5659
OOOR80107
RECEIVED
FEB 29 1980
L HKOftCllON AGENCY
LIBRARY, RZaiCN tf
SJATE/EPA AGREEMENT
INDIANA/U.S. ENVIRONMENTAL PROTECTION AGENCY
FISCAL YEAR 1980
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AGREEMENT
This Agreement is effective on the first day of October, 1979, by the U.S.
Environmental Protection Agency, Region V (USEPA) and the Indiana State
Board of Health (the State).
The proposed strategies and activities reflected in this Agreement are
mutually acceptable to both parties. Both parties agree to work toward
the full implementation of the strategies and activities herein, to
cooperate to the fullest extent possible in the implementation of this
Agreement, and to make their best efforts to resolve issues related to
the implementation of this Agreement.
This Agreement represents the aspirations of the State and USEPA for FY
1980 in jointly selected areas of program activity. Failure to completely
implement provisions of this Agreement by USEPA shall not result in any
additional obligatory responsibilities. Failure to completely implement
this Agreement by the State shall not result in sanctions of any sort
being imposed by USEPA, except to the extent that unfulfilled provisions
in the Agreement are also unfulfilled legal commitments by the State in
its acceptance of any grant awarded by USEPA.
This Agreement may be amended at any time, except as limited by applicable
laws or regulations. Amendments shall be made by supplemental Agreement,
endorsed in writ-ing by the parties hereto.
Date:
Indiana State Board of Health
3
_ _
Donald- G. Bl^en^HTer, M.D- " r /
Secretary / //
^___ _ Date:
in McGuire
jional Administrator
Environmental Protection Agency
'Region V
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TABLE OF CONTENTS
I. Introduction Page 1
II. Environmental Quality Status
- Air Page 3
- Water Page 11
III. Highlight Issues and FY 1980_ Problem-Solving Approaches
A. Implementation of the State Implementation Plan for Air Quality Page 14
B. Development of Hazardous Waste Management Program Page 19
C. Development of Pretreatment Program and Strategy Page 22
D. Multiple-Media Impacts of Residual Wastes Page 24
E. Development of Integrated Public Participation Program and Page 26
Strategy
F. State and EPA Roles and Responsibilities Relative to Delegations Page 30
of .Program Authority
IV. Cross-Cutting Issues
A. Identification and Assessment of Abandoned or Hazardous Waste Page 35
Disposal Sites
B. Hazardous Chemical Contamination and Its Impact on Drinking Page 37
Water
C. Quality Assured Laboratory Capability for All Environmental Page 39
Programs
D. Identification and Monitoring of Toxic Substances in the Page 41
Environment
E. U.S.-Canada Water Quality Agreement: Identification of Programs Page 43
and Roles
F. Implementation and Refinement of the Clean Lakes Program Page 46
G. Completion of Waste Load Allocations Page 49
V.. Development of FY 1981 Indiana State-EPA Agreement Page 51
vr» Appendices Page 52
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I. INTRODUCTION
This document is the State/EPA Agreement for the State of Indiana for Fis-
cal Year 1980 ("SEA"). The SEA is the result of a long negotiating process
designed to better establish the partnership effort between the Indiana
State Board of Health (ISBH), as administrative agency for the Indiana
Environmental Management Board, the Indiana Air Pollution Control Board,
and the Indiana Stream Pollution Control Board, and the U.S. Environmental
Protection Agency (U.S. EPA) in the management of environmental protection
programs in Indiana. The Agreement itself is an attempt to identify signi-
ficant environmental and/or program management issues to receive special
attention in Fiscal Year 1980. The Agreement also designates several
important issues involving more than one program that require careful coor-
dination in developing solutions to the problems. Substanital discussion
between personnel of the State of Indiana and the U.S. EPA resulted in the
identification of the issues herein, and the approach to solving the envi-
ronmental and institutional problems identified.
Ideally, the general purposes and uses of the SEA include:
- Decision Document
- Management Tool
- Communications Tool
- Identification of High Priority Environmental Issues
- Focus Attention of Top Officials On Integrated Planning
- Focus Attention On Tracking Progress Made Toward Solving Identified
Problems
- Information Document Useful To EPA, State, Local Governments, Area-
wide Agencies and the Public
- Simplify Guidance
- Eliminate Duplication of Work
- Reduce Paperwork
While all purposes of the SEA will not be met during Fiscal Year 1980,
this document is a start at integrated management of several environmental
programs (air, water and solid waste). The agreement is intended to set a
positive tone in program management, to provide communication and oppor-
tunities of interaction with local governments, areawide agencies and
the public, and to clarify the approach taken to certain key problems by
U.S. EPA Region V and the State of Indiana.
The SEA is not a comprehensive document which covers all problems, nor
does it fully integrate State and Federal management of environmental acti-
vities in all media. Both the ISBH and U.S. EPA recognize the need to coor-
dinate program management. Region V U.S. EPA has established State Coordi-
nators for each of its six states in the Office of the Regional Administra-
tor to assist in program integration and coordination. The ISBH is conti-
nuing to work toward a fully coordinated programming, budgeting and work
planning procedures for EPA funded programs in its program development
efforts.
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The specific program areas that will be impacted by the SEA are:
- Sections 106, 205(g), 208, and 314 of the Clean Water Act (CWA)
- Sections 3011, 4008 and 4009 of the Resource Conservation and
Recovery Act (RCRA)
- Section 105 of the Clean Air Act (CAA)
The SEA is a process as well as the actual document. This SEA is a step
in the evolution of a-comprehensive and meaningful vehicle of communica-
tion and negotiation between the State and U.S. EPA. The process will
guide important EPA, State and local decisions on environmental and program
problems, priorities, timing, responsibilities, and allocation of resources,
(both monetary and human). Joint discussion and problem resolution are
important goals for the SEA. The SEA, as a public document, should
increase public understanding of the priorities and programs for Fiscal
Year 1980, and encourage ongoing communication at all levels, throughout
the process.
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ENVIRONMENTAL QUALITY STATUS
AIR QUALITY
While most areas of Indiana in 1978 were in compliance with national pri-
mary (health) ambient air quality standards for suspended particulates,
sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone and lead, some
areas of the state do not at present meet national primary standards for
the pollutants mentioned above. In addition, some areas of the state,
whether or not they currently meet ambient air quality standards, are pro-
jected to be in violation of certain primary ambient air quality standards
by the clean air deadline of December 31, 1982. Section 107 of the 1977
Clean Air Act Amendments resulted in the designation of "air quality control
regions" (non-attainment areas) based on both monitored air quality data and
projected 1982 information from modelling studies. It should be noted that
the monitored data summarized below was not the basis for the Section 107
"non-attainment" designations in Indiana published in the Federal Register.
Total Suspended Particulates
Monitoring for total suspended particulates (TSP) at 106 sites in 24 of
Indiana°s 92 counties revealed compliance with primary health related stan-
dards in all but a portion of 7 counties. Primary standards are believed
to be met in the remaining 68 non-monitored counties. The counties having
one or more sites not meeting primary standards were Allen, Clark, Dubois,
Jasper, Lake, Marion, and Vanderburgh. The violations of primary standards
are believed or known primarily to be caused by specific point source
facilities, and at which actions to reduce emissions are either now com-
pleted or underway. Some areas of the state are carefully checking the
relative contributions of point sources and area sources to the total TSP
problem. Lake County°s particulate situation is more complex involving
many sources and continues to undergo a detailed study to implement further
control. The secondary 24-hour TSP standard was met in 10 of the 24 moni-
tored counties. Bartholemew, Monroe, Grant, Vigo, Wayne, St. Joseph, and
Tippecanoe met primary standards but contained sites exceeding secondary
standards.
