5003
-EPA
United States
Environmental Protection
Agency
Region 5           May, 1983
230 South Dearborn Street    ,
Chicago, Illinois 60604      \]Q \f \
                                                 cop
.I
Environmental
Management
Report
               Parts 1&2
                905R83121
             Valdas V. Adamkus, Regional Administrator

                                 US. Environmental Protection Agency'
                                 2^0 SOL;
                                 Chicago,
                          ill;..

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       REGION V
   DATE:    AU8  121983
SUBJECT:  Final Environmental Management Reports (EMR's) - All Pj\ions
   FROM:  William H. Sanders III, Director
         Environmental Servicas Division

     TO:  See Addressees Below
         Enclosed are copies of the final Envirormiental Management Reports (EMR'i.)
         from each of the Regions along with Region-specific EMR summaries.   The
         Regional summaries were prepared orig.n^liy to brief the Adnrinis tremor
         prior to his visits to each of the Regions.

         Region V will continue to use the EMR ,v>alyses as input to the FY'84
         Regional planning process.  In September, the Office of Policy and
         Resource Management will conduct an evaluation of this year's "pilot1'
         EMR process including conducting interviews in each Region.

         The Environmental Results Branch, OPRM, will seek a wide range of perspec-
         tives on this year's process to determine (a) whether or not to prepare
         EMR's in the future, (b) if so, how to restructure the process or maximize
         their usefulness and reduce the effort required to prepare them,

         Please contact Stephen Goranson at 353-2306 if you have questions or comments
         on these reports or suggested plans for FY'84.
                                             William H, Sanders III
         ADDRESSEES

           Bill Constantelos, 5H
           David Kee, 5A
           Charles Sutfin, 5W
           Robert Spri
           Lou Tilley,
  EPA FORM 132M (REV 3-76)

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                                     - 1  -

                                    ABSTRACT
The Region V Environmental Management Report  is  in  three  volumes  -  Parts  1
and 2, Attachment A and Attachment 8.Each volume is divided into portions
covering air, land  and  water media and  the Great  Lakes.  Emerging  issues
are also discussed in Part 2 and in Attachment B.

Part 1 contains  a condensed summary of  the status  and trends of environmental
problems and management  in the Region.   Part 2  is  a more detailed  description
of programmatic  and  geographic  problems  facing the  Region.   The discussion
includes a description of the barriers to problem resolution and  the actions
required of the states,  the Region and Headquarters.  Attachment A contains
the "reference" materials used to  develop Parts 1 and 2.  This is  primarily
detailed support  documentation.   Attachment  8   contains  detailed  problem
analyses of selected, problems from each medium.

Air quality problems  are concerned with the  criteria pollutants  -  ozone,
total  suspended particulates, carbon monoxide, sulfur dioxide and  oxides  of
nitrogen.  Lead, radiation and air toxics are  also addressed.

The handling/mishandling  of  waste  materials  and toxic  substances  is the
focus  of  the  land  portion   of  the  report.  Hazardous  waste  management,
superfund activities, pesticides  and  toxics management  and  spill   response
are addressed under the land section.

The water medium  includes surface water,quality  (rivers and  inland  lakes),
drinking water  and  groundwater.   Problems  described  for  water  range  from
the concerns about  dioxins  in specific  geographic  areas  to  overall water
supply compliance' to  combined sewer overflows to the disposal  of contami-
nated  sludges to  in  situ  contaminants to the  control  of underground  injec-
tions.

The Great  Lakes  are discussed  separately.  The discussion includes  an
overview of the  status  of the  lakes  and  focuses on  two  major  problems  -
nutrient enrichment  and  toxic  contaminants in the  Great  Lakes.  Areas  of
concern are also described in some detail.

Acid rain, air  deposition in the Great Lakes,  aldicarb  contamination  in
Wisconsin groundwater  and  multimedia  unregulated   toxic substances  are
discussed under emerging issues.

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                                   -  11  -
                  REGION  V  ENVIRONMENTAL MANAGEMENT REPORT

                             TABLE  OF  CONTENTS
                               Parts  1 and  2
Abstract
Figures (Part 1 only)
Tables
     Introduction
     Air - Part 1
     Land - Part 1
     Water - Part 1
     Great Lakes - Part 1
     Air - Part 2
     Land - Part 2
     Water - Part 2
     Great Lakes - Part 2
     Emerging Issues - Part 2
  i
iii
 iv
  1
  2
 14
 18
 28
 32
 45
 55
 76
 93

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                                  - 111  -
                  REGION  V ENVIRONMENTAL MANAGEMENT  REPORT

Number                          F1gu res                               Page
 A-l            Air Quality Status  for Ozone                            6
 A-2            Air Quality Status  for TSP                              7
 A-3            Air Quality Status  for CO                               8
 A-4            Air Quality Status  for SC>2                              9
 A-5            Air Quality Status  for Nitrogen  Oxides                 10
 A-6            Air Quality Status  for Lead                           11
 A-7            Status of Radiation Emergency Response  Plans           12
 A-8            Hazardous Waste Incinerators                .           13
 S-l            Spill  Reports (1978-1981)                              17
 S-2            Spill  Reports by Type                                 17
 W-l            WQI-STORET-Bacteria                                   20
 W-2            WOI-STORET-Nutrients                                  21
 W-3            WQI-STORET-Amronia                                     22
 W-4            WOI-STORET-Dissolved Oxygen                           23
GL-1            Trophic Status of Great  Lakes                         30
GL-2            Areas of Concern - Great Lakes                        30

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                                   TARLES



Title                                                Page

Class A and Class B  Areas of Conern                    89

Evaluation of Remedial  Measures  in Class A            90-92
  Areas of Concern

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                                     - 1 -

                   REGION V ENVIRONMENTAL MANAGEMENT REPORT


                                 INTRODUCTION
The qualities which make  Region  V great, are also qualities  that  make it  sus-
ceptible to  environmental  problems.  The  successes  of  industry,  agriculture
and resource development in Region  V  have  contributed problems  to  the environ-
mental management of the Region's Air, Land and Water resources.

A capsule view of the Region:

     * Centered around the Great Lakes which has allowed
       Region V to become the most highly populated inland
       area in the world

     * Population in excess of 46 million - 22% of United
       States total

     * 52% of the Region's people live in 12 major metro-
       politan areas

     * 23% of cities with populations  greater than 25,000

     * Producer of more than 25% of the nation's manufac-
       tured goods

     * 23% of agricultural land in the United States  is
       in Region V accounting for more than 22% of agri-
       cultural  income in the United States

     * Nearly 65 million acres of forests providing a
       liveable habitat for plants and animals and re-
       creation for people

     * 50% of the nation's nuclear power sites (28% of
       the world total)

     * The 5 Great Lakes constitute 95% of  the surface
       fresh water in  the country (25% of the world's
       supply)

The Environmental Management  Report (EMR)  is organized by air, land  and  water
media to  address  the  environmental management  problems  and  issues in the  on-
going regional effort  of  protecting  the public's  health and the  environment.
The Great Lakes  are discussed separately  due to  the complex  interactions  of
air, land and water in this ecosystem.

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                                     - 2 -

                   REGION V ENVIRONMENTAL MANAGEMENT  REPORT

                                    PART 1
                                     AIR
Air quality for  the  criteria pollutants is described  in  this  part of the  re-
port.  Radiation and  air toxics are also highlighted.  The  current status  of
each pollutant is summarized in the following.
OZONE (Q.Q
                                                       /
Ozone remains the Region's most significant  air quality  problem.   138  counties
were officially designated as  not meeting the standard  in 1979.  This  repre-
sented over 25 percent of the Region's counties, with an  affected population  of
approximately 31  million.  25  counties  (including the extension  cities),  with
a population of 15 million people, did not achieve  final  attainment  by the end
of 1982.  These areas are shown in Figure A-l.

Ozone levels have  been  reduced by controls  applied to industrial sources and
processes, and the continued  implementation of the Federal Motor Vehicle Control
Program (FMVCP).   Other  vehicle emission  control plans will  be required in the
Detroit, Chicago/NW  Indiana/SE Wisconsin, Milwaukee,  E.  St. Louis,  and Louis-
ville metropolitan areas in order  to  meet air quality  standards.  On February  3,
1983, Region V proposed rulemaking on the five  required Ozone State Implementa-
tion Plans  (SIPs)  submitted  by  Illinois,  Indiana,  Wisconsin,  Michigan, and
Ohio.  All,  except   Ohio's,  are  recommended for  disapproval  because  of the
failure to  institute a proper Inspection and  Maintenance Program,  failure  to
implement Reasonably Available Control Technology  (RACT), and inadequate model-
ing demonstrations.   Ohio  demonstrated  attainment  by modifying  the  1979 SIP
submittal.
TOTAL SUSPENDED PARTICULATE (TSP)

The nonattainment  areas  for primary (health) TSP  violations  in Region  V  have
been reduced.  State  Implementation Plans (SIPs)  identified 50  distinct areas
in 1979 in which primary violations  occurred.  This  number  has  been reduced  to
16 (shown  in  Figure A-2).   This  significant  reduction has  been  achieved  by
increased use of cleaner fuels  and  the installation of controls on industrial
point (stack) sources.  Of  the  4,500 major  industrial  air pollution sources  in
the Region, 87 percent are currently in final compliance with  clean-air regula-
tions.  Despite the improvement in  TSP  air quality,  nearly  7  million people  in
Region V  continue  to  be exposed  to excessive amounts  of  TSP.   Compliance  at
the remaining noncomplying  facilities  will  be  pursued.   Further TSP reductions
through controls on fugitive  dust emissions  from such  sources  as  coal  storage
piles, road  and  parking lot  dust,  and  construction sites will   be  achieved.

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                                    - 3 -
Region V has approved Part H Plans for all  States except Ohio,  and  Lake County,
Indiana. Partial  approval  is  pending  for Wisconsin.  The State of Michigan  has
several outstanding conditional  approvals  related  to iron and steel  which  are
described in more detail  in Part 2 of this report.
CARRON MONOXIDE (CO)

Compared to the massive contamination of the ambient air  by  pollutants  such  as
TSP and ozone, CO  constitutes a  relatively less  significant  environmental  pro-
blem in Region V.   Originally, 19  distinct  areas  in the Region were designated
as being  over  the  standards; now,  only  seven are  not  expected  to meet  final
attainment of  the  standards  by  the statutory  deadline.  However, these  areas
(shown in  Figure  A-3) have  experienced a general trend toward improved air
quality, primarily  attributable  to the implementation  of the FMVCP.   Several.
metropolitan areas continue to experience high  levels  of CO  (see  Attachment A),
generally in heavily travelled corridors  on/near major intersections.  Approxi-
mately 1.1 million people are still  adversely  affected  by high CO  levels.  The
CO SIPs for  Indiana,  Illinois,   Wisconsin, and Michigan  were not  approvable.
SULFUR DIOXIDE (SO?)
    problems have been  virtually  eliminated  through  generally  strict  emission
limitations in many  urban areas and by conversion to  cleaner fuels.   Presently,
S02 air quality problems in Region V  are  confined  to  limited  areas  surrounding
coal fired power plants, refineries,  pulp  and paper mills,  and industrial  boil-
ers.  The number of areas  in Region V  considered to have S02  air quality  worse
than the primary standards has been  reduced  from 44  in 1978 to 10  in 1982 (see
Figure A -4).

Eight of  the  nonattainment  areas  do  not  have  fully approved   regulations
design signed  to  provide timely  attainment  of the  standards.  Currently  2.2
million people  are  exposed  to SO?  levels   in  excess of  the primary  ambient
standard.
NITROGEN OXIDES (NOx)

The standard for nitrogen  dioxide  is  exceeded (as  of the end of 1981) only  in
the Chicago  area  (see Figure. A-5).  The  population exposed in  this area  is
approximately 500,000  (including  the  working  and   residential   population).

Controls on  mobile  sources  continue to be  the most  effective nitrogen  oxides
control strategy used in  Region V although emissions from the stationary sources
contribute significantly  to the  air quality problem.  The  implementation  plan
for the Chicago problem area has  been  approved.

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                                    - 4 -

LEAD (Pb)

Since 1973, there has been an overall  improvement  in  ambient  lead  concentration
in the Region.  Several areas that  were in violation of the lead standard are
now showing compliance with  the standard.   The  major  reason  for the  reduced
level of lead is the implementation of  FMVCP, and the phase down  of the use  of
lead in gasoline.  Monitors  near  lead smelters in St.  Paul,  Minnesota  and  Granite
City, Illinois continue to show violations  of  the  lead  standard (see Figure
A-6).  Monitoring sites  in  Hammond  and  East  Chicago, Indiana  have recently
shown increases  in   lead   concentrations,  which  are   of   potential  concern.

Michigan and  Ohio have approved SIPs  for lead;  Illinois  has  an approved SIP
for all  areas  except Granite City;  and Indiana,  Minnesota, and  Wisconsin are
currently preparing  lead  SIPs.
RADIATION

Region V has  21  nuclear  power sites  with  36  reactors  (20  operating and  16
under construction). This  represents  28% of the  world's  nuclear power  gener-
ation capacity and  50%  of  the national  total. These  21  sites  impact  approxi-
mately 590,000 people in the 10 mile emergency  planning zone.

A Radioligical  Emergency  Response  Plan  (RERP)  is  required  for  every  county
located in the 10  mile  zone.  There  are 37 counties in the  Region that  require
RERPs. Four of these  plans  have  been aapproved,  to date, by  the Federal  Emer-
gency Management  Agency and  have  been  published in  the  Federal   Register.
Seven plans, approved Regionally,  require national approval. Twenty-six  plans
are currently being reviewed  in  the Region  (Figure A-7). Each State  has  also
submitted a RERP. The Illinois plan has  been approved  nationally and  the  other
five Regional state's RERPs  are  currently under Regional  review.

Industrial  radiation  sites,  abandoned  and  operating,  are  of  concern to  the
Region. Foremost among these is the Kerr-McGee site in  West Chicago,  Illinois.
The Region is exploring legal  action under CERCLA  to  clean up extensive thorium
contamination throughout the  residential  community.  Other  sites involve  aban-
doned thorium mantle  and  radium  companies that operated prior  to enactment  of
the Atomic  Energy   Act,  and  unregulated  industries  that  utilize   radioactive
materials incidentally as part of their  raw  materials.  These  sites  are identi-
fied in  Attachment A.   Site  specific  discussions are  also  in Attachment  A.
AIR TOXICS

Considerable concern exists  in  the  Region about the   potential  health  effects
of air  toxicants.  This  concern comes  from the  substantial  concentration  of
industrial facilities and hazardous waste  incinerators  (see  Figure  A-8) in the
Region with  the  potential  for  air  toxicant emissions  and  their proximity  to
population centers.  A  well  developed system  for regulation and  compliance  is
      in NESHAPS. Delegation of NESHAPS is also well  advanced.

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                                     - 5 -

There is a significant  lack  of monitoring data and  rules  for  other pollutants
to guide priorities for  data  acquisition  and control. However, authority  does
exist in the States to  regulate non-NESHAPS pollutants and  additional  NESHAPS
regulations are expected, with  subsequent delegation. Thus, Regional  emphasis
has been on cooperative  efforts  with  the  States to assist them in  the problem
definition and  the subsequent development  of air toxicant  programs.

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                                   -6-
                Figure A-l:  Region V Air Quality Status for Ozone
   Problem Area
   Note:  Current as of 2/l/%i
Note: See Attachment A for identification of these areas

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                                    -7-
      Figure A-2:  Region V Air Quality Status for Total Suspended Participates
Primary Problem Area
Secondary Prob1en Area
»!ote:  Current as of 2/1/83
Note: See Attachment A for identification of these areas

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                                    -8-
          Figure  A-3:   Region  V  Air  Quality  Status for Carbon Monoxide
  Problem Area

  Note:  Current as of
         2/1/83
Note: See Attachment A for identification of these areas

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                                  -9-
         Figure A-4:  Region V Air  Quality Status  for Sulfur Dioxide
                                       S   A£-r'>rs
  Prinary Problem Area
  Secondary Problem Area
  Note:  Current as of 2/1/83
Note:  See Attachment A for  identification of these areas

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                                    -10-

           Figure A-5:   Region V Air Quality Status for Nitrcren Oxides
        Problem Area

        Note:  Current  as  of
              2/1/83
Note: See Attachment A for identification of these areas

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                                    -11-
               Figure A-6:   Region  V  Air  Quality Status for Lead
Problem Area
Note:  Current as of 2/1/83
 Note: See Attachment A for identification of these areas

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                                       -12-
                           Figure A-7:  Region V Status of Radiation
                                        Emergency Response Plans
D
Radiological Emergency
  Response Plans not annroved
  by the Regional Assistance
  Committee as of 2/1/83
   •  Operating Plants  (20*)
        * One unit currently  shut down

   C  Plants Under Construction  (16)
      Note:   Half of the nuclear sites have more
             than one nuclear plant on site.

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  h'gure A-8
                                           -13-
                       Region V Hazardous Waste Incinerators
)te:
O Existing Incinerate

• New Incinerator

Q Incinerator Status
     Unknov
  Listing based on
  applications received.
  Further review may reveal
  that some of the listed
  Incinerators are not subject
  Resource Conservations and
  Recovery Act regulations.

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                                     - 14 -

                      REGION V ENVIRONMENTAL MANAGEMENT REPORT

                                   PART 1




                                    LAND
Hazardous waste program activities under  RCRA,  CERCLA,  TSCA and FIFRA  as  well
as the spill response  program  are  addressed in this part  of the  report.  These
activities deal with the management of hazardous waste generators  and transport-
ers, active and  inactive  hazardous  waste sites,  hazardous  substance  spills,
toxic chemicals and pesticides.
HAZARDOUS WASTE MANAGEMENT

Region V has  been  establishing and  refining  the database associated  with  the
universe subject to  regulation.  Notifications filed as  of February  28,  1983,
by type of activity, are:

   NOTIFICATIONS           TYPE                             TOTAL
     RECEIVED      GENERATOR  TRANSPORTER  TSD	ACTIVITIES

     17,921         11,424      2,942      4,681            19,047

Part A applications received, by process category are:

   REGULATED*  STORAGE  DISPOSAL  TREATMENT  STOR. STOR.   DISP. STOR.
    PART As      ONLY     ONLY      ONLY     DISP. TRTM.   TRTM. DISP.
   	TRTM.

      2,305     1,224      52        133      30     775     19    72

   *Approximately 20% of the national total.

Called in Part 8 applications as of February  10,  1983,  hy process category are:

   STORAGE    TREATMENT   INCINERATION   LAND DISPOSAL        TOTAL
     ONLY     (W orW/out
   	Storage)	

     83          108           22             18                231  CALLED
     36           54            4              2                 96  RECEIVED

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                                     - 15 -
Compliance/enforcement efforts and activities for FY 81 and  FY  82  are  compared
as follows:

   INSPECTIONS   WARNING   COMPLIANCE           PENALTIES            DOJ
	LETTERS'     ORDERS	ASSESSED   COLLECTED     REFERRALS

'81   1,201       110          86          $227.5K      $5K           0
'82   1,379*      721          31          $ 57K        $28K           5

           *Total  does not include inspections  conducted  by Illinois,
            Indiana and Wisconsin after they received Phase I Interim
            Authorization(IL-5/17/327nT-8/18/82;WI-l/15/82)


REMEDIAL PROGRAM(SIJPERFUNn)
Region V has over 2,700 abandoned hazardous waste sites  that are known  to exist
or have been reported.  Theses sites require a preliminary assessment  to confirm
their existence.  Some  of  these  sites may  not contain  hazadous  waste  or  may
pose no threat  to  people  or  the environment.  Sites that are judged to  pose  a
threat are  investigated,  sampled and a  numerical  score, called  the hazardous
ranking score(HRS), is  assigned.

Sites with the highest  MRS values were aggregated nationally and  a National  Pri-
ority List  (NPL)  of  the "worst" sites  was developed.  The initial NPL had  418
sites listed, 99  of  them(24%  of  the  NPL)  in Region V. Listing  on the  NPL  made
these sites  elgible  for remedial  action  under Supprfund.  Information  on  the
Regional sites  is detailed in Attachment A  of  this  report.  It is  summarized as
follows:

   ** Approximately  7,618,500 people  are  threatened by hazardous waste  at  the
      Region V NPL sites.

   ** There  are 104  threats  to  aquifers   by  hazardous  waste at  the  Regional
      sites.

   ** There are 66 threats to surface waters by hazardous waste  at the  Region  V
      sites.


TOXIC SUBSTANCES'

There are 1,506 chemical  manufacturers  in  Region  V (about 20%  of the  national
total). There are  11,262 chemicals manufactured in  the  Region,  5,892  exclusively
in Region V.

Polychlorinated biphenyls(PCBs)   seem to  he the most prevalent  toxic substance
in the  Region.  Numerous  manufacturing  facilities, public  utilities,   storage
warehouses, airports,  refineries,  tool   and die  companies,  etc.  use  or  have
used PCBs in one  form  or  another.  Transformers and capacitors  containing  PCBs
are present throughout  the urban and  rural  environment  of the  Region.

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                                     - 16  -


PCB inspections have revealed a  significant  number of storage, record  keeping
and marking  violations,  flue to  a  lack of  awareness of  the PCS  regulations.
PCBs are  being stored  because  of  the current  high cost  of disposal. There
is only one permitted landfill  in Region V.

