ENVIRONMENTAL
MANAGEMENT
REPORT
UPDATE
REGION 6
SEPTEMBER 1984
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TABLE OF CONTENTS
Subject Page
Part I, The Regional Administrator's Overview 1
Part II, Regional Environmental Problems 4
Listing and Ranking of Environmental Problems 5
Growth 9
Ozone 11
Toxics 14
Ground Water Quality Problems 16
Pesticide Drift 19
Nonpoint Source Pollution 21
Sludge Management and Disposal 23
Leaking Landfills 25
U.S./Mexico Border Problems 27
Part III, Recommendations for the Agency's 29
Fiscal Year 1986-1987 Priority List
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EXECUTIVE SUMMARY
Region 6 has within the borders of its five states—Arkansas, Louisiana,
New Mexico, Oklahoma, and Texas—over 560,000 square miles. There are
marked differences across Region 6 in climate, topography and ecosystems
which require a wide range of State and EPA programs to adequately
protect the environment and public health. From the large industrial
centers to the sparsely populated deserts, great differences are found
in demographic make-up, socioeconomic structure, and environmental problems.
These differences combined with the rapid population growth occurring ano
projected in much of Region 6 present a very challenging task for both
the States and EPA.
Located in the "Sunbelt," states of Region 6 are experiencing a major
population growth. A number of urban centers have doubled or tripled
in population over the last 10 years. Austin, Texas, for example, has
been recently been rated as the fastest growing city in the United States.
In addition, such expansion has not been restricted to major metropolitan
areas such as Dallas-Ft Worth, San Antonio, and Houston, but has extended
to the desert southwest cities of El Paso and Albequerque, NM.
The population growth in the "Sunbelt" states of Region 6 has caused major
growth problems for water utilities—not only water supply but in dealing
with vast increases of wastes—municipal sewage and sludge. Solid and
hazardous waste problems have been intensified with municipal and industrial
expansion.
In addition to population growth, the heavily industrialized areas of the
Texas and Louisiana coasts continue to experience growth in the primary
areas of chemicals and allied products as well as in a wide variety of
other industries. There are significant problems in these areas as a
result of Volatile Organic Carbon (VOC) emissions from the petroleum and
chemical industries. In two metropolitan areas, the Ozone National Ambient
Air Quality Standard (NAAQS) is not being met in large part because of
stationary source emissions. A unique problem also exists with rural
nonattainment of NAAQS for ozone as a result of VOC emissions in the Gulf
Coast area. We and the states are actively pursuing solutions to both
the rural and metropolitan ozone problems through State Implementation
Plan revisions.
Ground water quality in Region 6 has generally been very good and no
public water supply has had to close because of contamination. Localized
Incidents have, however, affected some private supplies. Because the
potential for ground water contamination exists throughout Region 6, steps
have been taken to focus on ground water protection by establishing
and staffing an Office of Ground Water (OGW) in the Water Management
Division. The OGW serves as a clearing house and coordination center for
Implementing the Ground Water Protection Strategy in Region 6.
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Water quality problems also result from nonpoint source (NFS) pollution.
In some areas with compliant point source controls, NFS pollution will
prevent water quality standards from being met. Solutions to this problem
will Involve many parties with divergent interests.
Region 6 has a 1200 mile border which it shares with Mexico. This is
Mexico's densely populated northern region and environmental quality issues
can be difficult to resolve because of the economic disparity between our
nations. Region 6 is making progress toward the resolution of those issues
which do exist through the implementation of the Environmental Agreement
signed by the Presidents of the United States and Mexico.
Toxics control has a high priority in Region 6 and all media (air, water
and solid wastes) are involved. Significant control efforts are being
implemented in the areas of pretreatment, sludge management, air toxicant
emissions, leaking underground storage tanks, landfills, and agricultural
chemicals. There are many emerging toxics issues and problems both regional
and national in scope which must be assessed and assigned a priority over
the next few years if progress is to be made in this area.
The objective in Region 6 is to continue to meet the challenge of protecting
the environment and human health without unnecessarily restricting economic
growth. To do this the Region must continue to focus on preventative
measures to protect the gains that have already been made while at the
same time pursuing meaningful and achieveable objectives for environmental
improvement.
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Part II, Regional Environmental Problems
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1984 EMR UPDATE
S1on1fleant Environmental Problems
Environmental Problems
by Relative Ranking
Growth
'Ozone
Toxics
Geographic
Scope
Growing
Metropolitan
Areas
Major
metropolitan
& Industrial
centers and
adjacent
rural areas
Reglonwide to
some extent;
particularly
along Gulf
Coast area of
Industrialized
TX and LA
Major Impacts
Water Quantity and
Quality Air Quality,
Sensitive Areas,
Public Health
Public health
effects
Level of
Public Concern
Low to Moderate
Medium to high
Contamination of
ground water,
surface water,
and air toxic
pollutants;
health hazards
High
Major Sources
Growth Related
Activity
Automobile
emissions *
Industrial
voc's
Petrochemical
and Chemical
manufacturing
Industries;
hazardous waste
incinerators;
electroplaters
Contaminant
of Concern
Numerous
volatile
organic carbon
Volatile
organic
compounds,
other toxic
organic
compounds, and
heavy metals
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1984 EMR UPDATE
Significant Environmental Problems
Environmental Problems Geographic
by Relative Ranking Scope
Ground Water National
Quality Problems
Major Impacts
Depredation of water
supported by ground
water discharges
Level of
Public Concern
High
Major Sources
-Injection wells
-Improperly plugged
or completed oil &
gas wells
-Improperly plugged
or completed water
wells
-recharge wells
-unllned disposal
pits
-solid waste
-land application
-septic tanks
-fertilizers
-feedlots
-irrigation return
flow
-overpumplng
-highway deidng
-spills
-mining A milling
-leaky storage
-tanks A pipelines
Contaminant
of Concern
brine, municipal
* indust. waste
brine
brine,
mineralization
mineralization,
bacteria
brine, municipal A
indust. waste
organics, heavy
metal
heavy metals,
nitrates
nitrates, bacteria
nitrates
nitrates
nitrates
salts
sodium, chloride
hazardous
chemicals
metals,
radiochemlcals
salts
organic compounds
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1984 EMR UPDATE
Significant Environmental Problems
Environmental Problems
by Relative Ranking
Pesticide Drift
Geographic
Scope
Req1onw1de
Nonpolnt Sources
Region/
Nationwide
Sludge Management
Municipal
Industrial
Regional &
National
Regional
Major Impacts
Drift of pesticides
from agricultural
application can
damage other crops
& oardens, cause
contamination of
food and can
sometimes result
1n health effects.
