RANKING OF REGION V MAJOR ENVIRONMENTAL PROBLEMS

                   A. HAZARDOUS WASTE MANAGEMENT AND RESPONSE

                          1. Hazardous Waste Response
                         2. Hazardous Waste Management

                        B. CONTAMINATION OF GROUNDWATER

                    C. DISCHARGE OF TOXIC MATERIALS TO WATER

                              Contaminated Sludge

                             0. IN SITU POLLUTANTS

                                      PCBs

             E. VIOLATION OF PRIMARY AMBIENT AIR QUALITY STANDARDS

         F. SYNTHETIC ORGANIC CHEMICAL CONTAMINATION OF DRINKING HATER

                    G. TOXIC SUBSTANCES - EXISTING CHEMICALS

                             I.  Pesticides Misuse
                                  2.  Asbestos

                                 H. AIR TOXICS

                        I. GREAT LAKES AREAS OF CONCERN

                       J. NONPOINT SOURCE RUNOFF TO WATER

                 K. PROTECTION OF WATER QUALITY IN INLAND LAKES

                            Preservation of Wetlands

                           L. COMBINED SEWER OVERFLOW

                       M. EMERGING ENVIRONMENTAL PROBLEMS

                             1. Indoor Air Polution
                2. Vehicular and Industrial Emitted Lead in Soil

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 A.  HAZARDOUS  WASTE MANAGEMENT AND RESPONSE

 !•  Hazardous  Waste Response


 Problem Assessment

 Region V has  192 of the 812 uncontrolled hazardous waste sites on the National
 Priorities List (NPL).  Sixty-one of these sites are 1n Michigan, 34 1n Minnesota,
 28  In Ohio, 24 In Wisconsin, 23 1n Illinois, and 22 1n Indiana.  Region V antici-
 pates 16 more sites will be added to the NPL 1n August, 1985.  The Region also
 has over 4,000 abandoned hazardous waste sites that are not on the NPL, but which
 may still threaten human health or the environment.  The concentration of heavy
 industry and  agriculture in the Midwest and the associated number of uncontrolled
 hazardous waste sites have raised the public's concern and level of understanding
 of  the immediate public health threats of Superfund sites.  They also understand
 many site contaminants are potential carcinogens or mutagens which have the poten-
 tial to cause serious long-term health effects.  This level of public concern and
 awareness of  the risks associated with Superfund sites has placed great demands on
 our emergency remedial response program.

 The primary environmental threat from hazardous waste sites in Region V is
 contamination of grounawater which the Region relies on for private, municipal,
 industrial, and agricultural water supplies.  In addition, releases of hazardous
 substances by generators or transporters in the Region may cause serious public
 health threats in areas without adequate emergency preparedness measures.

 Regional  Agenda

 0  Continue program implementation to focus removal actions at sites posing
   the most serious threats and to move current and potential  NPL sites
   through the "pipeline" so remedial activities can be accomplished through
   Fund financed or responsible party actions.  Region V expects to undertake
   aoout 30-40 new removals in FY 86, and initiate remedial actions at 15 new
   sites.  Also planned are about 30 new RI/FS and 20 RDs.  Special priority
   will  continue at sites where groundwater is threatened.

 0  900 preliminary assessments will  be conducted in FY 86, with 300 sites
   undergoing detailed evaluations,  including on-site inspections.   With
   the completion of 500 preliminary assessments in the remainder of FY 85,
   and the 900 scheduled for FY 86,  the majority of Region V's identified
   potential  uncontrolled hazardous  waste sites will  have had  preliminary
   assessments.

0  In addition to the above, other Regional  FY 86  priority activities  will  oe to:

     - Pursue responsible party clean-ups and cost recoveries.

     - Continue to strengthen  our relationships with  the States,
       encouraging them to  take the  lead  role in site clean-ups.

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     - Continue implementation of the dioxin strategy through exposure studies,
       actions to limit exposure, and evaluation of regulatory alternatives.
       If appropriate, the Region may take emergency actions or try to place
       additional sites on the NPL.

     - Continue the Community Relations program to improve Agency credibility
       and public understanding.

0  During FY 86, Region V will undertake a special initiative to assist States
   and local areas in improving emergency preparedness for accidental  releases of
   air toxics.  To begin this effort, U.S. EPA is developing an "acute hazards"
   list to identify those chemicals which would pose the greatest hazard if
   accidentally released.  Accompanying the "acute hazards list" will  be guidance
   to assist local communities in assessing the hazards of chemicals handled and
   stored at facilities, thus allowing the community to determine the potential
   for concern.  The acute hazards list, the identification of facilities and
   the review of existing safety systems will  form the basis for communities to
   begin developing or enhancing emerqency response plans.  To support this
   initiative to improve responsiveness to accidental releases of air toxics,
   Region V will provide training and technical assistance to States and conmuni-
   ties in emergency preparedness and response planning.

Headquarters Actions Needed

0  Planned increases in the number of sites and investigations will raise the
   analytical demands on the contract laboratory program.  Headquarters should
   continue to explore ways to improve data reliability and turnaround time.

0  Region V has a numoer of sites that do not  now qualify for the NPL, but may
   be environmentally significant.  Additional resources should be provided to
   further investigate these "middle class" sites to allay public concerns and
   see if they warrant inclusion in the NPL.

0  Region V has potentially uncontrolled hazardous waste sites at 42 Federal
   facilities.  We need procedures to coordinate with the OOD Installation
   Restoration Program for a host of activities in addition to remedial actions,
   as well as to clarify the RCRA/CERCLA issues resulting from HSWA.

0  Region V has experienced late and substandard work from Superfund contractors,
   and has been billed for cost and level-of-effort overruns.  We realize the
   Inspector General is looking at this problem but nothing has yet been resolved.
   Headquarters should look at available options for improving contractor perfor-
   mance, especially the use of firm, fixed-price contracting with guaranteed work
   products.

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Expected Environmental Results

Protection of public health and the environment has been achieved by both
Removal and Remedial activities under CERCLA.  For example, at Burrows Land-
fill (Hartford, MI) open lagoons of corrosive metal hydroxides were removed
to prevent seepage into the local water supply.  The removal  protected public
health by preventing contact with and/or ingestion of the substances at this
frequently used recreation area.  One definite indicator of our success at
this area was the natural aquatic ecology.  The populations of various plants
and animals in this area indicated significant stress due to the contamination,
but they have now been restored to their natural, pre-contamination balance.

Groundwater protection was also addressed recently at the Verona Well  Field
site (Battle Creek, MI).  Prior to remedial  action, drinking water from conta-
minated wells resulted in water being supplied to consumers with concentrations
of Volatile Organic Compounds (VOCs) up to 17 ppb, causing an equivalent cancer
risk of 5 deaths each year per 1,000,000 population.  Following the initial
remedial measures, VOCs were at undetectable levels.

Similar measures are planned in Fiscal Year 1986 at the Main Street Well Field
(Elkhart, IN), where an air stripper will remove 99 percent of the VOCs in the
water supply, lowering the equivalent cancer risk to less than one death per
10,000,000.   Planned remedial actions are to pump out, clean, and return water
to the contaminated aquifer, thereby lowering the VOC concentrations of the
aquifier itself.

The Kummer Sanitary Landfill near Bemidji, Minnesota, was found to have VOCs
of various types with concentrations up to 49 ppb, which resulted in a
cumulative excessive cancer risk of 333 deaths per 1,000,000 population.
Remedial actions are being taken to restore the water supply from a new well.
Bottled water for drinking and cooking is being distributed by the State as
an interim measure.

These are a few examples at sites in Region V where we can quantify the
ability of Superfund activities to ameliorate the effects of leaking hazardous
wastes on human health and environmental quality.


2. Hazardous Waste Management

Problem Assessment

Region V is concerned with 2 primary hazardous waste problems.  The first
is direct threats to public health: groundwater contamination, acute and
long-term toxicity to humans and the environment, explosions, corrosiveness,
and fire.  The second problem is institutional:  insufficient disposal  capacity
for existing and future amounts/types of wastes, their long-term environmental
persistance and stability, the propensity to control one media's hazard by
transferring it to another (e.g., contaminated waste water being placed in
surface lagoons which may leach into the groundwater), and the widespread
extent of the problem.  Region V has 265 land disposal and 47 incineration
facilities (17 and 21 percent respectively of the national total).

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These facilities are not concentrated in a specific geographic area.  The
ready mobility of waste allows them to be easily transported, scattering the
problem throughout many areas in the Region.  Therefore, both rural  and urban
areas in Region V have been affected.

Despite landfilling's short and long-term risks, it has been the most often
selected disposal option because of its lower initial costs.  While realizing
the grave long-term risks - even the best landfills will eventually leak and
require some remedial actions - EPA has been forced to focus on controlling
short-term risks through permits and enforcement actions.  The long-term
solution needed is for alternatives which will  simultaneously reduce the
total amount of wastes generated and provide sufficient disposal capacity.

There are several other sources of hazardous waste threats to the environment.
A newly recognized threat to groundwater is from Region V's estimated 150,000-
200,000 underground storage tanks.  The number that are now or could soon be
leaking, and the impact of these on groundwater is not yet known.  Neither do
we know the groundwater impact of the over 10,000 solid waste disposal sites
without groundwater monitoring wells.  Some of these sites may have received
smaller quantities of hazardous wastes and all  are receiving some amount of
hazardous substances from normal household refuse.  Only new solid waste dis-
posal facilities are required to have monitoring wells.  In addition to these
concerns, RCRA's lowered exemption level has added about 30,000 newly regulated
small quantity generators to Region V's regulated community.

All of these concerns have created tremendous public attention and apprehension,
wh^ch has subsequently made it very difficult to site any type of hazardous or
solid waste facility.  This situation - high costs and limited disposal capacity •
heightens the danger of illegal, "midnight" dumping.

Regional Agenda

During FY 84, Region V began implementing the national accelerated permit
strategy, but was slowed during FY 85 due to passage of the Hazardous and
Solid Waste Amendments (HSWA).  HSWA established a number of new require-
ments for land disposal permitting, including much more stringent permit
requirements, a vast expansion of the regulated community, and a corrective
actions program for active and inactive facilities with prior releases.  The
corrective action provision requires identification of all past or present
solid waste management units and all releases,  requires clean-up actions for
those releases, and demonstration of financial  assurance for the completion
of such actions.

To meet these requirements, the Region has implemented a Facility Management
Planning (FMP) process, which includes extensive permitting and enforcement
coordination, and issuing joint State/EPA HSWA permits.  Region V has called-in
Part B permit applications for all land disposal facilities and incinerators, but
no land disposal permits have been issued.  However, six land disposal facility
closures have been approved.  Region V estimates that HSWA could cause about 50
percent of the land disposal facilities and 10  percent of the incinerators to
close voluntarily or as a result of the permitting or enforcement process.  The
primary program barriers for Region V include the large number of land disposal

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                                      10


facilities on which to act, and the tight time frames for facility screening
and FMP development.  These problems are exacerbated by the lack of final  HSWA
implementation guidance.  The Region will attempt to meet these goals using
internal staff, State programs, and contractors.

In FY 86, the Region V certifications, permitting and enforcement focus will
be to:

0  Evaluate Part Bs received from land disposal facilities to determine
   environmental significance.  All land disposal facilities will be screened
   by January 31, 1986, with completed FMPs to follow by July 30, 1986.

8  Schedule implementation of all FMPs developed in FY 85.

0  Address corrective actions for all facility closures with the States.

0  Assess HSWA-mandated exposure information to determine need for full scale
   health assessments.

0  Attempt to increase the rate of permit issuance, supporting issuance/denial
   of all disposal and incinerator permits.

'"  Perform comprehensive compliance evaluations of all significant land disposal
   facilities posing immediate threats to the environment, especially to ground
   water.

0  Take enforcement actions against all  interim status facilities with groundwater
   monitoring problems, and all other high priority and Class I violators.

0  Issue corrective action orders [under §3008(h)] to abate offsite contamination
   at TSDs with Solid Waste Management Units.

0  Work with Illinois, Indiana, Michigan, Ohio, and Wisconsin to assure final
   pre-HSWA authorization in early FY 86 (Minnesota is already authorized).

3  Continue permitting and enforcement work (States now perform about 75 percent
   of permitting, about 90 percent of enforcement) with the States through co-
   operative agreement and grants, including joint permitting until  State  receives
   full HSWA authorization - especially at Federal Facilities.

5  Initiate the UST program by providing State grants to process notifications, and
   develop approvable programs.

0  Continue outreach programs, including Education of Small  Generators notification
   activities, and educating the public on the proper disposal of hazardous
   household wastes.

Headquarters Actions Needed

0  Development of alternatives to land disposal should be the top Agency Research
   and Development (R&O) priority.

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                                      11


0  Develop and issue final regulations and guidance documents for implementation
   of HSWA, including the conduct of Comprehensive Groundwater Monitoring
   Evaluations (CMEs), areas of vulnerable geology, and Corrective Action Orders,
   standards for small quantity generators, UST regulations, and tank  standards.

0  To determine SPMS targets for FY 86-88, Headquarters should evaluate the
   universe of land disposal facilities in each Region and set targets according
   to the number of land disposal facilities that can realistically be addressed.
   The large number of such facilities in Region V places a strain on  State
   and Federal resources, and the quality of the program may suffer in attempting
   to meet gross numerical requirements.

0  OSWER should consider modifying the Subtitle D program to Include non-hazardous
   waste land disposal facilities, many of which also contain hazardous wastes
   and present a significant threat to the environment, especially groundwater.

Expected Environmental Results

Currently, the RCRA program has few true environmental indicators, most are
indicators of program results expected in FY 86, such as:

0  A 20 percent increase in permitted Incinerator ctpacity.

0  All land disposal facilities will have adequate groundwater monitoring
   systems, capable of detecting/assessing groundwater contamination,  or be
   under formal enforcement to install such systems.

0  A 25 percent increase in the number of facilities in compliance with the
   closure and financial requirements.

0  A reduction in the volume of wastes disposed of at land disposal facilities.

0  An increase in public awareness of hazardous waste problems, as evidenced
   by public participation in permit hearings and household hazardous
   waste disposal projects.

The most important and most real  program result of RCRA/HSWA will  be to discourage
and, wherever possible, prohibit land disposal  of hazardous wastes. Also,  based
on the expansion of the program due to HSWA, previously unaddressed inactive
facility problems can be corrected.

The environmental effects of changes of disposal practices and the corrective
actions programs will be to prevent groundwater contamination and direct soils
contamination.  We are still trying to develop measures to describe such progress
on a larger scale but, so far, can only do it for specific areas (see  Part  II,
p. 3, "Hazardous Waste Response," Environmental Results Expected.)

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                                      12


B. CONTAMINATION OF GROUNDWATER


Problem Assessment

Approximately 40 percent of the total population and 95 percent of the rural
area population depend upon groundwater as their prime source of drinking
water.  Most of this drinking water is withdrawn from shallow aquifers which
are susceptable to contamination from on-going inadequate land disposal of
hazardous wastes, chemical spills, abandoned hazardous waste sites, leaking
underground storage tanks, and municipal land disposal facilities receiving
nonhazardous wastes.  Other sources of contamination include improper agri-
cultural practices, failing septic fields, and unregulated underground
injection control wells.

Groundwater protection is among Region V's highest environmental priorities
for several reasons.  First, Region V is underlaid with an extensive and com-
plex groundwater regime - it is a tremendously large and widespread resource.
Second, because of Region V's level of industrialization and agriculture and
resultant production and use of hazardous wastes and toxic substances, there
is a prevalent danger of contamination.  Simply put, there is a tremendous
amount of groundwater all over the Kegion V area; there 1s also a tremendous
amount of wastes/toxic suostances in widespread disposal/use; and therefore,
there is a commensurate potential for groundwater contamination.  Also,
Region V has several unique areas such as Wisconsin's Centra1 Sands and Minne-
sota's karst area whose unusual geological/hydrogeological characteristics
make them extremely vulnerable to groundwater contamination.

EPA's authorities to control these contamination sources are almost exclusively
site-specific, in that they do not address multiple contamination sources in
specific geographic areas.  There is an exception in that CERCLA can include
the effects of multiple contamination sources in their site ranking criteria.
Region V has already identified several areas where the groundwater contamination
is due to multiple sources - particularly the Grand Calumet Basin in Indiana.
The lack of comprehensive Federal and State groundwater legislation overlooks
longer-range approaches to contamination of large areas that could draw on the
site-specific findings of EPA's and other Agencies'  programs to integrate infor-
mation into a comprehensive multi-contaminant, multi-program response for areal
groundwater protection.

Regional Agenda

The Region has established the Groundwatsr Coordinating Committee supported by
an Office of Groundwater to address such issues as data sharing, areal contami-
nation problems, and oversee the implementation of the National Groundwater
Strategy.

Region V will also continue to use the following ongoing program site-specific
authorities and tools to abate existing groundwater contamination and to prevent
future occurrences:

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                                      13


CERCIA and RCRA

0  Under CERCLA, the Region's highest priorities will continue to be taking
   removal actions at sites which pose imminent threats to public health,
   and taking remedial actions at NPL sites, especially where there is danger
   of groundwater contamination.

0  The Region will continue to implement the RCRA Subtitle C program, where
   we will issue permits at land disposal facilities, Incorporating the more
   stringent requirements of the HSWA.  The new law provides for minimum
   technology requirements, expands requirements for groundwater monitoring
   systems, prohibits certain land disposal practices, bans particular wastes,
   and requires retrofitting of some existing surface impoundments with double
   liners.

0  The first RCRA program priority will  be to use HSWA authority to issue
   corrective action orders to both regulated facility and solid waste
   management units to abate offsite contamination, particularly of groundwater.

0  RCRA enforcement priorities will also be on protecting groundwater.  The
   Region will conduct comprehensive compliance evaluations at land disposal
   facilities, and take enforcement actions against all Interim status land
   disposal facilities that have not implemented adequate groundwatar monitoring
   systems.