Sulfur Dioxide
Primary and secondary ambient air quality standards for sulfur dioxide were
met in all but one of 15 monitored counties at 104 separate locations.
Compliance with the national standards in all but Lake County reflects
improvement in control in control programs implemented in the state.
Nitrogen Dioxide
Continuous and bubbler data from 69 nitrogen dioxide monitoring sites in
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counties reflects continuing compliance with the standard.
Carbon Monoxide
Monitoring for carbon monoxide was operated at 5 locations in 3 counties,
The 1-hour standard was met all sites; however the 8-hour standard was
violated at 3 sites located in Marion and 1 site in Vanderburgh county.
Violations noted in Marion and Vanderburgh counties are believed due
primarily to emissions from automobiles.
Ozone
The Indiana network of ozone monitors has grown steadily from 3 counties
in 1975 to 6 counties in 1978. The 13 monitors are located in urban,
suburban and rural areas of these counties. On February 8, 1979, the
national ambient 1-hour standard for ozone changed from .08 parts per
million (ppm) or 160 micrograms per cubic meter (ug/m3) to .12 ppm or 235
ug/m3. All analyzers operating during May through August, the peak ozone
season, recorded numerous excursions of the .08 ppm standard; however, 9
analyzers in 4 counties exceeded .12 ppm. In Vanderburgh County, along
the Ohio River, attainment of the revised ozone standard is now in question
as a result of monitored violations in the Kentucky part of suburban
Evansville. The complex ozone problem will certainly require a coordinated
state, regional and national control strategy.
Lead
Lead became a criteria pollutant on October 5, 1978, when the ambient air
quality standard of 1.5 ug/m3 quarterly average was promulgated by U.S.
EPA. During 1978, composite quarterly averages for lead were determined
at 54 sites in 22 counties. All sites met the new standard for all
quarters.
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1178 TSP STPfTOS
AREAS EXCEEDING PRIMARY
STANDARDS
O AREAS EXCEEDING ALERT LEVELS
INSUFFICIENT DATA TO MAKE
JUDGEMENT
UPWARD TREND — AIR QUALITY IMPROVING
DOWNWARD TREND 3- AIR QUALITY WORSENING
f NO SIGNIFICANT CHANGE
MIXED TREND
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TO SO2 STATUS
AREAS EXCEEDING SECONDARY
STANDARDS
AREAS EXCEEDING PRIMARY
STANDARDS
AREAS EXCEEDING ALERT LEVELS
INSUFFICIENT DATA TO MAKE
• JUDGEMENT
UPWARD TREND — AIR QUALITY IMPROVING
DOWNWARD TREND -- AIR QUALITY WORSENING
' NO SIGNIFICANT CHANGE
MIXED TREND
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117? NOZ
AINING HEATH
AREAS EXCEEDING SECONDARY
STANDARDS
AREAS EXCEEDING PRIMARY
STANDARDS
OH AREAS EXCEEDING ALERT LEVELS
PI INSUFFICIENT DATA TO MAKE
1 - l JUDGEMENT
UPWARD TREND — AIR QUALITY IMPROVING
DOWNWARD TREND — AIR QUALITY WORSENING
" NO SIGNIFICANT CHANGE
MIXED TREND
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AREA
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AINING HEATH
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rTH AREAS EXCEEDING PRIMARY
Li» STANDARDS
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UPWARD TREND — AIR QUALITY IMPROVING
DOWNWARD TREND — AIR QUALITY WORSENING
' NO SIGNIFICANT CHANGE
MIXED TREND
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AREAS EXCEEDING SECONDARY
STANDARDS
AREAS EXCEEDING PRIMARY
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AREAS EXCEEDING ALERT LEVELS
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JUDGEMENT —
UPWARD TREND — AIR QUALITY IMPROVING
DOWNWARD TREND — AIR QUALITY WORSENING
' NO SIGNIFICANT CHANGE
MIXED TREND
— 10
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WATER QUALITY
Water quality characteristics of major river systems in Indiana have
been documented from data collected by the statewide monitoring station
network depicted on the following map. Water quality parameters that
have been monitored include temperature, dissolved oxygen, acidity
(pH), bacteria, ammonia, phosphorus, and inorganic and organic toxi-
cants. The table of water quality characteristics below summarizes
conditions in Indiana°s major river systems. Because the information
presented in this table is general, it may not accurately depict
water quality conditions in specific stream segments within the major
river systems. However, the information in the table does provide a
picture of overall river water quality in 1978 and trends over a five-
year period.
11
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HIGHLIGHTED ISSUES
In addition to the priorities established in the Five-Year Management Stra-
tegy, and complementary to them, the Indiana State Board of Health and
Region V, U.S. EPA agree on six issues to receive priority attention during
FY 80. These highlighted issues and associated problem-solving actions to
be taken by both agencies are described below in no particular order of
priority.
I. AIR QUALITY IMPLEMENTATION PLAN
A. ISSUE: Need to work toward insuring full implementation of State
Implementation Plan (SIP) rules, schedules, strategies and
programs.
B. OBJECTIVES:
1. Develop and enact the ten addition VOC RACT documents.
2. Implement New Source Review Program.
3. Correct all identified deficiencies in 1979 SIP.
4. Major stationary source enforcement.
5. Enforce against schedule violators.
6. SIP development for secondary nonattainment areas for which
extension has been granted.
7. Coordinate lead local agency planning activities to continue
development and tracking of necessary CO/03 transportation-air
quality planning activities and assure implementation of RACT
measures.
8. Report on RFP for all pollutants.
9. Initiate activities to develop 1982 SIP submission for 03/CO as
applicable (where there will not be 1982 attainment).
10. Conduct air monitoring for SIP strategy development.
11. Inspect major stationary sources in nonattainment areas.
12. Implement air monitoring regulation.
C. PROGRAM SCOPE:
1. Planning.
2. Standards.
3. Modeling and Data Analysis.
4. Local Agency Liasion.
5. Permit and Plan Review.
6. Surveillance and Investigation.
7. Variance and Compliance Tracking.
8. Ambient Sampling.
9. Emissions Sampling.
10. Analytical.
11. Quality Assurance.
12. Administration.
13. Legal.
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D. ASSUMPTIONS:
1. Adequate staffing will be available to accomplish objectives.
2. Sufficient funds will be available to accomplish objectives.
E. APPROACH AND SCHEDULE:
1. PPA: Develop and enact the ten additional VOC RACT documents.
a. Develop and enact the ten additional VOC RACT regulations--
December 1980.
b. Research ten VOC RACT regulations and amend APC 15 as
necessary—December 1980.
c. Develop Emissions Data Base for VOC RACT support.
d. Perform VOC emissions tests and collect available emissions
data to develop an emissions data base.
e. Correlate emissions data to control equipment to develop
technical support for RACT regulations.
2. PPA: New Source Review Program.
a. Submit quarterly reports to EPA as to the number of sources
reviewed.
b. Follow the prescribed procedures in reviewing all new
sources.
c. Send EPA a copy of the public notice for all sources
requiring such notices.
d. Project 60 New Source Reviews subject to public comment and
ten NSRs to a tier PSD review.
e. Conduct engineering review which will include determination
of BACT or LAER as appropriate, compliance with all appli-
cable regulations, including NSPS and NESHAPS.
f. Conduct air quality impact analysis utilizing OAQPS guide-
line #1.2-080.
g. Issue required public notices and construction permits for
sources reviewed and collect permit fees.
h. Obtain, install and document the latest UNAMAP models (PAL,
ICS, etc.).
i. Review modeling studies and install and document the latest
EPA models.