Impact potential
on water quality
frequently
exceeds point
source
Level of
Public Concern
High
Moderate to low
possible contamination
of food, ground and
surface waters, fear of
disease, odor, flies.
Possible contamination
of food, air, ground
and surface water,
fear of toxic and
hazardous wastes
Low to moderate
High
Major Sources
Agricultural A
Home application
of pesticides.
Agricultural
Urban Runoff
Residual Waste
Silviculture
Mining
Construction
Runoff
Municipal WWT
facilities
Industrial
processes
Contaminant
of Concern
Herbicides 4
Insecticides
Pesticides 4
Herbicides
Nutrients
Metals
Oxygen-demanding
matter
Turbidity
Salinity
Organics &
Hydrocarbon
Odors, path
Nutrients
Hazardous Material
toxic substances.
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1984 EMR UPDATE
Significant Environmental Problems
Environmental Problems
by Relative Ranking
X
Leaking underground
storage tanks
nternatlonal
Border Problems
Geographic
Scope
Nationwide
US/Mexico
border with
Texas
Major Impacts
Contamination of
ground water
A1r Quality
Attainment
Sewage pollution
Illegal transpor-
tation/disposal
Public health
threat/Environ-
mental damage
Environmental
dispersion of
wastes
Level of
Public Concern
High
High
High
High
Medium
High
Major Sources
Underground
storage tanks
Juarez emissions
Nuevo Laredo
Unknown
Industrial
facilities,
transportation
Radioactive
waste handlers
Contaminant
of Concern
Gasoline,
solvents
C0,03
Raw sewage
Hazardous/
Toxic Wastes
011 and
hazardous
substances
and wastes
Cobalt-60,
and other
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GROWTH
1. Problem Assessment
The five States of Region 6 -- Arkansas, Louisiana, New Mexico, Oklahoma
and Texas « lie at the heart of the "Sunbelt". Growth in population and
industrial activity in and around metropolitan areas throughout the Region
has been tremendous. More than 26 million people now live in Region 6,
and population is expected to increase by almost 40 percent by the year
2000. Presently, three of the twelve largest cities and two of the ten
largest Metropolitan Statistical Areas (MSA) in the country are in the
Region. Almost all of the metropolitan areas in the Region are growing at
rates faster than the national growth rate. Metropolitan Houston and
Dallas-Fort Worth were the fastest growing large metropolitan areas in the
country from 1980-82, at 11.5 percent and 7.3 percent, respectively.
Population and industrial growth in Region 6 is resulting in increased
pressures on the environment in virtually every area, including:
- increasing demands for fresh water, which is placing pressures on the
ability to maintain quality and quantity within water supply systems;
- increasing sewage discharges putting pressure on treatment facilities,
often in areas where assimilative capacity of receiving waters is limited;
- proliferation of inadequate septic systems;
- increasing development in urban areas and around water supply reservoirs
near urban centers, generating non-point source discharges;
- overpumping of ground-water resources resulting in salt water intrusion,
increased susceptibility to contamination and surface subsidence;
- increasing energy exploration and development;
- increasing air emissions from mobile sources in combination with stationary
sources are resulting in difficulty attaining and maintaining NAAQS for
ozone and carbon monoxide in metropolitan and adjacent rural areas.
- development of lignite coal fired electric power generation with the
associated impacts such as discharges of S02 and particulates;
- increasing potential for exposure to toxic air pollutants from industrial
sources due to growth in densely populated metropolitan areas;
- increasing hazardous waste generated by a growing number of generators;
- increasing residential development in previously agricultural areas,
resulting in increased potential for drift of pesticides into residential
areas;
- increasing potential for environmental emergencies brought on by increasing
industrial activity, concentration of people near industry and transpor-
tation corridors and development in or near hazardous waste dump sites;
- increasing development placing pressures on environmentally sensitive
areas such as wetlands, fishery nursery areas, and floodplains.
Most of these areas of environmental concern are related directly to the
ability of local governments to plan for population increases. Most people
do not perceive the growth being experienced in Region 6 as a significant
environmental problem. However, they do perceive some of the potential
environmental problems resulting from growth as significant concerns.
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2. Regional Agenda
a. Expected Results of Regional Action: Region 6 action to address
growth as an environmental problem and work with State and local governments
In Implementing appropriate planning measures to accommodate growth would
result 1n prevention of significant degradation in many areas. By acting
to correct these problems before they become more serious, we reduce the
risks of more detrimental effects on the human population and the costs
necessary to correct the problem are minimized.
b. Extent of State Participation: Extensive participation of State
and local governments would be necessary. Many of the programs affected,
e.g., construction grants, review of air emission sources, vehicle inspection
and maintenance, are delegable to the States. Other activities relate to
areas where states have responsibilities under state law. Local government
planning would also be important.
c. Regional Actions and/or Plans: EPA, Region 6, plans to make efforts
to maintain environmental quality and make improvements in areas where mean-
ingful environmental gains are possible. A key part of accomplishing this
in the fast growing metropolitan areas will be effective planning to address
environmental concerns before they become more serious.
d. Timing requirements: Dealing with growth as an environmental
problem will be necessary as long as the present trends continue.
e. Barriers: The principal barriers are: 1) the pervasiveness of
_.__,,._ ~* ^ f __^,- ..,.L L,_h it must ^e coordinatr
program which includes
e. Darners: i ne principal carriers are: i) u
the problem; 2) the number of entities with which it must be coordinated;
and 3) the difficulty inherent in promoting any progi
« a II* I • »__^___» ___.«__ ^
elements that may be viewed as land use control
3. Headquarters Actions Needed
a. Specific Action Requested: EPA, Region 6, requests headquarters
support in time and resources in developing and implementing policies
geared toward early action in addressing growth related issues.
b. EPA Offices and Programs Involved: EPA, Region 6, forsees all EPA
Offices and Programs to be involved — some continuously.
c. Timing Requirements: Dealing with growth as an environmental problem
will be necessary as long as the present trends continue.