3  During FY 86, the Region and States will begin to develop and implement the
   underground storage tanks (LIST) program.  This program will regulate storage
   tanks and require corrective actions  for tanks releasing regulated substances
   into the environment.  The LIST program will be a major contribution to the
   resolution of the groundwater contamination problem.

Clean Water Act Actions

0  Provide groundwater grants to the States, after negotiating appropriate
   levels of financial and technical assistance, given their groundwater
   protection program needs.

0  Ensure that each state produces a comprehensive ground water strategy.

3  Manage the implementation of State programs so that area!  contamination
   problems are addressed.

0  Develop and implement projects with States on public information and education,
   data management, groundwater monitoring.

Safe Drinking Water Act Actions

3  Implement the Underground Injection Control Program to control  previously
   unregulated underground injections which have caused significant problems.

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0  Coordinate EPA health effects data and provide data to States in a timely
   manner.

0  Implement the Public Water Supply Supervision Program which monitors the
   quality of drinking water delivered by public water systems.

Groundwater Coordinating Committee/Office of Groundwater (6WCC/OGW)

In addition to specific program actions, the Region will continue to implement
the National Groundwater Strategy as part of our State program development
multi-media coordination efforts, and focus appropriate Regional program
attention on area! contamination problems.

0  The Region has established the GWCC and the OGW.  The GWCC is being refocused
   to serve as a policy body to oversee implementation of the National Groundwater
   Strategy, coordinate program responses to such issues as areal contaminations,
   and recommend appropriate Regional policies.  The OGW will serve as staff to
   the GWCC by analyzing issues and making recommendations as required.  Also,  the
   GWCC will perform a variety of coordination functions, the nature and scope
   of which will depend on what is needed.  Some samples are:

     - Assuring that all appropriate Regional  programs consider groundwater
       protection as an integral part of their program implementation.

     - Assuring that all Regional program concerns and needs are appropriately
       factored into the State workplans and strategies.

     - Seeing that relevent State data are made available to all the appropriate
       Regional programs, and tnat all Agency technical information, monitoring
       data, research developments, and regulatory or policy news is provided to
       the State and Regional programs.

Headquarters Action Needed

0  Implement the National Groundwater Strategy.

0  Provide program and funding guidance for State groundwater grants within
   tne operating guidance.

0  Provide the Regions with more timely and consistent health advisories.

°  Involve the Regions in the various task forces created to establish a
   policy framework for EPA groundwater programs.

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                                       15
Expected Environmental Results

The Region's program activities will help protect groundwater from new
contamination and rectify some amount of past contamination.  But, as of
yet, the groundwater data base is insufficient to project exactly what
improvements will be accomplished.  In fact, we are just beginning to
develop the ability to map and catalog our groundwater resources and begin
to assess potential threats.  The major specific results we expect will be
from implementing existing programs at individual sites - where each will
be quantified separately.

Two major program initiatives will have the greatest environmental effect  on
groundwater - the groundwater classification system and the total regulatory
program effect of eliminating land disposal of hazardous waste as a viable
disposal option.  Obviously, if the day comes that there is no longer any
hazardous wastes buried, a significant threat to groundwater will have been
eliminated.  The groundwater classification system will have more subtle
effects.  Mainly, it will allow EPA, the States and other agencies to set
priorities and concentrate on the most important or the the most threatened
water bodies first.  An Indirect benefit is that, to accomplish the classifi-
cation scheme, significant amounts of monitored data will have to be gathered,
This data gathering - in .and of itself, and for the processes that must be
established to collect and manage it - can only increase our awareness and
knowledge of groundwater.  But these processes must be made as efficient ana
effective as possible.  Any such monitoring program should be modeled after
the Air Ambient Monitoring program and should avoid the problems of a system
such as STORET.

C. DISCHARGE OF TOXIC MATERIALS TO WATER
Problem Assessment

The discharge of toxic materials to water from a variety of industrial  and
municipal sources has caused the chemical contamination of fish and aquatic
life.  It has also caused direct contamination of surface drinking water
supplies and significant impairment of water uses.  The resulting bioaccumu-
lation has caused sport and commercial fishing advisories in 31 of the  42
Great Lakes areas of concern, and these involve all  five Great Lakes.  All  of
the Great Lakes have fish-eating bird populations carrying substantial  body
burdens of PCBs and other organochlorines.

Regional  Agenda

0  Work with States to identify key municipal  and industrial NPOES permits  for
   major and significant minor facilities with a high potential for the
   discharge of toxicants which need issuance in FY  86/87 and include them  in
   the FY 86 program plan.

0  Provide technical  assistance to POTWs/States to implement pretreatment
   programs.

•   tio^k with the States to revie-1 and Devaluate water quality standards and
   wasteload allocations every 1 years to incorporate specific toxic control
   parameters in NPOES permits.

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                                       16
0  Assure municipal and industry compliance with pretreatment limits and NPDES
   permit requirements for toxicants.

0  Provide technical assistance on biomonitoring programs to assess the
   toxicity of municipal and industrial discharges.

0  Implement tissue residue monitoring activities to identify presence of
   toxic chemicals such as dioxin, dibenzofuran, etc.

0  Continue to refine standards for issuance of fish consumption advisories
   based on toxics levels in fish.

0  Ensure timely and appropriate State and EPA enforcement response to
   instances of significant noncompliance with NPDES permit requirement or
   pretreatment standards.

Headquarters Actions Needed

0  Develop standard sampling and analytical protocols for toxicants,
   particularly for short-term testing to surface potential toxicant problems
   which affect aquatic-life, human health, and wildlife (e.g.,  Ames test,
   chemical structure-activity, etc.).

0  Protocols to measure environmental conditions, pollution concentrations,
   and biota chemical  body burden before and after control actions are taken
   should be mads standard operating procedures for Federal, and State toxic
   programs.  Agencies should have to explain why this requirement is inappro-
   priate to obtain an exception.

0  Focus resources and direct activities of Headquarters compliance, permits.
   and ambient control on improved coordination for toxicant problems.

0  Provide additional  guidance on procedures and requirements to assure
   States review and reevaluate water quality standards and wasteload
   allocations every 3 years.

0  Place a higher national priority on continuing pretreatment program operations,
   particularly program audits, categorical standards enforcement, and evaluation
   of needs for local  toxicant limitations.

0  ORD needs to better coordinate its work with the Regions and  provide results,
   particularly of field work, in a significantly shorter time.

Expected Environmental Results

With strong EPA technical  and policy participation, the States are expected
to assess the needs for and establish local toxicant limits as part of the
pretreatment and NPDES permit implementation programs.  These actions should
also help convince the public that the regulatory process is working to assure
the safety of water resources.  The water resources themselves should eventually
be restored to their full  designated uses as natural cleansing mechanisms purge

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                                       17


toxics from waters and sediments, or heavily contaminated sediments are dredged.
Meanwhile, NPOES discharge limitations should reduce the reintroduction of toxic
substances to the environment.  There will  be a lag time between the clean-up or
discharge reductions and corresponding reductions in biota chemical  body burden,
but again, as the impact of toxic materials to water bodies decrease, so should
the levels of toxics in aquatic life.  So far, EPA has not placed any priority
on such before and after monitoring, so very little data is available.  This  is
a significant Agency oversight that should be corrected and become standard
procedure.

Contaminated Sludge

Problem Assessment

Many Region V waste treatment facilities have reached or exceeded their capacity
to store or properly dispose of contaminated sludge.  This problem may be
underestimated because of additional problem sludge management facilities that
have not yet been identified.  Runoff from contaminated sludge has deposited
varying amounts of pollutants in ditches, streams, lakes, and surface water
reservoirs.  This runoff causes taste and odor problems, as well as toxic sub-
stance contamination in drinking water supplies, toxic levels of pollutants in
surface waters, and hazards to aquatic life and public health.

Regional Agenda

 0  Provide technical and financial support to the States' remedial  initiatives
    to eliminate contaminated sludge sources.

 0  Work closely with the States to prepare a strategy for the elimination
    of improperly operated sludge management systems.

 0  Analyze the State inventories of contaminated sludge remedial  action plans
    to determine if additional sludge management control measures are needed.

 0  Upon promulgation of proposed Part 501  Regulations, work closely with the
    States to assure that contaminated sludge remedial action plans are inte-
    grated into new State Management Program Plans.

 0  Closely monitor how effective the States are in promoting and sustaining
    local agency remedial action initiatives.

 0  Work to develop fully integrated Federal, State, and local contami-
    nated sludge control programs.

 8  Refine and update the listing of identified "worst case" contaminated
    sludge problem areas on an ongoing basis.

Headquarters Actions Needed

 0  Complete the proposed Part 503 Technical Sludge Regulations, and proposed
    Part 501, State Sludge Management Program regulations and implementation
    guidelines.

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                                       18


 0  Conduct seminars within the Region to allow the States full  access to all
    available guidance.

 0  Develop and provide information on the best management practices,  structures,
    and methodologies for the elimination of contaminated sludge sources.  Serve
    as a clearinghouse of contaminated sludge remedial  action information.

 0  Coordinate and encourage participation of other Federal  and  State  agencies
    in remedial action initiatives to prevent and eliminate contaminated  sludge.

 0  Refine and update the national strategy on technical  sludge  regulations
    and contaminated sludge action initiatives.

Expected Environmental Results

The remedial action initiatives will redress previously neglected contaminated
sludge problems and restore environmental quality to acceptable  levels in
problem areas.  In addition, a consolidated strategy will anticipate and  prevent
future contaminated sludge environmental  problems.  The actual  Improvements in
water quality will be specific to the individual areas  where actions are  taken.
In some cases where contaminated sludge is threatening  or actually causing
problems in water supplies, the improvements may be significant.

D. IN-SITU POLLUTANTS

Problem Assessment

Most of the rivers and streams in industrial  areas have varying  levels of
contaminants.  The number of waterways known to have sediments containing
excessive levels of toxic contaminants has grown rapidly  in  rscent years, and
efforts are continuing to find and evaluate others.  Most of the existing data
is on PCB and pesticide contamination, though there is  some  inforraitlon on
other organic chemicals such as PAH.  Some of the waterways  that are known to
contain significant levels of contaminants are:

    0   Waukegan Harbor, Illinois
    0   Fields Brook and Ashtabula River, Ohio
    0   Sheboygan River, Wisconsin
    8   North Branch of the Chicago River, Illinois
    0   Grand Calumet River, Indiana, and Illinois
    0   Black River, Ohio
    0   Milwaukee Estuary, Wisconsin
    0   Indiana Harbor, Indiana
    0   Menominee River, Michigan and Wisconsin
    0   Fox River, Wisconsin
    0   St. Louis River, Minnesota

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                                       19
Regional Agenda:

Although the Region has significant Information regarding the extent of
contamination in the areas mentioned and investigations continue on others,
the ability of the Region or States to implement remedial programs is very
limited.  Dredging 1s the most often used remedial  action, but with a
few exceptions, the only dredging that has been done is navigation channel
maintenance by the Corps of Engineers (COE). EPA and States advise and
regulate the COE in these activities but generally have not been able to
increase the scope of the COE's navigation projects, to include desirable
clean-up activities.  There has been some exceptions, notably the proposed
dredging programs at Waukegan and Ashtabula, and the consent judgment with
U.S. Steel Corporation for dredging of the Black River, Ohio.

Following are some additional Region efforts to deal with 1n-situ pollutants:

    0  The In-Place Pollutant Task Force will  continue to coordinate Regional/
       State efforts; to investigate dredging and disposal options, available
       treatment technology, and methods of funding; and to develop site action
       plans.

    0  The Environmental Review Branch of the Planning & Management Division
       is preparing a Dredging/Disposal  policy document to clarify the roles
       of individual regional programs and criteria for evaluation of dredging
       and disposal projects.  A policy paper 1s to be completed in early FY 86.

    0  The Great Lakes National Program Office (GLNPO) is expecting to fund
       a multi-year demonstration program for in-place pollutants.

    0  The GLNPO is assessing sediment contamination in a number of areas to
       develop Area of Concern Remedial  Action Plans.

    0  Tne Environmental Services Division is developing a confined disposal
       policy for PCB contaminated sediments as a basis for TSCA permits.

    0  The Water Division, GLNPO, and ESD will evaluate coke oven discharges
       across the Region to see whether the associated PAH and metals sediment
       contamination found in the Black River, Ohio and Grand Calumet River,
       Indiana exists elsewhere.

    0  Several programs are working with the COE to evaluate innovative
       dredging and disposal approaches.  The COE is investigating advanced
       design confined disposal facilities (CDF) and other disposal approaches.

    8  The Water Division will continue to work with Headquarters to establish
       a National strategy for in-situ pollutants.

    Headquarters Actions Needed:

    8  Expedite development of sediment  contamination and action criteria and
       a structured implementation framework.

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                                       20
    0  Determine a basis for Agency remedial sediments programs through
       Section 115 of the Clean Water Act, modification of CERCLA's hazard
       ranking system, use of new RCRA regulatory authorities or other means.

    0  Analyze existing sediment data nationwide on contamination patterns
       to determine if further regulation is necessary.

    0  Support Regional Investigations of the waterways most susceptible to
       contamination.

Expected Environmental Results

The discussion immediately below, under Section D., PCBs, Expected Environ-
mental Results, covers the improvements expected from clean-ups of in-situ
pollutants, focusing on PCBs.  The discussion is applicable to other pollutants
as well.

PCBs

Problem Assessment

Polychlorinated biphenyls (PCBs) nave severely contaminated several Region V
waterways and contaminated a number of others to a degree where action is still
necessary.  Most of this contamination has been found to be from .facilities
located in these drainage areas.  An aggressive inspection and enforcement
program has uncovered numerous violations and resulted in a number of enforce-
ment actions.  This has largely eliminated VOC discharges and spills and
apparently, cleaned-up areas are not being reccntaminated.

The disposal of PC3 or otherwise contaminated sludge is - for technical, institu-
tional and financial reasons - very difficult.  The tremendous volume of wet
dredged material makes them prohibitively expensive to transport very far, to
incinerate, or to put in an approved waste landfill.  Therefore, an alternate  -
usually a CDF - is almost always sought.

A CDF is a vessel or enclosed area, usually constructed in or near the waterway
being dredged, built of graded limestone, protected with armor stone on the
outside and lined with silty sand on the inside.  CDFs are built to withstand
the largest recorded Great Lakes storm or even collisions with ships.  CDFs
are controversial because, while monitoring shows CDFs effectively retain the
sediments and their effluent meets specified discharge limitations, they are
permeable.  While permeability is not a severe problem with PCBs, trace quanti-
ties of other contaminants can be released over time.  Also, some critics still
question their long-term structural integrity and ability to withstand severe
storms.

Also, beyond the control of discharges and spills to *ater and contaminated sludge,
we are concerned with the environmentally safe disposal of PCB contaminated sedi-
ments.  Additional  work needs to focus on alternative disposal technologies.

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                                       21


Regional Agenda

0  The Regional TSCA program focuses on ending active PCB discharges.   With
   approximately 8,000 facilities in the Region subject to the PCB regulations,
   Region V projects that approximately 700 facilities will  be inspected  during
   the next year for compliance with these regulations.

0  The Regional TSCA program has developed a draft Regional  PCB cleanup
   policy which is being reviewed by the States and by Headquarters.   The
   Regional policy will be implemented until  a national  policy is  developed.

0  Water Division and the Environmental Services Division will jointly determine
   the impact of in-place PCB on the attainment of water quality standards  that
   protect designated uses.

0  Clean-up of PCB contaminated sediments is being evaluated or conducted by  the
   Superfund program in a number of Regional  areas where the contamination  threatens
   public health.  In other areas, where the contamination is unknown  or  less of a
   direct threat, the COE is the lead agency, involving the Superfund  program as
   appropriate.  Some of the areas EPA and/or COE are addressing contaminated sedi-
   ments include:

     - Sheboygan Harbor, Wisconsin
     - Ashtabula Harbor/Field's Bronx, Ohio
     - Waukegan Harbor, Illinois
     - Green Bay, Wisconsin
     - Lorain, Ohio
     - Chicago, Illinois
     - East Chicago, Indiana

Headquarters Actions Needed

0  Develop a uniform National  Policy to address clean-up of PCB contaminated
   sediments to an acceptably safe level.

0  Continue funding for research and development of methoas  for analyzing
   sediment samples for PCBs.

0  Provide R&D projects for methods to break  down PCBs in moist sediments,  sludges,
   and soils into a non-toxic form.  This would be most important  to treat  in-situ
   sediment contamination.

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                                      22
Expected Environmental Results

In some of the most Intensively studied areas, such as Saglnaw Bay, direct
discharges to tributaries appear to have been eliminated by NPDES permit
limitations, spill controls, and leakage abatement efforts.  EPA has not
consistently followed-up on the monitoring of post-activity environmental
conditions, but we can provide some Indicators of the results we expect.  At
Saginaw Bay, the COE has dredged the navigation channel.  Prior to about 1976,
the sediments 1n the channel averaged 10-20 ppm of PCBs, but there are PCB
contaminated hot spots - in the River but outside the dredged navigation channel
- that far exceed that concentration.  Due to continuing projects to dredge
and dispose of contaminated channel sediments, the remaining sediments now
average about 2 ppm, and have maintained this level - they do not seem to be
accumulating any more PCB.  Apparently, the discharges have stopped.  In time,
the lower levels of sediment and water contamination should restore beneficial
water quality uses and lower the PCB levels in aquatic life.

E. VIOLATION OF PRIMARY AMBIENT AIR QUALITY STANDARDS

Note:  There is a separate Air Addendum included as Appendix B, which presents
a great deal of quality environmental indicators and data.  This Addendum should
be referred to as it is referenced in this Part II narrative.