J. Perform eight reviews of sources within local agency juris-
diction. These will involve the three Lake County integrat-
ed steel mills. Also, assist local agencies in sixty-five
NSR°s with respect to engineering and legal consultations.
3. PPA: Correct All Identified Deficiencies in 1979 SIP
a. Clark County TSP Plan—January 1981.
b. Wayne, Dubois, Dearborn and Vigo Counties TSP Plans—Decem-
ber 1980.
15
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c. CO plans for Marion and Lake Counties—January 1981.
d. Amend regulations—As needed.
4. PPA: Major Stationary Source Enforcement
a. Continue enforcement of Air Pollution Control Regulations
for all sources out of compliance.
b. Enter into Consent Decrees as needed.
c. Conduct adjudicatory hearings where cooperation is not
received.
d. Submit Orders or Decrees to EPA as SIP revisions.
*
5. PPA: Enforcement Actions Against Schedule Violators
a. Follow up on all compliance timetables and take prompt
action on any violations of the increments.
b. Supply EPA with quarterly reports, including data on
schedule violators.
c. Issue Notices of Violations, negotiate compliance programs,
enter into Consent Decrees and initiate legal action where
cooperation is not obtained.
d. Assist local agencies in their efforts to enforce schedules.
6. PPA: SIP Developmental for Secondary Nonattainrnent Areas for
Which Extension Has Been Granted.
a. SIP development in secondary nonattainment areas; e.g.,
Wayne, Dearborn, Vigo, Dubois, Vanderburgh, St. Joseph,
LaPorte and Howard Counties.
b. Estimate impact of fugitive dust sources—December 1979.
c. Evaluate impact of various area and point source control
strategies—June 1980.
d. Select alternatives—July 1980.
e. Develop necessary regulations.
f. Conduct annual modeling for secondary nonattainment counties
for attainment of the secondary standard—June 1980.
7. PPA: Coordinate Lead Local Agency Planning Activities to
Continue Development and Tracking of Necessary CO/03
Transportation-Air Quality Planning Activities and Assure
Implementation of Reasonably Available Transportation
Control Measures
a. Coordinate Lead Local Planning Activities to continue
development and tracking of necessary CO/03.
b. Assure implementation of Reasonably Available Transportation
Control Measures in Lake, Porter, Marion, Floyd, Clark,
St. Joseph and Elkhart Counties.
8. PPA: Report on Reasonable Further Progress for All Pollutants.
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a. Update the emission inventory for nonattainment areas.
b. Report baseline estimates and 1979 emission rates for over
900 points. First report will be made to EPA by July 1980.
c. Report on Reasonable further progress.
9. PPA: Initiate Activities to Develop 1982 SIP Submission for
03/CO as applicable (where there will not be 1982 attain-
ment)
a. Initiate activities to develop 1982 SIP submission for CO/03
as applicable.
b. Obtain commitments.
c. Section 175 Reviews.
d. Contractual agreements.
e. Obtain, install, and documents selected photochemical models.
10. PPA: Air Monitoring for SIP Strategy Development
a. Perform short-term ozone and precursor pollutant special
studies. Will consist of site survey and establishment,
equipment maintenance and operations, data manipulation for
computer input.
11. PPA: Major Stationary Source Inspections in Nonattainment Areas
a. Inspect all major sources in nonattainment areas.
b. Assist local agencies in inspections of major sources in
nonattainment areas.
12. PPA: Implementations of Air Monitoring Regulation
a. Install, document, test, and run programs to quality assure
the air quality data—October 1979.
b. Revise the SIP related network description of all state
and local ambient air monitoring stations—March 31, 1980.
c. Perform short-term ozone and precursor pollutant special
studies.
F. OUTPUTS:
See item E, above.
G. RESOURCES:
The exact resource level necessary to fully accomplish the specified
work during the next year will be finalized in the approved program
plan. Financial support will be provided by State funds and funds
provided under Section 105, Clean Air Act Amendments.
H. CONTACTS:
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1. Lead Office: ISBH, Air Pollution Control Division
2. EPA Contact: Air Programs Branch
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II. DEVELOPMENT OF AM EFFECTIVE HAZARDOUS WASTE MANAGEMENT PROGRAM
A. ISSUE:
The development of a more effective and expanded hazardous waste
management program.
B. OBJECTIVE:
To develop an effective hazardous waste management program to insure
safe and adequate handling of hazardous wastes at key points in the
management scheme (generation, transportation, and disposal). Exist-
ing program efforts will be reviewed, modified where necessary, or
expanded within available resource capability to insure adequate
management procedures.
C. PROGRAM SCOPE:
Hazardous waste management.
D. ASSUMPTIONS:
That necessary enabling legislation is enacted, that adequate program
support is obtained, that adequately trained staff can be assembled
and that technical, socially acceptable, and environmentally sound
solutions can be found to resolve the many currently insoluable pro-
blems.
E. APPROACH AND SCHEDULE:
1. Address current and projected and monitory resources necessary
for development of an EPA authorized hazardous waste program.
Immediate projections will related to interim authorization.
Future projections will prepare for full authorization status.
Prepare authorization plan and application upon promulgation of
final rules and regulations by EPA.
2. Continue and expand present permitting procedures for disposal of
certain hazardous waste streams.
3. Develop appropriate rules, regulations and guidelines with due
consideration given to EPA guidance and regulations, to support
activities where necessary.
4. Secure computer support through contractual arrangements or
Indiana State Board of Health services.
5. Continue, expand, and strengthen present surveillance and enforce-
ment programs. Coordinate with other agency divisions as they
19
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relate to hazardous waste management events (spills, disposal
requirements, discharges, etc.). Active hazardous waste disposal
sites will receive highest priority.
6. Continue ongoing public participation efforts, coordinating with
other agency divisions and the public information officer and
regulatory boards. Staff will continue to assist and coordinate
with the Industrial Solid Waste Technical Advisory Committee and
Citizens Advisory Committee of the Stream Pollution Control Board
and the Solid Waste Management Study Commission of the Indiana
General Assembly.
7. Continue and expand ongoing licensing of hazardous waste trans-
porters. Liquid industrial waste haulers are presently licensed
under Regulation SPC-17. Program expansion envisions development
of a manifest system with development of supporting regulations
and necessary computer support with due consideration of federal
regulations and guidelines.
8. Continue to assist ongoing emergency response capabilities pre-
sently within the Division of Water Pollution Control and Air Pol-
lution Control. Staff presently responds to emergencies on dis-
posal and treatment facilities and review spilled materials for
candidate waste disposal sites.
F. OUTPUTS:
The following outputs reflect activities to be undertaken in the FY
80 hazardous waste management effort and refer directly to the
approaches outlined above:
1. Authorization plan and application.
2. Summaries of approvals for disposal of certain hazardous waste
streams at selected landfill sites.
3. Draft regulations covering generator, transporter, and hazardous
waste management facilities.
4. ADP support system reports and summaries.
5. Participation of staff at hazardous waste management control pro-
grams and spill prevention seminars as deemed advisable.
6. Notices of violations, administrative hearings, and court
proceedings.
7. Inspection reports.
8. Acquisition of additional qualified personnel within available
20
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resources.
9. Documentation of staff participation with the Industrial Solid
Waste Technical Advisory Committee, the Solid Waste Management
Study Commission, various brochures, information packets,
speeches, etc.