The Region receives a significant number of  inquiries about  products  containing
formaldehyde, such  as   urea-formaldehyde  foam  insulation,  plywood, particle
hoard and other home furnishings. Only insulation,  of the  formaldehyde products
on the market, is  regulated. Little  is known about  the  extent  or severity  of
indoor air pollution from these  and  other  toxic  substances.


PESTICIDES

Approximately 900  million pounds  of  pesticides  are  annually used in the  U.S.
About 20 percent  of this, or 180 million pounds  are used  in  Region V. There are
2,746 pesticide  producing  entities  in  the  Region(26% of  national producers).
These facilities   produce about  280  million pounds  of  pesticides  annually.
All Regional   states have  significant  pesticide  regulations. The Region  has
cooperative  enforcement  agreements  with all  States  except Ohio.  Applicator
certification programs have been delegated to all  States.

Incident data  shows  that aerial application results  in  the highest  number  of
violations when  compared to  the total  incidents/complaints investigated.  An
average of 42 percent of the incidents  investigated  were  violations. Agricult-
ural incidents/complaints,  other than  aerial   application,  have  a  violation
rate of 30 percent.  Violations  occur  25 percent  of the time when  non-agricult-
ural incidents are investigated.

Aldicarb, a  highly toxic,  systemic  carbamate  insecticide, has  been  used  in
Wisconsin and has  been  detected in the  groundwater at concentrations  ranging
from less  than 10  parts per  billion  to  as high  as 111  parts   per billion.
Most samples contained from 11  to 30 parts per  billion of  aldicarb. The  thresh-
hold action  level  is 10 parts  per  billion.  This problem is  discussed  further
in Part 2 of this report.

The use  of  pesticides  by the consumer  in his  home environment is of concern.
1980 census  data  indicated  that  almost  70 percent  of the  Region's   people
lived in urban or non-farm areas. Data indicates that almost 90 percent of these
residents use pesticides in  their homes, gardens and yards. Data supports that a
majority of  human poisoning incidents  reported  occur  in  these  urban settings.
SPILL RESPONSE

The Spill Response  Program  (Regional  and State) has seen a steady  increase  in
the number of spill reports over the past 5 years.  An increase of approximately
60 percent occurred from  1978 to 1981. The general trend shows  an  increase  on
spills at fixed  facilities  and  a decrease  in  spills related to transportation.

The most  frequently spilled  products,  in  addition to  oil  and petroleum  by-
products, are PCBs, ammonia(fertilizer and  anhydrous), acids(sulfuric and hydro-
chloric), solvents,  sodium hydroxide,  chloride and  phenol.  The  accompanying
figures summarize the spill reporting information.

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                                     -  17  -



                                   Figure  S-l

                         Spill  Reports   -  1978  -  1981
1978

1979

1980

1981
        1000     2000     3000      4000     5000     6000     7000     8000
                           Nunber  of Spill Reports
                           (Base Year  1978 = 6000 Reports)
                                   Figure S-2


                            Spills Reports by Type

                                   F
1978
1979
                                                        F = Facility Related
                                                        T = Transportation
1980            T                                             Related
1981
        TO   20   30   TO    50    60    70   80   90
                   Percent  of Total  Reports

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                                     -  18  -


                    REGION V ENVIRONMENTAL MANAGEMENT  REPORT


                                     PART  1


                                     WATER
In the early 1960's the Cuyahoga River  in Ohio caught fire.  Thick oil  slicks
covered the Calumet River  in Indiana, the Rouge  River  in Michigan, and  other
rivers of  the  Region.   Little, if  any,  significant  aquatic  life existed  and
water uses such as  swimming,  boating,  fishing, water supply, etc.,  were  nonexis-
tent or restricted in  segments  of  the Fox (WI),  Wabash (IN), Kalamazoo  (MI),
Scioto (OH), Black  (OH),  Ottawa  (OH),  Grand  (MI),  Mahoning  (OH),  and  other
rivers.  Today, swimming areas have been  reopened, water  supplies improved  and
fish and  people  have   returned  to  previously degraded  waters as  a .result  of
the measurable water quality improvement  from the extensive cleanup efforts  by
municipalities and industries.
MATER QUALITY OF RIVERS AND STREAMS
                                                        #>
While measurable  progress  has  o'ccurred,  considerable  water use  and quality
impairments justify additional  control.   Monitoring data  based upon  chemical
parameters from 58 major  rivers  were analyzed for  calendar year 1981 using  a
Water Quality Index (WQI).

Based upon the WQI evaluation, only  24  percent  of the  rivers analyzed were of
good water quality  (WQI 0-20),  meeting  fishable/swimmable  Federal   criteria.
Forty-five percent of  the major  rivers  in Region  V  had  a  WQI scale between
20-60, meaning they had moderate  water  quality  problems but usually  met  fish-
able/swimmable Federal  criteria.  Severe  (WQI  of more  than 60) water quality
problems were found in 31  percent  of  the rivers.   Figures  W-l to W-4  illustrate
regional stream  water  quality  for   four  parameters:    bacteria,   nutrients,
dissolved oxygen, and  ammonia.  Detailed  state  maps and  a description of the
WQI are  found  in Attachment  A.   Specific status and trends are described by
the following selected water quality  indicators:

  Bacteria (Coliforms)

  Severe bacterial problems  were  found  in  25  percent  of  the  major   rivers in
  Region V in  1981.   Forty-eight  percent  had moderate  problems.   Improvements
  from previous years,  however, were found in the Mississippi River  in Minnesota
  and the Illinois and Kaskaskia  Rivers  in Illinois.

  Nutrients
  Severe nutrient problems were  observed  in  21  percent of the major  rivers  in
  Region V  in 1981.   Moderate  nutrient  problems were  found in  46  percent.
  Improvements were observed  in  the  Kaskaskia  River in Illinois and  the  Grand
  and Kalamazoo Rivers in Michigan.

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                                   -20-
                          Figure  W-l,  Bacteria
Barer Quality

Very Good W.Q.
Meets Stds.
Satisfactory
W.Q.
Usually meets
Stds.	
Poor W.Q.
Often violates
Stds.	
SOURCE:  STORE! data analyzed by the Water Quality Sub-Index
         for Bacteria, 1981

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                                  -21-
                                                           L2GZND
                          Figure H-2, Nutrients
Water Quality

Very Good W.Q.
Meets Stds.
Satisfactory
W.Q.
Usually meets
Stds.	
FOOT W.Q.
Often violates
Stds.	
SOURCE:  STORE! data analyzed by the Water Quality Sub-Index
         for Nutrients, 1981

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                                   -22-
                                                           LZGZSD
                           Figure  H-3,  Ammonia
Uater Quality

V«ry Good W.Q.
Meet* Stds.
Satisfactory
W.Q.
Usually meets
Std».	
Poor V.Q.
Often violates
Stdi.	
SOURCE:  STORE! data analyzed by the Water Quality Sub-Index
         for Ammonia, 1981

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                                 -23-
                                                           LIGZND
                         Figure W-4, Dissolved
                                        Oxygen
Utter Quality

Very Good V.Q.
Meets Stds.
Satisfactory
W.Q.
Usually Beets
Stds.	
Poor W.Q.
Often violates
Stds.	
SOURCE:  STORE! data analyzed by the Water Quality Sub-Index
         for Dissolved Oxygen, 1981

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                                     - 24 -
Existing information and the  source of that  information  is  depicted on maps.
Specific biological  information exists  for  less  than  20  percent  of the Region's
river miles.  Of these approximately 10 percent have significant water quality
problems and  approximately  30  percent  have moderate water  quality problems.

Fish flesh  contamination  and fish  kills  continue to  be a  problem but there
currently are  insuffient  data  to  make  a  meaningful   trend  analysis.   The
latest 305(b) reports do indicate areas within each  State where health adviso-
ries are  issued  in  conjunction   with suspected  fish  flesh  contamination.

Most of the major documented fish  kills can be traced to a toxic spill.  There
were over 800,000 fish killed  in 1980 and 1981 in Region  V.   Pesticide leakage
from agricultural operations  and   chemical  spills  from industrial   operations
account for a majority  of the fish  kills.


OHIO AND MISSISSIPPI RIVERS

Two major rivers flow through the Region.  The Ohio  River Basin drains 203,000
square miles  of  land,  approximately  30 percent of it in  Region V.   The Upper
Mississippi  River Basin drains  189,000  square  miles  of  land, approximately 69
percent of it in Region V.
  N.

  Ohio River

  Water pollution in the Ohio  River was most  seriously degraded  in the upper
  one-third (approximately  300  miles)  of the  river.   Significant improvements
  in water  quality  were  made  throughout  the  river between 1950  and  1980.
  Since 1960  the  most  dramatic improvements have  been  made  in the upper 100
  miles of the  river while water quality  in the lower two-thirds  of the river
  where degradation  was much  less severe has either remained  stable  or improved
  only slightly.  In view of  the increased population of the  basin during these
  two decades, such  a  stabilization  is  encouraging.

  Upper Mississippi  River (UMR)

  Water quality   problems  occur in  several  locations  on the UMR.   The  most
  serious problems  are  between  Minneapolis  and Lock  and Dam 2,  downstream of
  Lock and Dam 13 and below the  metropolitan area of East St.  Louis - St. Louis.
  These areas have  problems with  toxic metals,  turbidity   and  low dissolved
  oxygen.  Unacceptable PCB  levels  have been  found  in  the  UMR  from the Twin
  Cities to  St.  Louis. PCB  levels  in  fish  in Lake Pepin   and Lake Onalaska
  (above La  Crosse,  Wisconsin)  have exceeded the FDA  standard by more than ten
  times.  The largest  point  source  dischrges  are  the  wastewater treatment
  facilities in  the Twin  Cities and St. Louis areas,  power plants along the
  River and  large steel, oil  and  chemical  facilities in  the East St.  Louis -
  St. Louis   area.   However,  point  sources   of  discharge are  not  the dominant
  factor influencing the overall water  quality  in  the  UMR,  although localized
  problems do occur. In general, nonpoint pollution  is the  most serious problem.

  Significant water  pollution problems  attributed to  nonpoint pollution in the
  UMR are excessive  loadings  of  suspended solids and  sediment.  Sediment yields
  range from 10  to 500 tons/sq mile/yr in the northern portion  to yields exceed-
  ing 6000 tons/sq mile/yr  (0.66 inches/year)  in the  south.

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                                     - 25 -

FACTORS IMPACTING WATER QUALITY

Two factors which impact water quality, not addressed in the previous  paragraphs
are comhirred sewer overflows (CSOs)  and NPDES compliance/noncompliance.  The CSO
issue is site  specific  and  addressed differently  by each state. A 1982  survey
indicated that there were 513 combined  sewer systems  in  the Region.  These  have
the potential,  during  storm  events,  of  causing   immediate  contamination  to
receiving streams. CSOs are addressed  further in Part  2  and in  the Great Lakes
portion of this report.

Non-compliance with NPDES permit  limits  occurs  at approximately 20  percent  of
the permitted  facilities.  Non-compliance  events  result  in the  discharge  of
oxygen depleting  materials, toxic or  toxicity  causing  compounds  and  solids.
Significant progress has been made in  increasing compliance  rates, however,  we
must continue to  strive  to  reach  the  statutory  goals of the Clean  Water  Act.

INLAND LAKES AND WETLANDS

Inland lakes provide recreation and  drinking water  for many Region  V  communi-
ties.  In the  northern  States,  lakes  are  often  the significant factor  in  the
economic base  of  small  communities.   Generally,  lakes located  in the  southern
portions of Michigan, Minnesota and  Wisconsin are experiencing  cultural  eutro-
phication.

The status  of  wetland  resources  in  Region  V is  somewhat uncertain. There  has
been a systematic effort, over the last century to convert wetlands to drylands.
Both Federal and  State programs  are underway to  inventory remaining  wetland
resources.  The National Wetland  Inventory  has, to  date,  produced wetland  maps
for two-thirds  of  the  State of Ohio,  three-fourths of the State of Michigan,
and portions of  the States  of Minnesota  and Indiana.  The State of Wisconsin
is conducting  its  own  wetland mapping  program,  and the  State  of  Illinois  is
considering a similar effort.  Due to  a lack of detailed historic data, these
inventories will  serve  primarily  to  identify existing resource levels  and  aid
in determining future trends.

Current estimates indicate that about 90  percent of the original  wetland  acreage
of southeastern Wisconsin have been  converted to  agricultural  and urban use  in
the past  century.   This figure  approaches  100  percent  in some  counties  in
south central Minnesota, and the  once  vast  wetland  complexes along the  western
shore of Lake Erie in Michigan and Ohio and along  the Kankakee  River  in  Indiana
have all but disappeared.

Several States are  currently taking  steps  to protect  their  remaining wetlands.
The State of Michigan has enacted a  comprehensive Wetlands  Protection  Act  that
is designed  to prevent  the indiscriminate  conversion  of  wetlands to other
uses, and the  State  of  Minnesota  has provided tax  incentives to encourage  the
preservation of wetland  resources.   In addition,  the Wisconsin, Illinois,  and
Indiana legislatures are all  exploring  means to  protect and preserve  wetland
resources.

GROUNDWATER

Region V has abundant  supplies  of good quality groundwater.  Approximately  40
percent of the population within Region  V  depends upon groundwater as a  source

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                                     - 26 -

of drinking water.   In  rural  areas  in  particular,  95  percent  of the population
depends upon  groundwater.   Most  of  the  groundwater  used  is  withdrawn  from
shallow aquifers.  These shallow aquifers  are  susceptible  to  the  contamination
resulting from activities  in  manufacturing, agriculture,  and energy  recovery
practices that are prevalent within  Region V.

Although some data are available,  it is difficult to assess the  specific trends
of groundwater quality  because historic  information on  contamination  sites and
ambient groundwater  quality  is still  insufficient to  make  an  analysis.   The
States in Region  V have monitoring systems for  public drinking water  wells.
However, a  baseline  assessment of  current groundwater quality conditions  is
not possible  based on public  drinking  water  well  data  because information  is
geographically disjunct  and  does not   generally  include  grace quantities  of
synthetic chemicals.  An  example  of  other types  of  information  available  is
the assessment of  groundwater problems  completed  by  the State  of  Michigan.
Sites were  identified  from complaints  made by  local  citizens  and  officials.
Of the  50,897 sites  inventoried,  441  are considered  as  known  contamination
sites.  Only  for  the  known  sites  is  complete  water  quality  data  available.

Another example of  systematic  data  collected  related  to groundwater quality  is
the ambient groundwater quality  monitoring program of  the Minnesota  Pollution
Control Agency which  was  initated  in  1978.   The  program  currently has  data
from 318 wells or  springs  and  includes  samples  from 56  of Minnesota's 87 coun-
ties.  In addition to the  various types  of  information  the States have,  Region
V has  aquifer maps  of  each State which  were recently prepared  to assist us  in
implementing the underground injection control  program.

A concern is  the  number  of  sources   of groundwater  contamination  which  are
unregulated or poorly  regulated  and  which continue  to threaten  irreversible
damage to the quality of groundwater.

The magnitude of  contamination problems is represented by the following  data
extracted from a recent  study  by the  State of Michigan  on known and  suspected
contamination sources.  The  State's study, updated in  1982,  listed:   a)  112
known and 27  suspected  incidents  related to storage and handling of  petroleum
products; b)  59  known  and  2   suspected  incidents  related  to unknown  sources
appearing to be gasoline contamination;  c)  33  known and 86 suspected incidents
related to  salt  storage/roadsalting; and,  d) 8  known  and 8 suspected incidents
related to agricultural sources.   Aside  from the lack of regulatory  control  of
groundwater problems, there is  a  lack of  systematic documentation of  groundwater
quality, groundwater  use  and  groundwater  contamination  incidents  which  are
needed if effective groundwater management is  to occur.

DRINKING WATER
There are 8,300  community  water systems serving a population  of  approxiamtely
38,000,000 in  Region  V.  There  are  approximately  64,000  noncommunity  water
systems in the Region.

All states  have  historically   conducted  strong  drinking  water  surveillance
programs, but these  programs  involved  mobile  home parks  only marginally  and
did not address  noncommunity water supplies.  Thus,  the most significant  improve-
ments in terns  of compliance  with  monitoring  requirements and drinking  water
quality standards have come in those areas.

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                                     - 27  -
In FY 79,  42.1  percent  of  Region V  community  water systems had  one or  more
violations of microbiological monitoring and  reporting  requirements. This  was
reduced to 35.3 percent  in  FY 80 and 23.1  percent  in FY 81. Region  V  systems
with microbiological  MCL  violations  decreased  from 8.9 percent  in  FY 79  to  6
percent in FY 80 and  81. "

The monitoring for ten inorganic, six organic,  and radiochemical  parameters has
detected ahout 100 violations of the inorganic  drinking water MCLs  and  about
265 occurrances of  high  alpha  radiation  activity.  The  necessary  follow-up
isotope analyses are  now  being performed (during  FY  1983) and the  confirmation
rate for natural radium MCLs is expected to be  high.

Total trihalomethane   (TTHM)  concentrations were  determined  for  all  Region  V
water systems over 75,000 population during 1981  and  1982.   These analyses are
now also  proceeding  on  all  systems  over  10,000  population.   Water  supplies
relying on naturally colored, inland  streams as a  raw water  source are experi-
encing some difficulty meeting the the 100  micrograms  per liter  (ug/1) TTHM MCL
under current treatment  and  disinfection practice.   Some of these  systems are
changing to combine  chlorination  or chlorine dioxide to  come  below the 100 ug/1
TTHM level.

Pilot studies indicate that  2Q%  of Regional  well  waters are contaminated  with
synthetic organic  chemicals.  Volatile  solvents and degreasers have  been  found
throughout the Region,  usually  in  low  part  per billion (ppb)  concentrations,
but sometimes -high  enough  (e.g.,  greater  than  50 ppb) to  cause  significant
health hazards.  Every  State has  had  to  close down  major  public water  wells
because of this problem.  The new  generations of  pesticides  and  herbicides are
also emerging in Regional drinking waters  -- from  both ground and surface water
sources.  Aldicarb commonly migrates to  well  waters  where it 'is applied  on
sandy soils,   and  atrazine,  metalachlor, et-al.,  are found  in  drinking  water
obtained from agricultural rivers.  These chemicals are  not  currently regulated
in drinking water.

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                                     - 28 -

                    REGION V ENVIRONMENTAL MANAGEMENT REPORT


                                     PART 1



                                  GREAT LAKES
The Great Lakes  are  a  complex ecosystem of  interacting  components—air,  land,
water and living organisms.  Because the Lakes  act  in many respects  as  a  closed
system—less than 1%  of the pollutants  entering the Great Lakes system  leave
the St.  Lawrence  River in  any  single year—they  are  an especially  sensitive
indicator of the  effectiveness  of  air,  land and water protection programs,  as
the accumulated pollutants often show their first  effects (particularly chronic
effects) in this vast interconnected lake system.   Furthermore,  since  the Great
Lakes Basin includes more than 40%  of the  population, land  areas and  rivers  in
Region V, the responses of the Lakes are a significant  indicator of  the success
of regional remedial.programs.

General Overview

Both human health and ecosystem  health problems are well  documented  in  the Great
Lakes.  They are reflected in the impairment (non-attainment)  of numerous  bene-
ficial uses caused mostly by two categories of pollutants:  toxics and nutrients.
Fish consumption advisories  are  in  effect  in  each of the Lakes because  of  health
risks, and the ecosystem is under stress and degradation  due to  both toxics  and
excessive nutrients.

The rate of decline in trophic conditions of the Lakes  appears to have  signifi-
cantly Decreased  in  response to  nutrient  control  programs,  and considerable
improvement has been made in the case of  most locally acute eutrophication  prob-
lems.  The status of toxics  in  the Lakes  varies considerably from  compound  to
compound due to  their  different  behavioral  characteristics, whether  effective
control programs are  in place, and because  of our rapidly  changing technological
ability to identify and measure  these materials.  The Great Lakes are  signifi-
cantly affected  by toxics  inputs  from  the  atmosphere, tributaries,  municipal
and industrial  discharges,  and large deposits of in-place pollutants in harbor/
estuary areas.   The  status  of the sources and.sinks of these toxics  is  not well
known.

Within the lake  system there are  concentrated  areas of  pollutant  loading  and
degradation which have  been  identified by EPA and the International  Joint Commi-
sion (IOC) as key Areas of Concern that  require special attention.

Toxic Contaminants

Contamination of the Great Lakes  by  persistent toxic substances  represents  the
most serious environmental  problem in the  Basin.   Since  the Great Lakes  are  an
essentially closed system,  they  accumulate whatever'persistent toxic substances
input tr> them.   The  problem is basinwide,  not only  confined to  "hot spots,"  as

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                                     - 29 -

IJC and  USEPA  inventories  of  all  ecosystem  compartments  showed  ubiquitous
contamination.  Declines in the  concentration  of  some  toxic chemicals  in  the
annual sediment deposits and  biota  have  been  observed  in  most lakes,  due  to
control programs.   However, the  overall  trend  of  all  toxics generally  varies
considerably, depending on  control  programs in  place,  the behavioral  character-
istics of any given compound,  and our rapidly changing technological  ability  to
identify and measure these  materials.