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OZONE
1. Problem Assessment
Region 6 has an ozone problem that Is not adequately addressee by national
guidance and must use unique approaches to protect the health of citizens
regionwide. This will be a resource intensive effort.
There are currently 32 counties/parishes in Region 6 that are classified as
nonattainment for the Ozone National Ambient Air Quality Standard (NAAQS).
Six urban areas (Dallas, Tarrant, and El Paso Counties in Texas, East and
West Baton Rouge Parishes in Louisiana, and Tulsa County in Oklahoma) are
classified as post 1982 nonattainment areas and received calls to submit
State Implementatation Plan (SIP) revisions by February 24, 1985. Harris
County, which is also an urban nonattainment area, has been given an
extension to demonstrate attainment by December 31, 1987. Eighteen
counties/parishes are considered rural ozone nonattainment areas and are
not now subject to SIP revisions that require attainment of the NAAQS.
The remaining areas are urban nonattainment areas which are expected to
be redesignated to attainment soon. They are: Pulaski County in Arkansas;
Nueces County in Texas; and Bossier, Caddo, Jefferson, St. Bernard,
and Orleans Parishes in Louisiana.
The major components of the ozone problem are hydrocarbons (HC) and nitrogen
oxides (NOX) emitted by automobiles and Volatile Organic Carbon (VOC)
emissions from stationary sources. Region 6 suspects that the lack of
continuous compliance from major stationary sources and increased automobile
emissions because of a high rate of tampering and misfueling are major
contributors to the continuing ozone problems in Region 6, especially the
six post 1982 nonattainment areas.
Listed* in Table 1 are the 18 ozone nonattainment areas in Region 6 which
are classified as rural nonattainment areas because they lack central
city populations of 200,000 or greater. The official EPA position is
that they exceed the NAAQS because of the impact of emissions from nearby
urban areas. In Region 6, we believe some of these areas are generating
their own problems. For example, in 1982 Jefferson County, Texas had VOC
emissions totaling 103,800 TPY. By comparison, Dallas County, an urban
nonattainment area, had VOC emissions of 82,400 TPY during that same
year. The petroleum industry and other sources of VOC emissions in the
Gulf Coast area have created this unique situation in Region 6.
Table 1
Rural Nonattainment Areas in Region 6
Orange Co., TX
Jefferson Co., TX
Victoria Co., TX
Brazoria Co., TX
Gregg Co., TX
Galveston Co., TX
Ascension Par., LA
Iberville Par., LA
St. James Par., LA
St. John the Baptist Par., LA
Calcasieu Par., LA
Point Coupee Par., LA
Grant Par., LA
Beauregard Par., LA
Lafourche Par., LA
Lafeyette Par., LA
St. Mary Par., LA
St. Charles Par., LA
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3. Regional Agenda
a. Expected Results of Regional Action: (1) The receipt of ozone
SIP revisions for the urban areas into the Regional Office in 1985. (2)
Development of SIPs in some rural areas in FY 1985; submittal in FY 1986.
(3) Generation of reliable information to show the impact of source
upsets/malfunctions on attainment. (4) Development and implementation of
Inspection/Maintenance (I/M) or Antitampering programs in the majority of
the post 1982 nonattainment areas.
b. Extent of State Participation: (1) Texas is currently cooperating
with EPA on HC sampling in preparation for ozone modeling to be carried
out in the urban areas to determine the emissions reductions needed.
Louisiana has also begun an HC sampling program. The State presently has
data for Baton Rouge and is working to collect data for rural areas. (2)
FY 1985 and FY 1986 air grants will require the states to study the
impact of source upsets/malfunctions on attainment.
c. Regional Action/Plans: (1) A major initiative will be required to
determine if the problem is due mainly to emissions from automobiles or
stationary sources. Also, the impact of source upsets and malfunctions
will be adequately evaluated so that corrective measures can be incorporated
into the SIP control strategy development process. (2) Ozone modeling
will be performed to determine the extent of VOC controls necessary. (3)
A set of criteria to determine ozone self-qeneration in rural areas has
been devised by Region 6 Air Branch staff and forwarded to OAQPS for
comment. Region 6 intends to identify self-generators by criteria based
on air flow patterns, ozone contamination from other areas, and natural
ozone levels. Then, Region 6 will call for SIP revisions for VOC controls
in the identified counties/parishes. (4) Region 6 plans to finish categor-
izing the rural counties and discussing the results with the states by
Fall 1984. (5) Calls for SIP revisions have been issued by Region 6 to
the affected states for the urban areas. (6) Additional HC and MOX data
collection efforts are underway in a 1984 special summer monitoring study.
(7) Development of mobile source control programs, such as anti-tampering
programs, in all post 1982 non-attainment areas when needed.
d. Timing Requirements: A call for SIP revisions is expected to go
out in late 1984 - early 1985. However, it may not include all affected
rural areas due to the Region's limited resources. Some will need to be
addressed in FY 1985 and FY 1986.
e. Barriers: (1) OAQPS may rule that our Rural Ozone approach is
unacceptable, or Texas and Louisiana may take serious issue with our
criteria. Any controls ultimately proposed may be difficult to implement
because of increased resistance to tighter controls on industries. (2)
Modeling difficulties that would delay control estimates as would public
protests over the proposed control stategies.