10. Summaries of license totals.
11. Draft SPC-17 revision.
12. Manifest documents and related forms.
13. Summaries of staff responses to hazardous materials spills.
G. RESOURCES:
The above-outlined approaches and outputs represent the FY 80 hazar-
dous waste management program effort within the Solid Waste Management
Section. Responsibility for these activities lies primarily within
the purview of the Solid Waste Management Section. However, certain
outputs with respect to emergency response capabilities may be found
within the Divisions of Air Pollution Control and Water Pollution
Control. Coordination with the Air Pollution Control and Water Pollu-
tion Control Divisions will occur on a regular basis when hazardous
waste issues cross jurisdictional lines.
H. LEAD OFFICE:
ISBH-Solid Waste Management Section
EPA Contact-Waste Management Branch
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III. DEVELOPMENT OF PRETREATMENT PROGRAM AND STRATEGY
A. ISSUE:
EPA°s pretreatrnent regulations (June 19, 1978) require all NPDES states
to establishment and implement a pretreatment program compatible with
federal law. In order for the state to retain NPDES permit authority,
it must apply to operate the program and develop the necessary
resources, regulations and programs to do so.
B. OBJECTIVES:
To develop a timely approach and strategy to submit and implement an
adequate and approvable pretreatment program.
C. PROGRAM SCOPE:
NPDES
Water Quality Management Planning
Water Quality Monitoring
Compliance and Enforcement, and;
Hazardous Waste Disposal
D. ASSUMPTIONS:
1. That adequate resources are available.
2. That EPA approves the program.
E. APPROACH AND SCHEDULE:
1. Finalize draft of state pretreatrnent program plan by August, 1979.
2. Request preliminary adoption by Stream Pollution Control Board
by August, 1979.
3. Revise and modify, if necessary, after public meeting and request
final SPCB adoption by November, 1979.
4. Submit final plan along with request to EPA for authority to
operate the program under NPDES, December, 1979.
5. EPA approves delegation and both parties sign memorandum of under-
standing by March, 1980.
6. Revise regulation SPC-15 preliminary adoption by December, 1979 and
final adoption by April, 1979, and promulgation by September, 1980.
F. OUTPUTS:
Approved pretreatrnent program.
G. RESOURCES:
To be spelled out in pretreatment program plan.
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H. CONTACTS:
Lead Office:
ISBH
Permits and Approvals Section, WPC
EPA
Region V Pretreatment Coordinator
23
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IV. CONSIDERATION OF MULTI-MEDIA IMPACTS OF RESIDUAL WASTES
A. ISSUE:
Various air and water pollution control and drinking water treat-
ment technologies, as well as various solid waste management
techniques, all create residual wastes which may vary in volume,
characteristics and concentration, depending on the technology
used. In addition, the impact of ultimate disposal of such wastes
on the environmental media (air, land, and water) may vary accord-
ing to thewinitial treatment of disposal technologies selected as
well as the means of ultimate disposal selected.
Without early consideration of the ultimate disposition of residual
wastes in the preliminary engineering phase for air pollution and
water and waste water treatment and management systems, certain
alternatives affecting the type and amount of residual wastes
generated and the medium of ultimate disposal are foreclosed from
consideration. This may result in an improvement to one medium at
the expense of another and an overall negative impact on the envi-
ronment as a whole.
B. OBJECTIVE:
To establish procedures whereby the multi-media impacts of residual
waste can be recognized and minimized to the greatest extent
practicable.
C. PROGRAM SCOPE:
Air Pollution Control, Water Pollution Control, Water Supply and
Solild Waste Construction Permits and facility plan review (all
programs).
D. ASSUMPTIONS:
None
E. APPROACH AND SCHEDULE:
1. Prepare policy for EMB adoption which would require permitees
to include in preliminary engineering studies an analysis of
the residual wastes created by each alternative design option,
and an analysis of alternate methods and sites ultimate dis-
posal and the impacts thereof by November, 1979.
a. Final adoption by March, 1980.
2. Prepare internal policy for interprogrammatic staff review
and evaluation of such analyses by March, 1980.
24
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3. Establish procedures for resolution of any multi-media con-
flicts, interprogrammatic conflicts and any interregulatory
conflicts and for selection of the best alternative with the
least multi-media impact involving the permittee, the public,
the regulatory boards and EPA by March, 1980.
F. OUTPUTS:
The policies and procedures outlined above.
G. RESOURCES:
To be determined.
H. CONTACTS:
Lead Office: ISBH, Office of Assistant Commissioner for
Environmental Health
EPA Contact: State Coordinator, Office of the Regional
Administrator
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V. DEVELOPMENT OF AN INTEGRATED PUBLIC PARTICIPATION PROGRAM AND STRATEGY
A. ISSUE:
Notwithstanding a detailed EPA regulation devoted to requirements
of public participation under the CWA and guidance on the subject
from EPA since 1973, no one involved yet seems to agree on exactly
what public participation is or should be. There are disputes on
what kind and how much information the public or advisory groups
should receive, at what point in time and in what form they should
receive it, at what level it should be received (local, regional,
or state), and the method by which the advisory groups should
express their viewpoints—individually or collectively.
In addition, detailed specific forms of public participation seem
to be required under only the CWA, even though public participation
is now required under all the acts. There is now one advisory
group to the Water Pollution Control Program and one state and 19
regional groups for the 208 Program within water pollution and a
Technical Advisory Committee for the Solid Waste Management Program.
There are none for the other programs. If similar numbers of advi-
sory groups were formed for the Solid Waste Management, Hazardous
Waste Management, Air Pollution Control and Drinking Water Programs,
chaos would probably result. Therefore, an integrated public parti-
cipation program for all the major environmental programs is needed.
B. OBJECTIVES:
1. To develop a process by which all parties involved (public and
special interest groups, public advisory groups, affected
state agencies, and EPA) can consider and express their views
on various procedural approaches to public participation,
resulting in adoption by the EMB of uniform procedures which
meet or exceed the intent of public participation are accepta-
ble to a majority of public representatives and the agencies
affected, and can successfully be implemented by the agencies.
2. To develop a strategy for developing an integrated public
participation program for all environmental programs.
3. To develop a public participation process that meets State
needs and requirements and the general requirements of Federal
Regulations.
4. To develop staff capabilities in public participation techni-
ques.
C. PROGRAM SCOPE:
Water Pollution Control
Air Pollution Control
Solid/Hazardous Waste Management
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Safe Drinking Water (EPA)
D. ASSUMPTIONS:
That form all the divergent interests, consensus will evolve and
that adequate resources will be available.
E. APPROACH AND SCHEDULE:
1. Formulation of public participation procedures.
a. Prepare a questionnaire to elicit views from program direc-
tors, program staff, board members, PDR members, areawide
regional planning agencies, CAC members, SPAC members, PAC
members, the public at large, and EPA program directors, as
to the appropriate timing, subject matter, level, and
method of determining public position regarding:
(1) Regulations
(2) Implementation plans (208, SIP, etc.)
(3) Agency program policies
(4) Agency annual work programs
(5) Other
b. Collate the responses and summarize the approach(es)
favored by the various groups of recipients (but tallied
individually).
c. Evaluate the above for conformance or conflict with appli-
cable EPA regulations and for practicability and effective-
ness. Identify any constraints which could impede imple-
mentation of any of the various approaches.
d. Form an Ad Hoc Committee composed of one Indiana State
Board of Health representative (Office of the Assistant
Commissioner for Environmental Health), one nonspecific
public interest group (League of Women Voters), one repre-
sentative of locally elected officials, and one of the EPA
Regional Administrators office to study the above documents
and make recommendations to the EMB (recommendations would
not have to be unanimous but could be separate recommenda-
tions from each member).
e. At the same time, submit the above documents (questionnaire
summaries, evaluations) to the SPCB and APCB for their study
and recommendations to the EMB. It is suggested that each
board assign an Ad Hoc study committee of board members to
make recommendations for consideration by the boards.
f. The EMB shall have all the preceeding documents and
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recommendations submitted to it. An Ad Hoc study committee
is also recommended for the EMB. Upon reporting by the study
committee the EMB would preliminarily adopt operating pro-
cedures for public participation applicable to itself, the
SPCB, and the APCB.
g. A public hearing on the proposed procedures would be held,
after which the board would adopt finalized procedures as
policy.
h. After adoption and following implementation, any program
director, member of the public, advisory group member, or
any person affected could petition the board for a change
or revision.