Problem Assessment

Region V has experienced numerous violations of ambient air quality standards
for several pollutants.  Except for Minnesota, violations of the ozone NAAQS in
Region V have been widespread ana persistent, affecting some 31 milltan people.
Violations were particularly severe in several large urban areas, requiring the
implementation of inspection and maintenance (I/M) programs.  Several  of these
areas will probably not attain the ozone standard by the Clean Air Act's 1987
deadline.

Monitored ambient SO? violations are much less widespread.  Wisconsin is the
only State in the Region which has recently experienced such violations.  S02
remains a pollutant of concern in Region V because of the widespread use of
high sulfur Midwest coal by industries and electric utilities.  The use of
taller stacks for pollutant dispersal, modern control technology (e.g., flue
gas desulfurization), and selective use of lower sulfur coal has largely
eliminated ambient monitored violations.  However, dispersion modeling analysis
has indicated much remains to be done in Region V's S0£ control program.  There-
fore, decisions regarding the selection and application of dispersion models can
have major impacts on the SOg control program.  These decisions can necessitate
major reanalysis of Region V SOg SIPs, to address such issues as tall  stack
regulations, block vs running averaging in modeling, etc.  Although SIP limi-
tations are in place for most sources, Wisconsin does not yet have statewide
regulations, and individual  sources in other States may require revised
1 imitations.

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                                       23


Particulate matter has traditionally been Region V's major air pollution concern.
The high concentration of heavy manufacturing facilities, (e.g., integrated iron
and steel mills) in combination with the general TSP emissions associated with an
urban environment (e.g., industrial fugitive dust, reentrained road dust, etc.),
have caused widespread violations of the TSP standards in Region V.  Other than
enforcement, the Region's regulatory program has been held in abeyance by unre-
solved policy issues of an air quality standard for fine particulate matter.

Regional Agenda

0  Ozone

   Region V has initiated a variety of actions to address primary ozone violations,
   including a vigorous enforcement program which inspected over 90 percent of the
   sources in the nonattainment areas in FY 85, a mobile source control  program
   which has stressed I/M for all major urban areas with 1987 attainment date
   extensions, and an anti-tampering/fuel switching program for several  States.
   Also, control regulations have been adopted and are being implemented for
   numerous categories of stationary sources, with regulations for the remaining
   major sources under development for all  major urban nonattainment areas.

   For FY 86, Region V's ozone control activities will focus on sustaining and
   completing current initiatives.  Tne enforcement program will inspect major
   sources in accordance with SPMS requirements and take expeditious enforcement
   actions as in accord with the State-EPA enforcement agreements (SEEA).  The
   regulatory program's first priority is resolving remaining SIP issues and
   getting approved SIPs in place.  Other regulatory priorities are developing
   ant^tampering/misfueling programs in selected States/local areas, estab-
   lishing I/M in the 3 remaining States, and obtaining a suitable enforcement
   mechanism for Indiana's I/M program.  Federal funding and other restrictions
   may have to be placed on areas failing to develop and implement approved
   SIPs.

0  Sulfur Dioxide (503)

   In FY 86, Region V's S02 control programs, while being a lower priority than
   ozone, particulates, and air toxics, will focus on resolving S02 SIP issues
   in a number of states.  The major state-specific efforts will be to:

   0  Illinois and Michigan - review and rulemake on the S02 SIPs for several
      small areas that received SIP deficiency notices;

   0  Wisconsin - review and rulemake on the first comprehensive statewide $03
      SIP;

   0  Indiana - analyze and address the effects of recent court decisions
      on the statewide S02 SIP;

   0  Ohio - resolve tne current interim enforcement policy.

   Overall, the Region will  be dealing with all  the States in implementing
   tne recently promulgated tall stack regulations, inspecting major sources
   ac:ording to SPMS requirements, and taking expeditious enforcement actions
   in accordance with national  guidance and SEEAs.  Also, the Region wil1  be
   tricing witn the States to revise their SO? monitoring networks and replace
   obsolete and worn-out equipment.

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                                       24
   Regions V and I will be the lead Regions for development of national policy
   and direction for the SO? control program.  This initiative will  focus on
   the resolution of several unresolved rulemaking issues (e.g., block vs running
   averaging times, ambient standards, etc.) and enforcement initiatives (e.g.,
   use of CEMs, nationally consistent enforcement policies, etc.).

0  Particulates

   The Region will continue to work with Ohio on the development and promul-
   gation of an approvable Ohio TSP SIP.  Also, recent court decisions will
   require Federal promulgation of partial or complete TSP SIPs for  Illinois,
   Indiana and Michigan.  The enforcement program will inspect major sources
   in accordance with SPMS requirements and take expeditious enforcement
   actions.  Enforcement initiatives will include efforts to enforce existing
   State fugitive dust regulations.  Monitoring activities will focus on
   collection of TSP data.

   In response to the proposed PM-10 standard, the Region will be working with
   the States to develop technical information so they will be able  to develop
   an approvable SIP when the PM-10 standard is finalized.  Monitoring activi-
   ties will focus on data collection from existing PM-10 monitors as well  as
   the siting of additional PM-10 monitors.

Headquarters Actions Needed

0 Ozone

  0 Complete Control ,echnique Guidelines for Group III source categories.

  0 Provide assistance as necessary on available controls for major  non-CTG
    sources.

  0 Clarify guidance on requirements for control  of major non-CTG sources.

  0 Provide a final decision on Stage II vapor recovery.

  0 Provide updated policy on requirements for approvable 1982 ozone SIPs.

  0 Promulgate the Benzene NESHAPS for coke oven by-product plants on schedule.

  0 Provide a final national  decision on the appropriate  legal  and technical
    means for granting compliance extensions to VOC sources.

  0 Provide Agency policy on implementation of anti-tampering/anti-fuel  switch-
    ing programs.

8 S02

  0 Resolve outstanding issues effecting establishment of SOg emission
    limitations; for example:  running vs. block averages, changes to Guide-
    line on Air Quality Models, sulfur variability in fuel  compliance test
    method, and averaging time.

  0 Resolve existing inconsis*»icies in the enforcement of $03 regulations
    across the nation.

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                                       25
0 TSP

  0 Finalize the PM-10 standard.

  0 Provide an updated policy on the requirements for an approvable TSP  SIP
    for Part D of the Clean Air Act.

  0 Provide technical support for PM-10 attainment demonstrations;  for example:
    emission factors, particle size distributions.

Expected Environmental Results

0  Ozone

   Because of its control efforts, the Region expects a continued reduction
   in the magnitude and extent of the ozone problem.  The maps on pages  1
   and 2 of the Air Addendum (see Appendix B) illustrates the changes  In
   designated ozone nonattainment areas between 1979 and 1985.  In  general,
   these maps indicate a shrinking of the nonattainment areas with  the
   remaining areas centering on major urbanized areas in the Region.  While
   the charts on pages 3 and 4 demonstrate a diminished geographic  extent  of
   ozone nonattainment, the population exposed to elevated ozone levels  has
   only decreased 20% between 1978 and 1985.  The charts on pages 5 and  6
   demonstrate ozone levels and numbers of exceedances for the Milwaukee
   nonattainment area.  While the design value for the area has not changed
   significantly between 1979 and 1983, there is an apparent downward  trend
   in the number of exceedance days.  The graphs on page 7 demonstrates  the
   projection of reasonable further progress in emission reductions expected
   in the Milwaukee area.  Since the Milwaukee 1982 ozone SIP is the only
   finally approved extension area SIP in the Region, it is the only ozone
   extension area with a reasonable further progress (RFP) demonstration.
   As other extension area SIPs are approved, similar RFP information  will
   become available.  Finally, the chart on page 8 demonstrates the expected
   VOC emission reductions from known violators in the Milwaukee area.  This
   chart will  change throughout the year as more violators are identified  and
   existing cases against violators are resolved.  Similar charts are  included
   for the ozone extension areas which summarize the direct environmental
   improvement attributable to enforcement actions, as well as graphs  showing
   trends in number of exceedance days.

0  S02

   The Region expects that the direct environmental  results of its  502 efforts
   in FY 36 will  be limited.  The charts on pages 28 and 29 of the  Air Addendum
   indicate the change in $63 nonattainment areas between 1978 and  1985.  As
   graphs show, comparatively little change has occurred in the designated
   nonattainment areas.  The charts on pages 30 and 31 indicate a relatively
   small percentage of the population in the Region is exposed to $03  nonattain-
   ment and that level has dropped 23 percent between 1978 and 1985.  In FY 86,
   the Region expects further reductions in population exposure as  resolution
   of the Minnesota S02 SI? and designations are completed.  However,  if
   unilateral  nonattainment designations by EPA were still  allowable under
   Section 107 and Part 0 of the Clean Air Act, the Region would expect  the
   number of designated nonattainment areas to increase, mainly in  Indiana
   ana Wisconsin.

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                                       26
0  TSP

   The Region expects limited direct environmental effects of its TSP efforts
   in FY 86.  The maps on pages 32 and 33 of the Air Addendum show the modest
   changes in designated TSP nonattainment areas in Region V between 1978 and
   1985.  The charts on pages 34 and 35 indicate a 33 percent reduction in
   the number of people exposed to TSP nonattainment between 1978 and 1985.
   The Region expects continued improvement in FY 86 predominately due to re-
   designation of nonattainment areas in Ohio and Wisconsin.  The charts on
   pages 36 to 41 indicate a reduction in the magnitude and frequency of TSP
   exceedances in three major metropolitan areas.  The Region expects this
   trend to continue in FY 86.  The Region's FY 86 TSP SIPs development program
   will not have direct and immediate environmental results but will  establish
   regulations which will reduce the pollution in the future.

F. SYNTHETIC ORGANIC CHEMICAL CONTAMINATION OF DRINKING WATER
Problem Assessment

Historically, groundwater has been viewed as a relatively pristine resource,
and has generally been used as a drinking water source without major treatment
other than disinfection.  However, the 1981  National  Groundwater Survey, which
provided a random sampling of groundwater systems across the country, indicated
that a significant number uf drinking water sources had measurable levels of
contamination from synthetic volatile organic chemicals (VOCs).  Those findings
have effected the current systematic efforts of Region V's Drinking Water
Program to achieve complete VOC monitoring in Indiana and the primacy States'
commitments to VOC monitoring.  To date, Region V State and Federal  drinking
water programs have cumulatively analyzed approximately 6,872 out of 15,634
(44 percent) community water wells for VOC compounds.  The current totals
indicate that at least 440 (6.4 percent) of those tested wells have been shown
to contain some VOCs.  This sampling program has a high priority in the Drinking
Water Program to detect VOC contamination before they become serious public
health problems.

VOC contamination involves two major concerns that have not yet been fully
addressed.  The first concern is the existing health  risk to people using a
contaminated source of drinking water.  With the increasing number of v'OC
detections, it is essential that more health advisory information be provided
to the Region to better evaluate the risks.   The other major concern 1s the
potential  for futjre/further contamination of groundwater sources of drinking
water.  The fact that these contaminants are all  synthetic, indicates that
contamination is due to human activities.  The levels of health risk and the
activities causing the contamination can both be best assessed through a
consistent synthetic volatile organic chemical testing program in all States.

Regional  Agenda

0  Continue the VOC monitoring program in Indiana and on all  Indian
   lands to complete sampling all community  water system wells by the
   first quarter of FY 37.

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                                    •II
0  Assure that the public is notified by water suppliers if.contamination
   is found.

0  Continue to encourage primacy States to complete all  VOC monitoring,
   consistent with this strategy within four years.

0  Compile all quarterly monitoring program findings into an automated
   data system for future tracking and reporting.

0  Routinely alert the Regional Superfund program 1f high levels of
   contamination are found.

0  Correct drinking water problems when VOC's are found, including use
   of the Superfund program.

0  Re-test systems that have been found to be contaminated with VOC's
   on a regular basis.

0  Provide State program grants to increase laboratory capacity and
   capability.

0  Provide information and technical  assistance to States, and other
   Federal Agencies.

0  Coordinate closely with the Superfund and RCRA programs to ensure
   that drinking water technical and  health effects considerations are
   properly addressed at all sites.

0  Participate on the Regional  Ground Water Coordinating Comnr. *ee to
   address synthetic volatile organic chemical  concerns.

Headquarters Actions Needed

0  Increase research and development  efforts to:

   0  Develop surrogate methods of detecting VOCs in drinking water.

   0  Reduce the costs of testing samples (current average cost is
      $300/sample).

0  Promulgate regulations concerning  VOC maximum contaminant  levels
   (MCLs) and monitoring requirements on schedule.

0  Provide the Regions with comprehensive health advisory information
   which includes a broader spectrum  of synthetic volatile organic
   chemical  contaminants and multi-route exposure scenarios.

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                                    28
Expected Environmental Results

Actual environmental results (as opposed to program actions) are difficult
to quantify due to the lack of federal regulations and consistent State
reporting requirements.  With about one-half of the Region V water supplies
tested, an estimated 4.5 million people depend in some part on water supplies
that have detectable VOCs.  Thus far, contaminations estimated to be greater
than the 1x10-6 excess lifetime cancer risk have been confirmed in about 237
(3.4 percent) of the tested wells and greater than the 1x10-5 excess risk in
104 (1.5 percent) of the wells.  The current VOC findings have led to the
removal of at least 60 public drinking water wells from routine service.  At
other  sites, VOC removal treatment systems has been installed.  And at the
remaining locations, the options of either treatment or providing new water
sources is being studied by State and local authorities.

The Region V Superfund program is routinely alerted if unexplained high
contamination levels are found in a water supply.  Several of Region V's
largest Superfund sites were initially discovered by the drinking
program through their monitoring.

G. TOXIC SUBSTANCES - EXISTING CHEMICALS
1. Pesticide Misuse

Problem Assessment

Because of extensive agricultural production, the Region V area is among
the highest pesticide users in the country.  About 20 percent of the
national total (one hundred and eighty million pounds) of pesticides are
used in Region V annually.  Region v also has 26 percent of the pesticide
producing facilities, which manufacture about 280 million pounds of
pesticides annually.

The highest rates of violations have been found among the following user
groups:  aerial application (40%), agricultural ground application (30%),
and nonagricultural application structural usage (25»).  These rates
may not reflect true environmental exposure because most use compliance
monitoring data is tabulated from citizen complaints and other "for cause"
investigations.  Nevertheless, pesticide use violations can and must be
reduced and vigorous enforcement taken in cases where there is the poten-
tial for environmental damage.  State/EPA enforcement agreements negotiated
yearly will be the primary tool for shaping program direction and pesticide
use enforcement programs.

The greater sensitivity of new analytic tools has recognized an increasing
problem of groundwater pesticide contamination even with properly applied
pesticides.  AldicarD, a systemic carbamate insecticide used in Wisconsin,
has been detected in groundwater at 1 ppb up to 111 ppb.  Triazine-type
herbicides have been detected in Ohio and Wisconsin at low ppb levels.
Even though groundwater contamination can result from proper use, additional
jse compliance activities are needed to minimize the problem wherever

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                                    29
Regional/State Agenda

0  The EPA/State pesticide use and marketing enforcement agreements, funded
   partially by EPA, are the cornerstone of a coordinated enforcement program
   directed at use compliance programs.

0  Continue to upgrade State programs to train and certify applicators
   in the proper use of pesticides.

0  Priorities are set for use compliance programs by the cooperative
   agreements in accordance with the annual National Pesticide Guidance.
   Region V's current use compliance priorities are:

   0  pesticide drift and overspray violations for both ground and
      aerial applications,

   0  structural/urban pest control application violations
          a. exposure to humans and domestic animals
          b. damage to gardens and trees/shrubs

   0  pesticide and pesticide container disposal,

   0  pesticide runoff from storage and handling facilities,

   0  other general use inconsistent with label practices violations, and

Headquarters Actions Needed

0  Establish standards for consistent label directions and precautions
   (Label  Improvement Program).

0  Continue funding and national  direction to promote State use compliance
   programs and certification programs.

0  Implement the National  Pesticide Monitoring Plan to collect pesticide
   data on groundwater, surface water, soil and air.

Expected Environmental Results

0  Reduced levels of pesticides in human tissue.

0  Resurgence of wildlife populations previously suspected of being
   endangered/threatened by pesticides in the environment.

0  Reduced pesticide contamination of groundwater, surface water, soil,  and
   air.

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                                    30

2. Asbestos

Problem Assessment

There are 2 primary EPA asbestos related programs.  The first and largest
is the Asbestos-In-Schools program.  In this program, EPA is concerned with
the disease-causing potential of intermittent low-level exposures to asbestos.
The durability, small size, and fiberous shape of asbestos fibers, allow them
to remain airborne for long periods of time.  Under section 6A of TSCA, the
Agency has taken steps to minimize the exposure of school  children to asbestos
by mandating that both public and private schools perform Inspections for
friable asbestos-containing materials.  EPA then requires school officials to
notify other school employees and parents of the dangers of that school.  While
we have no further authority to require corrective actions, public concern and
pressures on the school systems usually results in corrective actions.

The second, smaller EPA program is the air media's NESHAPs, which limits
airborne emissions from manufacturing use, demolition, renovation, and waste
disposal of asbestos.

Regional Agenda

8  Region V, using the American Association of Retired Persons (AARP) and
   Regional personnel, will accelerate the compliance monitoring inspections
   of schools as well as disseminate technical  information and guidance.

0  Region V projects that approximately 400 local educational agencies will be
   inspected during FY 86 for compliance with the Asbestos-in-Schools Rule.

3  Wisconsin will be awarcdJ a grant to conduct school asbestos compliance
   inspections which will continue as long as Federal funding is available.

   This active program should bring noncomplying facilities into compliance
   with the regulation, as well  as provide technical  assistance to school
   officials on abating asbestos problems.

3  Under the Asbestos School  Hazard Abatanent Act (ASHAA), approximately
   $45 million in Federal grants and loans will  be available in FY 86 to
   help abate asbestos in schools with potential  health hazards.  In
   Region V, approximately 75 schools may receive Federal  funding for
   asbestos abatement projects.