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4. Headquarters Action Needed
a. Specific Action Requested: Specific guidance has been, and will
continue to be, required for EKMA/OZIPP modeling, collection of HC grab
samples, and the use of the Mobile 3 emissions model.
b. EPA Offices and Programs involved: Office of Air Quality Planning
and Stanbards, Control Programs Branch, and Office of Mobile Sources.
c. Timing Requirements: A reply to our submittal of July 19, 1984,
on the Region 6 classification criteria should be made as soon as possible.
Initial decisions on SIP revisions were submitted to OAQPS August 21,
1984. Additional calls will be made as the data are generated in FY 1985
and 1986.
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TOXICS
1. Problem Assessment
Existing and potential problems regarding toxics in the environment have
been cause for some public concern within Region 6. Primary concerns in
addition to those cited under "Ground Water Problems" are with potential
air, water, and soil contamination by toxic pollutants from the petro-
chemical , refining, and chemical manufacturing industries located along
the Gulf Coast area from the Houston Ship Channel to the Lower Mississippi
River area. EPA and the States are monitoring effluents, receiving waters,
and ground waters where the presence of toxicants is suspected. Enforcement
of pretreatment requirements and the investigation of potential leaks from
underground storage tanks are activities necessary to control potential
soil and ground water contamination. Adequate data are not always avail-
able to fully assess the health hazard from toxic air pollutants. The
Office of Air Quality Planning and Standards has started a pilot program
to regulate emissions of acrylonitrile through Memorandums of Understanding
(MOUs) with the affected states (Louisiana and Texas in Region 6). This
will allow the Region to assess and control potential health hazards from
emissions of acrylonitrile in a more timely manner than would occur through
the promulgation of a Federal National Emission Standard for Hazardous Air
Pollutants (teSHAP).
2. Regional Agenda
a. Expected Results of Regional Action: The following results are
expected to be accomplished through Regional actions: (1) major participa-
tion by the Region 6 states and local agencies in developing ground water
protection strategies, in gathering the required environmental information,
and in formulating adequate data bases, to assess, and to implement control
measures for problem solutions, in all media (e.g., biomonitoring for
various stream segments), (2) vigorous enforcement by Region 6 of the PCB
and asbestos regulations focusing inspections upon the sources having the
greatest potential for public exposure, (3) the development by Region 6
states of effective toxics programs in all media (4) the use of an inte-
grated, coordinated approach to toxic pollutant problems within the Region,
and (5) the negotiation of MOUs with the Region 6 states concerning the
regulation of acrylonitrile.
b. Extent of State Participation: State participation is critical to
the solution of the Region's toxic problems. With the delegation of many
program responsibilities to the states, the state agencies have assumed
much of the lead for developing and implementing programs to control the
pollution of surface water, ground water, and air toxicants.
c. .Regional Actions and/or Plans: Specific Region 6 actions underway to
achieve the expected results are the following: (1) the development of a
Regional program to provide the Region 6 states with guidance and funds to
develop and to implement their own programs for controlling ground water
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contamination from toxic pollutants, (2) the identification of specific
water bodies which receive toxic pollutants, and the identification of
pollutant sources whose permits will be revised to eliminate, or to minimize,
toxic pollutant discharges, (3) the continuation of an active Regional air
toxics program which provides to the Region 6 states technical information,
program coordination, and support to states in developing regulatory programs
for a variety of toxic air pollutants, (4) the use of an integrated approach
within the Regional Office to coordinate across-media and (5) the drafting
of MOUs with Louisiana and Texas for the regulation of acrylonitrile sources.
d. Timing Requirements: Region 6 anticipates having guidance and avail-
able funds from CWA Section 106 grants for addressing the ground water toxic
pollutant problem by the end of Fiscal Year 1985, and to have implemented
ground water protection programs by July of 1986. The identification of
specific water bodies receiving toxic pollutants, and the specific sources
contributing these pollutants is already underway. Acrylonitrile regulatory
MOU's will be initiated with Region 6 states in August 1984, finalized in
October 1984, and monitored throughout FY 1985.
e. Barriers: Barriers to the success of the Region 6 toxic-related activi-
ties are the following: (1) the absence of technical information and guidance
for toxicant monitoring activities in the water and air media, (2) the poten-
tial for implementation problems in the regulation of acrylonitrile sources
through MOUs, (3) the lack of a focused national toxics strategy, and (4)
costly analytical methods and equipment which limit the amount of data
which can be effectively obtained.
3. Headquarters Actions Needed
a. Specific Actions Requested: To accomplish the goals regarding the
toxics problem within Region 6, the development of a national strategy,
implementation guidance, and technical assistance for the air toxics pro-
gram and for controlling toxicant introduction in all media would greatly
enhance the toxics programs of the individual states.
b. EPA Offices and Programs Involved: The Office of Ground Water
Protection, the Office of Solid Waste and Emergency Response, the Office
of Air, the Office of Pesticides and Toxic Substances and the Office of
Drinking Water will be involved in the development of a national toxics
strategies.
c. Timing Requirements: Immediate finalization of the national ground
water strategy, and the provision of an acceptable national air toxics
strategy by mid-FY 1985 will be required.
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GROUND-WATER QUALITY PROBLEMS
1. Problem Assessment
Ground water quality in Region 6 is good; no public water supply
system has been forced to close because of contaminated ground water.
Contamination has occurred, however, and both public and private water
supply wells have been affected by localized incidents. There is no
consolidated data source available to assess the degree of contamination
1n the Region, but many aquifers have probably been locally impacted at
some time. The knowledge of specific incidents and contaminants is
scattered through the files of many State and Federal agencies. A number
of potential sources of contamination have been identified in Region 6,
including (not in priority order): (a) injection wells, (b) improperly
completed or plugged oil and gas wells, (c) water wells which are uncased
or unplugged or have leaky casings, (d) recharge wells, (e) unlined
disposal pits, (f) solid waste disposal, (g) land application, (h) septic
tanks, (i) fertilizer, (j) irrigation return flow, (k) salt water intrusion,
(1) deicing salt, (m) accidental spills and leaks of hazardous materials,
(n) mining and mill tailings, and (o) leaking storage tanks and pipelines.