2. Formulation of integrated public participation for all environ-
mental programs.
a. After the above procedures have been preliminarily adopted,
those aspects requiring integration, if any, can be ascer-
tained.
b. The technical secretaries and chairpersons of all three
boards, the State Health Commissioner, and the Deputy
Health Commissioner will meet to review and consider the
following:
(1) Any imbalance in public participation among programs.
(2) If discerned, whether or how the imbalance should or
could be corrected.
(3) Whether consolidation of any advisory groups is war-
ranted or whether any additional groups should be
formed.
(4) The balance of membership of existing and proposed
advisory groups and whether any changes should be
recommended.
(5) The cost of public participation activities.
(6) The implementation aspects of the procedures prelimi-
narily adopted by the EMB.
(7) Any other consideration concerning integrated public
participation.
c. A report of the findings and any recommendations shall be
made and submitted to EPA for review and comment. Upon
receipt of EPA°s comments the above committee will make
any reconsiderations deemed necessary and either implement
recommendations or submit the recommendations to the appro-
priate board, whichever is proper. (Some things only
Indiana State Board of Health administration can do, some
things only the boards can do.)
28
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3. Training in Public Participation Techniques.
A short-course (2-3 days) in public participation strategy
and techniques will be conducted for ISBH staff in all program
offices. Like recent EPA training on the same subject,
emphasis will be placed on the training of top and middle-level
management, in addition to technical staff as determined
appropriate by ISBH.
F. OUTPUTS:
1. Explicit uniform public participation procedures for all pro
grams.
2. Recommendations pertinent to an integrated public participation
program.
G. RESOURCES:
1. Funds under Section 208 of the Clean Water Act will be provided
for the purpose of retaining a consultant to conduct the train-
ing seminar.
2. ISBN-Office of Assistant Commissioner for Environmental Health.
3. ISBH-Program Directors and Program Staff.
4. ISBH-Commissioner, Deputy Commissioner, Assistant Commissioner
for Environmental Health.
5. APCB, SCPB, EMB-Board Chairpersons, Members and Technical
Secretaries.
6. All of the Advisory Group Members
7. EPA-Office of Regional Administrator, Program Directors
H. CONTACTS:
1. Lead Office: ISBH, Office of Assistant Commissioner for
Environmental Health
2. EPA Contact: Office of the Regional Administrator
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VI. DELEGATION OF AUTHORITY
A. ISSUE:
Clarify State and EPA roles and responsibilities relative to indivi-
dual delegations of authority to the State.
Significant differences of opinion exist between the State and US
EPA with regard to the nature and extent of program delegations to
the State and the nature of the US EPA overview of program responsi-
bilities. In some cases, the State feels that there is not a "true"
delegation of program authority and decision-making, but is instead
a partial delegation requiring joint, Federal/State activity before
outputs can be accomplished. The State objects to the close, case-
by-case program overview conducted by US EPA in some programs,
such as NPDES. In other programs, such as the construction grants
management assistance program, the State contends that it lacks the
necessary guidance on what benchmarks of accomplishment precede US
EPA consideration of the Section 205(g) delegation to the State.
On the other side, the US EPA questions the State°s performance of
its existing delegated responsibilities in the construction grants
program. In other program areas, such as NESHAPS enforcement,
there is a question as to whether the delegation to the State is
practically meaningful. The US EPA questions the State°s perfor-
mance of its enforcement responsibilities, and at the same time,
the State objects to what it calls "second-guessing" of the State
decisions by US EPA. In one other program area, water supply, the
problem of State/EPA role and responsibility clarification is dif-
ferent because the State has not accepted primacy. (The US EPA
agrees with the State°s decision not to accept primacy.) In this
situation, there is a critical need to agree on a specific allocation
of program responsibilities between the State and US EPA; there is a
companion need to establish commitments to perform certain specified
tasks according to the agreed allocation of responsibilities.
B. OBJECTIVES:
- To clarify State and EPA roles and responsibilities in programs
that have been delegated to the State.
- To identify major performance accomplishments necessary for pro-
gram delegation consideration (in particular, the State Management
Assistance Program).
- To determine specific responsibilities of the State and EPA in
the Water Supply Program (assume the State does not have primacy).
- To develop a program-specific agenda for reassessing the nature
of EPA°s program overview role and for recommending any needed
modifications and actions by the State and EPA.
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C. PROGRAM SCOPE:
For the purpose of this highlight issue, the following programs will
be discussed.
- Water Pollution Control
- Water Supply
- PSD/NSPS/NESHAPS/Air Enforcement
D. ASSUMPTIONS:
- The State of Indiana will not accept Water Supply Program primacy
in FY°80.
- The outcome of program-specific discussions about delegation is
not predetermined. Any changes in program delegations (extending
additional delegation, withdrawing existing delegations, or return-
ing existing delegations) may result, or may be signaled, by
discussions about this issue.
- There will be a conscientious effort on the part of the EPA and
the State to review patterns of performance and program operation
needs, and to avoid probably fruitless argument about specific
individual substantive decisions.
E. APPROACH AND SCHEDULE:
I. WATER POLLUTION CONTROL
1. November 1, 1979-December 15, 1979 - U.S. EPA and the ISBH
will develop a short-term (one year) operations strategy
designed for the purpose of expediting the construction
grants process, while ensuring satisfaction of the substan-
tive and procedural regulatory requirements governing the
program. U.S. EPA will have the initiative in developing
this strategy.
2. A management study of the entire State water pollution con-
trol function, including the Construction Grant and Water
Enforcement/NPDES Programs, and the other associated program
areas within the water pollution control effort, will be
cooperatively conducted by the ISBH and U.S. EPA. U.S. EPA
will fund the study by a supplemental Section 106 grant
(additional to the basic FY 1980 program grant). The con-
sultant selection process will be under the joint direction
of the State and U.S. EPA, with the following timetable:
Develop Plan of Study December 1, 1979-December 31, 1979
Issue request for proposals January 1, 1980-January 31, 1980
31
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Interview Candidates
Sign Contract
Complete Management Study
(Accepted by Regional
Administrator and State
Health Commissioner)
February 1, 1980-March 15, 1980
March 15, 1980-March 31, 1980
April 1, 1980-August 1, 1980
November-December, 1979 - U.S. EPA will provide (as soon as
possible) three Federal assignees for the ISBH pretreatment
staff. These positions will be funded by a supplemental
Section 106 grant.
II. WATER SUPPLY
The discussion concerning State and EPA Water Supply responsibilities
will follow the approach and schedule outlined in the problem-solving
approach. The Task Identification Checklist prepared in early FY
1979, which tentatively defined the allocation of program activities
between US EPA and the ISBH, will be the focus of the discussions.
1. October 1, 1979 - ISBH and EPA will designate an individual
responsible for the overall coordination of the discussions.
The ISBH and the EPA program offices involved in the discussions
will designate staff contacts for this prupose (See H).
2. November 1, 1979 - The designated ISBH and EPA staffs will
exchange discussion drafts on specific issues needing to be
resolved (including statement of justification), and initial
statements of perceived program needs and deficiencies (includ-
ing reasons why). The formal exchange of drafts will be through
the designed coordinator, while informal discussion and negotia-
tion will occur at the program level.