0  The Air Management Division will provide 105 grant funding for and
   assure State program wor
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                                    31
0  EPA needs to continue funding the ASHAA program to correct the asbestos
   problems.

0  Headquarters should assess the overall national compliance Inspections
   progress and success rate of the existing regulatory process in resolving
   school asbestos problems.

Expected Environmental Results

The NESHAPs asbestos program should help limit the public's exposure to
fugitive asbestos particulates in the ambient air.  The actual  environmental
improvement would be very site-specific, but - as anyone Mho has observed
building demolition without dust suppression measures can attest - the
improved protection can be significant.

An EPA report entitled, "Airborne Asbestos Levels in Schools" documents
tne higher levels of airborne asbestos particles in schools with friable
asbestos containing materials.  The mean levels of airborne asbestos at
all the schools tested prior to remedial actions was about 179  ng/m^.
After corrections, studies of airborne asbestos at these same schools
showed a reduction of airborne asbestos to about 6 ng/m3, about the
background level of asbestos in outdoor air.  While individual  schools
in Region V may have higher or lower levels than the study mean, we can
expect similar improvements in the quality of the air in those  schools -
that is, almost the complete elimination of any excess exposure or risk.

H. AIR TOXICS


Problem Assessment

The toxic air pollutants problem in Region V is currently difficult to assess.
Because of the type and extent of industrialization within Region V, a multi-
tude of potentially toxic chemicals are emitted into the air.  Since so few
chemicals are regulated under existing air programs, no recordkeeping is
required for thousands of these chemicals.  Therefore, the quantity, type, and
extent of the problem is largely unknown.

Air toxics are also a threat to other media, since the atmosphere acts as  a
pathway between the contaminant source and the water and soil.   This is of
particular importance to the Great Lakes, which receive up to 55 percent of
their PCB and essentially all of their toxaphene loading from the atmosphere.

The regulatory program is an issue in itself.  Of the thousands of potentially
toxic air emissions, the National  Emissions Standards for Hazardous Air Pollutants
(NESHAPS) program has promulgated regulations for only five source categories and
has listed only seven pollutants.  The USEPA has been promoting various activities
at the Regional level to encourage States to initiate programs  within their own
authorities.  Further, the Agency is presently exploring an alternate approach to
NESHAPS Dy placing State and local agencies in the lead to make technical  assess-
nents and decisions to ^egulate pollutants with a low national  incidence but high
local risk.  But as of yet, EPA has not defined the characteristics of a Das
State air toxics program.

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                                    32

Regional Agenda

0  The Regional program in FY 86 will continue to focus on improving State
   and local capabilities to characterize, monitor, and control hazardous
   air pollutants.  Regional plans include efforts to improve stack and
   ambient monitoring capabilities through technical assistance and imple-
   mentation of pilot toxic air pollutant monitoring projects at selected
   locations.  The Region will continue to conduct and manage risk assess-
   ments to determine whether control is appropriate.  Further, the Region
   will work closely with State and local agencies, especially in Ohio,
   Michigan and Illinois relating to acrylonitrile, the first air toxic
   chemical to be addressed using the State/local option.  The Region will
   encourage programs under State authority by providing Section 105 grant
   resources and technical assistance, as well as issuing a regular air
   toxics newsletter to share experience and information on toxic air
   pollutant problems, sources, and remedies.  States will be encouraged
   and assisted to evaluate possible monitoring sites, conduct source
   surveys, review emissions inventories, perform risk assessments, develop
   permit programs, and take compliance actions.  The Region will continue
   analyses of the air toxics problem in Southeast Chicago, focusing on
   estimating the extent and magnitude of the air toxics problem, estimating
   emissions for specific toxic compounds, performing dispersion modeling of
   sources of these compounds, and conducting.exposure risk analyses.

Headquarters Actions Needed

0  Provide information on health effects, emission sources, monitoring methods,
   and acceptable risks.

0  Decide what actions are needed to implement the results of the national
   study, The Magnitude and Nature of the Air Toxics Problem in the United
   States.

0  Define the National/International  nature of the air toxics deposition
   problem.

0  Further guidance on control procedures and other possible candidate pol-
   lutants to effectively implement the State/local  approach to air toxics.

0  Define characteristics of a base State Air Toxics program.

Expected Environmental Results

Since the Air Toxics program is still relatively under-developed, specific
environmental indicators do not yet exist.  Certainly, the Region believes
that analysis, regulatory decisions,  and aggressive enforcement of existing
NESHAPS standards can mitigate risks  in some cases.  However, given the broad
array of potential  air toxics compounds, complete risk analyses for every
area and every chemical  in Region V is not feasible.  The Region believes that
consistent with Agency's "six months  study", the best indicators of general
air toxics risks are the conventional pollutants, TSP and VOC.  Therefore, the
Region expects that continued improvement in TSP air quality and reductions
in VOC emissions will reduce the Regional air toxics problem.  In specific
area studies, such  as Southeast Chicago, it may be possible to better charac-
terize ambient levels of specific toxic compounds.  That study may lead to a
better understanding of appropriat  . methods for characterizing and tracking
air toxics problems.

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                                      33

I. GREAT LAKES AREAS OF CONCERN


Problem Assessment

The Water Quality Board of the International Joint Commission (IJC)  has Iden-
tified 42 localized "Areas of Concern" (see Figure 1, Appendix C) 1n the
Great Lakes Basin where environmental quality is degraded or beneficial water
uses adversely affected beyond guidelines established by the Great Lakes Water
Quality Agreement.  Of these, 30 are located (wholly or partially) within the
United States.  Although these areas constitute only a relatively small portion
of the total area of the Basin, they contain a large percentage of the Basin's
population and industry and are concentrated loading points for many pollutants.

Over the past 10 years, the environmental quality in the Areas of Concern (AOCs)
have improved considerably, particularly problems associated with conventional
pollutants (such as BOD, suspended solids, and oil and grease) and some heavy
metals such as mercury.  While 27 of the 42 areas still have some problems
associated with conventional pollutants, remedial actions have reduced the
severity and extent of these problems.

In these AOCs with remaining conventional problems, control measures currently
in place are inadequate to solve some or all of the following problems:
municipal and industrial discharge control, leachate from waste disposal sites,
combined sewer overflows, urban land and agricultural runoff, and in-place pol-
lutants.  For example, municipal and industrial  dischargers are not  adequately
controlled in the Grand Calumet River/Indiana Harbor Canal; pretreatment pro-
grams are inadequate at the Black River in Ohio, the Buffalo and Ninara Rivers
in New York, and at Massena, New York.  Unsecured waste disposal sites are
leaching toxic substances into the Grand Calumet River/Indiana Harbor Canal
areas, the Black and Cuyahoga Rivers in Ohio; and the Ashtabula, Niagara and
St. Lawrence Rivers, and the Massena area of New York.

Several areas need construction projects to reduce various pollutant loadings
emanating from combined sewer overflows and urban land runoff, including the
Rouge River Basin, the Detroit area, and the Grand Calumet River/Indiana Harbor
Canal area.  Environmental  improvements that could be expected from  control
of specific CSO and urban runoff sources are not completed identified, and
correcting these sources is an expensive, lengthy process.  In some  other areas,
agricultural runoff is the major water quality problem.  Projects have been
initiated in the Saginaw Bay/River Basin to demonstrate cost-effective runoff
reduction techniques, but continued funding for these projects is not assured
and no other long-term programs are in place to control agricultural  runoff.

Most of the remaining problems are non-conventional problems of toxic sediments
contaminated by past discharges.  Their effects on water quality, aquatic life
and overall environmental integrity vary by site and are often not well under-
stood or documented.  Although GLNPO is studying whether natural processes will
eventually restore the ecosystem in the Great Lakes connecting channels, it  is
doubtful whether some areas, including the Grand Calumet River/Indiana Harbor
Canal, the Rouge and Raisin Rivers in Michigan,  the Cuyahoga and Ashtabula Rivers
of Ohio, and the Buffalo River in New York can be fully restored to  the quality
levels called for in the 1978 Great Lakes Water Quality Agreement without
.-iditional  remedial  efforts.  Even if all practical controls are implemented  in
t.nese areas, sediments will  remain degraded, and will require special  programs
for remediation.

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                                      34

Regional Agenda

The GLNPO does not Implement any control programs of Its own.  Instead,  it  acts
in concert with the IJC as a research and coordinative body that advocates  and
directs actions by other regulatory control programs.  Obviously, coordinating
the multitude of activities by all the various actors 1s a tremendous task, and
the IJC has recently revised its approach to the AOCs.  All the Great Lakes
jurisdictions have agreed to prepare Remedial Action Plans, which the IJC Water
Quality Board will subsequently review to assess their adequacy.  Because the
AOCs are not located on free flowing streams, standard problem assessment methods
are often not applicable.  The new Remedial Action Plan process to assess and
evaluate the actual results of the remedial actions taken should provide better
estimates of the relative benefits of various control activities.  While several
plans are completed, all Plans are expected to be completed and submitted by the
end of 1986.

The Remedial Action Plans describe environmental conditions, identify sources,
detail needed corrective actions, specify roles, delineate implementation actions
and schedule needed activities.  The plans also describe surveillance and monitoring
to track program effectiveness.  If it is deemed infeaslble to restore all  water
quality uses, then the Plan will identify the quality and uses which can be achieved.
Some of the activities GLNPO and cooperating programs will be implementing  in FY  86
include:

0  Implement specific portions of the Great Lakes National Program Office
   five-year strategy that support AOCs, including preparation of Remedial
   Action Plans to specify environmental conditions and sources of
   contamination; detail corrective actions, responsibilities, schedules;
   and establish mechanisms to monitor plan effectiveness.  (See Appendix C
   for complete description)

0  Complete prototype plans for the Rouge River and Indiana Harbor, and  initiate
   plans for Lower Fox/Southern Green Bay; Waukegan Harbor, Sayinaw Say, Detroit
   River/Lake St. Clair/St. Clair River, Black River, Raisin River, and  the
   Buffalo/Niagara area.

0  Track the environmental effects of remedial plans in Waukegan Harbor  (through
   fish flesh monitoring), and all otner areas where feasible.

0  Finalize draft Lake Erie/Saginaw Bay Phosphorus Load Reduction plan.

0  Extend the "Master Plan" for the Grand Calumet River/Indiana Harbor Canal  to
   nearby Lake Michigan.

0  Implement the recommendations of the "Report on Lake Michigan Total Maximum
   Daily Loads", that specify actions that must be taken by U.S. EPA and the
   States to ensure that Great Lakes water quality standards are not violated.

0  Expedite water quality standards reviews associated with AOCs and ensure
   that special  attention is given to toxicants.

0  Ensure that States rigorously review permits that impact AOCs prior to
   permit reissuance, and tnat pretreatment programs are incorporated into
   those permits.

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                                       35


0  Provide guidance to Regions and States to develop the Regulatory Authority
   to control atmospheric deposition under the State/Local option:  (See H,
   Air Toxics) Focus this authority on those lake contaminants whose primary
   source is air deposition.

Headquarters Actions Needed


0  Develop national standards and methods for removing, containing, or
   stabilizing in-place pollutants.

0  Continue to refine standards for issuance of fish consumption advisories
   based on toxics levels in fish.

0  Funds and advocate research on and development of estuarine and
   large lakes computer models to aid remedial efforts.

0  Complete all effluent guidelines with special  emphasis on toxicants.

Expected Environmental Results

Major water quality improvements have come from compliance with basic require-
ments for best practical treatment for industry and secondary treatment for
municipal discharges.  However, with minor exceptions, little further improvement
can be expected without additional pollutant reductions.

While the Remedial Action Plans may provide emphasis and importance for
actions, the real environmental improvements will come only with the
implementation and success of ot.ier programs, such as CSO reductions,
NPOES permitting, and Superfund.

J. NONPOINT SOURCE RUNOFF 70 WATER


Problem Assessment

Farming is a major industry in Region V, and improper management of agricultural
land has created extensive nonpoint source (NPS)  water quality problems -  many
of whicn could be prevented or corrected through  proper soil management techniques
without hindering crop production.  Runoff from agricultural lands transports
varying amounts of agriculturally-related NPS pollutants (nutrients, pesticides,
and organic and inorganic particulate material) which are deposited in ditches,
wetlands, streams, lakes and reservoirs.  Excessive erosion and runoff containing
animal wastes often cause dissolved oxygen reductions, accelerated sedimentation,
along with high levels of nutrients and residual  pesticides in those water bodies.
Nutrients, especially phosphorus, adhere to eroded soil particles, causing excess-
ive algae growths and other undesireable aquatic  vegetation.  NPS runoff can cause
problems with almost all uses of water, including taste and odor problems, oxygen
depletion, and toxic levels of chemicals.  These  problems can cause direct harrri
and loss of habitat for aquatic life, detrimentally affect drinking water, and
cause sufficient bioaccumulation of toxic chemicals in fish to pose a hazard to
to consumers.

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                                      36

Regional Agenda

0  Provide technical and financial support through Sections 106, 108, and
   205j of the Clean Water Act to strengthen the States'  role in NPS water
   pollution control, and assure that Regional NPS control  needs are fully
   considered during program grants negotiations.

0  Provide technical assistance to 6LNPO to assure the Section 108 projects
   benefit NPS water quality problems.

0  Work with GLNPO and the States to develop and implement  water quality
   based herbicide-free and herbicide-reduced agricultural  NPS abatement
   strategies and projects to minimize herbicide loadings and correct
   other identified water quality problems.

8  Work with GLNPO to assure that the NPS strategies and  programs in Indiana,
   Michigan and Ohio reflects their roles in the Great Lakes Phosphorus
   Reduction Plan.

0  Document, evaluate, and analyze existing data to define  the water quality
   impacts of agricultural NPS pollution.  Where data are inadequate to do  this,
   develop plans to obtain the appropriate information.

0  Assist States and other Federal agencies in evaluating and analyzing
   State control strategy implementation, including NPS project plans ar.d
   individual Best Management Practices.

0  Initiate or follow-up contacts with other Federal agencies and private
   organizations to support both group's participation in NPS prevention
   and control programs.

0  Either independently or in coordination in EPA Headquarters, provide
   direct support and assistance to innovative State or local NPS projects
   with tne potential to mitigate newly identified or emerging NPS-related
   problems.

°  Work with water quality control and soil conservation  agencies to establish
   jointly funded projects that serve both soil  conservation and water quality
   management.

Headquarters Actions Needed

0  Implement the USEPA Nonpoint Source Policy and Strategy  in its entirety,
   based on existing authority under the Clean Water Act.

0  Develop and provide technical guidance and data on analytical methodologies,
   best management practices, management structures and financing.

0  Provide a central clearinghouse for NPS water quality  information.

0  Coordinate/encourage participation through programs of other Federal  agencies
   in State-selected projects.

-  Refine and update National  NPS Policy and Strategy as  needed.

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                                        37
 Environmental  Results  Expected

 The water  quality benefits of erosion, pesticide, and nutrient loss control
 are well documented  and measured by the reduction of use impairments.  State
 strategies to  reduce erosion and agricultural chemical discharges to water
 bodies will  reduce nuisance vegetation, turbidity, and pesticide  levels,
 and improve  the quality of fisheries and surface water supplies.  The actual
 amount of  improvement  is site specific and depends on the extent and success
 of Individual  projects.

 Indicators of  expected environmental results can be drawn from such examples
 as the Blue  Creek Watershed Project.  The main water body, Pittsfield City
 Lake, had  identified drinking water supply and recreational use impairments
 due to agricultural  runoff and sedimentation.  Over a 3-year period, USEPA
 and the Department of Agricultural implemented a joint demonstration project
 with local farmers and others, implementing erosion control practices.  These
 practices  reduced soil erosion by over one-third, which reduced sedimentation
 in Pittsfield  City Lake by 25 percent and phosphorus by 17 percent.  There
 were significant improvements in recreational use due to the decreased rate of
 sedimentation  and levels of in-lake turbidity.

 Over the next years, sixty-one watersheds have been targeted to receive accelerated
 technical  and  cost-sharing assistance to correct NPS problems.  We expect the
 implementation of nutrient management, terraces, vegetative coverages, conservation
 tillage, and best pesticide management practices on critical lands within these
 watersheds will reduce pollutant and sediment loadings by an average of 60 percent.
 We have calculated the following ranges of water quality improvements from imple-
 menting these  practices in various areas:
   0 60-95 percent phosphorus reduction
   0 55-90 percent nitrogen reduction
   0 75-95 percent sedimentation reduction
   0 50-90 percent pesticide Deduction
While these improvements will take some time to actually have their effects,
they will eventually have benefits on groundwater, wildlife habitat, and water
quality uses.

K. PROTECTION OF WATER QUALITY IN INLAND LAKES


1. Cultural Eutrophication

Problem Assessment

Most of Region V's 25,000 lakes are located in Minnesota, Wisconsin and
Michigan, and they provide drinking water and recreational  opportunities
for millions of people each year.  Although most of the Region's lakes  are
not covered by lake classification surveys funded under the Clean Water Act,
lakes in the southern portions of Minnesota, Wisconsin, and Michigan have
been analyzed and found to be undergoing long term degradation from such
processes as runoff from agricultural and urban areas, leaching from septic
*ields, destruction of adjacent wetlands, and interference  with stream  flow.

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                                      38
In spite of these findings, watershed management plans for these lake
areas have never been developed or implemented.  Historically, the Clean
Lakes program has focused on structural changes, such as dredging and weed
harvesting, to rehabilitate lakes.  While these solutions enhance short-term
recreation potential, they are costly and often ignore the basic causes of
eutrophication.  The Clean Lakes program has received low levels of funding
over the past several years and, therefore, very few lakes have been rehabil-
itated.  Basically, the problem is less one of not having the technical tools
to understand or resolve the environmental threats, but instead the problems
appear to be more of priority, funding, and institutional ennui.