The Great Lakes are a multiple use  resource for the residents of the  Basin,  and
the surrounding population  may  be  exposed to  toxic  substances  from the  Lakes
through a variety of  pathways.   Until  recently no major human  health  implica-
tions were directly related to the  toxic water quality of the Great  Lakes.   How-
ever, a direct linear  correlation between PCS  contamination in Lake Michigan fish
and levels of RGB's in the blood of  sport fishing families  in the 18  Michigan
State counties bordering Lake  Michigan has been indicated.

Sources of these toxic residues are the atmosphere, tributaries,  municipal  dis-
charges, industrial  discharges and  erosion.   Sinks include  tributary  outflow,
sedimentation, degradation,  water-air exchange, chemical  inactivation and media
transfer.  The  status  of the  sources  is  not well  known, and trends  among  the
various sink compartments may  differ.

Nutrient Enrichment

Major ion concentrations in Lake  Superior and northern Lake  Huron have remained
essentially stable, indicating few open lake nutrient enrichment  problems  in  the
upper lakes, but the studies  on which these reports were based were necessarily
short term; and there  is a  need  for longer term information.   In the  most  se-
verely poluted  lakes  -  Erie,  Ontario and Michigan - major  eutrophication  ills
still exist,  but  progress  is  being  made.   A significant decline  in  municipal
and industrial  phosphorus  loadings  has  occurred  since  the mid-1970's.   Open
water responses, such as decreased phosphorus  concentration,  decreased  biomass
or algal species  shifts  are documented  in Lake Ontario,  Lake Erie  and  in parts
of Lake Michigan  and  Lake  Huron  (Saginaw  Bay).   Improvements have been  noted
in water quality  problems at  several drinking  water intakes, and  recreational
uses  (swimming,  boating and  fishing)  have  been  restored  in  numerals  areas
throughout the Basin.  However,  the  total  commercial  catch  of fish  in each  of
the Great  Lakes  continues  to  decrease steadily,  as  it  has for  the  past  30
years, even though State stocking  of salmonids has helped  sport fishing  stage
a comeback.

When municipal point source control programs  are completely  in place,  municipal
inputs will contribute only 20-25% of the  phosphorus load to the Lake Erie Basin,
while nonpoint sources,  primarily from  agricultural land  in  the western basin of
Lake Erie, will  account  for more  than 60%  of the phosphorus input (roughly 7% of
the phosphorus is airborne).   Successful  demonstration programs  at  Black  Creek,
Indiana, and Honey Creek, Ohio, have been  undertaken to  develop  cost-effective
soil conservation and  land runoff  control measures.   These  projects  have  been
expanded into 31 counties of the Lake Erie Basin in order to  reduce  the  nonpoint
loading nf phosphorus and other pollutants to the lake.

Localized Impaired Areas (Areas of  Concern)

Within the  lake  system  there  are  certain  localized  areas  where  environmental
quality is severely degraded.   Although these areas constitute only a  relatively

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     Figure  GL-1
IUMV
                                                  -30-
                    Summary of the trophic status of the Laurentian Great Lakes.
                    (EF*,GLNPO,1981)
Highly 01 igotroohic
Oligolrophic
Mnotraphic
Eutraphc
Special pobtetn area
                                                     Figure GL-2
                                                     AREAS OF CONCERN

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                                     - 31 -

small portion of the  total  area  of the basin, they contain a large percentage of
the Basin's population and  industry and are concentrated loading points for many
pollutants.

The IJC has  identified 39  of  these  areas  throughout the  Great Lakes  Basin.
Fourteen of these Areas of Concern  in  the U.S.  are classified  as Class A (areas
exhibiting significant environmental  degradation and where  impairment  of bene-
ficial uses is  severe), and an  additional ten  U.S. Areas  of Concern  are desig-
nated Class B (areas  exhibiting  environmental  degradation and  where  uses may he
impaired).  Municipal and  industrial wastewater  treatment facilities presently
in operation or  coming  on  line  in  the  next five years should  effectively con-
trol  conventional pollutants,  metals and  substances causing toxicity  (i.e. ammo-
nia).  Sources  of  these substances,  in  addition  to  municipal  and  industrial
discharges, are  unsecured  waste disposal sites,  combined sewer overflows  and
urban land runoff,  agricultural  land  runoff,  and in-place pollutants.

In the areas of  concern, unlike most other portions  of the  Lakes,  swimming and
aesthetic uses are often impaired.   These impairments affect millions of people
and are the result  of bacteria,  virus and anoxic conditions caused,  for the most
part, by overflows  from combined sewer systems,  which  are  not addressed by exis-
ting programs.  Resolution  of  all  identified  problems and  restoration  of  all
uses will  not  be accomplished  in  any  of the U.S.  Class  A Areas of  Concern in
the near term.   Continued long term operation  of  existing programs  is expected
to result in attainment of uses  is  four areas.   Loading reductions  and eventual
partial attainment  is  expected  in  all  areas.   But, in eleven  areas,  continua-
tion of existing programs  will  not  be adequate to ensure full  use  attainment.

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                                      -  32  -

                     REGION  ENVIRONMENTAL MANAGEMENT REPORT


                                     PART 2


                                      AIR
 Air quality  problems  are clustered into three priority categories (1, 2 and 3)
 using population  exposed and  air  quality  levels and trends as  ranking criteria.
 A detailed  identification of the counties involved are contained  in Attachment
 A.   The following are the  most  significant  air quality  problems  in  Region V:


 Priority  1                   Priority  2                         Priority 3

 °03 nonattainment           "03 nonattainment  Counties  (106)   "TSP I S02 Secondary
   target  areas  (8)           "TSP  nonattainment Counties (51)    nonattainment areas
 "TSP nonattainment           °CO nonattainment  Counties  (12)   "RERP's needing Fed-
   target  areas  (7)           "S02  nonattainment Counties (18)    era! Approval (7)
 "CO maintenance areas  (7)    "Industrial Radiation Sites   (9)
 "S02 primary nonattainment
   areas (8)
 °NOX nonattainment
   areas (1)
 "Lead nonattainment
   areas (2)
 "Industrial  Radiation  Site
   (1),  RERP's needing  Re-
   gional  Approval  (2fi)
 "Acid Rain  - emerging
'°Air Toxics  - emerging



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                                      -  33  -

 riers  towards  improving air  quality  were identified  and appropriate remedial
 actions  developed  for these six areas.  Environmental management results plan-
 ning packages  will  be developed  at  a later  date  for the  remaining criteria
 pollutant  problem  areas.

 Six priority 1 target were selected as focal  points  for environmental  management
 results  efforts.   Specific barriers towards  improving air quality were identi-
 fied and appropriate remedial  actions  developed for these areas:

                     Ozone:  Chicago/NW  Indiana/SE Wisconsin
                            Detroit
                            Milwaukee

                       TSP:  Chicago/NW  Indiana
                            Detroit
                            Cleveland

 Specific barriers  and  actions  are  also  described for Air Toxics.
 OZONE

 Overview of  Environmental  Problem

 The most significant Regional ozone  problems  occur  in the Chicago/NW Indiana/
.SE Wisconsin,  Detroit  and  Milwaukee areas.  Extensions of the attainment dates
 for the ozone  standard  to  1987 have  been  requested for these areas.

 Exceedances  of the  ambient Ozone standard are attributable to Volatile Organic
 Compounds (VOC)  and Oxides of Nitrogen  (NOX).  The  major  VOC  emitters are  in-
 dustrial  processes  and motor  vehicles.   The major  NOX  sources  are combustion
 processes and  motor vehicles.

 A number of  VOC  emission control programs  have been  implemented, including con-
 trols  on evaporate  sources and mobile  source  emissions.  The two most  effective
 control programs have  been the implementation of RACT  and the FMVCP.   The FMVCP
 is expected  to reduce  total VOC  emissions  by  approximately 20 percent  in Region
 V.  The application of RACT  for industrial   sources  will  produce decreases in
 total  VOC emissions of  approximately  25  percent.

 The transport  of ozone  and its precursors  (VOC and NOX) is  a  major Regional con-
 cern.   The impact of transported ozone is particularly significant  in the South-
 ern Lake Michigan area  where  the urbanized areas of  Chicago/NW Indiana and Mil-
 waukee are in  close proximity.  Available data indicate that  precursor  emissions
 in the Chicago  area  may  lead to  high  ozone  concentrations in  excess  of  the
 Ozone  standard in Kenosha  and Racine Counties, Wisconsin.

 Principal Barriers  and  Actions

 The primary  difficulty  in  dealing with the ozone  nonattainment problem  in Region
 V is the disaggregated nature of the  VOC emission inventory.   While there  are
 numerous large sources of  VOC, a significant  portion of  the inventory is com-
 posed  of small  sources.   There are thousands  of  these  relatively  small   VOC
 sources that individually  are not  significant,  but which in the aggregate con-

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                                     - 34 -

tribute significantly to the ozone problem.  The very nature  of  the  ozone pro-
blem makes  management  efforts  to  attain  air  quality   standards  and  enforce
emission controls very complex.

Other barriers to reducing  the ozone problem involve inadequate and/or unapprov-
ed attainment strategies (SIPs);  uncertainity  about the  status of the statutory
requirement for Inspection  and Maintenance (I/M)  in the areas with extensions;
and, delay in development of final  RACT III Control Technique  Guidelines (CTGs)
by USEPA.

Barriers:

 1.  Illinois, Indiana,  Wisconsin  and  Michigan  submitted final  and  draft.1982
     Ozone SIPS  for  the NE  Illinois,  NW  Indiana, SE  Wisconsin, Detroit  and
     Milwaukee areas.   Due  to  several  major  noted  deficiencies,   including
     adequate modeling  demonstrations  deviations  in  the areas  of  stationary
     source emission control commitments; gasoline dispensing facilities  through
     put exemption;  transportation control measures and  emission  inventories,
     EPA is proposing disapproval   of  these SIPs.   It  is anticipated that  the
     States will  protect these disapprovals  resulting  in significant delay  in
     adoption by  the States of  needed  modifications to the SIPs.

 2.  The EPA approved the 1979 Ozone SIP for Northeastern Illinois, Northwestern
     Indiana, Detroit and'Milwaukee on the grounds that they  meet certain  I/M
     implementation  schedule dates.  The States  have  failed to  meet  these  key
     dates.  This delay  in  the implementation of  the I/M program  has hindered
     progress toward further ozone  reductions.

 3.  Delay in development  of final RACT III  control  techniques guidelines  by
     EPA is resulting in a  delay  by  Illinois,  Indiana,  Wisconsin  and Michigan
     to develop control  regulations  for  these  sources  and,  therefore,  in  a
     delay in implementation of the control by industry.

 4.  Reluctance of Illinois  and Indiana to accept responsibility for significant
     ozone exceedances in Southeastern Wisconsin (Kenosha and Racine  Counties)
     is delaying  development of control  strategies sufficient to  correct  this
     problem.  Ozone exceedances observed in Southeastern Wisconsin during 1979
     through 1981  were  as  high  or higher  than  those  observed in  Northeastern
     Illinois. Analysis of  Wisconsin  ozone  data and available  meteorological
     data indicate  that these high  exceedances are  due primarily  to VOC  and  NOx
     emissions in the Chicago/NW  Indiana urban area.  Illinois and Indiana  are
     not committed  to control VOC emissions to a  level sufficient to  attain  the
     ozone standard  in Racine and Kenosha Counties.   Illinois'  position  is that
     SE Wisconsin  is  outside its  air quality control  region.   Indiana  claims
     that EPA's  position is  based  on  limited  meteorological data.   Similarly,
     the Wisconsin   monitoring  data  used   in  the  1982  SIP  have  raised some
     questions over  the magnitude and extent of the ozone  problem caused by  the
     precursor emissions from the  Milwaukee  area.  Due  to  quality  assurance-
     questions, Wisconsin chose to  ignore high ozone concentrations observed  in
     Sheboygan County  which is typically downwind  from  Milwaukee on  high  ozone
     days.   Although EPA-approves  this  action  based on the quality  assurance
     questions, it  is not known whether or  not high concentrations  did actually
     occur here.   In  addition,  Wisconsin's monitoring  system suffers  from  a
     critical  coverage gap,  between fifteen and forty kilometers, downwind from

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                                     - 35 -
     the Milwaukee  urban  area where high  ozone  concentrations  may be expected
     based  on  observation  in other  urban areas.   It  is possible  that  ozone
     problems  will  persist in the  Sheboygan County  area due to  a  failure to
     consider  potentially  high ozone standard exceedances.

 5.   Rulemaking  in  Illinois  is  the  responsiblity  of the  Illinois Pollution
     Control Board  (IPCB).   The  IPCB is an  independent  body  subject to statu-
     tory procedures  established  by legislation. There  is  no effective mecha-
     nism for  requiring the  IPCB  to  complete  its  rulemaking procedures  in a
     timely manner.   As a  result  of  IPCB's  lengthy procedures,  Illinois  was
     unable to submit RACT II regulations or a  sufficient  commitment to adopt
     RACT III  measures  on schedule.  Therefore,  EPA  proposed to disapprove the
     1982 Ozone  SIP.  Additionally,  EPA  is concerned that the IPCB will  not be
     able to adopt  regulations governing  other  major sources of VOC emissions
     within the  required  time  periods.    All  efforts to date have  failed to
     convince  the IPCR  to  adopt required regulations  on time.

 6.   Michigan  has generally failed  to submit detailed compliance  schedules for
     sources subject  to  VOC  rules.   This lack  of   compliance  schedules  will
     interfere with  enforcement activities.

 7.   Wisconsin has  fully  approved RACT I  and II  and  has  indicated that it will
     adopt RACT  III  and -IV.  Wisconsin  needs to enforce interim RACT emission
     levels or a  slippage  of  final compliance dates  may  result and would inter-
     fere with "reasonable  further progress.

 8.   Inadequate  source  compliance data from Wisconsin does not provide informa-
     tion which  documents  or supports  the  compliance statements made  by the
     State or  Federal  compliance  reporting mechanism.   For  example,  recent
     lists prepared  by a  WDNR  of  all  major (greater than 100  tons per year)
     VOC emitters  subject  to the RACT  regulations  do  not  indicate  when the
     final  compliance plan was  received,  what  compliance  approach  the source
     chose, whether  the state accepted  or  rejected  those  plans, nor  does it
     indicate  the  subject  progress  lines  within the sources.   Also,  further
     improvements are delayed because the largest emitters  of  VOC are covered
     by extensions  or  their  final  compliance  data which   have  not arrived.

 9.   Wisconsin does  not have  a clear understanding of what EPA will  approve for
     variances from  RACT   requirements,  especially  in the area  of high solids
     and water based coatings,  an  area in  which technology improvements have
     not progressed  as rapidly  as  expected.   This  has  resulted  in  a level of
     uncertainty  and  delay in the development of an  overall control  strategy in
     the State.

10.   Fiscal conditions  are limiting both  the ability and willingness of indus-
     tries in  the area to  install  needed  VOC  emission controls.  In addition,
     reduced staffing and funding at  the  States of  Wisconsin and Michigan has
     limited their  ability to  inspect emission  sources and to  enforce State
     and local regulations.

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                                     - 36 -
State Actions:

 1.   Illinois,  Indiana, Wisconsin  and  Michigan should  submit  final  1982 SIPs
     that adequately address  IISEPA's  comments.

 2.   Illinois,  Indiana, Wisconsin and Michigan  should  submit  approvable  vehicle
     I/M components of'their  SIPs.

 3.   Illinois and  Indiana  should accept  responsibility  for significant  ozone
     exceedances  in Southeastern  (Kenosha and Racine  Counties)  Wisconsin and
     commit to  the  VOC control  level  needed  to  attain the  ozone standard  in
     Southeasten  Wisconsin.   It is likely that  Illinois  and  Indiana  will need
     to implement stage II  vapor recovery  in  order  to  achieve the  necessary VOC
     control.

 4.   Michigan,  Illinois and Indiana  should adopt and submit  draft  RACT  III and
     major non  CTG VOC control  regulations for  preliminary  EPA  review.

 5.   Illinois,  Indiana, Michigan and Wisconsin should  develop  a joint enforce-
     ment effort  with local  pollution control  agencies, and  EPA to address the
     large number of  sources of  VOC  in the problem area.   Enforcement agencies
     should meet  to allocate  enforcement  responsibility categories  contributing
     to the ozone problem.

 6.   Michigan should implement  a voluntary self-auditing program for  industries
     in Detroit,  or accept increased EPA  inspections  of industrial  sources  to
     supplement their inspection programs.

Federal Actions:

 1.   Review final 1982  SIP  submittals, and public  comments  on the  notices  of
     proposed rulemaking and prepare  as expeditiously  as practicable the  final
     technical  support  documents  and  final  rulemaking.   As deficiencies are
     noted, work  with  the  States to correct these deficiencies.

 2.   Review  ozone  monitoring  system for the  Milwaukee area  to   determine  if
     modifications are  necessary  to  eliminate the  previously noted   barrier
     concerning the monitoring   gap between Milwaukee and Sheboygan.  Develop  a
     mutually acceptable schedule  for  modification to the  monitoring  system.

 3.   If  the  vehicle  I/M  component  of the  Illinois,  Indiana, Wisconsin and
     Michigan SIPs are disapproved  and  determined to be a major SIP deficiency,
   •  work with  the States  to  expedite  implementation  of  the  I/M program.

 4.   Negotiate  with Michigan  to obtain  an  acceptable schedule for  submission  of
     the detailed RACT I Compliance schedule  containing increments  of progress.

 5.   Development  of final RACT III  CTGs  by USEPA:  See Part  C,  "Headquarters
     Actions."

 6.   If Illinois  and Indiana  fail  to  commit to the VOC control level  needed  to
     attain the  ozone  standard in  Southeastern Wisconsin  (Kenosha and  Racine
     Counties)  and this is determined  to  be  a  major SIP deficiency,  work with
     the States of Illinois,  Indiana, and  Wisconsin  to  resolve  interstate  ozone
     transport  issues.

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                                     - 37  -
 7.   Track Illinois anH Indiana's progress in adopting and submitting RACT  II,
     III, and major non-CTG  VOC  source regulations.   Encourage States to  submit
     draft regulations  for  preliminary review.   Itemize  and  not  deficiencies
     while regulations  are" in draft stage and bring them to the  State's  atten-
     tion.

 8.   Encourage a joint enforcement effort by the States,  local  pollution control
     agencies, and EPA to  address  the large number  of  sources  of  VOC   in  the
     problem area.  Enforcement  agencies  should  meet to  allocate  enforcement
     responsibility and  prioritize  resources to  cover the entire range  of  VOC
     source categories  contributing to the  ozone problem.

 9.   Encourage implementation of voluntary self-auditing  programs  for industries
     in Northwest  Indiana  and Detroit.  Alternatively, increase EPA  inspections
     of industrial sources  with  the cooperation  of the States  to  supplement  the
     States inspection  program.

10.   Encourage Wisconsin to enforce interim RACT  emission  levels and if  neces-
     sary work with the State to develop a priority enforcement  list by  facil-
     ity or source category.

11.   EPA  should send  Section 114 letters  seeking specific information  on  the
     compliance status  of  those sources  identified in  the  Wisconsin  SIP  as
     needing to reduce  emissions.   In addition  the  State should  assist  EPA
     identifing all major  VOC  sources  violating  RACT  requirements.   After major
     violating VOC  sources  have been  identified,  the  State and  EPA   should
     explore procedures  to  expedite  enforcement activity at these  sources.

12.   EPA  and  Wisconsin  need to  agree to joint  compliance activities  for  the
     major coating operations.   *\n  interagency workgroup  should he formed  to
     evaluate the  final  compliance  plans and to  establish  processing and  track-
     ing procedures for variance requests.  This  workgroup should  be provided
     with all appropriate Headquarters  guidance on  variance  approval require-
     ments.

Headquarters Actions Requested

 1.   Headquarters   should  develop more  useful  criteria  for a  State to   use  to
     demonstrate that emissions from  sources in another State  adversely  affect
     it.

 2.   Headquarters   should encourage  continuous compliance  by stationary sources
     through research  into establishing  source-specific  operating standards
     and  guidance.

 3.   Headquarters   should work closely with  the  Congress  to get a clear resolu-
     tion of the pending Clean  Air  Act Amendments concerning the  status of I/M.

 4.   Headquarters   should  develop  an   equitable  approach  on the  part of  EPA  in
     dealing with   each State which does  not have an  inspection and maintenance
     program included in the SIP.  This should  include consideration of  States
     which have made good faith efforts to implement  I/M.

 5.   Headquarters   should  expedite  final  publication  of  the remaining RACT  III
     CTGs.  Headquarters should  also  develop  guidelines  on available controls
     for major non-CTG  sources.

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                                     - 38 -
 6.  Headquarters  should  develop  recommendations  for Stage  II  Vapor  Control
     Recovery Programs.
TOTAL SUSPENDED RETICULATE

Overview of Environmental  Problem:

Persistent TSP violations  are concentrated  in  the most highly  industrialized
portions of the populated urban areas in Region  V.  The  most  severe  and urgent.
TSP problems  occur  in  steel making  areas  of Chicago/NW Indiana, Detroit,  and
Cleveland.  The  major  causes  of  the  persistent TSP  problems  are  industrial
process and fugitive emissions.   Other factors  are elevated  background levels
as well as  emissions resulting from urban activities, including blowing (non-
traditional) dust from  roadways,  parking lots, and construction  sites.

