5659
                                              OOOR80107
                                                      RECEIVED

                                                           FEB 29 1980

                                                              L HKOftCllON AGENCY
                                                          LIBRARY, RZaiCN tf
                             SJATE/EPA AGREEMENT

                 INDIANA/U.S.  ENVIRONMENTAL PROTECTION AGENCY

                              FISCAL YEAR 1980

-------
                             ns
 Tui  S.  i-  ,••!-•;'*»•    "i:  1;
         .  ^;.   • ,   *    .: ,s:
         "    •   '  " •'•  -       •
   <;fc  it.
•:•»',  j- r<',.
 d ?--;-^
V ^
 •>  •"?••.
                     -'   r

-------
                                   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

-------
. "!<• p'.   '„   „'•   -,.   P"    *'.'

-------
                                 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


-------
';"    - •'..:   * 'J   t   L;:v
r;;,  2f ••    >-"   , ;..  '

-------
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.

-------
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.

-------
                         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

-------
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.

-------
                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

-------
                  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

-------
                     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


-------
                                  co
AREA
STAN
              AINING HEATH
m     AREAS EXCEEDING SECONDARY
     STANDARDS

 rTH AREAS EXCEEDING PRIMARY

 Li» STANDARDS


 G3 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

-------
                                              STflTttS
cm
Tn\ AREAS EXCEEDING SECONDARY
t&t STANDARDS
m AREAS EXCEEDING PRIMARY
ItU* STANDARDS

TTO AREAS EXCEEDING ALERT LEVELS

- J—1 INSUFFICIENT DATA TO MAKE
 1 — * JUDGEMENT
 UPWARD TREND - AIR QUALITY IMPROVING


DOWNWARD TREND - AIR QUALITY WORSENING


f  NO SIGNIFICANT CHANGE


  MIXED TREND

-------
IB
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
                                  —  10

-------
                              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

-------
r   fc-V,

-------
                                                                                                                                            _J
i
o  a   a
•43   r*
M  U   O*
b
O
?p
CJ
IW «^
Si
I
Problem Area
Organic
Toxics
Inorganic
Toxics
M i 5
a a b
322
H o- a
q
B
^4
b
U
a
a
S
Dissolved
Oxygen
Tempcr-
uturu
"Si

\
1


o
e
d.
*
^
CO
z
en
z
-
-T
-T
-T
*c. =
Cl >>
a 3
a 9
->
• *j
u b*
CO >-'
and
1 Discharges
a — i
G. b
.2 §
C "3
SS
s
a
CO
V4
Z
^
-t
ta
Z
CO
z
•
.T
.^
•T
•"< o
(3 4>
b b
H U
and
1 Discharges
•35
C. b
u a
§1
S >->
s
A
3
.«-
*
•
S
.t
oT
-T
•t
•a
A c
a. u
a a
m
o j:
*^ ^j
3
- 0
u ->
East Chicago/
Hammond
-T
-
-t
•T
-
.T
^
°T
L
~ o
a =
e e
3 U
— t
•a b
e o
and
1 Dlschargca
a -H
C. b
U 01
e -a
Below Vlnccnncs
•k
•*
Z
CO
z
.4-
.T
-T
-T
"3
0
e:
and
1 Dlachargcs
a -*
& b
u n
s -a
Muncle to An-
deroon1, Nora
to Centcrton
-
-t
ea
z
^
.T
•T
=t
1
U
£
O
a -*
£5
ond
1 Discharges
** a
C. b
u a
C -3
15
b
0 3
°-5 *
a ci e
!"!
*S ,§ J
^
-t
CO
z
CO
z
^
t
0 I
o
/\
u
ti
a
S
3
S

!


Seymour to
Petersburg
o C
o^~
50
z
CO
z
t
o !
ot
-T
-r
w
S
X
K 3





-T
-t
CO
z
en
Z
^
o<-
-t
•r
Knnkakec
                                                                                                                          e   u
                                                                                                                         •a  -a
                                                                                                                          e
                                                                                                                          a   >
                                                                                                                          2-   §
 o
u  03
 B  r«
14  a»
to  —
    i
*M  •?
 O  r«
    o»
 s  «•
 a
«  -3
W  Cl
 B  >
t^  O
 O  b

t  &
                                                                                                                          I   -H  C
                                                                                                                     >•   \O  >H  (3
                                                                                                                     td        a  w
                                                                                                                          o  -a  -a
                                                                                                                         •a  b
                                                                                                                          c  e  "
                                                                                                                          a  -a  c
                                                                                                                          ^1  =  0
                                                                                                                         CO  G  *•«
                                                                                                                             u  u
                                                                                                                          X  CO  —
                                                                                                                         >
                                                                                                                         o  a  u
                                                                                                                             2  "*
                                                                                                                              t   a
                                                                                                                         •003
                                                                                                                          o  
-------
                              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.
                                        14

-------
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

-------
    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.
                               16

-------
        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:
                                   17

-------
1.  Lead Office:  ISBH, Air Pollution Control  Division
2.  EPA Contact:  Air Programs Branch
                               18

-------
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

-------
        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

-------
        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
                                        21

-------
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.
                                          22

-------
H.  CONTACTS:



    Lead Office:
    ISBH
    Permits and Approvals Section, WPC



    EPA



    Region V Pretreatment Coordinator
                                        23

-------
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

-------
    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
                                  25

-------
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
                                       26

-------
    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
                                   27

-------
        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

-------
    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
                                   29

-------
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.


                                        30

-------
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

-------
                  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.
                                       32

-------
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
                                       33

-------
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
                              34

-------
                    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

-------
        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

-------
                    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

-------
        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

-------
                    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

-------
        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

-------
                    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

-------
        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

-------
                     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.
                                        43

-------
    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
                                        44

-------
EPA

Great Lakes National Program Office-Madonna McGrath
Water Quality Management Branch-Don Roberts
                                   45

-------
                           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
                                        46

-------
    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.
                                        47

-------
    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
                                        48

-------
                    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


                                        49

-------
        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
                                       50

-------
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.
                                        51

-------
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)
                                       52

-------