3. By February 1, 1980 - On a program-specific level, the final
draft outputs of the preceding discussions will be submitted
to the Regional Administrator and the Assistant Commissioner
for Envorinmental Health.
4. By February 15, 1980 - The Regional Administrator and the
Assistant Commissioner for Environmental Health endorse final
outputs from these discussions. The endorsed report of the
"delegation of authority" discussions will become a major set
of program assumptions for the purpose of FY 1981 program
planning.
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III. AIR ENFORCEMENT PROGRAM
Action Date
Meeting - EPA Air Enforcement Branch October 24, 1979
Staff and Indiana Air Pollution Control
Division Staff
Joint Steel and Visible Emissions December 1, 1979
Conference
PSD Delegation January, 1980
Enforcement Audit January 15, 1980
Joint Case Agreement April 1, 1980
News Source Review Audit Not later than May, 1980
Review Steel SIPs Continual
Additionally, there are bi-monthly conference calls. Quarterly compliance
summaries are also submitted 15 days after the end of each calendar quarter.
F. OUTPUTS:
The outputs referred to in Item E. will vary in content. Depending on
the program, there may be a modification to an existing delegation
agreement; there may be a memorandum of understanding establishing a
division of work responsibilities between ISBH and EPA; there may be
detailed guidance from EPA on what the State must demonstrate to
receive a desired delegation and a companion agreement by the State to
accomplish certain steps on a schedule; and there may be other outputs
not contemplated at the outset.
G. RESOURCES: To be determined.
H. CONTACTS:
EPA: Dave Stringham, Coordinator, 353-2200
Al Manzardo, NPDES, 886-6090
Jim Hanlon, 205(g) 353-2190
Bev Kush, Water Supply, 353-2151
Dave Ullrich, Air Enforcement, 353-2082
Jay Bortzer, Air Program, 886-6066
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ISBH: L.R. Carter, Coordinator, 633-8467
Joe Stallsmith, NPDES, 633-0713
Joe Krieger, 205(g), 633-0711
Arnold Viere, Water Supply, 633-0210
Sue Shadley, Air Enforcement, 633-0618
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 1
IDENTIFICATION AND ASSESSMENT OF ABANDONED OR
HAZARDOUS WASTE DISPOSAL SITES
1. ISSUE:
The subject involves three different programs; RCRA, the CWA (Section
208) and the SDWA. Identification, monitoring, and remedial action
is required for all three programs. There is great potential for
overlapping, duplication of effort and funding, and poor optimiza-
tion of all resources unless work in this area is coordinated and
integrated among all programs.
2. OBJECTIVES:
To outline procedures to avoid the potential problems outlined above.
3. AUTHORIZATIONS:
RCRA Section 3011
CWA Section 208
SDWA
4. ASSUMPTIONS:
That the means or criteria to assess whether or not a site is
hazardous will eventually be developed.
5. COORDINATION AND INTEGRATION PROCEDURES:
A. Any identification and/or assessment activities proposed to be
undertaken under any program will be coordinated among the ISBH
Solid Waste Management, and the WPC planning and Water Supply
staffs, and the identified EPA program offices, in particular
the Hazardous Materials Enforcement and Response Program Commit-
tee. All will be apprised of activities planned by each program to
avoid duplication and to permit cross utilization of data obtained,
Methodology will be discussed to strive for uniformity in site
identification and assessment.
B. Any sites preliminarily identified by any program staff as having
either actual or potential hazardous leachate migration or other
environmental media impacts will be reviewed by the joint program
staff, including air pollution control staff, to determine, or
develop the means to determine, the impact on water users or other
media.
C. If any water user impacts are determined, the ISBH Water Supply
Section will be the lead staff in determining recommended courses
35
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of action, in consultation with the Solid Waste Management and
Water Pollution Control Division staff. Where toxics or treat-
ment advisements are necessary, the SDWA staff (EPA Region V Water
Supply Branch) will be contacted.
0. Assessment and resolution of source problem will be carried out
by the program having jurisdiction in consultation with other
media staff.
6. STATE/EPA PROGRAM CONTACTS:
ISBH EPA
Office of Assistant Waste Management Branch-Jay Goldstein
Commissioner-Bob Carter Water Quality Management Branch-Don
Water Pollution Control Roberts
Division-Jeff Feller Water Supply Branch-Don Maddox
Water Supply Section-Neil Ott HMERP Comrnmittee-Dale Bryson
Solid Waste Management
Section-Dave Larnm
Air Pollution Control
Division-Ed Stresino
36
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 2
HAZARDOUS CHEMICAL CONTAMINATION AND ITS IMPACT ON DRINKING WATER
1. ISSUE:
Drinking water sources may become contaminated from wastewater dis-
charges, contaminated runoff or leachate from hazardous waste disposal
sites. Activities in Water Pollution Control and Solid Waste Manage-
ment must take into account such impacts in the permitting process,
including siting of facilities, selection of treatment processes and
in selecting the ultimate disposal alternatives. In many cases, the
pollutants must be treated at their source rather than at the water
purification stage. This requires coordination among the various pro-
gram staffs.
2. OBJECTIVE:
To ensure procedures are in place which require evaluation of the
impacts of Water Pollution Control and Solid Waste Management activi-
ties on drinking water sources, that information on such impacts is
"fed back" and integrated into the decision making process and that
mechanisms are established to carefully evaluate water pollution and
solid waste problem solving alternatives that do not adversely impact
drinking water sources.
3. AURHORIZATIQNS:
CWA, Section 208
SDWA
RCRA
4. ASSUMPTIONS:
That the above authorizing acts are flexible enough to permit and
support multiple program approaches to addressing the issue.
5. COORDINATION AND INTEGRATION PROCEDURES:
A. Since all of the above programs are administered within the Bureau
of Engineering, ISBH, a great deal of coordination and integration
already exists. NPDES permit effluent limitations take into
account calculation of the individual and cumulative impact of
permittees0 discharge on downstream water supplies. In addition,
the WPC Division°s water quality monitoring sites are and have
historically been located at major surface water intakes suscepti-
ble to pollution inputs. If water quality criteria or drinking
water standards are violated, the situation is reviewed by both
Water Pollution Control and Water Supply staff for significance,
probable source and remedial action.
37
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Also, protection of ground water is a prime consideration in the
approval and siting of solid waste disposal facilities. In addi-
tion, the emergency response staff of the WPC Division has all
public water supplies located on topographic maps so that when
spills occur, they know whether public water supplies may be
jeopardized. In the event that they are, the Water Supply Section
is notified and that section initiates action to notify the supply
and advise and assist in any special actions necessary.
In the event that adverse drinking water impacts may result from
waste treatment or management projects, the Bureau Director (SPCB
Technical Secretary) and the Assistant Commissioner for Environmen-
tal Health (EMB Technical Secretary) discuss the situation and take
an agreed upon recommendation to the respective boards. If an EPA-
supported project is apparently involved, the ISBH program contacts
will promptly notify the Region V EPA, Water Division. Preventive
or remedial steps to correct a hazardous chemical contamination
problem will be taken jointly by the ISBH and EPA. Alternately,
unilaterial actions by either the ISBH or EPA will be taken only
after consultation with the other responsible agency.
B. In the event of hazardous chemical contamination, or the threat of
contamination, of a drinking water source, the primary contact
agency, either ISBH or EPA, will promptly notify the counterpart
agency and establish coordinated procedures for addressing the
identified problem.