An important issue  is the projected  institution  of  a  new inhalable particulate
standard.  While  this  issue   is  pending,  both  the  regulatory  agencies  and
industry are  uncertain as  to  what  control strategies will  be necessary.   In
addition, while  enforcement  of   existing  and   pending   reasonably   available
control technology is  likely to result in some further reductions  in particulate
pmissions, the application  and enforcement of more  stringent controls may  be
required in certain areas.

Principal Barriers and  Actions:

Barriers to reducing the  extent of the Regional  particulate problem involve  un-
certanties resulting from  the proposed change  to the  inhalable particulate
standard; lack of  accurate up-to-date  emission  data for  major  sources  which
hinders the regulatory agencies'  knowledge  of  compliance  status  of  sources;
lack of emission data  for  fugitive  emission  sources which hinders the  ability
nf regulatory agencies  to develop  air pollution  control strategies and  take  en-
forcement actions;  and, delays  in  final  approval  of consent degrees which impede
implementation of a source's control program.  These barriers  along with fiscal
conditions have limited both the  ability  and willingness of  industries  to  in-
stall needed  controls.    Also,  reduced  staffing  levels at  State and local  air
pollution control  agencies  has  limited the  regulatory  agencies'  ability   to
inspect and enforce the standards/regulations.

Barriers:

 1.  Several conditionally  approved  SIP items in  Michigan and in Ohio,  related
     to the overall control  strategies  for  the iron  and steel  industry,  were to
     he satisfied  by December 31,  1982.   Both   State's  current  schedules  for
     obtaining adoption of  the revised  rules for several  of these  conditions
     will not  meet EPA's  deadline.   In   addition,  Michigan's  one   remaining
     disapproval  item needs to be  resolved concerning the mass limit  rule  for
     sinter plants.  This is the  only point sources limit  on  which EPA  and  the
     State of Michigan  have not reached  agreement.  These delays  in the  resolu-
     tion of the conditional approval items  and  final point  source  limit rule
  •  will hinder progress  toward  further TSP  emission  reduction.

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                                     - 39  -

 2.   The Lake County  Indiana TSP  (including fugitive dust) SIP is currently not
     approved.   Indiana  has  not  submitted a complete modeling demonstration as
     requested  by EPA. Until  the  Lake  County TSP Plan is approved, as an acctable
     Part D  Plan, the Region will enforce the existing federally-approved SIP,
     and Lake County  will continue to have growth sanction's in place.

 3.   Northern Porter County  (Indiana)  has been  redesignated  primary  TSP non-
     attainment.  Legal  challenge by the State and industry to  the Porter County
     redesignation  may delay the  State's  development  of an attainment plan for
     that area.

 4.   Illinois'  regulation for blast  furnace  casthouses  and  operating permits
     for coke oven  pushing;  Indiana's opacity  and coke  oven pushing regulation;
     and Ohio's  new  rule  for  coke quenching  do  not  represent RACT.   If these
     rules are  disapproved,  the  TSP  SIPs  may  be  deficient (less than RACT) in
     some respects.

 5.   Indiana has  committed to  perform studies of non-traditional fugitive dust
     sources and their control.   Drafts  of these studies have been submitted to
     EPA, but have  been  finalized.  Similarly, Ohio has  recently submitted to
     EPA a  letter  and  documentation addressing  the  State's   non-traditional
     fugitive dust  sources and their  control.  This data does not satisfactorily
     fulfill Ohio's commitment to study  these sources. EPA's final rulemaking
     action  on Michigan's Fugitive Dust Regulations did  not  contain  a date by
     which the specific  sources'  fugitive  dust control  program would be submit-
     ted to   EPA.   Although  Michigan is  working  to develop  these  programs  a
     final deadline needs to  be set.   Delay  in the  submittal  to EPA  of the
     Fugitive Oust  Regulations  will  result  in  a  delay   in  implementation  of
     these controls by industry.

 6.   The  Cleveland local air  pollution  control  agency is presently backlogged
     evaluating compliance plans  for fugitive dust  source  permits.  This backlog
     results in less-than-adequate  identification  of  fugitive  dust  sources.

 7.   The Gary and  East  Chicago  pollution  control  agencies have been  delegated
     formerly State held enforcement  responsibilities  at steel plants  effective
     January 1,  1983,  but   lack  experience  in  these  functions.   A  lapse in
     enforcement may  therefore be inevitable.

State Actions:

 1.   Fugitive Dust  Actions:

     -  Illinois, Michigan, Indiana and Ohio should develop emission inventories
        for  potentially   significant  fugitive  sources in  order  to  determine
        which sources need control programs.

     -  Illinois,   Michigan,   Indiana and  Ohio   should develop  fugitive dust
        program elements for each major  source requiring a program.

     _  Illinois,  Michigan,  Indiana  and  Ohio  should  determine  compliance  status
        of all sources with  fugitive  dust programs.

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                                     - 40 -

     -  Indiana should  submit  final  non-traditional  dust studies and  indicate
        their potential  for adequate  emission  reductions.

 2.  Compliance Activities

        Illinois,  Michigan, Ohio  and Indiana should  identify  current list of
        violating  sources   and  prepare detailed  compliance  schedules  for  all
        major source violators.

     -  Illinois,   Michigan,  Ohio  and Indiana  should  assure that  all   major
        sources in  their  target  areas   are  inspected  annually   and   indicate
        whether compliance  has  been  maintained  since  the  last inspection.

 3.  Air Monitoring and  Data Analysis  Activities:

     -  Illinois,  Michigan, Ohio  and Indiana should  implement new monitoring
        locations  including PM-10  monitors,  in Chicago, Detroit,  Cleveland  and
        NW Indiana areas.

 4.  Regulatory Actions:

     -  Michigan should submitt additional SIP  submittals  for iron and steel.

     -  Michigan should  submit  fugitive dust permits.

     -  Illinois  should  submit blast furnace  casthouse rules  and   operating
        permits for coke oven pushing.

     -  Indiana should submit opacity  and coke pushing  regulations.

     -  Ohio should submit new  rule for coke quenching.

Federal  Actions:

 1.  EPA must take final  action  on Ohio's Part D TSP SIP.  Several disapprovals
     may make Ohio's TSP  SIP  deficient.   If EPA  disapproves  the  TSP  SIP,  EPA
     will  provide   specific guidance  to   this  State  on  how  to   resolve  the
     deficiencies  in the  plan.

 2.  Fugitive Dust Actions:

     -  netermine what sources in the Chicago,  NW  Indiana, Detroit  and  Cleveland
        areas are  subject  to the fugitive dust regulations  and which  ones have
        submitted  control  plans.

     -  Review the status   of non-traditional  studies  and indicate their poten-
        tial for adequate  emission reduction for sources  in Chicago, NW Indiana
        and Cleveland areas.

 3.  Compliance Activities:

     -  Review current* list of  violating  sources,  in the Chicago, Wayne County,
        NW Indiana,  and  Cleveland  areas;  prepare detailed compliance  schedules
        for all major violators; and,  indicate which sources are behind schedule.

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                                     - 42  -

     -  Continue to work  with Indiana  and  Lake County  industry  to obtain  an
        acceptable attainment demonstration  for the Lake County non-attainment
        area.

     -  Take final  action  on Indiana's opacity  and  coke  oven  rules.

     -  Resolve all legal  challenges  to the development of an attainment  plan
        for Porter County.

     -  Review air monitoring/emission tracking activities for the  Chicago and
        Wayne County areas.

     -  Develop rules for blast  furnace casthouses  requiring  technology  repre-
        sentative of RACT.  Develop  federal  rulemaking as  soon as  the  casthouse
        rules are submitted  by Illinois.

     -  Encourage  voluntary  Environmental Auditing  Program in the  Chicago and
        Detroit areas  that  will  be directed at  improving overall  compliance.

Headquarters Actions Requested:

Headquarters needs  to  expedite  its   decision-making  on  a proposed  inhalable
particulate standard  and  promulgate  any  new   standards   as  expeditiously  as
possible.

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                                     - 43 -

AIR TOXICANTS

Overview of Environmental  Problem

Numerous facilities exist  in  Region V with  actual  and potential emissions  of
air toxicants.  Many of these  facilities  are in proximity to  large  population
centers.  In  the  case  of  NESHAPs   sources,  lead  sources, and  to some  extent
for Benzo (a) pyrene from coke ovens, there  is  a modest  grasp  of the magnitude
of the  impacts  on  human  health  and  the  environment.   For  other  situations,
such-as  large  chemical  manufacturing  facilities,  neither  source nor  ambient
data as  yet  exists  to  describe  the problem  in  more  than  general   terms.

The Region inspected and followed-up NESHAPs  sources and identified 308 sources.
271 are in compliance or have been put on schedules,  1  is out  of  compliance,  and
36 are  of  uncertain   status   and   are  scheduled  for  inspection  this year.

Principal Barriers and Actions

Barriers:

The principal barriers  to  reducing  air  toxics emissions  in Region  V are  as
follows:

1.  Only a  limited  number  of  toxicants are  regulated  (4)  or listed  (7) under
    Section 112  (NESHAPs).  Only sulfuric acid mist  has  been  regulated under
    Section 111.  The status of the listing  process reflects the limits  in  the
    technical data base for other chemicals,  although  that  deficiency  is gradu-
    ally being  remedied.   In   the  absence of  such regulation,  potential   air
    toxicant emissions may be  uncontrolled.

2.  State and Region  V staff  members  frequently  have insufficient  background
    to define air  toxicant  problems or to devise  control  approaches.   Except
    for NESHAPs  pollutants, specific  manuals to assist staff in  questions  re-
    garding air  toxicant  control,   emission  inventories, monitoring,  modeling
    and health effects are not  yet  available.

3.  Waste oils containing hazardous wastes are  presently allowed under  certain
    circumstances  to be burned in boilers without violating RCRA rules.  State
    permits may  apply,  but  the necessary  technical  evaluation frequently is  a
    difficult one.  No guidance manual  exists.

4.  State agencies, with the Region's  help, are  developing  air  toxicant  control
    programs of  their  own.  Given the substantial  expense  in  toxicant monitor-
    ing, risk assessment,  etc.,  both  State  and Region  programs are  resource
    limited.

5.  There is a lack of ambient  and  source  data  for  air toxicants. There  is also
    a shortage of  appropriate monitoring equipment  and  a lack of experience with
    using such existing equipment.

6.  A dilemma is imposed by unregulated toxicants.   Although we  know  that con-
    trols for TSP  and  VOC  will  control associated toxicants to  some degree,  we
    can not properly make  use  of  such  information.  For example,  in  considering

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                                     - 44 -

    a bubble  involving  two sources  with  equal  amounts  of  TSP  but  different
    amounts of a  non-NESHAPs  toxicant,  we are  unable  to  legally separate  one
    from the other, even if potential  health  impacts  may be  involved.

7.  The Region has not yet established a comprehensive facility  listing  of  po-
    tential air toxicant  sources  for dialogue  and  resource planning with  the
    States.

State/Federal Actions:

The Region has developed  a  regional  air  toxics strategy which is dedicated to
realizing the following items  noted  below:

1.  The Region will  increase  attention to  air  toxics issues  that cross  program
    boundaries by continuation  of the Region's Toxics  Air  Emission Workgroup.

2.  A State/Federal  workshop  will  be held in  the summer of 1983,  which will
    bring EPA experts and others to  train  State and regional personnel   in  air
    toxicant monitoring, assessment,  and  control.

3.  The Region and the  State will  jointly develop  a  short  list  of target  facil-
    ities for air toxicant problem  definition.

4.  The Region will support efforts  by the  States  to  define  problems and  to  de-
    vise controls with such resources at  our disposal. "Limited  inspection  and
    monitoring has been done  by the  Region at  facilities  with potential  toxic
    emissions.  Request for additional  effort   is expected  by State  agencies.
    Section 105 funds or  enforcement  resources  will  he recommended  for  use  as
    appropriate.

5.  Staff assistance will  be provided for dealing with air  toxic issues in other
    media; for example, seeking the  sources of  mercury  found in northern  Minne-
    sota atmospheric deposition. Also staff  will  provide  advice  on  atmospheric
    impact from hazardous  waste sites.

Headquarters Action Requested:

1.  Headquarters  needs  to  accelerate the program to list and  regulate additional
    pollutants under Section 112.

2.  Headquarters  needs  to develop  a manual on  control technology for  air toxi-
    cants for use by State  and regional  personnel and  for  presentation  at  the
    workshop.  Funding  sources  for the Region's initial  proposal on  this item
    should be sought.

3.  Headquarters  needs  to  develop a manual for use  in  evaluating permits  involv-
    ing use of waste oils  in  boilers.   A  regional proposal   has  been  developed
    for this purpose using Ohio as  a  pilot.

4.  A national focus is needed for  air toxics, especially  as  related to those
    polutants which are not  yet regulated  under NESHAPs.

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                                     - 45 -


                    REGION V ENVIRONMENTAL MANAGEMENT  REPORT


                                     PART 2


                                      LAND
No attempt  was  made  to rank  or cluster  these problems   across  the  medium.
The Superfund NPL  is  a prioritization  system in  itself  and  the  pesticides
program has a ranking of the most significant problems  by  State.

The environmental  problems  for the  medium center around  the handling  and/or
mishandling  of  waste materials.  The most significant  problem  for the hazardous
waste management  program  is  gaining  control   of   hazardous waste  handling
processes.  The  Superfund program has the ranked National  Priority  List  (NPL)
and the  toxics  program  must  address  the handling  and disposal  of PCBs  and
substances such  ^s asbestos. The pesticides  program problems  range  from handl-
ing an application to grounrlwater contamination.

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                                  .   - 46 -


HAZARDOUS WASTE MANAGEMENT PROGRAM

Overview of Environmental Problem:

The most  significant  problem  for the  hazardous  waste  management program  is
the uncontrolled management of hazardous wastes by waste handlers.

The problem results from the growth  of the chemicals and synthetics industries.
It was compounded by a burgeoning, low-material-cost, discard oriented  economy ,
and the lack of any  specific, environmentally-based Federal hazardous waste laws
or regulatory programs to  enforce good  and  consistent practices  by  industry.

The RCRA programs are  still  being developed  at the Federal and State  levels;
they are setting  standards,  staffing  up, training,  developing policy,  develop-
ing data bases,  and most importantly,  obtaining public acceptance  and  industry
compliance.  These  factors  act in combination on  the regulatory   system,  and
because of its newness,  cause it to  be in a fragile  condition.

The Public has  demanded  instant,  incisive action  to mitigate or eliminate  all
hazardous waste problems—at  no  personal  cost or discomfort  and with  no risk
whatsoever to the individual  or community.

Barriers:

1.  Time  to  develop  an  operating   history   for  permit  issuance, compliance
    monitoring, or  enforcement.   The  decisions  to  be  made  and  actions  to
    be taken  are precedential,   rather  than  routine.   Outcomes   of   permits
    or enforcement  actions  have  not  been many,  and have  not  had sufficient
    time-in-place to demonstrate their viability as  solutions.

2.  The  States  have  experienced  austerity   budget  cutbacks,   and personnel
    freezes, each of which limits their ability to  provide matching funds.  Fewer
    State program  staff  are   available  to  assist   the  Region  in permitting
    work; this also could delay a State  in seeking  and obtaining authorization
    for its hazardous  waste programs.

3.  Time for  issuance of permits.  It may take as  long as 6 months  for   filing
    and 6 months  for  processing.  Control  of  portions  of this  time is  out  of
    the Region's control.

4.  Maintaining  and  developing  sufficient,   permittable  treatment,   storage
    and disposal  capacity,  based  upon the combination  of existing facilities
    and new facility proposals.

5.  Siting of facilities  to  satisfy criteria  and public demand.   The public  has
    been supportive  of efforts under RCRA, as long  as wastes are  not handled,
    treated, stored  or disposed near  their homes.

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                                     - 47 -
State/Federal Actions:

1.  Continue close  coordination  in  processing permit applications, as well  as
    in other  aspects   of  the  program.   Impact  time  frames  where  possible.

2.  Be cognizant  of public concerns,  but do  not  compromise where  regulatory
    intent would be compromised or circumvented.

Headquarters Actions:

1.  Provide  timely  assistance  to facilitate  decion-making and  the  permitting
    process.  Recognize that  it  will  take   several  years  to  accumulate  and
    interpret data into ambient terms.

2.  Issue regulations  and  guidance in a timely fashion.

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                                     - 48 -


REMEDIAL PROGRAM (SUPERFUND)

Overview of Environmental Problem:

There are  99  NPL sites  in  the Region.   Ninety-five  (95)  of these  sites  pose
threats to  groundwater and  51  pose threats  to  the  Region's  surface  waters.

Nine (9) sites pose potential threats to the air.

Barriers:

1.  10% match by States required.

2.  Technical  needs  are evolving  and  disposal   options  are  often  limited.   A
    great amount of time is  required to assess  the extent of  contamination to
    develop optimal  mitigative steps.

State/Federal Actions:
  •        ^
1.  Complete cooperative agreement or State/EPA contract as required.
2.  Provide necessary fundings.
3.  Oversee implementation and operation and maintenance,
4.  Negotiate settlements/pursue litigation.

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                                     - 49 -
TOXICS

Overview of Environmental Problem:

PCBs

Almost half of the  facilities  inspected  under the PCB inspection  program  have
been found to be  in  violation  of the regulations.  The most  common  violations
are improper storage and  disposal  of used PCB oils and allowing  PCBs  to  enter
the environment.   There are approximately  8,000 facilities in the Region subject
to the PCB regulations.

There is only one landfill in the Region  permitted to  accept PCBs  for disposal.
No incinerators for  destroying PCBs are  located in  the  Region,   although  Sun
Ohio is operating a  mobile PCB detoxification unit.   The shortage of  disposal
means has resulted in prolonged storage  and improper  disposal.

PCB contamination of the environment has  occurred  in Waukegan Harbor, in  the
sediments and in  a   nearby  drainage ditch.   Samples  from  the  area  have  been
measured to be as high  as 25 percent PCRs.  Other areas  where PCB  contamination
has been identified  are Green Bay and Ashtabula Harbor.  Cleaning up these  sites
will be both technically  difficult  and  expensive because of the  large amounts
of contaminated  sediments  that  must  be  either  disposed   of  or detoxified.

Asbestos

Approximately 62  percent, or 1,476  of the  schools  found with asbestos  have  not
performed any abatement  work to  control  the  friable asbestos material.   The
biggest factor affecting  whether schools  voluntarily  correct asbestos  problems
is funding.  Since nearly  every  school has  financial  problems,  available  funds
are used  for normal,   routine  maintenance,  rather   than  correcting  asbestos
problems.

Non-regulated Toxics

Identifying and resolving toxic substances-related problems  for which  specific
regulations do not   exist  is  a  problem.  Complaints  about  health  problems
associated with products  which contain  formaldehyde  such as  ureaformaldehyrie
foam insulation,  plywood,  particle  board  and  other home  furnishings  are  fre-
quently received.-  Although  it has  been  documented that  these  items'  can  have
an adverse effect on people's health because these items  release  formaldehyde,
only the insulation  product is  regulated.

At the present time  no  Federal  agency has  been granted jurisdiction over indoor
air pollution where  people  are  exposed to elevated levels of formaldehyde,  as
well as  other  pollutants.  Since  most Americans spend the  majority  of  their
time indoors, indoor air pollution can have a significant effect on  their health.
Additional work needs  to  be done to assess the  effect  of indoor  pollution  on
health.                     '  '

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                                     - 50 -
Barriers;

1.  Confusion concerning the PCB regulations  and shortage of disposal facilities
    Better laboratory capability and reliability.  Duplicative analytical  proce-
    dures  to test for PCBs are also needed.

2.  Lack of regulations to cover the toxicants such as formaldehyde.

3.  Local  funding to implement asbestos resolution programs.

State/Federal Actions

1.  Continue to integrate toxic programs to maximise resources.

2.  Provide technical assistance to local  agencies.

Headquarters Actions

1.  Ensure clarity in regulations and guidelines.

2.  Provide RflO for methods of dpstroying toxic chemicals.

3.  Provide  for  QA/OC  for  laboratories  doing   toxic  substances  analysis.

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                                     - 51  -
PESTICIDES

Overview of Environmental  Problem:

All region  V  States,  except  Ohio,  have  Cooperative  Enforcement  Agreements
with the  Region.   The States  as  part  of  the grant  process,  rank  pesticide
problems in establishing  enforcement priorities.   This  ranking  is:
Problem Areas Region-wide:
Priorities based on State Ranking
1. Pesticide drift and overspray
2. Improper handling storage, and runoff
3. Structural application/residential
4. Aerial application
"5. Pesticide container disposal
6. Groundwater protection
7. Unlicensed applicators
8. Farmworker exposure
9. Right-of-way application
10. Licensed Dealers
11. Pesticide odor complaints
State Ranking
II
1


3


2




IN
3
1-
2

4






MI
1
4
2
3
5






MN
1
2
4
4
3






WI
2




1

3
4


OH
2
6
1



4


3
5
Barri ers:

1.  Lack  of State  legislation  and  rules  providing  a  wide  range of  adequate
    enforcement options.

2.  Lack of sufficient funding and personnel.

State/Federal Actions:

1.  Continue  to provide  training for  personnel,  field  and  case  preparation
    staff.  Continue training programs for State pesticide laboratory
    personnel.
2.  Continue  funding  for cooperative enforcement and  applicator  certification
    agreements.