In summary, problems are localized, causes are varied, a variety of
contaminants are involved, and public interest is high. Region 6 States
are keenly aware of the importance of the ground water resource, and State
regulatory agencies devote considerable effort to the cleanup of past problems
and the prevention of future problems.
2. Regional Agenda
a. Expected Results of Regional Action: Actions to be taken in FY 1985
and 1986 are designed to enhance States' capabilities to manage ground water
resources, assess control measures for uncontrolled sources, and provide for
coordinated Federal and State ground-water activities.
b. Extent of State Participation: State agencies will have the lead
role in implementing ground water strategies, on a voluntary basis. For
FY 1985, supplemental Section 106 CWA funds will be specifically available
for ground water programs. All Region 6 States have an interest in
participating.
c. Regional Actions and/or Plans: The agenda for FY 1985 - 1986
is centered on improving existing ground water protection programs by (1)
focusing financial and technical resources on State programs, (2) assessing
existing uncontrolled sources, and (3) establishing procedures for coordi-
nating ground water policy issues within EPA and for coordinating with
other Federal and State ground water activities. To assist in accomplishing
these tasks, Region 6 established an Office of Ground Water in the Water
Management Division. The function of the Office is to implement the
Ground Water Protection Strategy, coordinate regional ground water programs
and serve as a clearinghouse for ground water information and data.
During FY 1985, the Office will develop a ground water monitoring strategy,
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assist States in developing programs and accessing data, and provide
technical assistance to States and other EPA programs. In FY 1986, the
monitoring strategy will be implemented and the Office will assist States
and other EPA programs in implementating strategies and programs. The
Hazardous Waste Branch will enhance ground water protection through the
enforcement of monitoring requirements, the call-in of Part B applications,
and the pursuit of full RCRA delegation to the States. The DIG program
will emphasize permitting of existing Class I and III injection wells in
delegated States, and implement a program on Indian lands. The Public
Water Supply program will participate in analysis of extent and effects
of contamination of subsurface drinking water at specific sites, and in
implementing corrective or mitigating measures. The Pesticides and
Toxics Branch will implement a monitoring strategy to assess ground water
impacts from pesticides and to evaluate regulatory needs. The Water
Quality Management Branch will assist States in developing and implementing
water quality programs. The Surveillance Branch will continue to develop
monitoring and data management tools. The Emergency Response Branch will
continue its response to emergencies and will work with States on building
response capabilities. The Superfuno Branch will begin construction on
five NPL sites in FY 1985, which include ground water protection, and
oversee four enforcement-lead cleanups.
d. Timing Requirements: It is important to begin implementing the
ground water strategy in FY 1985 because the strategy should be included
in RCRA Part B permitting and Superfund remedial actions which will begin
in FY 1985. Also, limited State funding of ground water programs is
available under CWA Section 106 for FY 1985.
e. Barriers: Barriers to the successful implementation of the ground
water strategy include jurisdictional issues such as quantity vs. quality
and complex technical and health issues. Given the leadership the Region
6 States have shown and the available technology, these barriers may be
overcome.
3. Headquarters Actions Needed
a. Specific Action Requested: (1) implement the Ground Water
Protection Strategy in 1985 so programs can move forward to develop a
procedure for applying RCRA ground water requirements to Superfund sites,
(2) provide risk assessment methodology for "alternate concentration
limits" to finalize remedial plans at several sites, (3) assist in the
training and recruitment of ground water professional staff, as a nationwide
shortage of qualified geotechnical personnel is hindering program development
at the State and Federal level, (4) continue the development of health
advisories which are in constant demand by State staff, and (5) revise
the allocation formula for ground water grants under CWA Section 106.
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b. EPA Offices and Programs Involved: A notable feature of ground
water problems is that solutions require the coordination of numerous
offices and programs. For the actions requested, involvement of the
Offices of Water, Solid Waste and Emergency Response, Human Resource;
Management, Pesticide Programs, Air and Radiation, and Research and
Development is needed.
c. Timing Requirements: The Ground Water Protection Strategy should
continue as a priority and be implemented in Fiscal Year 1985. Likewise,
resolution of Superfund/RCRA ground water clean-up issues is needed as
soon as possible. Recruitment, training, and development of health advi-
sories should be ongoing acitivities. Revision of the 106 allocation
formula is needed during FY 1985 so that subsequent ground water grants
will provide resources in relation to needs.
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PESTICIDE DRIFT
1. Problem Assessment
The drift of pesticides applied to agricultural crops onto nontarget areas
1s the major pesticides enforcement problem within Region 6. The population
growth In the Region has increased the problem as the urban population
moves Into areas which are still agricultural.
2. Regional Agenda
a. Expected Results of Regional Action: The Region will continue to
actively work with the states to improve the State/EPA pesticides enforce-
ment program in Region 6. Pesticides drift is a long-term problem which
will not be solved in one year. A continued strong pesticides enforcement
and outreach program should minimize the problem. This is a long-term
problem for which the states have primacy and which is being addressed
through a cooperative grant program. EPA provides grant funding, training,
and oversight to the states. The Region will also continue to encourage
the states to use innovative techniques in addition to traditional enforce-
ment actions to address the problem.
b. Extent of State Participation: Section 26 of the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA) delegates primary enforcement respons-
ibility for pesticide use violations to the states. Region 6 has cooperative
enforcement agreements with all five states which include the regulation
of the distribution and use of pesticides within the state. The states
take enforcement action under state law, but may refer state investigations
to EPA for enforcement action under FIFRA.