Regional Agenda

0  Prepare State applications for Section 314 funding.

0  Develop State-specific strategies to fund necessary revisions to
   Classification Surveys, and assure their consistency, where appropriate,
   with the Regional NPS strategy.

0  Ensure each new Phase 2 grant provides for two years of environmental
   results monitoring to encourage States with watershed management concerns
   to update or develop lake classification surveys.

0  Encourage development of Federally-funded watershed management projects
   prior to initiation of in-lake work.

0  Prepare nonconstruction projects fo1* State funding (approximately 2 per
   State per year).

0  Develop State funding sources for nonst^uctural  solutions,

0  Facilitate the transfer of technology on lake and watershed management
   techniques betwaen Regions and States.

0  Develop a general nonpoint source program directed at protecting inland
   lakes.

0  Provide technical assistance on watershed management classification
   systems, and other lake projects.

Headquarters Actions Needed

0  Provide a definitive national  statement on how the Clean Lakes program
   should be managed over the next five years.

0  Request that Congress reauthorize the Clean Lakes Program.

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                                    39


0  Specify ample lead time (at least 6 months) for State preparation and
   Regional review of candidate projects.

0  Implement the National Nonpoint Source Strategy.

Expected Environmental Results

For the past 3 years, Region V has advanced a watershed management approach
aimed at protecting and improving the water quality of surface Impoundments
and natural lakes.  The elimination or reduction of nonpoint source and
point source contributions will benefit water quality, enhance recreational
opportunities, and provide higher quality drinking water supplies.  Lake
aesthetics would improve because of reduced growth of nuisance algae.
Structural changes, such as dredging, can restore high priority lakes within
the context of an overall watershed management plan.

The Region can project specific environmental results based on experience
with several project types that have been conducted within watershed manage-
ment plans.  The Clearwater River (Minnesota) Chain of Lakes Clean Lakes
Project emphasized agricultural erosion reduction practices.  Even in  1984 -
a year of heavy rainfall with runoff rates 2 to 4 times the norm - the total
external phosphorus load to that watershed was reduced by 39 percent, from
86,000 Ibs. to 52,000 IDS.  One part of the project was particularly success-
ful, accounting for the vast bulk of the total reduction.  In that area, the
reduction was from 35,000 Ibs. per year to less than 1,000 Ibs.  We expect
further reductions as the watershed management plan continues.  During normal
rainfall/runoff years, we estimate remaining phosphorus loadings to vary
between 20,000-40,000 Ibs., and the anticipated watershed erosion reduction
practices yet to be implemented will reduce this to about 5,000 Ibs.

The Lake Le-Aqua-Na Clean Lakes Project combined a nonpoint source control
program with in-lake structural actions (dredging, algae harvesting) to restore
the lake's water quality.  So far, soil loss has been reduced from 5.12 to 2.0
tons/acre, for a total sedimentation reduction from 7560 tons/year to 3000 tons/
year.  Even though this is a relatively new project, it has already produced a
significantly improved, quality recreation resource.

2. Preservation of Wetlands

Problem Assessment

Agricultural, urban, and transportation developments have resulted in tne
loss of well over half of the known Region V wetlands, and their destruction
continues at an alarming rate.  This destruction of wetlands systems means
loss of important wildlife habitat; reduced natural protection from floods;
increased need for costly, man-made flood control  systems; increased levels
ot conventional and hazardous pollutants in the Region's waterways (partic-
ularly from non-point sources); and, an increased need for remedial pollution
control programs.  Several factors contributing to the continued loss of
wetlands remain unchanged:

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                                    40
0  Ideological perceptions that wetland issues are solely matters of land
   use and property ownership, without regard to ecological  consequences.

0  Legal and economic policies at all levels of government encourage
   wetland losses.  Agricultural price support systems, flood insurance
   programs, and inequitable taxation policies make development of
   cheap, "worthless" wetlands a profitable enterprise.

0  Inconsistent and uncertain administration of regulatory programs has
   hampered efforts to control losses and encourage responsible wetland
   use.

0  Current wetland protection regulations do not adequately  address
   harmful practices such as wetland drainage or piecemeal destruction.

0  Inability to conduct and maintain an accurate wetland inventory has
   hindered attempts to protect existing wetland areas.

Regional Agenda

0  Expand and emphasize the Advanced Identification of Disposal Sites
   program to protect important wetlands.  Such advance designation will
   help avoid permit issuance by designating, in advance, which wetlands
   are suitable for various purposes and what activities should be prohi-
   bited.

0  Utilize existing regulatory and management tools to minimize wetland
   degradation or destruction.

0  Develop and implement the Section 404 enforcement strategy.

0  Develop an audit strategy to evaluate the Michigan Section 404
   delegation.

0  Work with the States to:

   -  Establish water quality standards for wetland areas, to assist
      EPA, the States, and the Corps of Engineers in assessing the
      effects of discharges and other activities on wetlands physical
      characteristics.

   -  Develop water quality management plans that recognize  and encourage
      the protection of natural wetlands.

   -  Adequately reflect the status and importance of wetlands in the
      305(b) water quality reports.

0  Assure coordination between the Regional offices developing the in-situ
   pollutant policy and the 404 Dredge and Fill  program.

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                                    41
Headquarters Actions Needed

°  Renegotiate the MOA between EPA/COE to establish better procedures
   to enhance the environmental aspects of the 404 program.

0  Assess options to protect wetlands against harmful but currently
   unregulated practices.

0  Develop and implement regulatory programs to encourage and facilitate
   wetlands preservation in project planning.

Environmental Results Expected

A wetlands treatment system, part of the Long Lake Project, expects to reduce
internal phosphorous loadings to Lake Josephine by 57 percent (about 668 Ibs.
per year).  That wetlands treatment system has consistently achieved about 60
percent removal efficiency for phosphorous, about 30 percent for nitrogen and
about 80 percent for sediments.

If the Agency can continue to use environmental indicators such as the one
above to quantify specific benefits of wetlands preservation, we can make a
much more convincing case as to the value of wetlands.  With this information
and an expanded Advanced Identification of Disposal Sites program, tha
Region and States will  be able to identify and protect the Highest quality
wetlands from fill  activities which reduce wetlands sjrface area and
contaminate surface and groundwaters.  This will  improve recreational
activities along many of the Region's rivers and  streams.  Slowing the
rate of wetlands loss will  protect groundwater recharge areas and improve
habitat for fish and wildlife.

L. COMBINED SEWER OVERFLOWS
Problem Assessment

A problem for many of the older municipalities is controlling and treating
combined sewer overflows (CSO).  The CSO problem is complicated by its
site specific nature, and that CSO impacts are often masked by nonpoint
source impacts.

Larger storm events cause bypasses from the combined sewers to protect
treatment plants or because of inadequate sewer system capacity.  These
overflows cause several problems: 1) tne immediate contamination of
surface waters from untreated sewage; 2) the long-term pollution in the
receiving water because solids settle to the bottom and form sludge
deposits; (3) lost recreational potential; and (4) aesthetics degredation.

The Agency's bi-annual  needs survey in 1984 estimated a need of $6.4
billion for construction of CSO abatement projects in the Region.  This
represents 28 percent of the total national CSO need.

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                                     42
Part of the Regional and National  dilemna in assessing controlling CSOs is  the
difficulty of establishing water quality standards applicable to wet weather
flows.  Water quality standards generally allow standards exceedances under
unusually low flow conditions.  It may be equally logical to establish unusually
high flow conditions relief, as during a 100 year storm, for CSO.  There has been
no comprehensive policy for issuing NPDES permits dealing with CSO discharges.
Those permits issued have been done on a case-by-case basis, frequently emanating
from controversial situations.  While existing permits recognize CSO discharges,
the permits have no specific limits.  Therefore, enforcement actions against local
communities to require management or control cannot be taken.

Since many CSO abatement activities are primarily initiated for other objectives
(e.g., basement flooding), they frequently result in multi-purpose projects.  The
complexity of EPA's multi-purpose funding policy has many implementation pitfalls.
EPA's lack of a comprehensive policy has resulted in Region V's delegated States
making case-by-case decisions by default.  Therefore, project solutions, effects,
and costs vary considerably from State to State.

Regional Agenda

0  Control CSO pollution by completing the identification of the highest
   priority municipal facilities for which water quality standards viola-
   tions are linked to CSO events and develop appropriate conditions and
   controls in NPOES permits.

0  Complete water quality standards reviews/revisions and identify priority
   water bodies.  The priority water bodies in turn must be compared against
   CSO discharge points to determine the contribution of CSO to the problems
   in a given area.

3  Finalize a Regional CSO policy that includes specific actions for con-
   sistent implemention by the States.

0  Ensure CSO problems in all GLNPO-areas of concern are addressed as the
   remedial action plans are prepared.

0  Identify all dry weather overflows in the Region and ensure controls
   are implemented via permit enforcement or judicial orders.

0  Work with the States to improve sewer systan maintenance projects that
   will control inflow and infiltration.

0  Work with the States and municipalities to ensure that there is adequate
   sewer capacity that will prevent overflows and environmental degradation.

Headquarters Actions Needed

Provide more explicit National policy direction on criteria for NPOES permits
dealing with CSO discharges, and on setting water quality standards for high
flow conditions.

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                                     43

Expected Environmental Results

CSO projects vary tremendously - from those at such cities as Minneapolis/St.
Paul and Detroit to one at Boonville, Ohio (pop. 1500).  The Region and States
are now developing a CSO policy which will eventually lead to strategies and
projects with quantifiable environmental results, from reduction of suspended
solids and floatable materials which cause aesthic impairments, to reductions
of nutrients such as phosphorus which upset natural water ecological balances.

The Region has implemented several CSO remedial actions, primarily through
construction of retention basins and 1n-l1ne storage.  However, these con-
struction solutions have been extremely expensive to build and maintain.  A
new project that may provide dramatic environmental benefits at lower costs
is being tried at the City of Saginaw.  Beginning in 1979, the Region and
the City modified 13 combined sewer regulation chambers and constructed one
new in-line control chamber to maximize temporary storage of wet weather
combined sewerage that could be held for later treatment at the City's
treatment plant.  These innovative changes have incrementally reduced suspended
solids loadings to the Saginaw river by 16 percent, BOD by 20 percent, and total
phosphorus by 8.5 percent.

As the States finalize tneir own CSO policies in FY 36, the mechanisms will be
in place to plan for future strategies and projects that will have similar or
greater environmental  benefits.

M. EMERGING ENVIRONMENTAL PROBLEMS


1. Indoor Air Pollution

Problem Assessment

As more information becomes available, the problem of exposure to indoor air
pollution such as passive exposure to tobacco smoke, exposure to radon, and
exposure to formaldehyde have all  stimulated public concern that indoor air
pollution may be a serious health problem.  In Region V, the emphasis on
energy conservation has led to a lowering of the air exchange rate of a
typical home, and subsequently to potentially greater accumulations of indoor
air pollutants.  Even now, the Region routinely receives calls regarding
indoor radon concentrations in private residences.  With the "Increase in
data and public awareness, Region V expects a commensurate increase in
program demands for information and some Agency response.

Regional  Agenda

0   Establish and maintain an indoor air pollutant contact person to provide
   informed and factual responses to citizen concerns.

0   Provide information to State Air and Radiation agencies on indoor air
   pollution, including a regional  workshop on the indoor radom problem.

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                                      44
Headquarters Actions Needed

0  Headquarters should continue reseach Into the problem of indoor air
   pollution and provide technical information as it becomes available.

0  Headquarters should consider guidance on possible Agency responses
   to requests for action.

2. Vehicular and Industrial Emitted Lead in Soil
Problem Assessment

The City of Chicago Health Department recently performed a survey of public
playgrounds and parks to determine the soil  lead content.  These analysis
indicated significant soil lead concentrations in areas near major highways,
which prompted public concern regarding lead in playground soils.  As a
consequence, the State of Illinois is currently undertaking a broad state-
wide analysis of lead in the soil of playgrounds in the state.  The most
obvious source of this lead is motor vehicles using leaded gasoline.  Since
there are other major metropolitan areas in  Region V which have very signi-
ficant levels of motor vehicle traffic, the  Region expects that this will
become a broad Regional concern.

An additional concern with elevated soil lead levels is in the proximity
of lead point sources.  Recent soil analyses near two lead sources in North-
western Indiana have indicated significantly elevated lead levels in off-plant
property - one of which was a residential  area near the plant.  It is reasonable
to expect elevated off-plant property lead levels around other major lead
point sources in Region V and other areas  of the country.

Regional Agenda

0  Continue to work with Illinois to characterize the extent and magnitude
   of lead in soils.

0  Inform other states in the Region of this potential  problem.

0  Continue to work with states and local  agencies to develop misfueling
   programs to limit tne lead from motor vehicles as much as possible.

8  Explore potential clean-up of the most  polluted areas contaminated by
   vehicular lead.

0  Continue to work with Indiana to develop  an acceptable lead SIP for  point
   sources.

0  Explore potential clean-up of polluted  areas contaminated with stationary
   source lead emissions.

Headquarters Actions Needed

u  Define available resources which could  be used to pay for clean-up.

''  Define appropriate action level  for clean-up of lead in soil.

:  Establish Agency policy on requiring implementation  of anti-tampering/
   aiti-misf'jel ing programs.

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Relative Ranking of
Invironmental Problems
Contaminants  of
Concern
                                                     Key Words Characterizing the Problem
A. Hazardous Waste
   Management Response -
   Ri<_ > to human health
   via exposure to
   hazardous wastes.

   1.  Superfund sites
Numerous toxic  or
hazardous wastes.
   2.  RCRA facilities
Numerous toxic  or
hazardous wastes.
B. Contamination of
   Groundwater
Numerous toxic
or hazardous
substances.
Geographic
Scope
Major
Impacts
Level of
Public Concern
Major
Sources
Regionwide -
site specific.
Regionwide.
Region V has 17%
of the national
total of land
disposal facili-
ties and 21% of
the national
total of inciner-
ation facilities.

Regionwide:
Special  em-
phasis in
targeted
areas.
Impact on public
health due to
contamination of
groundwater, sur-
face, water, soil
and air.  Also,
Imminent hazards
such as explosions,
fires, etc.

Impact on public
health through
potential contami-
nation of ground-
water, surface water,
soil, and air.  Also,
Imminent hazards such
as explosions, fires,
etc.

Impact on public
health due to
contamination of
drinking water
supplies.  Impacts
on surface water.
Extremely high
Extremely high
Extremely high
Abandoned
hazardous
waste sites
Land
disposal,
existing
solid waste
mgmt. units
and Incin-
eration
facilities.
Land disposal
fad lities,
manufacturing
processes,
agricultural
pesticides &
herbicides,
energy recov-
ery prac-
tices, leak-
ing under-
ground stor-
age tanks.

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Relative Ranking of
Environmental Problems
Contaminants of
Concern
	Key  Words
 Geographic
 Scope	
acterizlng the Problem	
Major              Level of
Impacts
Public Concern
Major
Sources
C. Discharge of Toxic
   Materials to Water

   1. Contaminated
       SI ml'je
Dioxin,
chlorinated
hydrocarbons,
and other
toxic
chemicals.
 Reyionwide
n. In-situ Pollutants

   1. PCHs
PCBs, PAH other
lesser know
contaminants
 Regionwide
 site-specific.
Impact on public    High
health via con-
sumption of con-
taminated fish
flesh.  Possible
ingestion of toxics
adhering to crops
or uptaken Into
plant tissues. Expo-
sure to aerosols at
waste water treatment
plants.  Water sup-
pi ies contaminated
by runoff of agri-
chemicals, Inade-
quately treated
waste water, and
leaking sludge
beds.
                   Major industrial
                   and municipal dis-
                   chargers.
Ultimately
affects the
animal food
chain and
human health.
 Extremely high
 Improper storage
 disposal of
 PCBs

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Relative Ranking of
Environmental Problems
Contaminants of
Concern
Geographic
Scope
                                                   Key  Words  Characterizing  the Problem
Major
Impacts
Level of
Public Concern
E. Violation of Primary
   Ambient Air Quality
   Standards
  Ozone
                          Sulfur Dioxide
                          Participates
Chicago, Detroit
Cleveland, Cinci-
nnati , Louisville
Metropolitan Areas;
Milwaukee and SE
Wisconsin; North-
western IN; and
East St. Louis.
Transport from
major urban areas
contributes to
some areas' problems.
                   Only small  areas in
                   WI  actually exceed
                   ambient  standards
                   despite  high levels
                   of  S02 anissions.
                   Chicago,  Detroit,
                   Cleveland metro-
                   politan Areas,  NW
                   Indiana,  Stuhen-
                   ville.
2B million
people exposed
to risk of respira-
tory disease, property/
materials damage,
possible synergistlc
effects rfith other
pollutants.
Moderate-high
                      Local acidifi-
                      cation of preci-
                      pitation, respiratory
                      al intents, property
                      damage, synergistlc
                      Interactions with
                      other pollutants,
                      possible long range
                      damage via acidification
                      of precipitation.

                      Materials and property
                      damage.  Risk of respi-
                      ratory disease, visi-
                      bility degradation,
                      possible Interactions
                      with toxic substances.
                        Moderate-high
                          Moderate
Major
Sources
Auto
emissions,
petroleum
marketing,
varicjs in-
dustrial
processes
(primarily
those using
solvents,
paints, or
other VOCs,
other
stationary
sources).

Large In-
dustrial
sources,
electric
generation.
                  Fugitive
                  emissions,
                  dust rein-
                  trained by
                  vehicles, In-
                  dustrial
                  sources.