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                                     - 52 -
Headquarters Actions:

1.  A  recommitment  to  conduct  Label   Improvement  Programs,   especially  in
    areas of  pesticide  disposal  and  storage,  aerial  and  ground  application
    technology in areas of drift,  and  structural  pest control.

2.  Reinstatement of an active classification of  pesticides  program.

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                                     - 53 -


SPILL RESPONSE PROGRAM

Overview of Environmental Problem;

The most frequently  spilled  products, reaching land  and/or wate,  in  addition
to oil and petroleum products are:

                     Polychlorinated biphenyl  (PCB)
                     Ammonia  (fertilizer  and anhydrous)
                     Acid (sulfric  and hydrochloric)
                     Solvents
                     Sodium hydroxide
                     Chlorine
                     Phenol

These products can cause  great damages to  the  environment  and  can pose threats
to human health.

Barriers:

1.  The major obstacle facing spill  response is the  unpredictability of spills.
    Secondary to  the  unpredictability  of spills is  the  difficulty in the develop-
    ment and implementation of procedures to effectively respond to oil/chemical
    spills.

2.  Awareness and attitudes toward  spill  prevention  programs.

State/Federal Actions:

1.  Develop a workable response  plan which  incorporates:

    - effective communication network
    - well-trained response personnel
    - well-maintained equipment  and  vehicles
    - Regional/State cooperation

2.  Provide for training nf personnel.

Headquarters Actions:

1.  Develop  a  reasonable list of  reportable  quantities  of spilled  hazardous
    materials under  CERCLA.   For example,  if anyone  spills  over  1  pound  of
    asbestos (listed  in  Section  112 of the Clean Air Act), it is  required  to
    be reported to the National Response  Center (NRC).

2.  Develop SPCC  regulations  which  address  hazardous materials.

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                                     - 54 -
3.  Develop a cost  effectve  spill  prevention program.   Effective spill preven-
    tion is as important as efficient spill response.

4.  Ensure that  funding -mechanisms  for State programs are maintained.

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                                     -  55  -

                    REGION  V ENVIRONMENTAL MANAGEMENT REPORT
Regional  water quality problems  result  in impaired water  uses  and impacts on
public health.   The  Region  has  identified  priority  problems   which  require
Agency and State  actions  to  achieve the goals of the Clean Water Act. The States
are developing priority water body lists  during  FY'83  to aid them in planning
future efforts. This  section  of the  EMR  will  discuss  Regional  water quality
problems  clustered into three priority groups,  keeping  in  mind the development
of the priority water body lists. These priority groups  reflect  geographic and
programmatic issues.

   Priority 1

  0  Dioxin  and  toxic  materials related  problem areas  (focus  on  Midland, MI
     and  Sauget,  IL)
     Implementation of  the pretreatment program and second round  permit issuance
  0  Control  of  volatile synthetic  organic  contamination  in  drinking waters
     In situ organic pollutants  (Waukegan  harbor, IL; Fields Brook and Ashtabula
     River, OH; Sheboygan River, WI;  Chicago  River-North Branch,  IL)
  0  Water supply compliance
     Control of oxygen  depleting  discharges (i.e. maintain high  rates of munici-
     pal  compliance  through  construction grants,   permits and  enforcement)
  0  Development   and  implementation   of   the  permits program  for  underground
     injection control  systems

  Priority 2

  0  PCBs in Lake Michigan fish  and sediments
  0  Toxics in the Fox River,  WI
  0  Nonpoint discharges  to  Lake Erie in  NW Ohio
  0  Disposal  of  contaminated   sludges   (Gary,   Hammond,   East  Chicago,  IN;
     Detroit, MI)
  0  Ground water degradation -  Michigan;  Central  Sands  area, WI)
  0  Combined sewer overflows  (513  systems)
  0  In  situ  inorganic  pollutants  (Ashtabula  River,  OH;   Indiana Harbor and
     Grand Calumet River, IN;  Menominee and Fox Rivers,  WI;  St. Louis River, MN)

  Priority 3
o
o
o
  0  Nutrients and bacteria
  0  Nonpoint discharges - SE Minnesota
     Cultural eutrophication and  loss  of wetlands (S. Michigan; SE Wisconsin;
     Twin Cities, MN)

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                                     - 56 -

DISCHARGE OF TOXIC MATERIALS

  Overview of Environmental  Problem:

  The evaluation and control of toxicant's has  received  attention  because  of  the
  organic chemical contamination  of  fish  and  other aquatic life and  resulting
  mammal  contamination.   Sport  and commercial fishing bans or advisories  result-
  ed from DDT  and PCB in  Lake Michigan;  from  mercury in  Lake  St.  Clair  and
  lakes in Illinois, Minnesota and Wisconsin;  and from PCB  in the Fox, Wabash,
  Sheboygan, Mississippi  and other  rivers.   Significant levels  of chlorinated
  dioxins, PCB, dibenzofurans,  etc., have been identified in  fish eating  birds
  in Green Bay and Saginaw Bay.

  Barriers:

  1.  A principal  barrier  to  implementing  an effective  water use  impairment
      toxicant control  program is the  lack  of available data and the shortage
      of  adequately qualified  staff.   Also, there is  a  reluctance  by States,
      Region, and Headquarters  to address  the  localized toxicant  issues because
      of  the difficulty and the complexity of the work required.  There continues
      to  be the  tendency  to work on  conventional  pollutants  since  they  are
      easier to define and analyze.

  2.  While national  effluent guidelines  are or will  be available for  a  limited
      number of national  priority pollutants,  they do not cover  many  toxicants
      that are  causing  or  may cause  significant local  water  or  sludge  use
      impairments.  Also  the previous  national  ambient monitoring program  has
      not addressed and  is  not  now  addressing  significant  local  or Regional
      toxicants other than  a  limited  number  of  previously banned pesticides,
      and little data have been or are being developed  on  residues of  toxicants
      in  fish  tissue,  sediment,  or  water.  In  addition,  ORD and  Effluent
      Guidelines have been  very  reluctant  to  make their existing local  indus-
      trial  sampling data available  to the States.

  3.  The cost and complexity of analyses and the need for methods and  protocols
      for sample analyses in the  sub parts  per trillion  range  limits the  number
      of  samples that can be analyzed, Regionally  and nationally.

  State/Federal Actions:

  1.  EPA place an increased emphasis  on  addressing toxicants that are causing
      or  may cause significant  human  health  or environmental  damage through  the
      impositions of  permit limits   with  technology  based  effluent limits.

  2.  Develop  specific  monitoring schedule to  ensure   compliance  with  permit
      limitations.

  3.  An  acceptance by management that by  focusing on  high potential toxicant
      industries/municipalities,  other parts  of  EPA/State  programs  will   be
      downplayed and that this  may be questioned  by  the public.

  4.  Strong  National/Regional/State  direction to  require more adequate  coor-
      dination and  cooperative effort  between  the  several media  to address
      joint problems,  to  prevent  transfer  of  problems between  media,  and  to
      share development  of information.

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                                   - 57 -

5.  Implement priority water  bodies  so that permit and standards  activities
    focus on industrial  dischargers.

Headquarters Actions:

1.  Place  an increased  emphasis  on  addressing  toxicants that  are  causing
    or may cause significant human health or environmental  damage  by  providing
    technical and  administrative assistance to  permit  writers.

2.  Transmit  to   States/Regions   site specific  technical  information  from
    within the national  EPA programs  (ORO,  Effluent Guidelines, etc.)

3.  Ensure that  remaining Effluent Guidelines for  direct and  indirect dischar-
    gers are published on schedule and do not  contain  language  prohibiting  or
    interferring with  the development of  site  specific limitations  to  address
    local water  use -  water quality  issues.

4.  Emphasize priority water bodies  approach to  water quality  management and
    pollution control.

5.  Continue providing support to national  dioxin initiative  providing intra-
    Agency dialogue and with Congress.

6.  Continue supporting development  of sampling  and analytical protocols for
    toxicants.

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                                     - 58 -


CHEMICAL AND/OR BIOLOGICALLY CAUSED IMPAIRMENTS

  Overview of Environmental  Problem;

  Approximately 65 percent of the major rivers  in  the Region  experienced  moder-
  ate to severe  water  quality problems associated with  nutrient or  bacterial
  levels.  Less than 15 percent of the major Regional  rivers  experienced prob-
  lems associated with  elevated ammonia levels.

  Information on biological  indicators of water  quality  conditions  is  much  less
  extensive than for more traditional  chemical  indicators.

  Specific biological   information  exists  for  less   than  20  percent  of the
  Region's river miles.  Of those  river  miles  for which information  is  avail-
  able, approximately 30 percent have  moderate water  quality  problems.

  Fish flesh contamination and fish kills  continue to  be a problem  in Region V
  States, but there currently are  insufficient data to make  a meaningful  trend
  analysis.  The latest  305(b) reports  do indicate  areas  within  each  State
  where health advisories are  issued  in  conjunction  with suspected fish  flesh
  contamination.

  Barriers:

  1.  Ability to assess  river stretches  for use  impairment  by utilization or
      biological indicators  is highly  resource  limited.

  2.  Federal  and State resources  are  not  sufficient  to  abate  all water quality
      problems at  once.   Limited  resources  as compared  to  the  magnitude of
      problems to  be solved, require  establishment of  priorities for resource
      utilization.   Consequently decisions to  abate  a  given  problem here and
      now, is also  a  decision to  defer  solution  of another problem to  some
      later date.  Such decisions  can be,  and  often  are, highly controversial
      and subject to multiple review.

  State/Federal  Actions:

  1.  States define water quality  goals  by setting  appropriate  standards for
      thei r waters.

  2.  Negotiate resource priorities to accomodate  the increased need to  assess
      biological factors  and to collect  and utilize  biological  information to
      determine attainable uses.

  3.  Develop and implement,  as appropriate, mechanisms of correlating  in-stream
      water quality improvement  to  specific point/non-point compliance actions.

  4.  Negotiate monitoring resource priorities  sufficient to track water quality
      improvements  related to significant  compliance  actions  of  selected, key
      points in each State.

  5.  Expand analytical  capabilities to include  a  full  range  of  bio-monitoring
      and toxic pollutants in  standards revisions.

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                                      - 59 -

fi.  Region review  and  approve state  water quality  standards revisions  and
    assist the states in analyzing  use attainability.

7.  Continue  development of local  pretreatment programs and  incorporate  them
    into permits.

Headquarters  Actions:

1.  Continue  to stress  the need for adequate  biological  components  in  attain-
    ability analysis.

2.  Develop example programs  demonstrating potential  mechanisms  for correlat-
    ing in-stream   water quality   improvements  to  specific  point/non-point
    compliance actions.

3.  Assign high priority in  national  program  guidance materials to the  need
    for  ambient monitoring  activities tracking  water quality  improvements
    related to significant compliance actions at selected key points  on  each
    State.

4.  Finalize  revision of selected water quality criteria documents and  include
    guidance  on how to  interpret  and implement criteria.

5.  Adapt  and  test  less resource  intensive protocols,  such as  the  chemical
    fate model and  possibly toxicity factor models  for use in developing  sit*3
    specifics criteria.

6.  Provide technical assistance to the Region V  and  States  on the  use of the
    organism testing protocol  and  biological loading  model,,  validated  in
    FY'82 and '83.

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                                      -60-

NON-POINT SOURCE DISCHARGES

  Overview of Environmental  Problems:

  Agricultural  activities  increase the background amounts of  runoff,  sediment,
  nutrients,  organic matter, pathogens, and toxic materials  being  delivered  to
  both surface water and  groundwater systems.   High  nutrient  loadings,  acceler-
  ated sedimentation, and  the delivery  of  residual  pesticides to the  Region's
  waters  are  most  frequently mentioned  as  the primary  agricultural  related
  water quality problems.

  High sediment loads in the Region's  surface waters,  derived from  agricultural
  lands adversely  impact  aquatic  life.    A  significant  amount  of  reservoir
  storage capacity  is  lost  each year  due  to  sedimentation.   For example,  in
  Illinois over 8,000 acre-feet  of storage capacity  is  lost each year due  to
  sedimentation.

  Related to   direct   sediment   load  impacts,   agricultural   non-point   sources
  contribute  to high nutrient loadings which could offset  the  loading reductions
  achieved through  point  source  controls.  As  an example, phosphorus,  which  is
  frequently  the limiting  nutrient in  terms  of eutrophication,  is  strongly
  adsorbed to  easily  eroded clay  soil particles.   In most  cases,  more  than
  90 percent   of the  total   phosphorus  reaching  a  stream  from  agricultural
  land will be adsorbed-to soil  particles.

  In addition  to high nutrient   loadings,  residual  pesticides  also adhere  to
  eroded soil particles.  High levels  of  persistent  organochlorine  insecticides
  have been  documented in  lakes in Region V  which  have watersheds  comprised
  predominantly of   agricultural  land  uses.    Replacement  compounds  for the
  chlorinated hydrocarbons  are  less  persistent but  potentially  more  toxic  to
  fish; as a  result,  the  incidence   of   related  fish  kills  has  increased.

  Barriers:

  1.  Lack of   recognition  of   non-point  sources as  a  major cause  of  water
      pollution problems.

  2.  Verification  of non-point  source problems is very  resource intensive and
      long term.

  3.  Responsibility  for abatement  and control  is not well  defined at  any level.

  4.  The nature of non-point source discharges - air  and  water carried pollut-
      ants -  makes  control that  much more difficult.

  5.  Identification  of critical watersheds  impeded  by geo-political  or  resource
      considerations.

  State/Federal Actions:

  1.  Complete and  implement non-point  source control  strategies  (this  is  State
      specific  depending on  extent  of  state involvement).

  2.  Ensure  that the priority  water  body  lists include  areas where  non-point
      source  controls  are necessary to  achieve  the designated uses.

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                                      -61-

3. Update Water  Quality  Management Plans and  use  them as management tools to
   analyze and store data,  consider alternatives  and  promote  effective decision
   maki ng.

4.  Provide  for  implementation of  State strategies  by designated  management
    agencies.

5.  Provide for inter-agency cooperation to  maximize  resources.

6.  Provide inventory and status  of non-point  source  activities.

Headquarters Actions:

1.  Provide  recognition  to  significance  of  non-point  source  problems   and
    provide leadership in establishing Agency's  role.

2.  Coordinate  at  national  level  with  other  involved  agencies  to   effect
    unified approach.


3.  Issue technical  guidance on statistical methods  for determining  the proba-
    bility of non-point source  impacts.

4.  Issue final technical guidance  on  screening,  identifying and  updating  pro-
    gress on water quality-limited segments.

5.  Provide  aasistance  on the use of  the  River Reach  file and  aquatic  life
    survey tp help organize information on  water  bodies.

6.  Develop guidance on approaches for defining cause and effect relationships.

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                                      -62-
OXYGEN DEPLETING DISCHARGE

  Overview of Environmental Problem:

  Only two percent  of  the Region's rivers experienced severe  dissolved  oxygen
  problems in 1981.  However, 48 percent experienced moderate problems.   Incre-
  ased compliance with  permit  limits  and improvements at treatment  facilities
  have effected dramatic improvements on the Cuyahoga, Black and  Maumee  Rivers
  in Ohio and on Michigan's Grand River.

  Barriers:

  1.  Many rivers are affected by both point  and non-point sources of pollution
      that deplete oxygen.  It is a costly process to complete the major detailed
      studies to  analyze  problems and  determine  appropriate  action   steps,

  2.  Coordination among State,  Local  and Federal agencies (EPA, DNR,  AG,  etc.,)
      is cumbersome,

  3.  Lack of local funds to address  problems,

  4.  Lack of use attainability analyses to show effects  of  streams  not  mppting
      standards.

  State/Federal Actions:

  1.  Hevelop priority  water body list and use  it to address prioritized  areas.

  2.  Integrate program  priorities across  agency  jurisdictions to provide  for
      corrdinated and  effective  inter-agency  priority  setting  and  funding.

  3.  Provide  training  to  facilitate more  timely  State  actions to  increase
      compliance rates.

  4.  Issue  permits  to   cities  and industries, including  general permits,  to
      reduce the backlog of expired permits.

  5.  Revise current permit priority lists  to reflect  the priorities   in  the
      policy for second  round issuance  of  NPOES permits  and the National Muni-
      cipal  Policy.

  Headquarters Actions;

  1.  Provide leadership in recognizing  the non-point source problem.

  2.  Provide inter-agency coordination  at Headquarters level.

  3.  Develop and promulgate effluent guidelines for major industries.

  4.  Provide  technical  assistance  to  permit  writers  and develop  prototype
      general permit for specific categories  of discharges.

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                                      -63-


COMRINED SEUER OVERFLOWS

  Overview of Environmental  Problem;

  A problem for  many  of  the older  municipalities  is  controlling and treating
  combined sewer overflows  (CSO).  The  1982  needs  survey indicates that there
  are 513 combined  sewer  systems in Region V.  Larger  storm events cause by-
  passes in the  combined  sewers to  prevent  damage to or  upsets of treatment
  plants.  There are  two problems  associated with  these overflows:   1)  the
  immediate contamination  of surface  waters  from  untreated  sewage  and  2)  the
  long-term pollution  in  the  receiving  water  because   solids  settle  to  the
  bottom and form sludge deposits.   The CSO problem is complicated by the site
  specific nature of the problem and  each state treating the problem differently.

  One indirect or  surrogate measure  of environmental  impacts  of CSO's  is  the
  amount of dollar expenditures  for projects to correct or abate CSO  discharges,
  such as the  Agency's  bi-annual Needs Survey.   The  198? survey  indicates  a
  potential  estimated  need  of  $11.8  billion  for  construction of CSO abatement
  needs in the Region.  This  represents  33 percent of the total national  CSO
  needs.  A breakdown  of  these  needs,  by State and  by  levels  of control  associ-
  ated with meeting designated stream use  classifications, is  shown in  Attach-
  ment A.

  Barriers:

  1.  There currently exists  no definition  of  flow  regime  under  which water
      quality standards  are  applicable to  wet  weather flows.  Low flow relief
      is defined for  flows   less than the 7 Day/10  year flows.   While this
      recognizes that  WQS  cannot be  expected to  operate  under  unusually  low
      flow conditions,  it is equally logical  to establish high flow conditions
      that are unusual, (e.g.,  during a 100  ypar storm where major  river suspend-
      ed solids include  houses,  cars,  trees,  etc., a  typical suspended solids
      standard is obviously  inappropriate).

  2.  Due,  in  part, to  the  above,  there has been  no  comprehensive  policy
      for issuance of  NPOES  permits  Healing with CSO discharges.  Those  permits
      that have been issued  are generally done on a case-by-case basis frequent-
      ly emanating from controversial  situations.   However, most  CSO discharges
      are not permitted  with limits.  Therefore, enforcement  against the local
      community is  often  lacking.  Motivation  for  CSO projects are frequently
      emanating from pressures   other  than  pollution  abatement (e.g.,  basement
      flooding).

  3.  PG-61, the only guidance  document by EPA which  is  utilized as the basis
      for funding CSO  projects, was  not established on WOS  or  law but primarily
      on an economic basis.   The knee-of-the-curve  maximizes  removal of  BOD and
      similar pollutant  indicators  per dollar spent  without  making  a  direct
      analysis on whether  that  level of treatment is more or less  than necessary
      for attainment of  WO or benefits.

  A.  Definition of "significant water quality" problems  tend to  be indirect
      with regard  to  many  major  CSO  events,  causing  benthic  loadings  and
      downstream impacts   to  impoundments   which  may  be  difficult  to   assess.

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                                    -64-
    Additional ly, CSO impacts  are  often masked by non-point  source  impacts.

5.  Since the  basis  of  many  CSO  activities  include  other objectives,  they
    result frequently in multi-purpose  projects.  The complexity of the multi-
    purpose funding policy  used  by EPA  opens many pitfalls  for  implementa-
    tion, particularly  since  eligibility  cannot  be determined until  the end
    of the planning process.

6.  Finally,  since  established EPA guidance  in  this  area  is minimal,  many
    decisions concerning C.SO  projects  are made on a case-by-case  basis, and
    in five States in this Region these decisions  are made at  the  State level
    through delegation.   Therefore, it  is  anticipated  that  the  project  solu-
    tions, impacts,  and  cost  will  tend  to vary considerably  from State  to
    State.

State/Federal Actions:

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

Headquarters Actions:

1.  Provide National  policy direction in contrast to the barriers cited above.

2.  develop  national  policy for CSO  dischargers  for  use in  preparation  of
    NPDES permits.

3.  Assist Regions on case-by-case basis in preparing options  for  CSO  manage-
    ment.

4.  Prepare  a  national  policy for CSO that  assesses  the impact   of  benthic
    loading and downstream impacts  to  impoundments.

5.  Provide assistance in  development of modelling capability that  will  assess
    CSO impacts and  assist in preparing  better  management options  for  CSO
    relief.