The states, through a priority setting process, analyze their priority
problems each year. Four of the states (Arkansas, Louisiana, Oklahoma,
and Texas) determined that drift of pesticides onto nontarget areas is
the priority problem in their states. In addition to traditional enforce-
ment actions, the states are utilizing several different innovative
techniques. These techniques include preseason inspections of commercial
applicators in Arkansas to caution them about drift, increasing the
penalties for misuse in Louisiana, the use of press releases by Oklahoma
to publicize applicator license suspensions and revocations in the area
where the offenses occurred, and the classification by Texas of nine
herbicides, which were involved in many drift cases, as state-limited-use
pesticides which can be used only by trained applicators.
c. Regional Actions and/or Plans: The Regional Office will continue
to provide pesticides enforcement grant funds, training, and oversight to
the state lead agencies for Arkansas, Louisiana, Oklahoma, New Mexico,
and Texas. For FY 1985, Region 6 is authorized to provide $1,092,900 to
the States. EPA provides up to 85 percent of the funding to the States
to conduct this grant program.
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The Region also provides training to state personnel in investigative
techniques and case preparation. At least two States, Louisiana and New
Mexico, have requested EPA participation in training courses. Louisiana
plans a criminal investigation course, and New Mexico will hold a case
preparation course for all inspectors. The Regional Office conducted a
case preparation course in FY 1984 for personnel from all five states.
d. Timing Requirements: The enforcement grant assessments are con-
ducted in November and April. The state training courses are scheduled
for the first quarter of FY 1985. The Regional Office works with the
States throughout the fiscal year on individual cases.
e. Barriers: The primary barrier is State and Regional Office
resources. Both have limits on the number of personnel and funding
available to devote to the problem, which is complicated by the growth
of the regulated community in Region 6.
3. Headquarters Actions Needed
a. Specific Action Requested: Continue to provide the annual grant
guidance to the Regions. Continue to support the State/Regional pesticides
enforcement program. The training staff at the National Enforcement
Investigation Center have been very helpful in participating in training
courses for state personnel.
Additional funding is needed for laboratory equipment. High quality state
labs are needed to support enforcement investigations with the analaysis
of residue samples.
b. EPA Offices and Programs Involved: Compliance Monitoring Staff,
Office of Pesticides and Toxic Substances.
c. Timing Requirements: Training courses will be held in the first
quarter of FY 1985. The grant guidance is issued in the second quarter.
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NONPOINT SOURCE POLLUTION
1. Problem Assessment
The Region does experience water quality problems as a result of nonpoint
source pollution (NPS). The severity and extent of NPS pollution vary
within each State. Agricultural NPS pollution, urban runoff, and residual
wastes from septic tanks are frequent contributors to surface water and
ground water quality problems. Some waterways and lakes within the
Region are so heavily impacted by NPS pollution that expensive state-of-
the-art treatment is required of both municipal and industrial dischargers
to meet water quality standards (WQS). Despite a considerable investment
of State and Federal resources in NPS problem identification over the
past several years and efforts to institute both voluntary and regulatory
controls, much remains to be done.
2. Regional Agenda
a. Expected Results of Regional Action: The ongoing efforts by the
Region and States are to identify waterbodies which are most affected by
NPS pollution, to identify and quantify contributions by category or
source, and to identify effective controls. These efforts will provide
the Region the necessary information to address the NPS problem.
b. Extent of State Participation: The States have been evaluating
site specific areas and stream segments which are impacted or have been
determined to have the highest potential for water quality problems due
to NPS pollution. They state in their water quality management plans
that they prefer a voluntary control program; however, they feel that a
regulatory program is effective for some types of NPS, e.g., feedlot
permits, urban runoff, and construction runoff ordinances. The States
have been working for many years at the grassroots levels with the Soil
Conservation Service and the Agricultural Stabilization and Conservation
Serice, improving the awareness of NPS pollution and soil conservation
through informing and educating the public.
The results of these evaluations have given the Region a better understand-
ing of the problems and the needs. We expect the majority of Section 208
NPS pollution studies to be completed by the end of 1984.
c. Regional Actions and/or Plans: Pending the development of national
NPS policy, strategy, and funding for implementation, the Region will con-
tinue to work with the states to further identify, quantify, and address
NPS problems. In addition to ongoing Section 208 studies, additional
efforts are being made through partial funding with Section 205(j) grants,
as well as independently funded State projects.
d. Timing Requirements: Without the implementation of effective NPS
controls within the next 5 years, several major waterbodies within the
Region will not achieve existing WQS despite the construction of state-of-
the-art treatment facilities by municipal and industrial dischargers. In
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a few instances, 1t is possible that water-bodies may achieve non-nuisance
conditions despite stringent control of point source dischargers.
e. Barriers: Primary barriers are the lack of overall national NPS
policy and implementation strategy which include a discussion of resources.
3. Headquarters Actions Needed
a. Specific Action Requested: Issuance of a national NPS policy and
strategy and issuance of the Water Quality Management (WQM) regulations
which should include language on nonpoint sources.
b. EPA Offices and Programs Involved: Office of Water
c. Timing Requirements: Issuance of the NPS policy and strategy and
WQM regulations should be completed no later than the end of FY 1985, in
order to impact FY 1986 WQM grants.
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SLUDGE MANAGEMENT AND DISPOSAL
1. Problem Assessment
Sludge management and disposal problems are Regional in scope and vary
in complexity and magnitude from location to location. Growth of munici-
palities and wastewater treatment facilities to meet water quality demands
generate more sludge each year. Ineffective solids removal by wastewater
treatment systems pass sludge into the receiving waters. Inadequate sludge
management programs create environmental problems. Major impacts are
possible contamination of food sources, ground and surface waters, trans-
mission of disease, odors, flies, and fear of the unknown. The level of
public concern generally is low; however, when ineffective sludge manage-
ment programs result in contamination, public concern becomes high.
Also, public concern becomes high on an individual basis when sludge is
introduced for the first time in the local environment without adequate
public participation and education. Major sources and causes are municipal
wastewater treatment facilities, industrial processes, and ineffective or
non-existent sludge management programs, inappropriate technology, and
lack of pretreatment. Sludoe contaminants of concern are pathogens and
toxic substances, including hazardous wastes and heavy metals.