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Relative Ranking of
Environmental Problems
F.
Synthetic Organic
Chemical Contami-
nation of Drink ing
Water
Contaminants of Geographic
Concern Scope
Halogentated anrl Regionwide
aromatic hydro-
carbons.
Major Level of Major
Imparts Public Concern Sources
Impact on human High
health from inges-
tion of contaminated
water supplies.
Contaminates may
increase risk of
cancer.
Commercial
and indust
rial faci-
lities
fi. Toxic Substances -
   Existing Chemicals

   1. Pesticides Misuse
Various pesti-
cides - aldicarb
herbicides -
Triazine-type
Regionwide
   2.   Asbestos
Asbestos
Regionwide
Health affects of       Moderate
direct exposure or
consumtpion of fruits/
vegetables with
residues; surface,
groundwater contami-
nation effects on
wildlife, aquatic
orgenizms

Known health effects    Moderate
due to asbestos
exposure, cardinogemi-
city, asbestosis.
Pesticide
misuse, mis-
application,
mislaheling
Flaking of
structural
insulation
releasing
friable
asbestos par-
ticles, auto
brake lin-
ings, asbes-
tos from
demolition
of asbestos
containing
structures.

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Relative Ranking of
Invironmental Problems
M. Air Toxics
Contaminants of
Concern
Numerous
uncalaloged
toxic sub-
stances.
Geographic
Scope
Reglonwide
Major
Impact
A1r, surface
waters.
Level of
Public Concern
Moderate-
high
Major
Sources
Chemical
plants,
other
fossil-
1. Great Lakes
   Areas of Concern
J. Non-point Source
   Discharges to Water
Virtually full
range of conven-
tional fugitive,
and hazardous
pollutants, in
all media.
Agricultural
pesticides,
nutrients.
Organic and
Inorganic
partlculates.
42 discrete
geographic areas,
30 within U.S.A.
(See maps,
 Appendix    )
Reglonwide
Limitation of water     Moderate-
quality uses, poten-    high
tial health threats
from contaminated
water supplies,
harbor 1 Imitation
due to difficulty
in dredging and
disposing of conta-
minated dredge spoils
Eutrcphication, agal
and other nusiance
vegetation blooms,
damage to various
ecological regimes.
Impact on public        Moderate
health through
consumption of con-
taminated fish flesh.
Destruction of habitat
and fisheries through
oxygen depletion.
fuel burning
or other
types of
sources.

Contamination
from 1n-s1tu
toxic materi-
als, CSO, In-
adequate NPDES
permits and
pretreatment
programs, ur-
ban and agri-
culti»ral run
off, air depo-
sition of PCBs
and other
toxic sub-
stances to
Lakes.

Runoff from
Agricultural
lands, con-
struction
sites.

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Relative Hanking of
              Problems
K. Protect 7o» of Water
   Qual ity in Inland
   ! akes

   1. Preservation of
      Wetlands
L. Combined Sewer
   Overflow
                                               Key  Words Cha     erlzing the Problems
Contaminants of
Concern
Geographic
Scope	
Dredged or
fill material.
Runoff of
pesticides
from aglands.
Regionwide
Untreated
sewage, sol ids
and sludge
deposits.
Major
Municipal ities
TTajor
 Impact
Level of
Public Concern
Major
Sources
 Less  of  fish  and         Moderate
 wildlife habitat,
 groundwater re-
 charge,  floodwater
 storage, and
 degradation of
 surface  water
 quality  (sediment/
 nutrient filtering
 and augmentation
 of stream low flow).

 Loss  of  full  use         Moderate
 of waters for re-
 crat ion  and consump-
 tion.  Impact of
 human health  via
 consumption of con-
 taminated fish flesh.
                 Agricultural,
                 urban and
                 transportation
                 development.
                 Major round -
                 palities with
                 deteriorating
                 sewers or in-
                 sufficient
                 capabilities.

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                                    45
Part III - COMMENTS ON AGENCY PRIORITY LIST


Region V feels that the Agency's overall  priority list should be limited
to about 10 items, 15 at the most.  Beyond that number, they lose their
effectiveness and cease to be priorities  - if everything is a priority,
then nothing is a priority.

If additional priorities are desired, they should be included by the indivi-
dual national programs.  There need be no such numerical limit for those.

So, Region V's comment on the Agency Priority List is to keep the first 10
priorities as ranked and written, except  for number 10 which we suggest
be rewritten as follows:

10.  "Implement the national municipal policy to achieve municipal compliance
     with final effluent limits no later  than 1988 or as soon as practicable
     with or without Federal funding." This will help ensure timely and
     appropriate enforcement response to  instances of significant noncompliance
     with NPDES permit requirements (including requirements for pretreatment
     development) and of pretreatment standards to achieve compliance as
     soon as practicable.

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  Appendix A - Southeast Chicago - A Case Study of Environmental  Planning


Introduction

Region V has worked closely with the Illinois EPA (IEPA) and various other
Illinois Agencies and groups and accomplished an extensive amount of work in
the Southeast Chicago area.  This report will attempt to document what actions
were taken in the area, the reasons for those actions and what resulted from
them.
  •
Background

Southeast Chicago, in the vicinity of Lake Calumet, is a heavily  industrialized
area with a long history of disposal sites for a wide variety of  industrial,
commercial, and residential wastes.  Region V has had an ongoing  interest there
for many years, due to the concentration of heavy Industry 1n the area, and
their regulation under the Clean Air Act and Clean Water Act.  The Irondalers
Against the Chemical Threat (I-ACT), a local citizens group, has  been vocal and
effective in raising issues of public health and safety concerns  associated
with the generation, treatment, storage, and disposal of wastes in Southeast
Chicago.  In the fall of 1982, the IEPA was asked by I-ACT to study the environ-
mental pollution of this area with special emphasis on waste disposal practices.
This request was followed by a similar one from Senator Charles Percy, who
asked Region V and the Center for Disease Control (CDC) to perform "an environ-
mental assessment of the groundwater, air, and health effects that may be
associated with any or all of these (i.e., hazardous waste, municipal, and
industrial sites) sites" in the Calumet City area.

In response to these requests, the IEPA initiated a series of activities in
cooperation with Region V and the Illinois Department of Public Health (IDPH).
These activities focused on the risks from hazardous waste disposal  and the
numerous landfills in the area.  Because of the desire to complete the study
in a relatively short time and without supplemental funding, the  IEPA, in
cooperation with the IDPH and Region V, designed a special "toxics hot spot
assessment" program for the study area.  As part of this special  program,
historical data available from routine Agency activities were combined with
new information on the status of land, water, and air pollution.

This investigation presented unique challenges in that the study  area is rela-
tively large, there is a great variety of pollutant emission sources (including
landfills, an incinerator, steel mills, and chemical plants), and there is a
full complement of environmental issues which needs to be considered.

A major purpose of the IEPA study was to assess what actions should be undertaken
1n the study area.  Another purpose was to develop a compendium of environmental
data to serve as a useful baseline for subsequent assessments.

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                                     - 2 -


The study utilized existing data bases as much as possible, "in order to make
the best use of Agency resources.  However, it was necessary to conduct some
additional field work.  This included using a drill rig to extract soil and
groundwater samples throughout the study area for laboratory analysis, con-
ducting ambient air toxic pollutant monitoring, taking fish flesh samples from
Lake Calumet, and a limited groundwater and soil sampling program.

In coordination with the IEPA, Region V's Central District Office of the Environ-
mental Services Division (CDO/ESD), initiated a limited sampling program to
characterize the methane gas drawn from Waste Management Inc's CID Landfill and
offered for sale, and test for surface water and soil contamination in the
area.

The IDPH conducted a preliminary review of selected mortality statistics chosen
because they had previously been associated with environmental factors.  The
specific causes of death reviewed included malignant neoplasms of the digestive
organs, respiratory system, urinary organs and the total number of all malignant
neoplasms.

In addition, the IDPH analyzed available health statistics to compare cancer
and birth abnormalities in the study area to those in the rest of Chicago.  In
response, CDC committed to reviewing the environmental monitoring data, and
offered to assist the Illinois Department of Public Health (IDPH) in the design
and implementation of epidemiologic studies of the area.

Summary of Public Health Study

Comparison of death rates calculated over a 13-year period (1969-1981) indicated
that the rates of death from cancer from the three malignant neoplasms associated
with environmental factors were all lower than the corresponding rate for the
City of Chicago as a whole.  For the Riverdale area (see map), the age-adjusted
death rate from all malignant neoplasms was only slightly higher (though statis-
tically significant) than the City of Chicago 1n general.  The IDPH preliminary
review concluded that there was no indication of generally increased mortality
due to cancer in the study area during the thirteen years evaluated.  The IDPH
also evaluated information on birth defects and diseases for the years 1980 and
1981.  This review of the study area resulted in no unusual  findings.

CDC's review of the sampling data concluded that although an insufficient number
of samples were collected to define the extent of potential  human health problems,
the metals in the soil were within the bounds for naturally occurring soil con-
centrations.  In addition, the organic compounds identified at the various sites
were not at concentrations considered to pose a significant human health hazard.

Of principal concern was the question of whether there was imminent danger to
human health in the area from environmental pollutants.  Based upon all available
data, a draft report by the Illinois EPA The Southeast Chicago Study;  An Assess-
ment of Environmental  Pollution and Public Health Impacts was released in
April 1984.The draft report concluded that this was not the case.  However,
since many of the health impacts of concern are long term in nature, this report
was viewed as a starting, rather than an ending, point.

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                                    - 3 -


Citizen Petitions

After review of the draft IEPA report, several citizen groups were concerned
with the findings.  They stated the study did not address multiple pollutant
interactions and possible synergistic or antagonistic health effects.  Sub-
sequently, U.S. EPA received 2 separate petitions, both under Section 21
of TSCA.  The first, in July of 1984, requested that the Administrator issue
a rule to remedy unreasonable environmental and health risks in Southeast
Chicago, conduct a full field Investigation to determine the cumulative
health effects of multiple sources of an unknown variety of toxic substances,
and use the TSCA authority to assess and remedy the overall impact of the
combined exposure of many pollutants, rather than "the piecemeal enforcement
and regulatory actions taken under the other Federal statues."

A second TSCA citizen petition in April of 1985, presented 5 specific requests:

  1.  Determine each person/business entity that used, processed, or emitted
      any number of "Identified Substances."

  2.  Compel each of these persons/businesses to test fo- the cumulative
      health and environmental effects:

         - cumulative effects of extended exposure of these "Identified
           Substances,"  .
         - synergistic/antagonistic effects,
         - multi-media exposure to substances individual and in combination,
         - other possible health and environmental effects of the "Identified
           Substances" and any other chemicals/substances found in the area.

  3.  Set reasonable deadlines for work completion.

  4.  Allow public participation,

  5.  Establish further rules/orders as necessary to reduce environmental  and
      health risks.

U.S. EPA Reaction to Citizen Petitions

U.S. EPA denied both petitions, the first on the grounds that the other indi-
vidual environmental  acts could more adequately address the proolems than
TSCA.  Although the petition was denied, Region V did point out which individual
environmental investigations would be undertaken by the various media programs
to address the petitioners concerns.

U.S. EPA also denied the second petition - which focused on investigating the
multi-media/multi-pollutant, synergistic/antagonistic health and environment
risks in the area - based on the lack of set standards for testing of multiple
chemicals and their toxicological interactions.  The denial said the state-of-
the-art of such testing is insufficient to assure that the results would oe
reliable and adequate and that the scientific capability to make such assess-
ments simply does not yet exist.  The response also stated that EPA's research
program adequately addressed multiple chemical exposures.

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While the 2 citizen petitions raised valid questions regarding environ-
mental risk assessments, the scientific capabilities to assess multiple
pollutants risks or synergistic/antagonistic effects, simply do not yet exist
in any reliable form.  And, while a great amount of single media attention
was paid to the area, it became clear that a true multi-media, multiple
pollutant study of environmental risks in a specific area is difficult and
one for which neither the Region nor U.S. EPA as a whole have established
and tested procedures.

Region V set up an ad hoc Southeast Chicago Task Force, which concentrated a
number of individuaT~program activities and gathered a significant amount
of individual media data.  The ad hoc nature of the Task Force underscored
the need for a process to consistently utilize environmental indicators or
ambient data to assure that what we discover in the data analysis will cause
appropriate actions to be taken by the appropriate media programs.

This appendix details the media specific actions and findings from the study
area.  Obviously, a great deal of work went into collection of these data, and
no extreme environmental problems were found.

AIR

Historical air data available from routine Agency criteria pollutant aonitoring
and inspection activities were analyzed to determine baseline air quality
and needs for more specific sampling.  Although direct monitoring results for
specific organic compounds, which comprise a majority of potential toxic pollu-
tants, were not available, the Region V's air enforcement program for criteria
pollutants has had, and continues to have, a positive impact to reduce toxic
air pollutant emissions by controlling particulate and total volatile organic
compounds (VOCs).

There are also a wide variety of non-point, area sources in the study area,
including landfills, sludge-drying beds with odor problems, and fugitive parti-
culate emissions from general activities at major Industrial complextS*  During
warm summer days, odors emanating from these area sources can be trapped when
near-ground inversions start to form.  The stagnation associated with this
Tiateorological phenomenon often results in short-term odor problems.

On the basis of this analysis, the IEPA, in cooperation with the Illinois Depart-
ment of Energy and Natural Resources committed to additional air monitoring
for toxic pollutants in the Lake Calumet area.  The IEPA installed 2 PCS air
monitors and 1 nitrosamine sampler and increased its ordinary air sampling
program through the use of size specific monitors (10 micrometers) for
particulates and analyzed for 10 netals on the sample filters.

In June of 1985, Region V and the Office of Research and Development installed
a toxic air monitor (TAM) in the area to sample ambient organic compounds.
Our Air Management Division also committed to the preparation of an inventory

-------
                                  - 5 -
of probable air emissions sources and an atmospheric exposure assessment of
the area.  This effort involves quantifying specific emissions from point,
area, and mobile sources.

Summary of Air Pollution Impacts

Although TSP concentrations have been decreasing significantly since 1976,  we
found that the 1980 levels at all four TSP monitoring sites in the study area
exceeded the annual health-related National Ambient Air Quality Standard (75
ug/m3).  However, in the running 12-month period from July of 1982 thru June  of
1983, only one site exceeded the annual, health-related standard.  A decrease
is also apparent in the peak 24-hour averages.

Ambient lead concentrations are also decreasing in the study area.  Violations
of the lead National Ambient Air Quality Standard (a quarterly average of
1.5 ug/m3) were measured in 1974 and 1975, but there have been no violations
since then.  The areawide average of the peak quarterly lead values has de-
creased to less than a third of the national standard in the last two years.
Other than for lead, no ambient air quality standards exist for the TSP re-
lated trace elements.  However, when trace element averages in the study area
are compared to Illinois statewide averages, the trace constituents listed
are consistently higher in the study area than in the State as a whole.  The
trace elements measured are sulfdtes, nitrates, copper, iron, and manganese.

Nitrogen dioxide (NC^) has been monitored since 1974.  During that time, the
annual average showed an upward trend from 1974-1979, followed by a downward
trend from 1979-1983.  The annual National Ambient Air Quality Standard (100
ug/rrr) was not exceeded during any of these years.  The trend in NOg levels
in the study area parallels that of other areas of Chicago ana Cook County
during these time periods.  However, N02 concentrations in the study area have
generally been lower than in other parts of Chicago and Cook County.

Ozone has been monitored at two sites since 1978.  There is no real  trend
since 1978 in either the peak concentrations or the number of days exceeding
the standard.  Some years have been below the one-hour National  Ambient Air
Quality Standard (0.12 ppm), and other years have been above.

The IEPA/Illinois Department of Energy and Natural Resources Study focused
on 31 toxic pollutants, using a mobile trace gas monitoring system.  Only
four were detected—toluene, benzene, xylene, and acetone.  No nitrosamenes
were found.  There are no air quality standards for these contaminants.  How-
ever, the levels detected for these pollutants were all  below the multi-media
environmental goals (MEGs) suggested by the U.S. EPA.

Seven toxic substances were sampled using filters from four TS?  monitors
located in the study area.  Sampling was conducted for dioxin, arsenic,
beryl!ijm, nickel, polychlorinated biphenyls (PCBs), cadmium and chromium.
Dioxin and PCBs were not detected in any sample.  Low values of  the other
five pollutants were found at various sampling locations.  The results of
the filter analyses for arsenic, beryllium, cadmium, chromium and nickel
were compared to both TLV/300 and TLV/420.  The TLV/300 figure has been used
by some local, state and federal agencies as a guideline for safe ambient
levels in lieu of National Ambient Air Quality Standards.  TLV/420 may De
viewed as equivalent to a MEG.  All  levels measured were below both TLV/300
and "LV/420.

-------
                                    - 6 -
WATER

Region V's Water Division suggested possible research avenues,  If funds  became
available, but committed to no other actions within the study area.   They
took this position because there are only 40 area residents who do not  receive
city water, and virtually all the large industrial  sources along the Calumet
River no longer discharge their wastewater to the Calumet River.  General
industrial waste-water dischargers from these sources are pretreated and
discharged to the Metropolitan Sanitary District of Greater Chicago.  IEPA
committed to conducting additional surface and groundwater monitoring for
toxic pollutants.

Summary of Water Pollution Impacts

The primary water resources of the study area include Lake Michigan, Lake
Calumet and the Calumet River.  In addition, the study area has interior
drainage channels which carry storm runoff and seepage waters.

The quality of the fishery and associated biological  communities varies
within the study area.  The quality of the Calumet  River fishery upstream
of the O'Brien locks appears to be very good.  The  fishery downstream of
the O'Brien locks is of lower quality.  Yellow perch dominate the lakeward
half of the Calumet River while bluntnose minnows are the dominant fish
species in the lower half.  The fishery of Lake Calumet has game species
including largemouth bass, black crappie and yellow perch.  The northern
portion of Lake Calumet generally has higher quality fish communities than
the more industrial developed areas around the harbor complex.   The  lake
apparently provides for a limited bass population in the river  around the
inlet.