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                                      -65- "


CULTURAL EIITROPHICATION AND LOSS  OF  WETLANDS

  Overview of Environmental Problems:

  Three State's  inlake  classification  survey  results  point to  some  general
  conclusions:

                                                                 % of
                            TSI*           Trophic  State          Lakes
  Michigan                    39          Oligotrophic
  (653 lakes sampled)      39-52          Mesotrophic             62%
                              52          Eutrophic              26%

  Minnesota                   41          Oligotrophic             4%
  (543 lakes sampled)      41-50          Mesotrophic             26%
                              50          Eutrophic              69%

  Wisconsin                   47      „    Oligotrophic            14%**  21%***
  (2925 lakes sampled)     47-49      *    01 igo-Mesotrophic      16%     26%
                           50-53          Mesotrophic             30%     25%
                              53          Eutrophic              39%     27%

      *  Average  of  Carlson's  Trophic  State  Index  for  chlorophyll  _a_,  total
         phosphorus, and Secchi  disc for Michigan and Minnesota  only.

     **  Carlson's TSI for chlorophyll _a only.

    ***  Carlson's TSI for Secchi  disc only.

  It is  clear  that   Oligotrophic  lakes,  those that  are  nutrient-poor  and,
  therefore, have quite good clarity, are relatively  few.

  Lakes naturally become  richer in  nutrients  as time goes  on, speeded  up  by
  agriculture, industry,  and  other  intensive  use.  The  conclusion  is that  a
  shift toward  eutrophy  is taking place,  that  overall  lake  water quality  is
  deteriorating.

  Additionally, agricultural, urban and  transportation developments have result-
  ed in the loss of well over  half of the known wetland  resources in the Region.
  This loss  continues  at   an  accelerating  rate  and threatens to  eliminate the
  benefits that the development was intended to produce.

  Problems associated with the loss of wetland resources  are:

  1.  Urban and agricultural flood  damages  resulting from the loss of floodwater
      storage capabilities.

  2.  Decreased  commercial and recreational  opportunities resulting  from the
      loss of fish and wildlife habitat.

  3.  Depletion of groundwater resources resulting from the loss of groundwater
      recharge capabilities.

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                                    -66-


4.  Degradation of surface water quality  resulting from the loss  of  sediment
    and nutrient filtering  capabilities,  and from the depletion of  ground-
    water discharges  that supplement low flows.

Barriers:

1.  Ideological perceptions that wetland  issues are  solely  matters  of  land
    use and property  ownership.  This continued inability to think in "ecolog-
    ical" terms is probably the  single greater harrier to effective  manage-
    ment of our remaining wetland  resources.

2.  Legal and  economic policies at  the Federal, State and Local  levels  con-
    tinue to encourage wetland  losses.   Agricultural  price support  systems,
    flood insurance  programs,  and  inequitable  taxation  policies  make  the
    development of  cheap,  "worthless"  wetlands   a   profitable  enterprise.

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

4.  Resource intensive  studies  required  in  establishing  inter-relationships
    between watersheds and lakes  to  determine eutrophication  causes.

5.  Geo-political   boundaries  may  inhibit, solving  eutrophication  problems.

State/Federal Actions:

1.  Watershed  plans  for   protecting existing  uses  that are  compatible  with
    lake quality and  improving lake  quality  where   non-point  sources  have
    adverse impacts  need  to be  prepared   by  State and  local  entities  with
    Federal  agencies  providing  advice  as requested.

2.  Coordination at  the  State  and local  level is  necessary  to  carry  out
    watershed plans.

3.  Education  programs  regarding  factors  that  have  impacts  on lake  quality
    need to he  established for lake  property owners and watershed communities.

4.  The  level   of  Federal/State  coordination  of  wetlands  issues  must  be
    intensified.  Cooperative  efforts  to  identify  especially  sensitive  or
    threatened  areas   must be  initiated.   Special  efforts  must  be made  to
    encourage potential  developers  to  consider wetland impacts  during project
    planning.

Headquarters Actions:

1.  Management   of  regulatory programs must emphasize  increasing public aware
    ness of the need  to preserve valuahle wetland resources.   Programs design-
    ed to encourage and  facilitate  the consideration  of  wetlands  protection
    in project  planning must  be  developed  and implemented.

2.  Efforts  to decrease  the level  of  Federal  protection  given  to  wetland
    resources must  he resisted  until State and Local  capabilities  to  take the
    responsiblity are developed.

3.  Issue final  guidelines  in  accord  with Section 404(b)(l) for  development
    of permits  for discharge of dredged or fill  material.

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                                      -67-
IN SITU POLLUTANTS

  Overview of Environmental  Problem:

    Inorganic contaminants

    All of the rivers and streams in  industrial areas are known  to  have  sediments
    with some  level  of inorganic contaminants.  Contaminant  levels  vary  from
    insignificant to heavily polluted,  and almost all of the waterways  sampled
    have shown localized areas with  significant contaminant levels.  Waterways
    that have been  shown to  be severely  contaminated  include:

      1.  Ashtabula River, Ohio
      2.  Indiana Harbor,  Indiana
      3.  Grand Calumet River, Illinois  and  Indiana
      4.  Mpnominee River, Michigan  and  Wisconsin
      5.  Fox River, Wisconsin
      6. .St. Louis River, Minnesota

    Organic chemical contaminants

    The list of waterways known  to  have sediments containing  levels of  organic
    chemical  contaminants is continually growing.   Most  of the  existing data  are
    on levels  of PCB  and pesticide  contamination.   However,  more recent  data
    include information on  the  levels  of  some  of the  lesser  know  organic
    chemicals.  Waterways  that  are  known  to  contain  significant  levels  of
    organic chemical contaminants include:

      1.  Waukegan  Harbor, Illinois
      2.  Fields Brook  and Ashtabula River,  Ohio
      3.  Sheboygan River, Wisconsin
      4.  North Branch  of  the Chicago River, Illinois

  Barriers:
  1.  Lack of comprehensive data that will  show  the  full  extent  of  the  problem.
      The data which are now available are scattered, and  are usually the  result
      of an  investigation  conducted  in response  to a  specific  construction
      proposal.  As  a  result,  it is  difficult  to formulate  strategies that will
      address the problem on a watershed, area-wide  or Regional  basis.

  2.  Lack of  funding to  conduct  comprehensive  sediment  sampling and  the high
      cos-t of  adequately disposing of contaminated  sediments has hampered both
      public and private efforts  to  responsibly address  the problem.   Disposal
      options are further limited by the piecemeal  approach to the  problem that
      has so far been  the rule.

  3.  Technological  limitations   in  both  analytical  and  disposal  techniques
      have resulted  in long delays in finding  solutions to  problems  in  specific
      instances where  sediments with suspected or known high levels  of  contami-
      nation were proposed to  be disturbed  by  construction  activities.

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                                    -68-
State/Federal Actions:

1.  Existing sediment data must he compiled in a centralized  location  so  that
    they are  readily  available  for  use  in   developing  control   stratpgies.
    Waterways with known  or suspected toxic or hazardous  pollutant  dischargers
    will have  to  he  sampled  to  determined  areas  of  significant sediment
    contamination and to  fill in data gaps.

2.  Innovative dredging and  disposal  options for highly contaminated sediments
    must he  identified  on  an  area-wide  basis  for both  environmental   and
    economic reasons.

Headquarters Actions:

1.  Regulatory requirements  must  reflect  an understanding that contaminated
    sediments present  problems  unique from those  encountered  in  other situ-
    ations.  Opportunities for* Regional  and  State flexibility in  addressing
    these problems must be provided.

2.  Increased  emphasis must  be placed  upon the  coordination of sediment
    sampling efforts.   Exisiting  data  must   be  made available  for  use  in
    project planning,   and  work efforts  must be  directed  toward   completing
    data collection and interpretation.

3.  Assess  impacts  of  chemically  contaminated  sediment on  aquatic life  to
    determine the need  for sediment criteria  development.

4.  Issue final  guidelines  in  accord with Section 404(b)(l) for development
    of permits for discharge  of dredged  or fill  materials.

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                                      -69-


CONTAMINATED SLUDGE FROM WASTE  TREATMENT FACILITIES

  Overview of Environmental  Problem;

  Municipal  wastewater treatment plants and  industrial  facilities  produce  large
  quantities of sludge.   Ironically,  as  clean-up of  the discharge  continues,
  larger amounts of  contaminated  sludge  are produced.   Improper disposal   of
  these residuals,  if  they  are contaminated  with  toxic or  other  hazardous
  materials, can have adverse  impacts  on surface and  groundwaters.  -Addition-
  ally, incineration  practices  are  frequently  a significant  contribution  to
  atmospheric deposition of  pollutants.

  Sludge lagoons in Gary, Hammond and East Chicago are rapidly becoming filled
  and the sludge is contaminated with  heavy  metals  and PCBs.   Detroit  is  inca-
  pable of  properly  incinerating municipal   sludge.   They have  stored sludge
  on-site at the treatment  plant  for  long  periods  of time  while looking  for
  solutions.  Sludge has  been  discharged'to  the Detroit  River.   Milwaukee  had
  marketed sludge  internationally  as  a  fertilizer/soil  amendment,  but  has
  curtailed  that activity due to high  cadmium concentrations,  creating  a  major
  disposal dilemma.  Cleveland  sludges  contain heavy metals.  Sludge  in  Indian-
  apolis contained  high concentrations  of  PCBs.  Dayton's sludge is contaminated
  with heavy  metals  and  the capacity  to properly  store sludge is  becoming
  severely 1 i mi ted.

  Barriers:

  1.  Process  changes  at  industrial   facilities  cause  extreme  variations  of
      sludge content.

  2.  Pretreatment  systems create  extremely toxic sludges  at industrial sites.

  3.  There  is no national policy or regulations under  Section  3001 of RCRA  and
      Section 405 of CWA to effectively control  sludge.

  4.  There   are  enormous stock  piles  of sludge  that  have not been disposed.

  5.  There is public opposition to locating  landfills  in proximity to residen-
      tial areas.

  fi.  Costs  for hauling and incineration are extremely  high.

  7.  Incineration   technology   is  still  developing  and  may   not destroy  all
      toxicants in  the process.

  8.  Land application of sludge may be satisfactory in many  cases, hut depends
      on local  implementation to ensure  environmentally  satisfactory implemen-
      tation of safe limits on  acceptable sites.

  State/Regional Actions:

  1.  The States need to control  sludge and  septage disposal  via  a permit that
      is enforceable.

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                                    -70-
2.  The States need  to  develop  and implement a residual  waste  strategy  that
    establishes guidelines  to   protect  human  health  and  the   environment.

3.  Assure that  delegation  agreements  reflect  proper  procedures  for State
    level  actions.

4.  States should  develop  State  level  regulations  for sludge   and  septage,
    with Region providing technical assistance.

5.  States should develop and update  a  sludge  handling  amd  management  inven-
    tory and factor into the priority  water bodies  concept.

6.  Critical  problem areas should be defined.

Headquarters  Actions:

1.  Produce final regulations under Section  3001  of RCRA and Section  405  of
    CWA.

2.  Provide guidelines  on levels   of  significance  for toxic contaminants  in
    municipal  sludge for land  application.

3.  Develop a management  strategy  for coordinated  use of sludge guidance  in
    various programs.

4.  Provide assistance  to  the  States  and  the  Region   in  making   necessary
    adjustments to  construction  grants,  pretreatment and permitting.

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                                      -71-


DRINKING WATER - SYNTHETIC CHEMICAL  CONTAMINATION

  Overview of Environmental  Problem:

  Surveys in  Region  V  indicate 25  percent  of the  groundwater  systems in  the
  Region may be expected  to  have  at  least  trace levels of synthetic  chemicals
  present.  Random sampling  of  466  groundwater systems  across  the country  in
  1981 found 16.5 percent of those servicing  a population  under  10,000 to have
  measurable contamination from volatile organic chemicals, and 28.7 percent  of
  the systems serving over 10,000  persons were found to be  contaminated.  Recent
  tests completed on 208 community water system wells  by the  State  of  Wisconsin
  confirms that 25 percent have detectable  amounts  of synthetic chemical com-
  pounds.

  The chemicals being found  most frequently  in the  Region  are trichlorethylene,
  cis and/or  trans-l,2-dichloroethylene,  1,1,1-trichloroethane,  1,1-dichloro-
  ethane and tetrachlorethylene.  These  chemicals  have all   been designated  by
  EPA as being a danger to public health  at low parts per billion concentrations,
  due to toxic and/or carcinogenic effects.

  The VOCs being found in drinking water wells are all due to contamination  of
  the aquifer  by  human  activities.   Many  of the  chemicals being  found  are
  industrial solvents that  have been accidentally  or intentionally  dumped  on
  the ground from spills, dumps or  leaks,  and have filtered  down  to  the  lower
  groundwater levels. Herbicides  and pesticides (atrazine,  aldicarb  et. al.)
  are also found in  drinking  waters  at  concentrations  of 10 to 30 micrograms
  per liter. Attachment R contains a discussion of the aldicarb  being found in
  more than  60  drinking  waters  in  the  Central   Sands   area   of Wisconsin.

  Barriers:

  1.  There- has not  been enough testing  for  synthetic  chemicals to  draw conclu-
      sions on locations, conditions or types of systems  which are most likely
      to he  contaminated.  Also,  in- spite  of accelerated  research,  there  is
      presently no inexpensive surrogate test  for the  presence of  contamination.

  2.  Financial  resources  do not allow for  adequate  sampling.  Only  a  snail
      number of public water supply  systems  are  sampled which results  in only a
      small percentage of the population being protected.

  3.  Lack of health  risk  information on  many organics, may result in inadequate
      recommendations when total impact  is  unknown.

  4.  Lack  of consistency  of data   bptween  laboratories  causes  confusion  and
      reduces public confidence.

  5.  Potential  impact  on major  aquifers  implies  an  extraordinary expense to
      change sources of drinking water or clean  up the aquifer.

  6.  Inadequate public education, resulting in decisions being made on emotion-
      al and  political  pressure  rather than  on   sound  technical   judgements.

  7.  Lack of  control  of  point-of-use water treatment devices.   This  equipment
      has plagued the  market with  inaccurate claims  which  result in  a  false
      sense of security by  an uninformed public.  Also, some devices  may  cause

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                                   - 72  -
    a chronic problem to become  acute  if the unit releases  large  quantities
    of organics  accumulated over time.


8.  Laboratory  staff and  equipment  overload  results   in  time  delays  for
    generating data;  resulting in  pressure  from  data  users  which  promotes  a
    tendency to  take  shortcuts in QA-QC.

State/Federal Actions:

1.  Expand laboratory and  sampling capabilities  to identify problem  systems
    and to verify the results.   The  health  significance of the  levels  found
    will be reviewed  using  drinking water health  advisories.

2.  Investigate  and  respond to  discovered  instances  of synthetic  chemical
    contamination in  drinking water to define the extent of  the  problem,  its
    significance and  degree  of  public  health risk, and  how  to mitigate  any
    danger.

Headquarters Actions:

1.  Provide research  to  improve  laboratory testing  techniques,  further defin-
    ing the health dangers  of the  various substances  and provide  guidance to
    the Regions, States  and water  systems on contaminant removal  techniques.

2. - Promote continued and  enhanced monitoring to  define  the extent  of  organic
    chemical  contamination  in drinking water.  Scientific support  to  clearly
    define the  significance  of  these compounds  and  how to  control  their
    occurrences  and health  risks is vitally  important.

3.  Define  safe levels  of  contamination in drinking water  and define  how
    dangerous levels  of contamination  can be-mitigated. Maximum contaminant
    levels should be  promulgated for synthetic chemicals,  without  a monitoring
    requirement  mandated, as States can best define how to determine where  the
    contamination exists.

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                                     - 73 -
RROUNDWATER - DEGRADATION

  Overview of Environmental  Problem:

  Federal  laws (i.e., RCRA,  CERCLA and the Safe Drinking Water Act)  affect  only
  a snail   amount  of the  total   number  of existing  and potential  groundwater
  contamination sources.   A  serious  problem is  the potential for  groundwater
  degradation from non-federally  regulated  activities.   Of particular  concern
  are the activities which  are either uncontrolled  or ineffectively  controlled
  by States and local agencies.   Examples  are:   agricultural  activities  (pesti-
  cide and  fertilizer application  and  storage),  underground  petroleum  fuel
  storage (gasoline stations), and roadsalting.

  Pesticide contamination  incidents  have  been  identified,   but  also  require
  further study.   The Central Sands area  in  Wisconsin  is an  example. Monitor-
  ing at wells  for  aldicarb  showed  that  levels of  the pesticide were higher
  than health  advisories  allowed.  Additional  monitoring for  other  pesticides
  commonly used in the area  showed that the  levels  in many wells  was above the
  level  considered safe  for drinking water.   This  issue is  addressed  further
  in the emerging issues  section.

  Although it  is  known that corroded, damaged and  improperly  abandoned under-
  ground gasoline storage tanks  are a  significant cause  of groundwater contami-
  nation in Region V  States,  it has been virtually impossible to obtain accurate
  statistics on the  actual  number of  leaks  from these tanks.  State problems
  with underground petroleum fuel  storage  leaks   ranged  from  65  to  200  in
  1980.   State fire  marshals  and  State emergency response  personnel  state  that
  leaks  probably  go  undetected  or  are   not   reported  to   State   officials.

  Our States  are  in  varying stages  of  developing  groundwater  strategies  to
  control  the wide variety of groundwater  contamination sources.  An important
  part of these strategies is the identification of  types of  problems affecting
  groundwater and consideration  of how to prioritize the problems so that  man-
  agement solutions can be effected.

  Barriers:

  1.  Complexity  of  the  issue and lack of data on  the  extent  of the problem.

  2.  Lack of groundwater management  strategies at  State, Regional and National
      levels.

  3.  Regulatory  control  diverse and  spread  between several  agencies and  does
      not necessarily address groundwater degradation issues.

State/Federal Actions:
^^^T ~   ~ " "~ —"^^^^^^^^^-^^^"•

  1.  Develop State  groundwater management strategies.

  2.  Cooperate,  within  resource  limitations,  in defining  nature  and extent  of
      the problem.

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                                   - 74-


3.  Continue information transfer activities  to assist States.

Headquarters Actions:

1.  Effect a  national  groundwater policy to  support  actions  of Regions  and
    States within current resource limitations.

2.  Improve national transfer  of information  to  support Regional  and  State
    efforts. Disseminate, in  a  timely  fashion,  the  results  of  groundwater
    research and  studies.  Conduct  state-of-the-art  groundwater  workshops.

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                                     - 75 -
fiROIINHWATER - UNDERGROUND INJECTION CONTROL

  Overview of Environmental Problem:

  The UIC program will be  directly  implemented  in Indiana, Michigan and Minne-
  sota.  Illinois', Ohio's  and Wisconsin's primary  applications  are  in  final
  review.

  Barriers:

  1.  Helegation of UIC programs lagged  behind  schedule  because of administra-
      tive delays  e.g.,  slow  review of draft  application  and resolution  of
      issues by the Headquarters  Review team and legislative  changes  required
      by the States to insure consistency with Federal  Regulations.

  9..  Direct  implementation  has been delayed  by  the  repeated  postponement  of
      final regulations and major shifts in Headquarters  implementation policy.

  State/Federal Actions:

  1.  Assure  responsive  and timely  response to  the  state primacy  applications.

  2.  In  anticipation of  direct  implementation established   base  activities
      necessary to expedite implementaton.

  Headquarters Actions:

  1.  Provide  national guidance for implementation and  oversight  of delegated
      and directly' run MIC programs.

  2.  Provide  for  a  central  authority  to control  the UIC  application  review
      process and  assure  adequate resources  are  provided to  allow  for timely
      and responsive  reviews.

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                                      -76-



                    REGION V ENVIRONMENTAL MANAGEMENT  REPORT

                                     Part  2

                                  GREAT LAKES
The long retention time  of  the lake waters  is  a  unique characteristic of  the
Great Lakes ecosystem.   The  Great  Lakes constitute a closed system,  unlike  river
systems which discharge water  and pollutants in relatively short times.  This
closed-system nature exacerbates  the three  most  significant  problems  in  the
Great Lakes:   (1) toxic contamination, (2) nutrient enrichment,  and  (3) local-
ized areas  of  impaired use   (Areas  of Concern).  These  three problems impact
human health and impair water uses such  as recreation, water  supply and aquatic
life.

TOXIC CONTAMINATION

There is widespread concern about the contamination of  the Great Lakes by per-
sistent toxic substances  and the serious environmental problems which  can result
from this contamination.  A  history  of fish consumption  advisories based on  the
presence of toxic substances exists on the  Great Lakes.  Reyond this clear threat
to human health, the effects of toxic substances are less well  established  else-
where in the ecosystem. Laboratory  experiments  indicate that  DDT and PCRs  are
adversely impacting lake trout reproduction in  Lake Michigan.

Toxaphene and toxaphene-like substances have been detected in  fish  caught  in
Lake Superior and Lake Michigan between 1977 and  1980 in concentrations which
ranged from 0.4 to 10.9 mg/kg.   (The FDA action  level  is  5.0 mg/kg.)

Metals of concern in  the Great Lakes  are primarily those which can bioaccumulate
and therefore potentially represent,  a threat to  human  health and  the general
ecological  community.   Mercury, tin, cadmium, copper,  zinc and  lead are the pri-
marily concerns for whole lake problems.

Lake Superior

A contaminant problem unique to Lake  Superior  is  that of asbestos-like fibers
in the vicinity of Silver Ray.  Since tailings cover more than  1000 square miles
of lake bottom,  resuspension may  produce measurable levels of  amphibole fibers
in the Duluth area for  many years to come.  High  levels of toxaphene found  in
lake .trout  taken  from  Lake   Siskiwit  (Isle  Royale)  indicate  that  contaminant
problems in Lake Superior remain a serious  environmental  problem.  This concern
is also reflected in the contaminant  levels  in herring  gull eggs, where levels
of PCR and  dieldrin have shown  little change  between  1974 and  1980, as compared
to the Lower Lakes.