2. Regional Agenda
a. Expected results of Regional Action: (1) a continuous public infor-
mation/education and technology transfer program through state agencies
and universities for consulting engineers, local governments, equipment
manufacturers, and sludge handlers; and (2) State implementation of the
Policy on Municipal Sludge Management.
b. Extent of State Participation: (1) All states have been delegated
the Municipal Sludge Management and Disposal Program and full participation
is anticipated; and (2) each state has a Municipal Sludge Management
Coordinator to spearhead the state effort.
c. Regional Actions and/or Plans: Region 6 has a Regional Municipal
Sludge Management Coordinator and has issued Regional strategy and guidance
for municipal sludge management; co-sponsored one and participated in two
state sludge management workshops; encouraged beneficial reuse of sludge
through land application systems; maintained continuous public informa-
tion/education and technology transfer programs working through university
and agricultural extension/cooperative systems; and conducted one annual
state sludge management coordinators meeting.
For FY 1985, we will co-sponsor and participate in a sludge management
workshop in each state and, on an ongoing basis, will update Regional
strategy and guidance in accordance with current EPA policy; work with each
state agency with responsibility for sludge management and with state
universities to jointly develop plans to continue public information/education
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and technology transfer; conduct on-site inspections on construction
qrants projects involving sludge treatment and disposal; and work with
the enforcement program to enforce regulations when the state agency
fails to enforce.
d. Timing Requirements: A sludge management and disposal program
for each fiscal year is planned, including specific objectives to be
accomplished with budgets and dates for accomplishing the objectives.
e. Barriers: (1) Public often fears sludge because of misunderstanding
and misinformation (This can be overcome if they are educated in the safe
and beneficial uses of sludge); (2) institutional barriers (too restrictive
state codes in land application and reuse of sludge); and (3) design bias
of consulting engineers.
3. Headquarters Action Needed
a. Specific Action Requested: (1) provide personnel and financial
assistance in conducting seminars/workshops; and (2) proceed with timely
publication of regulations and guidance to support EPA Policy on Municipal
Sludge Management.
b. EPA Offices and Programs involved: OWPO, MERL (Solid Waste and
Technical Support Division)
c. Timing Requirements: Same as Regional. Each fiscal year will
have a plan with objectives and goals.
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LEAKING LANDFILLS
1. Problem Assessment
A major Regional problem involves the protection of ground water from
contamination by RCRA and Superfund sites. There are currently 30
sites on the National Priorities List (NPL) for Superfund in the Region.
Six sites are in Arkansas, 5 in Louisiana, 4 in New Mexico, 4 in Oklahoma,
and 11 in Texas. At present, 1 additional site has been submitted for
inclusion on the NPL by Arkansas, 1 by New Mexico, and 12 by Texas. The
contaminants of concern are many and varied. The effect of a large number
of facilities in the Region subject to RCRA ground water provisions (302
- the highest in the nation) and sites which have had previous improper
disposal practices can be serious. The stabilization of existing leaking
landfills and the need for ground water monitoring at hazardous waste
sites are concerns shared by the RCRA and Superfund programs.
In Region 6 the effects of leaking landfills are complicated by geogra-
phical diversity ranging from subtropical to arid areas. The subtropical
areas of Southeast Texas and Southern Louisiana produce the extremely
complex hydrogeological combination of shallow ground water tables, with
a stratigraphy of clay lenses mixed between silty clays and sands. Point
bars, saltwater intrusion, and interconnection of shallow aquifers with
coastal areas or rivers complicate the determination of groundwater flow
rates and directions. This is contrasted by the much more arid area of
Western Texas, Oklahoma, and New Mexico where ground water tables are
deeper.
Future Regional action is dependent on Headquarters directives and the
magnitude of the problem at active RCRA facilities and abandoned sites
that have the potential for inclusion on the NPL. Although RCRA non-
compliance rates are controversial and at times subjective, our State
overview inspections show a 48 percent noncompliance rate through the
first half of FY84.
The current proposed policy promoting land treatment instead of disposal
of wastes from Superfund sites will affect the selection of remedies at
the sites.
2. Regional Agenda
a. Expected results of Regional Action: In the Superfund program, the
initial action will be the placement of more sites into the Emergency and
Remedial Response Inventory System (ERRIS) for further assessment and
possible placement on the NPL. The Region primarily identifies candidate
NPL sites through the RCRA 3012 program with funding available to all
States. Candidate NPL sites are ranked, based on hazard potential,
jointly by EPA and the States. These sites, when added to the NPL, will
then be funded for remedial activities, including remedial design and
construction.
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The RCRA program is developing a comprehensive ground water evaluation
plan to be carried out in FY 1985 at all commercial landfills, facilities
undergoing closure, at facilities in assessment monitoring, and at facil-
ities with previous ground water violations. Results of this action will
be earlier detection of potential problems at RCRA landfills.
b. Extent of State Participation: States nominate all new sites considered
for the NPL by the Regional office and may keep the lead responsibility
for site work if they wish. Currently, the State of Texas may take the
lead responsibility at its nominated NPL sites.
All the States in Region 6 except Arkansas will receive interim preliminary
assessment/site inspections (PA/SI) funding to continue existing scopes
of work established by the RCRA 3012 program. Later, in FY 1985, a new
type of cooperative agreement for funding of these activities will be
available.
c. Regional Actions/Plans: In FY 1985, the RCRA program will be conducted
by the States through the Enforcement Memorandum of Understanding. This
memorandum will provide a much clearer picture of RCRA facility compliance,
including ground water monitoring and contamination. Compared to other
parts of the country, Region 6 has had some success in limiting leaking
hazardous waste landfills. This effort has been resource intensive. We
seriously question whether our projected FY 1985 and FY 1986 resources
will be adequate to perform the landfill permitting effort. However, the
comprehensive ground water evaluation process should be implemented in
FY 1985 to provide the Region with necessary additional ground water
information.