6. STATE/EPA PROGRAM CONTACTS:
ISBH
Permits and Enforcement Branch-Joe Stall smith
Water Quality Monitoring Branch-John Winters
Solid Waste Management Section-Dave Lamm
Water Supply Section-Neil Ott
EPA
HMERP Committee-Dale Bryson
Water Quality Management Branch-Don Roberts
Water Supply Branch-Don Maddox
38
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 3
QUALITY ASSURED LABORATORY CAPABILITY
FOR ALL ENVIRONMENTAL PROGRAMS
1. ISSUE:
Since sampling and analyses of both water pollution sources and
drinking water sources is or will be done in all three program—CWA
Section 208, RCRA and the SDWA—and the cross program utilization of
such data is necessary to optimize resources, and since data results
gathered from one program may require action in other programs, it
is necessary that all such data be as technically sound as possible
with the same relative soundness regardless of the program under
which it was gathered. This necessitates quality assured laboratory
capability with the same degree of quality assurance provided by all
laboratories.
2. OBJECTIVES:
To provide the means for establishing and monitoring quality assurance
for all laboratories conducting environmental analyses.
3. AUTHORIZATIONS:
CWA - RCRA - CAA - TSCA - SDWA
4. ASSUMPTIONS:
That the US EPA has the capability to monitor quality assurance pro-
grams for all laboratories. That the responsible ISBH and US EPA
staffs will confer regularly to resolve any quality assurance issues.
5. COORDINATION AND INTEGRATION PROCEDURES:
A. Samples analyzed by the ISBH for either water pollution, solid
waste management and drinking water, are done primarily by the
Water and Sewage Laboratory of the ISBH. The ISBH is currently
developing a full quality assurance program acceptable to, and
monitored by, US EPA. The ISBH will extend its quality assured
laboratory capabilities in the areas of toxic and hazardous
materials control. US EPA will provide specific guidance to the
State during the first half of FY 1980.
B. Air Pollution samplers are analyzed by the Air Pollution Control
laboratory, ISBH, which follows US EPA quality assurance proce
dures.
C. Samples collected under the water pollution control, solid waste
management or safe drinking water programs are now (water Pollu-
tion—Section 208) or may be (all three programs) contracted out.
39
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It is imperative that such labs be required to conform to the
techniques and quality assurance guidelines of US EPA.
6. STATE/EPA PROGRAM CONTACTS:
ISBH
Water and Sewage Laboratory-Craig Henshaw
Water Pollution Control Division-John Winters, Dennis Clark,
Jeff Feller
EPA
Quality Assurance Office-James Adams
40
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 4
IDENTIFICATION AND MONITORING OF TOXIC SUBSTANCES IN THE ENVIRONMENT
1. ISSUE:
With the advent of highly precise analytical techniques, more and
more substances, both natural and man made, are being found in trace
amounts in the nation°s water, in the food chain or in the air. In
addition, more and more substances are being disposed of or deposited
in or on the land because of air and water pollution treatment
requirements, creating more opportunities in more locations for
their entry into water, particularly ground water. Also, a public
awareness and fear of potential problems has been created, resulting
in either a demand for assurance or a solution to a real perceived
problem. Last, 5 federal acts call for identification, monitoring
and solutions to these problems.
The questions are: What substances are toxic (which one should be
monitored)?; In what concentrations are they toxic (what is the
"action level")?; What is the originating source?; How do they get
there (by direct discharge into the water, by indirect movement on
another substance, or by indirect and unknown transport)?; and last,
What means are available to mitigate the problems?
This issue deals with identification and monitoring only and with
interprogrammatic cooperation and cross utilization of the data
collected.
2. OBJECTIVES:
To develop procedures to ensure interprogrammatic cooperation and
cross utilization of data collected for the identification and moni-
toring of toxic substances in the environment.
3. AUTHORIZATIONS:
TSCA - CWA - CAA - RCRA - SWDA
4. ASSUMPTIONS:
That EPA will furnish a working list of those substances considered
toxic, along with the concentrations considered toxic (for both
aquatic life and human health) and any information on synergistic
effects in order for all programs to monitor for the same substances
at the proper concentrations.
5. COORDINATION AND INTEGRATION PROCEDURES:
A. Pertinent proceudres outlined in Cross Cutting Issues Number 1
41
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and 2 will be utilized.
B. The combined pertinent program staffs of the ISBH and the EPA
will establish a task force to agree upon what substances will
be monitored, to develop a uniform method (or methods) of moni-
toring and to assure uniform application throughout the programs.
6. STATE/EPA PROGRAM CONTACTS:
ISBH
Permits and Approvals Section-Larry Kane
Water Quality Planning Section-Jeff Feller
Solid Waste Management Section-Dave Lamm
Water Supply Section-Neil Ott
EPA
Surveillance and Analysis Division-Curtis Ross
Water Supply Branch-Don Maddox
Water Quality Management Branch-Don Roberts
42
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 5
U.S.-CANADA WATER QUALITY AGREEMENT
IDENTIFICATION OF PROGRAMS AND ROLES
1. ISSUE:
How to integrate the objectives of the Agreement into the overall
EPA and state programs in such a way that such programs permit timely
implementation of both the terms of the agreement and other federal/
state requirements, objectives and programs not specific to the
Great Lakes.
The agreement is based on objectives and requirements looking at the
basin or individual lake basins as a whole cut across state boundaries
and various jurisdictions. On the other hand, EPA objectives, require-
ments and programs are based on accomplishing legislative mandates on
a national and regional basis; the states are required to incorporate
not only national and regional but state requirements as well.
Therefore, when state program plans are developed (under EPA guidance
documents) national, regional and state programmatic objectives are
reflected and emphasized rather than basin-wide objectives.
While the ISBH Director of the Bureau of Engineering (and SPCB
Technical Secretary) is a member of the IJC Water Quality Board
which reviews and has input to the Agreement and is charged by the
IJC to "undertake liaison in coordination between the institutions
established under the Agreement and other institutions and jurisdic-
tions to ensure a comprehensive and coordinated approach to planning
and the resolution of problems...," such liaison and coordination
cannot be effected unilaterally by an individual member or state.
The Water Quality Board and, primarily EPA Headquarters in Region V,
must incorporate the terms of the Agreement into national and regional
requirements, allocate any loading requirements among the states and
take into account the increased program costs of implementing the
Agreement in the federal and regional annual program planning guidance
documents as well as in the allocation of the program and water
quality management grant funds.
Thus, if basin-wide agreement requirements are allocated among the
states, and additional grant funds are equitably distributed according
to the additional workload allocated to each state, and integrated
into national and regional EPA planning prior to the preparation of
individual state program plans, each state can more effectively incor-
porate Agreement objectives into their overall state plan.
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In this way, any cross cutting between individual programs or grants
will be distinguished during program plan preparation and taken care
of by the procedures outlined in the other cross cutting issue papers.
2. OBJECTIVES:
The integration of the terms of the U.S.-Canada Water Quality Agree-
ment of 1978 into EPA and state programs and the timely implementation
of its goals and objectives.
3. AUTHORIZATIONS:
CWA 104 CWA 201
CWA 106 CWA 208
CWA 108 TSCA 28
CWA 115
4. ASSUMPTIONS:
That lacking the above-mentioned incorporation and allocations of
basin-wide requirements into EPA program planning guidance for FY 80,
full integration of the terms of the Agreement into the state FY 80
program plan is impossible.
5. COORDINATION AND INTEGRATION PROCEDURES:
A. The Indiana member of the Water Quality Board will raise the
issues described herein at a subsequent WQB meeting and suggests
that a U.S. task group be established to develop the means and
methods necessary to resolve the issues. This should be completed
in time for consideration and approval by the U.S. members of the
Water Quality Board and for subsequent forwarding to EPA for
incorporation into the FY 81 guidance documents and grant
allocations.