Fish consumption  advisories  for  lake trout  (Michigan   waters)  and  all  fish
(St, Louis  River) are in effect.

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                                      -77-
Lake Huron

Analysis of Saginaw Bay gull eggs  shows  elevated  levels  of  TCOD,  approximately
six times higher than  the  "baseline"  levels  in  other  colonies  in Lake Michigan,
Lake Superior and other parts of Lake Huron.  Results from  a  study  by  the  U.S.
Fish and Wildlife  Service  on levels of  PCDD's  in the Great Lakes  support the
findings of the herring gull  study,  in  that residues  of TCDO were highest  in
fish from the Tittabawassee  River and Saginaw  Bay.   Fish  from  both   of these
water bodies contained TCDO  in  excess  of 20 ng/kg,  while a composite of  lake
trout sample from  Lake Michigan,  contained  5 ng/kg.   Fish  from Lake  Superior
and Lake Siskiwit  did  not  contain TCDD  or  other PCDD's in measurable concen-
trations.  Fish  and herring gull  samples  from Saginaw Ray and  fish samples  from
Lake Huron were found to have more complex mixtures  of  PCDD congeners  than the
usual 2,3,7,8-TCDD.

The fishery of  the Saginaw River  System and Saginaw Bay  is  impacted  by  PCB,
PBB, and dioxin contamination.   Fish consumption  bans  are  in effect   for  por-
tions of the  area  .rivers,  and  a fish  consumption advisory  is  in  effect for
Saginaw Bay.  Sediments in  the Pine River are contaminated  with PBB, and sedi-
ments in the Saginaw River  are contaminated  with PCB.

Additional fishing   advisories  for carp,  muskel lunge  (southern  half only) and
trout (southern half only)  exist on Lake  Huron.

Lake Michigan

Persistent organic   contaminants  remain  a  major  environmental  concern in the
Lake Michigan Basin, in spite of substantial  progress in reducing  inputs to the
Lake.

Levels of DDT  in  bloater   chubs,  coh-o  salmon,  lake  trout  and in herring  gull
eggs have declined  by  as much  as 90% between the  late  1960's and 1980, demon-
strating the rapid  response of  the biological system  to  the  1970 ban on the use
of DDT.  However, lake trout  levels still exceed the FDA action level (5 mg/kg),
and only bloaters  were reported  with analytical  concentrations below the U.S./
Canada Water Quality Agreement  objective  of  1.0  ug/g.

Total PCB's  in  lake trout and  coho salmon  also  exceed  the  FDA  action  level
(5 mg/kg), although total  levels in bloaters  is  below the FDA  action level.  No
category of fish was  reported  at levels  below the Water Quality  objective  of
1.0 ug/g.

In spite  of  the ban on the  use  of dieldrin, levels  in  fish  populations  (coho
salmon and lake trout) and herring gull  eggs  ahve not decreased, and concentra-
tions have  increased  in bloater chub,  exceeding the FDA action levels and the
objectives of the Water Quality Agreement.

Fishing advisories  for carp, catfish, salmon, all trouts and whitefish  (southern
half only) are in effect  on Lake Michi'gan.

A major  concern  of the fisheries  in Lake Michigan is that very  few naturally
produced lake trout have been  found  for over a decade.   It has been suggested
that toxic  substances  such  as   DDT  and  PCB  adversely  affect  the  lake trout

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                                      -78-
reproduction.  Recent studies found that cumulative mortality of lake  trout  fry
exposed to simulated  Lake  Michigan levels of  PCS  and DDT for  six months  was
twice that of unexposed fry.  Although  several  factors  probably contributed to
the lack of  natural  reproduction,  levels  of  PCB and DDT  in the  mid-1970's were
sufficient to reduce survival of any fry produced  in the lake.   The added  expo-
sure of the fry to other toxic substances known to  be  present in the lake  could
have further  reduced  survival,  illustrating  the  interactive nature  of  water
quality and resource management throughout the ecosystem.

Lake Erie

Great improvement is  evident for  Lake  Erie.   However,  problems  still exist.
Levels of pesticides, included  DDT  and  dieldrin,  which  showed  substantial  de-
clines prior to 1974, have  not declined  since, suggesting continuing contaminate
input.  The appearance of  mi rex in  Lake Erie sediments in 1979  suggests  a  new
source of  pesticde  contamination.  PCB's  and  DDT  are  major  contaminants   of
sediments in  the western basin,  along with industrial  metals such  as  chromium,
zinc and lead.

While levels  of PCB's in walleye appear to meet Water Quality Agreement objec-
tives (0.1 ug/g), PCB levels are nearly  twice the  Agreement Objective  levels in
perch and approximately  seven times that level  in  coho salmon.   A fish consump-
tion advisory for  carp,  catfish  and  muskel lunge  is in effect  in  the Michigan
waters of Lake Erie.

Lake Ontario

Lake Ontario has a long  history of contaminant problems.   Unique concerns  about
the lake have developed  because  of  local industrial  inputs of  nirex, endosulfan,
and dioxin.  In all  three circumstances, inputs into the Niagara River have  re-
sulted in lakewide problems because  of the geophysical  processes  which  influence
the eventual  fate of these  compounds.

The level  of  dioxin  (2,3,7,8-TCOD)  found in herring  gull  eggs   collected from
four colonies in Lake  Ontario  in 1980 was approximately 60 ng/kg.  This is  about
five times higher than the  "baseline"  levels  in  eggs from colonies in Lake  Mich-
igan, Superior, Huron (except Saginaw  Bay), and Erie.   The  even  distribution of
residue levels among the four colonies suggests that lakewide contamination  has
occurred in the fish  species  (mainly alewives and smelt) which comprise the main
aquatic portion of the herring  gull's  diet  in  the Great Lakes.   The  U.S. Fish
and Wildlife  Service  has reported  that  2,3,7,8-TCDO is present   in  brown  trout
collected near Roosevelt  Beach,  New York.

Fishing advisories are in effect on Lake Ontario for salmon,  trout, catfish  and
smalImouth bass.

Barriers

1.  Lack of coordinated  Great Lakes management strategy for directing  the  toxic
    substances activities being  carried  out by the  Federal, State and local gov-
    ernments  under diverse   pieces  of  legislation,  which has  led to fragmenta-
    tion of purpose,  direction   and  resources   for  addressing these  problems.

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                                      -79-
2.  Lack of a priority ranking of substances  found in  the  Great  Lakes  ecosystem
    which have the greatest potential  to adversely affect  human  and  environmen-
    tal  health.

    a.  Risk of cancer development that  is associated with  toxic  substances  is
        unknown in the Great Lakes Basin.

    b.  Lack of  understanding of  risk  assessment  and acceptable risk  as  they
        relate to control of toxic substances  in the Great Lakes Basin ecosystem.

3.  Lack of  coordinated  assessment processes  among  Great  Lakes  jurisdictions
    with which to design  plans of action or control measures.

    a.  Poor implementation or lack of  a well-coordinated strategy  for report-
        ing, documenting  and assessing waterborne  disease  outbreaks  which might
        be associated with  toxic substances.

    b.  Lack  of  understanding  of  the  chemistry of many  toxic  pollutants.

4.  Inadequate  knowledge of sources,  transport and fate  of toxic  substances.

    a.  Lack of understanding  of  the  mechanisms  of atmospheric  deposition (wet
        and dry) into the Great Lakes.

    b.  Lack of understanding of the flow of  contaminants  from the  lake  sur-
        faces to all  compartments of the Great  Lakes ecosystem.

    c.  Lack of understanding of Great Lakes  tributary loading  and resuspension
        of toxic substances.

State/Federal Actions

1.  Develop a  consistent approach in the  development of  chemical  inventories,
    including what chemicals need to be inventoried, the  data  required, and the
    frequency of updating lists.

    a.  Prepare a  single priority list  of toxic  substances in  the  Great Lakes
        Basin for which inventory data must be  developed,  rank  these substances
        according to  their  potential  environmental and  human  health  effects,
        and periodically  update the list and  the  ranking.

    b.  Establish  a   centralized  mechanism to  identify  all  inventory-related
        activities within the Great Lakes Basin.

2.  Establish a centralized mechanism to identify major compilations of charac-
    teristics-related data within the Great Lakes Basin.

3.  Improve the capability  to develop toxicological data.

    a.  Develop  a priority  list  of toxic substances  of  significance  for the
        Great Lakes  Basin  for which  characteristics  data should be  gathered.

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                                      -80-
    b.  Continue efforts to develop and use structure-activity  correlations  and
        the new  screening  tests for  toxic substances occurring  in the  Great
        Lakes Rasin.

4.  Reduce duplication of effort and utilize resources  more  effectively  in  toxic
    substances monitoring programs.

    a.  Coordinate the monitoring  and  surveillance programs among the  States,
        local jurisdictions and  Canada, in  order to support  the Great  Lakes
        International  Surveillance  Plan (GLISP) and to respond to the  require-
        ments of  Annex  12  of  the   1978  Great Lakes  Water Quality  Agreement.

    b.  Develop a joint priority list for  toxic substances  that  require immedi-
        ate environmental  measurements.

5.  Improve hazard and risk assessment capability.

    a.  Activities in  the areas of monitoring, inventory  preparation, short-term
        toxicity testing and epidemiology  should be intensified.

    b.  Share all available scientific data and their scientific  rationale  for
        each assessment of  hazard and of risk.

Headquarters Action

1.  Support  research  programs  directed toward the quantitative measurement  of
    the effects of exposure to ambient levels  of  toxic substances.   Coordinate
    research activities in  order to acquire the information needed for  priority
    setting and hazard assessment  (including development  of screening  systems,
    such as structure-activity  relationships).

2.  Support long-term research  on  the  impacts  of ambient  levels  of  toxic sub-
    stances on human  health in  order to establish management and  control alter-
    natives for these  substances.

    a.  Need to  develop ecosystem  studies  of the transport, fate, and  effects
        of ambient levels  of toxic  substances in  the  Great  Lakes.

    b.  Need  to  develop ecosystem tests   to  determine  the propensity  of  new
        chemicals to  bioconcentrate, and predict  ultimate  levels  in  humans  be-
        fore each chemical  licensing.

3.  Support research  on the atmospheric deposition of  toxic substances  in  ordpr
    to better assess  hazard and develop effective  control strategies.

    a.  Conduct joint  field and research  programs with  the States  and Canada
        into the atmospheric deposition of toxic  substances,  in order to con-
        duct scientific assessments and refine control strategies.

    b.  Develop  mnrp   degradable   chemicals  to  do  similar industrial   jobs.

4.  Accelerate development  and  implementation  of  programs  to control the  manu-
    facture and use of toxic substances in  the  Great  Lakes  Basin.

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                                  -81-
a.  Accelerate development  of  ways to  manage  the disposal  of toxic  sub-
    stances.

b.  Accelerate development of management techniques which will  prevent  dis-
    posal  of  toxic substances directly into the Great Lakes or other waters.

c.  Develop a  coordinated  control  strategy for the  atmospheric deposition
    of toxic  pollutants, and evaluate whether  legislative  changes  are  re-
    quired to  address  the problem of atmospheric deposition to the Great
    Lakes, including both  the  States and  Canada  in strategy  development.

d.  With Canada  and the  States  develop a common definition of  hazardous
    waste, and develop compatible programs  to ensure  the  safe transport  and
    disposal  of hazardous wastes  among the  jurisdictions.

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                                      -82-
NUTRIENT ENRICHMENT

Overview of Environmental  Problem

Accelerated cultural  eutrophication of the Great Lakes caused  by  increased  nu-
trient loadings has had detrimental effects on recreation,  water supply,  fresh-
water biota and wildlife.   An  increase in the supply of  nutrients  changes  the
population structure of the  aquatic  biota, the functioning of  an  aquatic  food
chain that supports lake  fisheries.,  or causes extensive algal  growth with  the
consequent deep water depletion of oxygen  which  supports  game fish  production.
The character of populations of shore  birds  and  animals in  turn is  greatly  de-
pendent upon the population characteristics of the  lake  fisheries.

Lake Michigan

The open  waters  of Lake  Michigan have  suffered  considerable degradation  in
trophic condition hut  are  still of high quality  with  some  evidence  of  improve-
ment in the last 10 years.   Acute  problems are localized in nearshore areas  of
the lake.  Increases in chlorides, sulfates,  blue-gre-en algae and  phytoflagel-
lates in  the  southern  basin of  Lake Michigan indicate  that  the system there
suffers from cultural  nutrient  enrichment.

Lake Erie

Accelerated eutrophication of Lake Erie has been a critical water quality con-
concern since the early 1960's.  An analysis  of Lake  Erie  water quality  for  the
past decade indicates   a general  improvement,  due in  part to high water  levels.
There have also  been major reductions in  phosphorus'  loads  to the  lake -  from
23,000 metric tons in  1970 (all sources)  to 13,000  tons  in  1979.

Concentrations of total phosphorus in  the  western, central and eastern  basins
have shown significant declines since  1970.   However, the decline has not been
entirely proportional  to  reductions  in  phosphorus  loading from point  sources.
This can partially be  explained by  phosphorus  release from  the sediment  through
wave resuspension  and  anoxic  regeneration.    (It  has been  demonstrated that
approximately 80%  of the  phosphorus  loading  to Lake  Erie  becomes  incorporated
in the bottom sediments.)

Canada has achieved the municipal  phosphorus  loading  goal  specified  in  the 1972
Water Quality Agreement.   The U.S.  has only three Ohio plants on  Lake  Erie, lar-
ger than 20 MGO,  which have not yet achieved  the  1.0 mg/1  limit objective  of
the Agreement.  There  are  approximately 50 smaller  noncompliant  facilities.  The
1978 Water Quality Agreement calls for further phosphorus  reductions, and  the
U.S. and Canada are currently  negotiating  new target loads  to meet these load-
ing objectives.   While  definitive  loading allocations have  not been  agreed upon
yet, the outcome of negotiations will  require  further reductions on the  part  of
both countries.   Numerous  no-till  and associated  soil  conservation  and CSO dem-
onstration programs are in place in this  basin, but existing programs  for long-
term control   of agricultural  erosion  and  combined   sewer  overflow  pollution
are not adequate to effect the  load reductions proposed.

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                                      -83-
Lake Huron

Eutrophication is not considered to  be  a  severe environmental  problem in Lake
Huron except in  localized  nearshore  areas  and in  Saginaw Bay,  which  now is
classified as moderately eutrophic.

Runoff from agricultural land in the Saginaw River Basin contributes  suspended
solids, nutrients,  organic  matter,  and pathogenic  organisms to  Saginaw Bay.
Siltation and associated turbidity degrades fish habitat,  fills  surface  drain-
age ways, and fills  the main navigation channel from the Bay into the Saginaw
River.  The nutrient and organic matter contributed  by  agricultural  activities
adversely affects the dissolved oxygen level  in the  Saginaw River.

To meet the phosphorus  load  reductions specified in the 1972 Water Quality Ag-
reement, an additional  130-150 tons  of  phosphorus  must  be  reduced  primarily
from nonpoint source  loads  to  the  Bay.   While a major agricultural nonpoint
source demonstration  project  is in  operation  in  the area, there  are no firm
requirements in place or planned  for long-term control  of excessive nonpoint
phosphorus loadings  from the Saginaw River tributaries.

Lake Ontario

Eutrophication of Lake  Ontario was a  major  concern  identified in  the  1980's by
the United States and Canada.  As  a  result of phosphorus  control  programs, some
localized areas, such as the Bay of  Quinte and the Toronto  waterfront, have  re-
sponded immediately  with improved water quality.  The  open waters of the lake
have responded with  small reductions  in the total phosphorus concentration  and
a reduction in total  hiomass in the western portion  of the lake which has been
maintained since 1975.   Phosphorus levels  in the nearshore zones  of Lake Ontario
appear to  have  stabilized,   having  declined from elevated levels observed in
1967.  Further reductions in  phosphorus  loading  are necessary  to  reach  the level
of algal biomass agreed  to  by the U.S. and Canada.

Only two U.S. plants  (larger than  20 MGD)  have  not yet achieved the 1.0 rng/1
objective in the Lake Ontario Basin. There are about  25  smaller  noncompliant
facilities in the  basin. The  1978  Water Quality Agreement  calls for further
phosphorus reductions,   and  the U.S. and  Canada are currently  negotiating  new
target loads to  meet these  loading  objectives.  While definitive  loading  allo-
cations have  not  been   agreed  upon  as yet,  the outcome  of  negotiations will
require further reductions  on the part of  both countries. No-till  and  associat-
ed soil  conservation and  CSO  demonstration  programs  are  in   place in this
basin, but programs   for  long-term control  of  agricultural  erosion  and combined
sewer overflow pollution are not adequate  to effect the load recutions  proposed.

Barriers

1.  Phosphorus  load  reduction plans  are  needed to  manage control programs in
    Lakes Erie and Ontario  and Saginaw Bay and Green Bay.

2.  Nonpoint  sources  are the major  remaining  obstacle  to  adequate control of
    accelerated eutrophication in the major problem  areas.

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                                      -84-
    a.  Agricultural runoff is by  far  the  largest  of  the  nonpoint  sources, and
        are the dominant sources in Lake Erie and Saginaw  Ray.

    b.  Although practices and programs for control  of agricultural  runoff have
        been successfully demonstrated  by  USEPA, U.S. ACOE and  USDA,  existing
        support for agricultural nonpoint  source control  practices  is  not ade-
        quate to protect the Lakes.

    c.  An  accelerated  control program  is needed throughout  the  Great  Lakes
        Basin.

3.  Municipal treatment plant compliance with the 1  mg/1 phosphorus  requirement
    by presently noncompliant plants is needed to provide  important  further re-
    ductions in municipal loading.

4.  Municipal wastes escaping treatment through system overflows, plant bypass-
    es and  plant  upsets pose  a  serious problem,  often  exceeding  the  loading
    from treated effluent. They result in  excessive loads to  the Lakes  and  in
    non-attainment of many local  areas.

    a.  Low priority given to combined sewer overflow  projects  prevents control
        of many of these sources.

    b.  Lack of  detergent  phosphate bans  in  Ohio,  Wisconsin  and  Pennsylvania
        allows high levels  of phosphate to  reach the  Lakes  from these  uncon-
        trolled sources.  Absence  of  detergent phosphate  controls  also  allows
        heavier phosphate loading  from treatment plants   of less  than 1  MGD,
        which are not  uniformly regulated for control  of  phosphorus.

5.  Alternative technology is needed for cost-effective control of  urban  runoff
    and combined sewer  overflows.   This  requires demonstration of  the  technol-
    ogy at project scale.

State/Federal Actions

1.  Load reduction plans should be jointly developed for Lakes Erie and Ontario.

    Implementation of   Lake   Erie   and  Lake  Ontario phosphorus  control  plans
    through appropriate Federal and State agencies.

2.  Continue expanded  demonstration of agricultural  nonpoint  source  controls  in
    31 counties  of  Lake Erie  Basin,   identifying  critical  areas for  controls
    throughout the Rasin along with requirements for necessary  levels  of  imple-
    mentation.  Encourage funding development  by  appropriate State  and  Federal
    agencies to assure  expansion  and continuation of control project  when  demon-
    stration is complete in 1985.

3.  Continue Saginaw Ray Monitoring and Evalution Project  to  identify  necessary
    agricultural pollution controls for entire  Saginaw Rasin on  a cost-effective
    basis.  Based on experience gained from M & E project,  develop and  implement
    this balanced plan  for phosphorus  and sediment pollution abatement  for  point

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                                      -85-
    and nonpoint sources.

4.  Continue Green  Bay Monitoring  and Model Development  Project to  identify
    phosphorus  control  needs  and restore fishery  throughout  the Bay.


5.  Complete setup  of  Lake Michigan  model  at RTP  for purposes  of  management
    runs» so as to identify supplemental phosphorus and other  control  needs  in
    the southern basin of  Lake Michigan.

6.  States  should  maintain  schedules  for bringing  major  noncompliant  sewage
    treatment plants into  compliance by 1983.  States  should  advance schedules
    for all  noncompliant facilities  so phosphorus  controls guaranteed  in  1978
    Water Quality Agreement  are  met.   USEPA  matching funds   should  be  made
    available for these construction projects on  a  priority  basis.

7.  States  should  give priority attention to combined sewer  overflows  in the
    Great Lakes receiving  waters, so as to gain funding from available sources.

8.  Where detergent phosphate  limitations  are not  in  place, States  should re-
    consider implementation of such a ban on  a voluntary basis.

9.  Develop   additional  remedial  programs to  address  combined  sewer overflows
    and urban  land  runoff  (including appropriate  assessments of  degradation
    and benefits).

Headquarters Action

1.  Support  continuation and completion of agricultural nonpoint sources demon-
    stration projects  for  Lake Erie and Saginaw Bay.

?..  Support   combined  sewer overflow abatement projects and development  of new
    technologies to abate  impairments at less cost.

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                                      -86-
AREAS OF CONCERN

There are localized areas in the Great Lakes Basin where environmental  quality
is severely degraded.   Although these areas constitute only a  relatively  small
portion of the total  area of the Basin, they contain  a  large percentage  of  the
Basin's population and  industry  and are  concentrated loading  points for many
pollutants.