The Superfund program will coordinate NPL site submittals by the States
and assist the States in funding requests for site-specific work as well
as continuing PA/SI activities. In addition, the Regional office will
retain the lead responsibility at all sites that are not State lead.
d. Timing Requirements: The NPL Update, to include all newly nominated
sites, is scheduled for publication in October 1984.
e. Barriers: (1) Lack of approved ground water strategy for use by
the Superfund and RCRA programs. (2) Timing is crucial to the Region
because most Superfund sites in the area have reached stages where waste
disposal is a relevant problem.
3. Headquarters Actions Needed
a. Specific Action Requested: At the Headquarters level, more specific
guidance suited for the problems Superfund faces in waste disposal is
mandatory. The Regional office is currently reviewing guidance developed
by Headquarters on the waste disposal issue prompted by Superfund sites.
However, the timeframe for implementation of this guidance remains a
major factor.
b. EPA Offices and Programs involved: Office of Emergency and Remedial
Response, Office of Solid Waste.
c. Timing Requirements: Guidance on implementing the proposed ground
water strategy is needed as soon as possible.
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MEXICO/UNITED STATES BORDER PROBLEMS
i
1. Problem Assessment
The most significant Mexico/United States border problems will be addressed
through implementation of the Environmental Agreement signed by the Presi-
dents of Mexico and the United States. Issues being evaluated by Mexico/
United States work groups include: (1) impact of air emissions in Ciudad
Juarez, Mexico, upon air quality (especially levels of CO and 03) of El
Paso, Texas; (2) impact of raw sewage discharge from Nuevo Laredo, Mexico,
upon water quality of the Rio Grande River; (3) transportation of hazardous
wastes and toxicants across the border; and (4) the need for a Mexico/United
States International Contingency Plan to deal with oil and hazardous sub-
stances pollution incidents. Competing priorities may delay implementation
of recommended actions.
Another significant border problem relates to the Cobalt-60 radiation con-
tamination of steel products in Ciudad Juarez, Mexico, and the need to insure
that future incidents are effectively covered under the International
Contingency Plan.
2. Regional Agenda
a. Expected Results of Regional Action: Actions taken by both countries
under the Environmental Agreement should result in (1) a recommendation for
a more extensive border air monitoring program to obtain actual transported
pollutant values from Juarez, coordination of air control strategies for
El Paso consistent with Clean Air Act requirements, and continued encourage-
ment of the exchange of emissions data and ambient data consistent with the
spirit of the 1983 U.S.-Mexico environmental agreement; (2) a proposal for
the planning, funding, and constructing of sewage treatment facilities for
Nuevo Laredo; (3) a better picture of the hazardous waste transportation
activity along the border, and a base for determining what additional
measures, if any, need to be taken to regulate it; (4) better knowledge
of the hazardous spills problem along the border, and a plai: for joint
responses to future spills; and (5) knowledge of, and control over the
transportion of material contaminated by the recent cobalt-60 incident.
b. Extent of State Participation: (1) The Texas Air Control Board is a
participant in the El Paso Air Quality Work group; the State and EPA are
cooperating in a hydrocarbon monitoring project; the state will conduct air
modeling exercises in El Paso for CO and 03; (2) the Texas Department of
Water Resources is a participant in the Nuevo Laredo/Water Quality Work
Group; (3) the States of Texas and New Mexico will need to track hazardous
waste shipments crossing the border under RCRA delegations; (4) the States
of Texas and New Mexico will need to participate in the development of a
Mexico/United States International Contingency Plan and associated Border
Response Teams, (5) the States of Texas and New Mexico have had direct
involvement in the Ciudad Juarez Cobalt-60 incident and are contining
radiation monitoring at border crossings.
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c. Regional Actions/Plans: (1) to participate in work groups estab-
lished under the Mexico/United States Environmental Agreement to address
problems associated with air quality in Ciudad Juarez/El Paso, water quality
of Rio Grande River at Nuevo Laredo/Laredo, hazardous waste shipments crossing
the border, and emergency response planning for pollution episodes along the
border; and (2) to cooperate with the States of Texas and New Mexico and
the Nuclear Regulatory Agency during followup activities of the Ciudad Juarez
Cobalt-60 incident and in planning to prevent future similar incidents.
d. Timing requirements: (1) the Environmental Agreement Work Groups
will submit reports to Mexico and to United States coordinators in October,
1984, and the EPA Office of International Activities (OIA) will set an
agenda between those coordinators; (2) Texas CO modeling and HC monitoring
results for EL Paso are due by early fall, 1984, with SIP revisions due by
February, 1985.
e. Barriers: (1) competing priorities may delay implementation of
recommended actions; (2) any one party to the agreement has little leverage
with the other parties; and (3) the region is not routinely notified of
international shipments of hazardous wastes.
3. Headquarters Actions Needed
a. Specific action requested: (1) continue emphasis through EPA OIA
and the State Department for the effective involvement of Mexico in carrying
out the Environmental Agreement; (2) establish an OIA system to notify the
Reigon of international shipments of hazardous wastes; and (3) review the
policy or air quality attainment dates for international border areas
(1987 may be unrealistic for El Paso to meet attainment).
b. EPA Offices and Programs involved: Office of International Activi-
ties (OIA), Office of Radiation Program (ORP), Office of Water Regulations
and Standards (OWRS), Office of Air Quality Planning and Standards (OAQPS),
Office of Solid Wastes (OSW), and Office of Emergency and Remedial Response
(OERR).
c. Timing requirements: (1) The Guidance for CO modeling is needed
as soon as possible; (2) the decision on attainment dates for border areas
should be made by Headquarters prior to fall 1984; and (3) the EPA OIA
sets agenda for Mexico/United States coordinators meetings under the
Environmental Agreement.
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Part III, Regional Recommendations for the Fiscal Year 1986-1987
Priority List
We have reviewed the Fiscal Year 1985-1986 Priority List and we do not recommend
any deletions. Two Region 6 specific priorities (Growth and Border Problems)
do not appear on the list. They are significant to only our region and possibly
a few others, and for that reason may not be appropriate for inclusion as
national priorities.
The Region 6 priorities for environmental and administrative action are reflected
in Part II. Our ranking in Part II reflects the Regional view of the priority
which should be assigned to these problems.
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