B. Indiana will furnish a staff person to work on the task group.
C. EPA Region V will furnish a person to work on the task group.
D. Upon approval by the U.S. members of the Water Quality Board and
incorporation by EPA into program planning guidance documents
and upon the availability of additional grant funds, Indiana will
incorporate Agreement objectives into its program plan to the
extent that resources will allow.
6. STATE/EPA PROGRAM CONTACTS:
ISBH
SPCB Technical Secretary-Oral Hert
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EPA
Great Lakes National Program Office-Madonna McGrath
Water Quality Management Branch-Don Roberts
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CROSS CUTTING ISSUE NO. 6
IMPLEMENTATION AND REFINEMENT OF THE
CLEAN LAKES PROGRAM
1. ISSUE:
Incorporation of activities of the Clean Lakes Program into the
Annual Work Program.
Section 314 of the CWA requires the State to do three things:
1. Identify and classify according to trophic condition all
publicly-owned freshwater lakes;
2. Establish procedures, processes, and methods to control
sources of pollution of such lakes; and,
3. Establish methods and procedures to restore the quality
of such lakes.
The State has essentially completed the first requirement, through
208 Water Quality Management Planning. With respect to the second
requirement, the following procedures, processes and methods are in
place or proposed for the following pollution sources: phosphorus
removal facilities are required for municipal and semi-public treat-
ment plants within 40 miles of a downstream lake; the State confined
animal feeding control law and program require storage and application
of animal waste from confined animal feeding operations; the recently-
adopted State Agricultural Non-point Source Pollution Control strategy
provides a mechanism to reduce inputs on a priority basis of sediment-
bound phosphorus from eroded cropland to those lakes and watersheds
where excessive cropland erosion is occurring. Therefore, the remain-
ing source of phosphorus (other than from atmospheric fallout) not
currently addressed by ongoing or proposed control programs or stra-
tegies is sewage from lakeside residences. However, even here, the
state limitation on phosphorus in laundry detergents reduces that
amount in sewage to primarily only that contained in human waste.
The issue is, how can the state incorporate the last two requirements
of the act, as applied to sewage from unsewered unincorporated housing
areas surrounding lakes, into the state work program.
Since the areas do not comprise a legal entity (other than as individual
homes and establishments) NPDES permits and enforcement are not viable
tools, nor do the areas qualify for construction grants. In addition,
under existing legislation, there is no management agency which will be
designated to implement 208 recommendations. While the state has a
septic tank (on lot disposal) regulation, enforcement authority is at
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the County Health Department and few, if any, lots could meet the
requirements of the regulation because of lot size, type soil, a
high water table or all three combined.
Given these conditions, the only remaining courses of positive action
left to the state appear to be:
1. Dissemination of lake assessment data to lot owner associations,
giving them some appraisal of lake restoration techniques pertinent
to their lakes and urging them to establish a legal entity, either
a municipal corporation, a conservancy district or a regional
sewer district, to serve as the vehicle to enable them to undertake
and finance collective action; and,
2. Investigate more fully the results of recent studies on chemical
additions to septic tanks to render the phosphorus unavailable
for biologic up-take and, if found to be effective, to promote the
installation with such devices; and,
3. Recommend to the legislature the establishment and administration
of a state grant fund to help finance and encourage implementation
of reclamation projects.
2. OBJECTIVE:
To establish a means by which the remaining aspects of the Clean Lakes
Program can be integrated into the State work program.
3. AUTHORIZATIONS:
CWA 314
CM 208
CWA 106
4. ASSUMPTIONS:
That adequate legal entities or management agencies exist or are created,
with the power to implement reclamation techniques, to receive grants and
to raise any matching funds required.
5. COORDINATION AND IMPLEMENTATION TECHNIQUES:
A. Publish and disseminate a limnological primer to lake associations
and other interested groups.
B. Publish and disseminate the basic state limnological data on each
lake for use in promoting and designing clean lakes reclamation
programs.
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C. Publish and disseminate the "cluster analyses" developed under the
208 program to aid lake associations, grantors and other interested
groups or persons in determining the relative severity of trophic
conditions and the range of choices of reclamation techniques availa-
ble duriong FY 80.
D. Arrange visits to advise lake associations of the means available
to address their problems and to promote and assist in the formation
of entities capable of implementing remedial measures (already occur-
ing).
6. STATE/EPA PROGRAM CONTACTS:
ISBH
Water Pollution Control Division-John Winters
EPA
Water Quality Management Branch-Don Roberts, Wayne Gorski
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COORDINATION AND INTEGRATION PROCEDURES
CROSS CUTTING ISSUE NO. 7
COMPLETION OF WASTE LOAD ALLOCATIONS
1. ISSUE:
Waste load allocations are required to determine maximum loadings
to streams in water quality limited segments and to allocate that
load among the various discharges. For nonconservative pollutants,
direct dilution calculations cannot be made since dynamic processes
cannot be accounted for. In this case, certain modeling techniques
are available. However, in order to be any more accurate than rule-
of-thumb methods, accurate flow and water quality measurements are
required.
Since the flow and water quality data must be obtained by the
Surveys Section, the modeling done by the Data Modeling Section, the
outputs utilized in 208 planning, construction grants, and NPDES
(and possibly enforcement), close cooperation and scheduling within
the division and in the annual work plan is imperative. In addition,
inter-sectional input and review are necessary for work done outside
the agency, whether by contract or by an areawide planning agency.
2. OBJECTIVES:
To insure the timely completion of technically defensible waste load
allocation in the water quality segments remaining and the integration
of the outputs into water quality management planning, construction
grants, and NPDES permits.
3. AUTHORIZATIONS:
CWA 201
CWA 208
CWA 106
4. ASSUMPTIONS:
The accurate flow and water quality measurements can be obtained at
proper flow conditions representing at least two separate surveys
reasonably close to low flow conditions.
5. COORDINATION AND IMPLEMENTATION TECHNIQUES:
A. A schedule of surveys for this purpose has been prepared in consul-
tation with the above mentioned staffs and incorporated into Sec-
tion 106 activities, with permit reissuance and construction grant
requirements establishing first priority.
B. Waste load allocations for eight additional water quality limited
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segments are scheduled for completion during FY 80.
C. The remaining six segments are to be completed during FY 81.
D. Any waste load allocation needs in addition to the ones in B.
and C. will be identified in early FY 80. Schedules for the
completion of any additional waste load allocations during FY
80 and FY 81 will be set immediately following identification
of the needed waste load allocation.
6. STATE/EPA PROGRAM CONTACTS:
ISBH
Survey Section
Data/Modeling Sections
Facilities Development Branch
Enforcement and Operations Branch
EPA
Water Quality Management Branch, Indiana-Illinois Sec., Don Roberts
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V. DEVELOPMENT OF FISCAL YEAR 1981 INDIANA STATE-ERA AGREEMENT
The schedule for the preparation of the State-EPA Agreement for
FY 1981 is in the process of being developed. The schedule is
expected to be finalized in December, 1979, at which time it
will be inserted as Section VI of this Agreement.
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VI. APPENDICES
The following documents are incorporated into this Agreement by
reference:
1. EPA program guidances to State.
2. State program plans and strategies.
3. Delegation agreements.
4. Memoranda of Agreement.
5. Memoranda of Understanding.
6. Published inventories and assessments (e.g. CWA 305(b)).
7. Continuing planning process (e.g. CWA 303(e)).
8. Emergency response plans.
9. Plans, regulations, and other program outputs.
10. Approved plans of designated substate agencies.
11. Other program documents.
12. Pubic meeting summary(ies)
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