Lake Calumet fish flesh sampling was conducted in October of 1983.  Contam-
inant analysis of largemouth bass, carp, and crappie included testing for
PCBs, hexachlorobenzene, hexachlorocyclohexanes (BHC), heptachlor epoxlde,
chlordanes, OUT and analogs, dieldrln, andrin, trans-Nonchlor,  and percent
fat.  All contaminant concentrations measured were  less than the Food and
Drug Administration (FDA) action levels.

A review of data collected at sampling stations on  the Calumet  River from
1970 through 1981 concludes the following:

    a.  The concentrations of cyanide in the Calumet River have decreased.

    b.  The concentrations of total  suspended solids (TSS) in the Calumet
        River have decreased.

    c.  Water quality of the Calumet River from Lake Calumet to Lake Michigan
        is generally good with few toxic substances in violation of  secondary
        contact standards.

-------
                                    - 7 -
Polychlorinated Biphenyls (PCBs)

Indiana Harbor Canal and the associated Grand Calumet River (IHC/GCR),  draining
the Southeast Chicago area of Illinois and Indiana, are tributaries to  Southern
Lake Michigan.  While not within the study area itself, the PCB problem attri-
buted to the IHC/GCR has had significant effects on the study area and  the
southern tip of Lake Michigan.  An intensively industrialized area, this drain-
age basin has historically received large quantities of run-off and effluent
laden with a variety of toxic substances, Including PCB's.  The IHC/GCR has been
identified as a leading source of PCB's to the Lake.

By the early 1970' s, PCB loading of Lake Michigan had exceeded 5 million metric
tons per year (MT/yr.).  The body tissues of resident fish species - bloater
chubs, coho salmon, and lake trout - had accumulated mean PCB levels of over
5.6, 12.1, and 22.9 milligrams per kilogram (mg/kg) respectively.  Herring gull
eggs contained an average of 175 mg/kg.

Human consumers of Lake Michigan fish were found to have blood serum PCB levels
5-6 times that of the general population.  Further studies have demonstrated
that the base level of blood serum PCB is permanently elevated after each occasion
of eating a PCB-laden fish, in proportion to its level  of PCB contamination.  The
longer the individual has been eating Lake Michigan fish, the higher the blood
serum PCB level .

In March of 1985, the Great Lakes National Program Office, together with the
Lake Michigan States issued an advisory recormending that the public limit
or terminate consumption of Lake Michigan fish.  Descriptions of alternative
preparation and cooking techniques, intended to minimize toxics exposure for
those who do eat the fish, have been promulgated throughout the area.

Because of the actions taken by Region V and compliance by industry, PCB dis-
charge into the IHC/GCR has been substantially reduced.  The very serious
problems of PCB-contaminated river and harbor sediments, combined sewer over-
flows, and lagoon/landfill seepage remain.

Measurable and positive results of the Lake Michigan PCB control program have
been identified.  By 1980, PCB loading to Lake Michigan had dropped 55* to 2.4
MT.  Lake Michigan fish had demonstrated a general  - if inconsistent -  decline
in PCBs of 60-75% (depending on species) by 1982.  Herring gull  eggs, by 1983,
carried 90% less
For humans, the picture is more mixed.  Because of the extreme persistance  and
accumulaoility in the human body, those eating the same amounts of the same
species of Great Lakes fish continue to increase their PCB Dody burden,  but
at a slower rate than ten years before.  Those who have changed their  diet  by
eating more salmonids (in response to the enhancement of the sport fishery)
have increased their exposure to PCB's, while those who have heeded the advisory
on fisn preparation and cooking have relatively reduced their PCB exposure.

More data and further analyses are needed to determine the interdependence  and
interrelationships of numerous variables, anticipated ana actual  exposure -
calculated according to food fish species, chronological time frames (specific
year individuals began/stopped eating the fish), and the effectiveness and
extent of implementation of the fish preparation and cooking advisory.

-------
                                     - 8 -

Generally improved environmental conditions have already permitted the limited
reestablishment of tolerant members of the biotic community.  As this process
continues, the returning organisms will be exposed to heavy toxics contamina-
tion, and can be expected to carry their PCB body burden back into Lake Michigan
and into the food chain and fishery.  Perversely, our success in cleaning the
waters of conventional pollutants sufficiently to restore aquatic life brought
back fish that were unsafe to eat; underscoring the need for a comprehensive,
coordinated approach.

HASTE

Region V's Emergency and Remedial Response Branch committed to performing
accelerated assessments and site inspections of closed or abandoned landfills.
The lEPA's State Superfund group has completed a surface removal operation
at U.S. Drum as part of the Clean Illinois program.  The site has been capped
and will be seeded shortly.  The three Paxton Avenue lagoons are the next site
on lEPA's cleanup agenda with remedial action projected to begin in September
of 1985.

The Regional Solid Waste Branch committed to performing accelerated inspection
and Part B call-ins of hazardous waste treatment, storage, and disposal faci-
lities.  Part B permit applications have been requested for all  of tUt treatment,
storage, and disposal facilities located in the area.  In addition, all of the
RCRA facilities in the area have been designated as "major" facilities and will
receive annual inspection from IEPA or EPA personnel.

There are 31 operating or retired landfills and waste handling facilities in
the study area.  Two sites are illegal special and hazardous waste storage or
transfer facilities in litigation.

One incinerator, having a destruction/removal efficiency of 99.99 percent for
aoproximately 12.5 million gallons per year toxic organics, was  permitted by
both U.S. EPA and IEPA to operate in the area.  Several other waste treatment
facilities have treated approximately 6 million gallons of aqueous hazardous
waste per year.

Summary of Land PollutionImpacts

In October of 1983, IEPA took soil borings and conducted groundwater sampling at
22 locations throughout the study area.  Analyses were conducted for 13 metals,
chlorinated hydrocarbon pesticides, PCB's, and volatile organic  compounds.
There were no significant amounts of organic compounds in any of the soil samples
tested, as most were in the less than 1-5 parts per billion range.  Levels of
metals in some soil samples were above the normal range and detectable concen-
trations were found for chrominum, cadmium, manganese, selemium  and zinc.
Analysis of groundwater samples showed that arsenic, barium, cadmium, chromium,
copper, lead, nickel, selenium, and zinc concentrations fell below Illinois'
water quality standards.  Only three of the metals analyzed (iron, manganese,
and silver)  were above these standards.  Though several volumes  of water were
removed from the well casing prior to sampling, sufficient flushing to adequately
remove sediments from the water was impossible.  This, plus the  industrial  waste
in the area, especially the slag from the steel manufacturing process, contributed
to the violations of the iron, manganese, and silver standards.

-------
                                     - 9 -
Regional Actions Planned:

Region V learned a great deal from the Southeast Chicago experience.   We
will be exploring possible ways to apply our experience gained 1n this
study to other multi-media problems.

-------
     -   i    r   .tr  "
•i   '    L   / •*—'>  /
                                    FIGURE 1.1
                          South Chicago Study Area Boundaries

-------
                       Appendix B - The Air Addendum


Note:   The Air Addendum covers page 1-41,  pages 42-59 describes  a proposed
        geographic-specific enforcement coordination effort  which has  some
        very interesting environmental  planning and environmental  indicators
        implications.

-------
United
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-------
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-------
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n t
0-
MU
rf
i

0 -

5 -

4 -

3 -

o _

1 -
' 0 -


g
A, / \
\
• \ *
f?
/ \ ' \ •'
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"^"-d \ ;
\ /

\ ; 1
•"' 1
, < 1
• . i
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Si

1 1 II 1 1
1977 1078 1079 1900 1901 M?n.*2 190'!

-------
W 5
       EXPECTED VOC EMISSION
                       CHICAGO AKKA
1 vf -
12 -

11 -

10 -

9 -
8 -

•w
/ -
6 -
5 -

4 -
3 -
I -
0_


















I
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                                                  f\l
                                                   I
                ACTUAL
                           EMJSPION

-------
04
g
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u


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o
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O
    190
       OZONE LEVELS  IN .SOUTHEAST INDIANA

                       CIIARLESTOWN, INDIAN* KITH
100 -
   I




170 -





100 -





150 -






140





130 -





ISO
     10
      1901
                                D— __
              D
                               1902


                    CENTER YEAR OF THREE YEAR

                 DESIGN VALUE          	  £
                                                    ' »O • )
                                                     ii.*
                                         'ERIDO
                                                              I

                                                             u»

                                                             tvj

-------
OZONE STANDARD EXCEEDAN< 'KS







w
0
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n
w
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d
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1 1 1
1900 luni iwi.'j nwifl M»
                               1<
             VKAH

-------
M 2
"I
8
         EXPECTED VOC  EMISSION  RKJ)ITf T1OJM
                            OZONK NA ARMAS
1 '1 -
13 -
12 -
11 -

10 -
9 -
0 -
pw
/ -
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5 -

4 -
3 -

2 -

1 -

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CI


















II
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1 T r%^













AKRON
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^_ ^
r!

J
                                         CINC'.
DL.
                IL.
                       MI.
Oil.
                ftCTOAL EMISSIONS
Oil.


[///I ALiounnir TMISIJONS
        MM. 7,


FORTKI-:


  IN.     vi.

-------
Environmental Protection Agency
            ftegtonV
               SO, 'ICNAT'AriME'iT A?£;S -- 1573
                   -23-

-------
Environmental Prota^on Aaancv
           n+9100 V

                  -29-

-------
POPULATION  IN NONATTA1NMKNT AIJKAS

                 SULFUR uicmnii;
K
                                          1
1 If -
9
0 -
•M
4 *~
§- o-
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,.' . ,*
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. "' - '" . '" ."" .-''
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•' .*
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...
.








•
.















                                                I
                                                CJ
                                                ro
                                                i
            1070
                     KAR

-------
0
    POPULATION IN NOW ATTAINMENT AKKAS
   *•*
   J ~
   1 -
  . 0
           IL
IN
                   SVIFVK
MN
f}i
                      PTATR

-------
         Umtao
Ehvfrorum.Ttat Prcttctteo Agency
            IS? NONATTAINMENT AREAS  —1973
                    -32-

-------
Eflvi ocifTHfitii PyotfcttefT Agency
             T3? NONA77AINME.VT AREAS — 1985
                     -23-

-------
O

 J a
t o
      POPULATION  IN  NONATTAlNMl-iNT AIWAS

                    TOTAL SUSPENDED rARTir:i.H,A1 W
14



JCI -



32 -



11 -



10



 » -


 0 -


 »M







 5 -



 I



 3 -






 1 -



 0
                    1070


                              VKAR

                   (ZZI I'RUiARV ST.^

-------
Bd
      POPULATION  IN NONATTA1NMKNT AK.KAS
 3 -



** •% _
•-» tVf —


 •*



1.5 -



 i -



0.5 -



. 0
               IL
                    TOTAL
                 IN
114
                             SL'ATtf
                               RTI
Oil
                                                            I
                                                            U1
                                            ~zrri

-------
CHICAGO TOTAL SUSPENDKJ) PAliTldJ LATttS
                TREND DATA AT WORST SITtf



r)
f
•++*
a
U
a
u
$
i-
f^
3,




100 -
100 -
170 -
100 -
150 -
140 -
1CIO -
120 -
110 -

100 -
90 -
00 -
70 -
80 -
7

1
Q-
~~-ra
L) ?' \
\ *1 » *
\
•
'•. •* •. •' •
\ / •. .0 \
\ •' \ -• i
ti fcr • \
\ ..n
fe"" " R.
11
t

•- ---n
' i
I I 1 1 II! 1 l - i - » l

i i i i i » : i i ' 1 i i
0 71 72 73 74 75 70 77 70 711 HO 01 R'2 OH H
 Q  WASHINGTON IIS SITE
                       YKAI?
ANNUAL ST.*

-------
o
      CHICAC 0  TOTAL SUSPENDK1.)  PART 1C' U1,AT
                        EXTRCTED EXCEED AN CB£* (n?171.\RV>
< u -
00 1

SO -

40 -
'JO -
20 -
10 -
o -

L
s, ^..•" "*».— _„-*"
B ^
rj





i i i i i i
71
             73
73
74
                      D
75
70
77
0   79
IIM
 1
01
                  YEAR
        WASHINGTON IIS PITIH
-H

—r
  no
  l\4
                                                               	|
IN

-------





*"V.
tf
5
kL CONC.
\


CLEVELAND TOTAL SI 'SPEND KD PARTK'UL
OOIJ
310 -1
200 -
IPO
100 -
170 -
100 -
150 -
140 -
130 -
120 -
110 -
100 -
00 -
00 -
70 -
00 -
7
TREND DATA AT TTORPT SITI-'
J

" m.
"3
V
\
*f
'• o ..D-... ..JJ
'TD r n
rj
• i
i
M -._..r-i '*
1
i

I i | ii I'l . i -.--.. i -| ... |

1 1 II 1 i 1 1 1 ' 1 ' *
II ***t 'v|o "->«-» ~> j '•-•x •"/< r-<»« " i » i*-4i itn til r» ~i r>o '•
U fl f£ fj /4 /O /II < / ill » » lid (11 il,Z '«.»
                                                                              I
                                                                              CO
D   4749 BROADWAY 31TR
                                  \\<:\R

-------
C'LKVKLAND TOTAL SUSPENJ)K1) PAKTH'i'l.ATKS
               EXI'KCTED EXnEPDANC-'fltf (I'l.'IM ArV>
 1 111


 imi
  00
  70 -
       q
           O
              a
                     _ n
40 -
no -
so-
0_
7
fcr"' ' ""•--..
13-— ___
i
n.. !
n.
"T3"'- •»:! 	 ii
1 "1 1 1 1 1 1 1 ! 1 • '
i 73 73 7i 73 70 7V in TU 150 HI II1,! n
                                                   I
                                                   111
              u

-------
DETROIT  TOTAL  SUSPENDED  PARTK'U
                 TREND DATA AT TUWFT r-'IJT':
                     ,AT





f
0
u
4
£
5




100 -
r
100 -
170 -
100 -
150
HO
130 -
120 -
110 -
100 -
90 -
80 -
70 -
00 -
*sn -
• %JU
7

}-

\
\
\ ^ _-0
\ N
ia— _
— D
-.,-,
PI—— r:*


i i i • i ... j | . ,, .. | ., ... | .. i .. . | . . . i i

i i i i i ; i i i i i i i
1 72 73 74 75 70 77 711 VH nil HI O.'J n.'J »JI
    D  DEARBORN SITE
'.Ts'AI?
  ^  ANNUAL r'TAWM'-'

-------
DETROIT TOTAL SUSPENDED
               EXPECTED EXCKEIMNC'ES (TK'IM/







§

a
ft








uu -
00^


70 -
00 -

50 -

40 -


30 -
20 -

10-
- 0-

1
\
\
\
\
\
\
V
\
\
b / p
\ *
*'*• *•' *
....ri'
0-""


i i i i i i
72 73 74 75 7fl 77 7'0
                 a
     YEAR
URARI30KN
                                o
                                    ri.
                                r
                                    1M)
                    01
112
in

-------
                Draft Geographic Enforcement Initiative - Major
                    Sulfur Dloxioe sources. Ohio River Basin


Attached is an outline of suggested activities for implementing a geographic
enforcement initiative (GEI) directed at insuring continuous compliance of
major sulfur dioxide emitting sources in the Ohio River Basin.  A major sulfur
dioxide emitting source  (MSDES) is defined as one whicn emits 50,000 tons of
sulf'ir dioxide (563) or more per year o£ which causes or substantially con-
tributes to a violation of the S0£ National Ambient Air Quality Standards
(NAAQS).  This draft GEI proposal specifically addresses those MSOESs
emitting 50,000 tons SOg or more.  Later drafts will include an Inventory
of those MSOES emittiny less than 50,000 tons S02 per year yet significantly
impacting amoient $02 air quality.

The basic thrust of this proposal is to use present authority to insure
strict and consistent compliance of all MSUES's with their existing emission
limits.  Tnose limits were established to either protect ambient air quality
standards or to reflect emission levels associated with tne best availaole
technology for new sources.  Because of a lacx of reported continuous
compliance data and the existence of conflicting interpretations of tne
applicable compliance averaging times for $02 emissions, the EPA cannot say
with certainty that these sources are in continuous compliance with their
established emission limitations.  Tnis lack of certainty is serious because
tne Ohio River Sasin has tne hignest concentration of SOj non-attainment areas,
Consequently, tne EPA 1s concerned that without close monitoring of compliance
of these MSDES's, ambient S02 levels: 1) will not soon improve in those areas
not meeting the NAAQS, 2) maybe in excess of the standards in unclassified
areas, and 3) coulc increase to exceedance levels in areas of marginal attain-
ment.

The Ohio River 3asin was cnosen for an air pollution G£I~because that area
nas a lingering amoient S02 problem and has been extensively characterizec in
the past by a joint Department of Energy and Environmental Protection Agency
researcn and development program (see "Ohio fliver Basin Energy Study (vW8£$):
Main Report", January 1981, EPA-600/781-008}.  The ORBES report provides
sufficient background information on the .r^ationship Of MSDES's and environ-
mental qua!fry in the basin.  The report clearly projects :ne effect of nign
S32 ambient concantrations due to emissions from MSOES's on crop losses and
puolic heaitn effects (increased mortality ard morbidity).

The area chosen for the GEI is a portion of the ORBES region.  It encompasses
those Air Quality Control Regions (AQCRs) directly bordering on or containing
portions of "he Ohio River (see Figure 1).  The proposes boundaries of tne
GEi include 11 AQCR"s and 163 counties in six different states.  Seven of tne
11 AQCRs cross state and £?A regional boundaries.  Interagency cooperation
ana coordination is a necessary component of any strategy for solving tne
amoient S02 prsolem in the Ohio River valley.  The boundaries of tne GEI
are preliminary ana could be cnanged based on input from Regions III or IV.
                                     42

-------
Though the proposed GEI area is approximately a third of the OR8ES area,
it contains a significant number of MSDESs.  The preliminary count of
MSDESs indicates 33 individual electric utility plant sites, all of which
were listed in the top 100 power plants nationwide in terms of S02 emissions
in 1980 (see Figure 2).  Twenty of these plants are located directly on tne
Ohio River.  Other than power plants no other type of stationary source
has been identified in the proposed GEI area that emits 50,000 tons or
more of SOg per year.  An inventory would be conducted after the GEI
boundaries are finalized in order to Identify other major sources of sulfur
dioxide that cause or significantly contribute to the elevated 503 ambient
air quality levels in the Ohio River Basins' non-attainment areas.

Our concern with the current status of the SOj air quality levels in tne
study area is illustrated by the following statistics:

     1)  In 1985 there are 16 counties designated as non-
         attainment or unclassified in regards to the SOg
         NAAQS within the proposed GEI area.  Nine of the
         11 AQCRs within the area have at least one non-
         attainment area.

     2)  IP 1983 and 1984, 23 of the total of 120 ambient 50s
         monitors located in the proposed GEI area recorded
         violations or marginal  comoliance with the primary
         S02 NAAtlS.  This is particularly significant in
         lignt of the recognized deficiencies in the existing
         amoient monitoring networks to effectively measure
         maximum SU2 impacts fror.: MSOES.  There are on average
        -4-ess-than-_one monitor-per county with an average of
         eleven per" AG.CR.~~~ Some of tne MQCRs have only three
         or four monitors total.  The existence of so many
         monitored exceedances with so poor « monitoring net-
         wor< indicates that there is a larger air quality
         proolem tnan wnac is currently being seen.

     3}  Emissions from the 33 power plants have remained fairly
         stable over the past six years.

Thus, we believe that the overall  air quality levels in the proposed GEI
area are currently showing a problem that has been lingering for many years.
Ensuring that tne MSOESs are at  least meeting the existing federally aoprove*
emission limitations on a continuous oasis would be a first step in expediting
elimination of the public nealtn proolem in this area.

-------
The proposed mechanisms for insuring effective enforcement of the applicaole
emission limitations, and thereby insuring continuous compliance are:

     1)  Determine the current applicaole S02 emission limits
         (or sulfur-in-fuel limits) for each MSDES.  Establish
         a hierarchy of those applicable SOg regulations using the
         classifying criteria of

         a)  numerical stringency of the emission limit,
         b)  stated or understood compliance averaging cime,
         c)  stated or understood compliance testing methodology,
         d)  stated or understood compliance testing frequency,
         e)  enforcement authority at the Federal, State and local
             levels.

     2)  Identify the SO? emission limitation chat best protects trie
         3-nour and 24-hour 302 NAAQS around each MSOES.

     3)  Identify any special enforcement or permitting programs tnat
         could effect the interpretation of the S02 emission limitations
         or attempts to enforce them.  This may Include factors such as:

         a)  stipulated penalty program based on continuous emission
             monitoring
         D)  pennit-to-operate
         c)  Pso/NSR/suBBLES/OfF-sETs/SANKiNG/TRADES
         d;  Environment Auditing
         e)  Site specific SIP revisions
         f)  Enforcement Orders and Consent Decrees
         g)  Enforcement Policies.

     A)  Identify for eacn MSOES the air pollution control  agency witn
         the primary responsibility for ensuring compliance fcr that
         MSDES with the SO? emission limitation that aest protects against
         snort-term amoient exceedances.

     5)  Establish commitments through AMAS, SPMS and performance Dasea
         grants for those specific lead agencies to require and evaluate
         emission information from those sources, to verify compliance
         with applicable limits using shortest apolicaole averaging time
         and to initiate enforcement if the source is not in compliance
         in accordance witn the EPA's timely ana appropriate enforcement
         policy.
                                    44

-------
     6)  Utilize discretionary authority (§114 or State authority) to
         require a uniform minimum level of source-generated emissions
         monitoring and reporting • CEM, FSA, intermittent monitoring,
         scheduled compliance test at each MSDES.

     7)  Establish schedules for installation of monitoring equipment
         and initiation cf reporting.  Allow approximately 6 months
         for initiation of reporting from sources installing and
         utilizing coal sampling and analysis (CSA) procedures for
         computing emissions on a 24-hour basis.  Allow approximately
         18 months for sources not presently equipped with SO2 C£Ms to
         install such equipment and begin reporting of S02 data.  CE*
         is tne preferred means of generating continuous compliance data.
         In the interim period, prior to installation of CEMs sources
         should be required to supply available CSA information.  MSDESs
         with 502 CEMs or CSA systems already in place would be required
         to begin reporting witnin 3 months of initiation of the program.

     8)  Establish and implement a consistent approach for the review ana
         use of continuous emission monitoring data and emission averaging
         times, for evaluating the compliance status of MSOESs in the GEI
         area.

     9}  Establish an interagency pool  of technical and enforcement expertise.

Also attached is background information on the area, ihe sources and the
regulations.  These areas would need to be further researched and detailed.
It is expected that personnel in Regions III and IV and in the state agencies
would be very active in all decision making associated with p. eparation of the
final draft proposal.

-------
                 GEOGRAPHIC ENFORCEMENT INITIATIVE (GEI)


1.  Purpose:

    Insure continuous compliance of major sulfur dioxide emitting sources,

2.  Major Source:     '
                                   i
    Emitting in excess.of 50.0CC tons SOj/year.

3.  Selected Area Must:

       show significant  decl.ine
       show lack 0^ Improvement
       be a threat to health
       have multi-media  violations
       have cross-boundary inpacts
       have enforceable  regulation

    Area Selected

    *  Ohio River Basin  (area has saricus SOj problems)

    8  Without close monitoring

       - Area will not imorove
       - NAACS will not  be achieved

    Area Cover;

    0  Illinois
    "  Indiana
    0  Ohio
    0  Pennsylvania
    "  West Virginia
    0  Kentucky
    0  11 Air Quality Control Regions (AQCRs)
    *  163 Counties

    07ants In Each State

    3  Illinois  	  1
    *  Indiana 	  *
    6  Ohio 	  9
    3  Pennsylvania	  6
    9
    a
West Virginia	  2
Kentucky 	  7

"OTAL 	  33 °!ants (A1!!  among the tco *.T. slants
                                      in the nation."
                                     46

-------
7.  The GEI Program will
       require emissions Information
       evaluate emissions Information
       verify compliance with applicable limitations
       Initiate enforcement
       utilize Section 114 or State authority to require:
                       compliance test
                       monitoring data
                       intermittent monitoring
                       CEM installation
    *  establish schedules for C£M installation
    *  establish procedures to review and use CcM data
    '  establish an interagency pool of technical  and
       enforcement expertise
    0  require coordination of twenty regulatory agencies
8.  Steos 9ecu1 red To Develop Gel
    *  Discuss tha problem area using geographic orientation.
    0  Coordinate with Ragion I and preoare a joint prooosa"!.
    '  Coordinate with Regions III and IV.
    0  Identify available enforcement requirements.
    0  Develop a list of minimum criteria for enforcing
       existing emission limitations.
    8  Identify all sources which emit significant quantities
       of S02.
    9  Identify actual emissions of each source.
    0  Identify allowable emission limits for each source.
    *  Develop a compliance and enforcement plan.
    a  Develop better, more elective-cooperative relationships
       with States.
    0  Develop performance based grants and S?MS commitments.
    0  Set overview procedures to track State and "ederal  progress
    9  Inif'ate federal enforcement action i* States do not o
       satisfactory.
                                     47

-------
Geograohic Enforcement Initiative
Addressing Major Sulfur Dioxide
Emitters in the Ohio River Basin

David '
-------
           OUTLINE FOR DEVELOPING A SO? GEOGRAPHIC ENFORCEMENT
                          INITIATIVE ACTION PLAN
Phase 1
1.  Select an area for pilot stu
-------
Phase 3
 9.  Develop better, more efficient-cooperative relationships with States.
10.  Develop performance based grants and SPMS commitments.
11.  Set overview procedures to track State and Federal  progress.
12.  Take Federal enforcement action If States do not proceed satisfactorily,
                                     50

-------
             ill Joppa

        INDIANA

             Plant
 2           IPL Petersburg
 3           PSI Gallagher
 4           PSI Gibson
 5           SIGECO warriex/Culley
 6           IKEC Clifty Creek
 7           IMEC Creed
 8           IMEC Tanners  Creek
33           HE Satis

STATE:   OHIO

No.          Plant

 9           8P Cardinal
10           CG4E BecKjord
11           CS4£ Miami Fort
12           QPSL Stuart
13           OE Burger
14.           OE Samnris
15           OVEC Kyger CreeK
15           OP MusKingum River
17           OP Gavin

S"AT£:   PENNSYLVANIAN

No.          Plant

18           WPP Hatfiela
19           °P Mansfield
20           P£ Conemauyn
21           ?E Homer City
22           ?E Keystone
23           PE
                                     51

-------
STATE:  WEST VIRGINIA

No.          Plant

24           OP Mltcnell
25           OP Kamrner

STATE;  KENTUCKY

No.          P1?nt

26           8REC Colerian
27           BREC Henderson  II
28           KU Ghent
29           IGc Mill Creefc
30           TVA Paradise
31           TVA Sha^nee
32           KP Big Sandy
                                     52

-------
                   Table 3.6

Ohio River Sun-Electric Pow Genentini Planu
                  1975 - 1913
Ml* Poiat

2.3
IS. 6
33.5
33.1
34.5
SS.O
S9.1
74.5
75. 0
101.9
102.5
in.i
160.3
160.5
241
254
260.2
405.7
414
451
453.3
471.4
490.3
494.5
536
551.5
400.6
604.0
416,6
611
771
752.1
755.3
773.0
7T3.0
773.1
793.5
103.6
946.0
951.3
Station

J. H. REED
F. PHIUXPS
BRUCE MANSFISLD
SHlPPINGaC
KAVBt VAtLET
V. H. SAM4XS
TCRCKTO
*«••
CW8INAL
MTTOm
R. E. MCE*
XMMEft
PLSA&WTS
WIU» ISLAM)
MTU? S?OW
GAVT>
JttUcK CSX
J. M. STUOS
•94**fcSS»»<-8BW»C
4CffBT
w. c. aojORo
NEST SC
MLMC KST
IMMEU OtfS
GET
ciFrr gy?y
VCU. OZBC
PATCY'S M(
CMC XX
GVI1AGSI
OXS4M
OMD63CH' MJN H
ELMER SMITH
NAWUOC »i,2,:
WAWICX 14
aurr
OHIO «%•&
HENDEaSCN
S^AXNC
JCPPA
Initialed Gtamtuif Capacity (MO
1975
1M
411.2
125
100
IS*
2303.5
175.1
226.3
1230.5
1632.6
544
712. S
-
215
1105.5
1300
1016.3
2400
-
-
1220.3
219.3
193.3
U00.3
5S9.9
1303.6
3ZL.1
337.5
1H6.7
637
340
52.5
41S
432
300
149.7
121.5
223.2
1?50
1100.:
1977
110
4u.:
1650
100
156
2303.5
17S.1
226.3
1145.5
1632.6
544
712.5
125
215
1105.5
260C
10M.3
2400
300
-
1220.3
as. 3
U93.3
1100.3
U13.1
1303.6
74«.l
337.5
1016.7
637
340
52.5
415
432
300
149.7
121.5
:25.:
1750
1100.3
1913
110
411.2
165C
100
1712
2303.5
17J. 3
0
IMS. 5
1632.6
544
712.5
1650
as
1105.5
• 2600
1016.3
2400
300
2023
1220.3
=19.3
1393.3
1100.3
1113. 3
1303.6
1171. 1
337. S
1016.7
. 637
340
52.5
415
432
300
149.:
121. S
22S.2
1750
1100.3
Saurc*:
       l PQKVT

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   54
v ""nnsir^ '


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REGULATORY AGENCIES
 1.  U.S. EPA Region III
 2.  U.S. EPA Region IV
 3.  U.S. EPA Region V    ACB
 4,  Illinois EPA Region 3
 5.  Indiana A1r Pollution Control  Division  (State  Board  of Health)
 6.  City of Evansville, Indiana A1r Pollution  Control Office
 7.  Ohio EPA Southwest District Office
 8.  Ohio EPA Southeast District Office
 9.  Southwestern Ohio Air Pollution Control  -  Cincinnati
10.  Regional Air Pollution Control  Agency -  Montgomery County
11.  Air Pollution Unit - Portsmouth City Health  Department
12.  North Ohio Valley Air Authority -  Sceubanville
13.  Mahoning - Trumbull Air Pu.,ution  Control
14.  Air Pollution Control Division - Canton  Health Department
15.  Pennsylvania Bureau of Air Quality Control
16.  Allegheny County Bureau of Air Pollution Control
17.  West Virginia Air Pollution Control  Commission
18.  Wheeling Air Pollution Control  Department
19.  Kentucky Dept. of Environmental Protection - Division of Air Pollution Control
20.  Jefferson County Air Pollution Control  District
                                    55

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                     56

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                               57

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Appendix C - Great Lakes National Program Office
             Areas of Concern and Anticipated
             Availability of Remedial Action Plans

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                                                  ««EAS OF CONCE.N ,« THE «,tM U«S 8AS.H
•WMICAMHMMM

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                                   T*BLE *
                  AREAS OF CONCERN IN THE GREAT LAKES BASIN
MAP
REF. «.«

1
2
3
4
5
6
7

8
9
10
11
12
13
14
15
16
17

18
19
20
21

22
23
24
25
26
27
28
29

X
31
32
33
3*
35
36
37

38
39
40
41
42
LAKE BASIN/AREAS OF CONCERN
Lake Superior
Peninsula Harbour
Jackflsh Bay
Nipigon Bay
Thunder Bay
St. Louis River
Torch Lake
Deer Lake-Carp Creek-Carp River
Lake Michigan
nanistique River
Menominee River
Fox River /Sou them Green Bay
Sheboygan
Milwaukee Estuary
Waukegan Harbor
Grand Calumet River/Indiana Harbor Canal
Kalanazoo River
Muskegon Lake
White Lake
Lake Huron
Sagioaw River/Saginaw Bay
Collingwood Harbour
Penetang Bay to Sturgeon Bay
Spanish River Mouth
Lake Erie
C1 in ton River
Rouge River
Raisin River
Maumee River
Black River
Cuyahoga River
Ash tabula River
Wheat ley Harbour
Lake Ontario
Buffalo River
Eighteen Mile Creek
Rochester Embayment
Oswego River
Bay of Ouinte
Port Hope
Toronto Waterfront
Hanril ton Harbour
Connecting Channels
St. Marys River
St. Clair River
Detroit River
Niagara River
St. Lawrence River
JURISDICTION

Ontario
Ontario
Ontario
Ontario
Minnesota
Michigan
Michigan

Michigan
Ml chi gan/Wisconsi n
Wisconsin
Wisconsin
Wisconsin
Illinois
Indiana
Michigan
Michigan
Michigan

Michigan
Ontario
Ontario
Ontario

Michigan
Mi chi gan
Michigan
Ohio
Ohio
Ohio
Ohio
Ontario

New York
New York
New York
New York
Ontario
Ontario
Ontario
Ontario

Ontario/Michigan
Ontario/Michigan
Ontario/Michigan
Ontario/New York
Ontario/New York
a.  See Figure 1.

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                                     TABLE  5
              NUMBtR OF AREAS OF CONCERN ASSIGNED IN EACH CATEGORY
                              BY THE JURISDICTIONS
JURISDICTION
Michigan
New York
Ohio
Wisconsin
Illinois
Indiana
Minnesota
Pennsylvania
Total U.S.
Ontario
Great Lakes Basin
TOTAL
14
6
4
4
1
1
1
.0
31
17
48*
CAT
1







— —
0
0_
0
2
4






—
4
L.
5
EGORIES
3
7
3
4
3



—
17
10
27
4
2
2

1
1
1
1
— -
8
A
14
S

1





—
1
o
1
6
1






—
1

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                     TAIU  t




ANTICIPATED AVAUAULITY  OF REMEDIAL ACTION PUNS
JURISDICTION/AREA OF CONCERN
ONTARIQ
Peninsula Harbour
Jackflsh toy
Nlpigon Say
Thunder Say
ColHngtood Harbour
Penetang Say/Sturgeon Bay
Spanish River Mouth
Wheatley Harbour
Say of Quinte
Port Hooe
Toronto Waterfront
Hamilton Harbour
St. Marys liver
St. Clalr River
Detroit River
Niagara River
St. Lawrence River
ILLINOIS
uaukegan Harbor
INDIANA
Grand Calweet/Indlana Harbor
MJC.HI6AN
Torch Lake
Deer Lake-Carp River
Manlstlgue River
NenoMlnee River
Kalanazoo River
Muskegcn Lake
white Lake
Saglnaw Rlver/Saglnaw Say
CUnton River
Rouge River
Raisin River
St. Marys River
St. Clalr River
Detroit River
St. Louis River
NCx roan
Buffalo River
Eighteen Nile Creek
Rochester Ue&ayeant
Oswego River
Niagara River
St. Lawrence River
OHIO
MauKee River
Slack River
Cuyahoga River
Ashtabula River & Harbor
PENNSYLVANIA
Menoninee River
Foi River/Southern Green Say
Sheboygan
Nllwaukre Estuary
TOTAL
CATEGORY
















4
3

4

4
2
4
2
3
3
b
4
3
•\
3
2
3
3
2
4
3
4
4
3
3
S

3
3
3
3

3
3
3
4

JUNE 85





X

X
X





X

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X



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_x
IS
JUNE Si

X
X
X





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X






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X
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X
X












X

X
X

—
IS
DEC 86




X

X




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X


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X


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X
X



X
—
18

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