There are 14 Class A  Areas of Concern in  the U.S.  (areas  exhibiting  significant
environmental degradation, where impairment of  beneficial uses is severe),  and
10 Class B Areas  of Concern  (areas  exhibiting environmental degradation,  where
uses may be  impaired).  Criteria uses for  this  evaluation were:  Agreement  ob-
jectives or  jurisdictional  values  violated;  the magnitude,  persistence,  and
geographic extent of the violation; age of the data;  uses  impacted; relationship
of violation to current discharges  and transboundary  implications of  the pollu-
tion.

Table 1 lists the Class A  and Class B Areas of Concern, while Table 2  summarizes
for each Class  A  Area of Concern the  sources  of pollution, the environmental
problems and consequences and the remedial measures planned or implemented  for
the area.  A summary  of Class B Areas of  Concern, together with their environ-
mental problems, is included  in Attachment A.

In the  majority  of the Areas of  Concern, the  programs   currently in place  are
not adequate to  solve the  environmental  problems identified.   Where  further
measures are in the process  of implementation   for those  few Areas  of  Concern
that may resolve the problems, restoration of water  uses  will  not  occur for  a
long period of time,  up to a  decade.

In the Class A  Areas  of  Concern,  inadequate measures exist  for some or all of
the following remedial  programs:   municipal  and industrial  dischargers, waste
disposal sites,  combined  sewer  overflows   and urban  land runoff,  agricultural
land runoff, and in-place pollutants.

Specifically municipal and industrial  dischargers  are not  adequately  controlled
in the  Grand  Calumet  River/Indiana Harbor Canal;  while  pretreatment programs
are inadequate  at  the  Black River,  Ohio; Buffalo  River,  New  York;   Niagara
River, New York; and Massena, New York.   Toxic  substances fron unsecured waste
disposal sites are inadequate at the  Grand Calumet River/Indiana Harbor Canal
area; the Black River and Cuyahoga  River,  Ohio; Ashtabula River, Niagara River
and the St. Lawrence  River at Massena, New York.

In 17 of 18  Areas  of  Concern,  in-place  pollutants  are contributing  to  the  He-
graded state of  these locations.   While  natural processes will eventually  re-
store the  ecosystem  in the  Great Lakes  connecting   channels,  it  is doubtful
whether the Grand  Calumet River/Indiana Harbor  Canal; the Rouge  River  and  the
Raisin River, Michigan; the Maumee  River,  the Cuyahoga River, and the Ashtabula
River, Ohio;  the Buffalo  River, New York  will be  fully  restored to  the  quality
levels called for  in  the 1978 Great Lakes Water  Quality Agreement.  In these
areas, even with  implementation of  all  practical  remedial measures   to  control
discharges, sediments  will remain  degraded because of  past pollution.

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                                      -87-
Areas which need construction to  effect  load  reductions  and water quality  im-
provements for a  wide variety  of pollutants  originating  from  combined  sewer
overflows and urban land  runoff  are the  Rouge River  Basin, Cityof Detroit,
and the Grand Calumet  River/Indiana  Harbor  Canal  area.  Continued funding  for
demonstrations of the  cost-effective  reduction  of pollution from  agricultural
land runoff is not assured for the Saginaw Ray/Saginaw River Basin, the Maumee
or Sandusky River Basins,  where  assessments  have  shown  agricultural  pollution
is an important  factor in  impairment  of  water uses.   No  long-term  programs  are
in place in these  areas  to control  this  agricultural  pollution  in the future.

Barriers

1.  No  remedial   measures  are planned  by  some  States  to effect  cleanup of some
    Areas of Concern.

2.  Necessary facilities  will  not  be operational within  five  years  in  some
    Areas of Concern.

3.  Release of toxic  substances  is  not  controlled in a  cost-effective manner.

    a.  Remedial  action is presently  conducted on  facility-by-facility or sub-
        stance-by-substance basis.

    b.  All  jurisdictions  lack  a  comprehensive management  strategy  for  toxi-
        cant control.

4.  CSO  and  urban  land  runoff  contribute  nutrients, bacteria  and  untreated
    waste directly into receiving waters  of  the  Great  Lakes.

    a.  Impairments  and/or extent  of  impairment are   not  fully  identified.

    b.  Where impairments  are  identified, they are  only partly corrected  in
        some areas.

    c.  Construction programs which  are  under way, planned, or being studied
        are very  expensive,  will entail   a  long  time-lag  for  completion,  and
        are dependent on availability of  funding.

5.  Agricultural   runoff  impairs  uses  in  two Class A Areas  of  Concern (Saginaw
    Bay, Michigan; and Maumee River,  Ohio).

    a.  Demonstration  programs have  no  assurance  of  funding  to completion  of
        project.

    b.  There are now no long-term follow-up programs  planned or on-line by  the
        States to control agricultural pollution in these areas.

6.  Even with implementation of  all  practical  remedial measures, in-place pol-
    lutants from  past  discharges will contaminate  the  sediments  in all  U.S.
    Class A Areas of Concern.

    a.  Dredging of some Areas  of Concern will  have  limited  beneficial  effects.

-------
                                      -88-
    b.  Technology for restoration has not been sufficiently researched or
        demonstrated.

    c.  Local and lake-wide impact of in-place pollutants needs to be quantfied
        and feasibility of remedial methods determined.

7.  Development of estuarine models to direct remedial  activities is inadequate
    and unsupported in most of the areas of concern.

State/Federal Actions


1.  Priority for cleanup:   all identified Areas of Concern should be a matter of
    priority attention for USEPA, the States and local  governments.

2.  The States and USEPA will develop Area of Concern Pollution Abatement Action
    Plans that will  be directed toward control of municipal  and industrial faci-
    lities, pretreatment implementation, controlling  the negative impacts of in-
    place pollutants, and abatement of agricultural and  combined sewer overflows
    causing water quality  impairments.

Headquarters Actions

1.  Implement recommendations for Headquarters Action in previous Toxic Contami-
    nation and Nutrient Enrichment sections.

2.  Provide support for research and demonstration of Best Management Practices
    for control  of toxicants from in-place pollutants.

3.  Provide research and development support for modelling estuarine regimes
    sufficiently to direct remedial efforts in Great  Lakes harbor-estuary Areas
    of Concern.

4.  Provide through R fit D  adequate quality assurance  support cheaper and less
    time-consuming organics analytical methodology, and  an improvided toxicolo-
    gical data base, so as to direct remedial  efforts in Areas  of Concern effi-
    ciently and  cost-effectively.

-------
                                      -89-
                  CLASS "A" AND CLASS "B" AREAS OF CONCERN
        CLASS "A"                                   CLASS  HB'
                             LAKE  SUPERIOR  BASIN

None                                         St.  Louis  River, Minnesota
                                             Thunder  Bay, Ontario
                                             Nipigon  Bay, Ontario
                                             Jackfish Bay, Ontario
                                             Peninsula  Harbour,  Ontario

                             LAKE  MICHIGAN  BASIN

Fox River/Southern Green Bay,  Wisconsin      Manistique- River, Michigan
Milwaukee Estuary, Wisconsin                 Menominee  River, Michigan-Wisconsin
Waukegan Harbor, Illinois                  vSheboygan,  Wisconsin
Grand Calumet River and                      Muskegon,  Michigan
  Indiana Harbor Canal, Indiana              White  Lake,  Montague,  Michigan

                    /          LAKE HURON BASIN

St. Marys River, Michigan and Ontario        Spanish  River Mouth, Ontario
Saginaw River System and                     Penetang Bay to Sturgeon Bay,  Ontario
  Saginaw Bay, Michigan                      Collingwood, Ontario

                               LAKE ERIE BASIN

St. Clair River, Ontario and Michigan        Clinton  River,  Michigan
Detroit River, Michigan and Ontario          Wheatley Harbour,  Ontario
Rouge River, Michigan
Raisin River, Michigan
Maumee River, Ohio
Black River, Ohio
Cuyahoga River  (Cleveland), Ohio
Ashtabula River, Ohio

                              LAKE  ONTARIO  BASIN

Buffalo River,  New York                      Eighteen Mile  Creek,  New York
Niagara River,  New York and Ontario          Rochester Embayment,  New York
Hamilton Harbour, Ontario                    Oswego River,  New York
                                             Toronto Waterfront, Ontario
                                             Port Hope, Ontario
                                             Bay of Quinte,  Ontario

                              ST.  LAWRENCE  RIVER

Cornwall, Ontario-Massena, New York          None

-------
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                                   -91-
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                                      -93-

                    REGION V ENVIRONMENTAL  MANAGEMENT  REPORT

                                     Part 2



                                EMERGING  ISSUES
ACID RAIN

  Overview of Environmental  Problem:

  The Region is an alleged source and a concerned  recipient  of  acid  deposition.
  Numerous studies and  lawsuits  have alleged  that midwestern  coal-fired  power
  plants with tall-stacks and high SOg emissions are  responsible  for a  signifi-
  cant amount  of  the  acid   rain  falling  in  the  Northeast U.S.  and   Canada.

  On the other hand,  Upper Michigan,  Northern  Wisconsin,  and Northern Minnesota
  also contain lakes  that are susceptible to acidification.   This has generated
  considerable concern by these States,  leading to intensive research  programs
  in Wisconsin and Minnesota with  actual acid rain  legislation being  promulgated
  in Minnesota.

  Barriers:

  1.  No direct mandate under the Clean Air Act  to control sources on the  basis
      of acid rain impacts.   The Act  directs EPA to ensure attainment and  main-
      tenance of  the  National   Ambient  Air Quality  Standards  (NAAQS).   Since
      there is no NAAOS  for  acid  rain, EPA has  no statutory authority  to  base
      controls solely on acid rain impacts. Furthermore, even  though acid rain
      is alleged  to  be a long-range transport  problem,  the interstate impact
      provisions of  the Act  (i.e., sections 110  and 126)  apply  only  to  criteria
      pollutants.

  2.  Considerable  uncertainty   in  the  existing   monitoring   data,  inadequate
      quality assurance,  inconsistent  measurement techniques,  and the   lack  of
      valid historical  records  at the same sites  are particular problems  with
      the existing data bases.  Because the data  are  so questionable and  frag-
      mentary, considerable  controversy  has surrounded  several  recent  studies
      which have  suggested that there has  been  a  significant  increase  in  both
      precipitation acidity in the Northeast and in the size of  the area receiv-
      ing acid rain  over the past few decades.

  3.  Lack  of  complete scientific understanding  of the  transport,  transforma-
      tion, and removal  processes exist.   As such, there is  no widely  accepted
      theory on which  to base modeling techniques.   For this  reason,   many  of
      the existing  models  are   very  simplified,   involving a  few  reasonable
      assumptions with  the  limited knowledge  to date.  Furthermore, since the
      existing data  bases are so imcomplete, there are not  actual field data to
      evaluate the performance  of the current models.  Therefore, the  accuracy
      of these models is unknown.

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                                   - 94-

    The consequences of having no reliable models are two-fold for regulatory
    purposes.  First, the effect of SO? emission  reductions  on  acid  rain im-
    pacts cannot he  accurately  quantified.   Most current models  have  had  to
    assume a linear transformaton; thus,  implying a  one-to-one  relationship.

    Since the transformation  process  is  generally accepted  to  be nonlinear,
    the true effect of a given reduction in S02 emissions cannot be estimated
    with any certainty.

    Second, source culpability  cannot  be  accurately  quantified.   Not  only  is
    there uncertainty in estimating the relative  local and long-range impacts,
    but individual source impacts are also questionable.  Thus, the develop-
    ment of  detailed   control  strategies   based  on  the  currently  available
    models is highly suspect.

4.  Uncertainty in  local  vs. long-range  culpability exists.   Although  acid
    rain has been  alleged to he  a long-range transport problem several  recent
    studies cast doubt upon this theory.  One  study  conducted at the Univer-
    sity of  Rhode  Island attributed  Northeast  acidity  levels  primarily  to
    local sources.  A  study  of  St. Margaret's Bay,  Nova Scotia  traced  over
    half of  the acidity in  precipitation  there  to  Halifax,  located  fifteen
    miles to the east.   A New York  study found  relatively  similar levels  of
    acidity in  precipitation regardless of wind direction.

5.  Problems with  measuring  dry  deposition exist.  Much of  the data collected
    to date have' focused on  measuring the wet deposition of  acid materials.
    Several studies  have  pointed  out that  dry   deposition  can   be  equally
    important.   No widely  acceptable  technique  exists,  however,  to  measure
    since measurements of total  deposition are not available.

6.  Lack  of  statistically  significant relationships  between  acid deposition
    and actual  effects  on   crop  and  forest  productivity exists.  Acid  rain
    mobilizes toxic metals  which can  then  be taken up  by plant  roots;  strips
    soil of  valuable  nutrients   such as  calcium,  magnesium,  sodium,  and
    potassium;  kills various  micro-organisms,  thus depriving the  soil  of  an
    important source of nitrogenous nutrients; as well as causes  direct  damage
    to plant leaf, stem, and/or  root systems.  On the other  hand, the sulfates
    and nitrates in acid rain can provide  fertilizing benefits.   These  short-
    term benefits  are  masking the harmful  long-term effects  which  are  not
    known.

7.  Enormous costs  of  controlling  S02  (and  NOX)  emissions to   the  degree
    required by various congressional  bills exist, in view  of the uncertainty
    of the true effect on reducing acid rain.  Not only  is  there doubt about
    whether these  bills  will  be  cost effective,  but whether these  measures
    will produce any environmental  results.

8.  Uncertainty over  the  background acidity levels  in  precipitation  exists.
    "Pure" rain is defined  as having  a pH  of  approximately  5.6.   Rainfall  in
    remote regions of  the  world, however,  is  often  well  below  this  value,
    with average values in  the range of 4.5-5.5.

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                                   - 95-

State/Federal  Actions:

1.  Continue to  develop  scientific data  bases.  This  includes the  Region's
    Great Lakes Air  Deposition  (GLAD)  network and  our participation in the
    National Atmospheric  Deposition Program.  Better data  are necessary not
    only to improve  our understanding  of  the physical  and  chemical  processes
    involved,  but also  to  establish more  accurate trends  in acidity.

2.  Reconsider the  need   for  separate  State actions.   Although  individual
    State research projects may  prove to  be  beneficial, individual  State  acid
    rain standards and  control  plans could lead to confusion  and  inconsisten-
    cies.  Interstate pollution problems  are better  handled  on a  national
    level.

3.  Establish a regional  program on acid  rain.  At  first,  this program would
    try to develop  regional  goals  (i.e., data collection,  such  as the  GLAD
    network) and   ascertain  the effects   of  current congressional  bills  on
    Region V.   The attempt of this  first phase would be  to put Region V  in  a
   -contributing  mode,  to  provide  information on  specific  economic,  environ-
    mental issues to Congress (e.g., the effects  of specific  control options
    such as coal   washing  on Region V  SO^ emissions and  on Region V utility
    bills).  We would  coordinate  our  efforts with  Headquarters  and welcomp
    the active participation  of each  State.  Although  this  initial  phase
    would not  be  designed  for regulatory  actions, it would put us  in a posi-
    tion to act accordingly if the  congressional bills are incorporated  into
    the CAA.

    The second and any  following phases would be  based  on the information and
    legislation considered  in  the   first phase,   and   directed  according  to
    these two items.

    This program   would put the Region  in  a middle-ground  between the two
    current polarized  sides on  the acid  rain  debate:    more  research and
    mandated large S02 reductions.   By remaining unbiased, Region V  can  con-
    tribute scientific  and  economic information  necessary  for Congress and
    the Agency to act wisely in  solving the  acid  rain problem.

    Furthermore,  most  environmental  action  has  been  taken  in  the  face  of
    uncertainty.   The very  nature  of  science  dictates  that we will  never  be
    able to establish  an  absolutely  certain cause and  effect  relationship
    between man-made emissions of  SC>2  and NOX  and   acid  deposition.  Thus,  a
    regional acid rain program would be  a step  forward  in dealing  with  this
    problem.

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                                     - 96 -

AIR DEPOSITION OTHER  THAN ACID RAIN - GREAT  LAKES  AND  OTHER  INLAND  LAKES

  Overview of Environmental  Problem:

  The International Joint Commission's Pollution from Land Use Activities  Refer-
  ence Group  (PLUARG)  - in  a preliminary  effort  to model  the transport and
  deposition of airborne materials  -  found that  the  amounts  of material deposi-
  ted from  the atmosphere  into  the  individual  Great  Lakes  were  generally
  proportional to  the lake  surface  area.

  PLUARG,  for  example,  calculated  that the  atmosphere  contributed about'1600
  metric tons of phosphorus in 1976  to  both Lakes Superior and Michigan.  The
  1976 phosphorus  input  to  Lake  Huron was  about 1100  metric tons.  Even the
  relatively small  surface areas  of  Lakes Erie  and  Ontario received about 800
  and 500 metric tons  of phosphorus,  respectively,  during this period.   It  is
  clear that the nutrient budgets  of the Upper  Lakes  must  consider atmospheric
  loading.

  Studies  undertaken  by  the  Upper  Lakes Reference  Group, as  well as PLUARG,
  indicate that a  variety of  other  contaminants  are  also  contributed in part  by
  atmospheric sources,   including  nitrogen,   lead,  copper,  sulfates,  PCBs and
  other synthetic  contaminants.  The  deposition  of  metals, most significantly
  lead, contributes a large  portion of the loading to  all  of  the lakes.   PLUARG
  (1978) reported  that the non-point  sources  of lead  dominate the  loading, the
  atmosphere being the chief  pathway  (Table  4).  Mercury,  tin, cadmium, copper,
  zinc and lead are  the primary  heavy metal  concerns  for whole lake  problems
  because of elevated  levels  and/or  the  ability to  bioaccumulate.   The deposi-
  tion of  synthetic  contaminants  such as PCBs has  been  shown to be sufficient
  to account  for  the  levels  contained  in  the  lakes  (Strachan  et  al,   1978;
  Hollod,  1979).   While urban areas  are  major sources of PCRs, the widespread
  dispersal  of this  contaminant  throughout  the  entire  sediments  of the   Great
  Lakes, including  areas remote  from industrial  centers, indicates the  impor-
  tance of atmospheric transport  of PCRs  throughout  the  entire Basin.

  Soil particles reach  the Great Lakes via atmospheric  deposition from construc-
  tion sites, plowed  agricultural  lands  or other cleared  land surfaces.   These
  soil particles  serve as input to any water area through atmospheric deposi-
  tion.  At  this time no baseline data exist documenting this source of  pollu-
  tion to  the lakes.

  Barriers:

  1.  Lack of  information  on atmospheric sources and  loadings  of major  metal
      and  toxic contaminants.

  2.  Lack of reliable  monitoring data.
      a. Accuracy  and  precision  of devices   to  measure  atmospheric deposition
         are uncertain.
      b. There is no  consensus as to  what an  adequate  monitoring network  should
         be  to monitor  total  atmospheric  deposition.
      c. Baseline data  for  ambient  levels are weak.
      d. Limited resources prevent implementation of  intensive sampling required
         for an adequate monitoring network.

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                                    -97-

3.  Fate of transported materials  is not well  understood.
    a.  Movement of materials across air/water interface is  poorly  understood.
    b.  Movement of materials between surface films and other aquatic compart-
        ments is poorly understood.
    c.  Resuspension  via aerosols and  other  mechanisms is  poorly  understood.
    d.  Net loading  budgest  are virtually unknown.

4.  Lack of  information on  health  effects of substances inputs to  the  Great
    Lakes by means of  atmospheric deposition.  Although many  of these  com-
    pounds are known  to have detrimental  health effects, such potential may or
    may not  be  realized under the  exposure  conditions experienced in  the
    Great Lakes Basin.

5.  Control programs  are inactive  or nonexistent.
    a.  There is no direct  madate under the Clean Air  Act to control  sources
        of atmospheric  deposition  on the basis of  their water quality impair-
        ment.
    b.  Use  of  State  issued NPDES  permits  (as  authorized  under the  Federal
        Clean Water Act) to  control stack emissions which impact water quality
        has not yet  been tried  or tested.
    c.  Cost effectiveness  data  for  control  strategies are not  available.
    d.  Control strategies  based  upon water  impacts  do not  exist.

State/Federal Actions:

1.  Continue support for  GLAD  and NADP  network  (with  support  of  all  States
    that wish to  participate  in this  monitoring  effort),   with  the  view  to
    provide historic  baseline  data  for  wet  and  dry  sample collections,  to
    evaluate the past bulk  sample  collections, and  to  obtain a  specific  Great
    Lakes Rasin data  base.

2.  Continue  cooperation  with Canada  to monitor  and  analyze  atmospheric
    deposition by providing comments and recommendations relative  to Canadian
    data and reports  and sharing  U.S. data,  reports  and analyses.

3.  Request all  State Governors to examine closely  (and to apply their author-
    ity to deal with) atmospheric  deposition  problems  originating  within each
    State's boundaries, carefully  considering the  innovative   use   of  NPOES
    permits to control  toxic and  metal  air  pollution  of the waters  of  their
    State.

Headquarters Action:

1.  The  Office of Research and  Development  must  initiate  research  focused
    upon airborn toxicants  including sources  of contaminants, air  deposition,
    transport, monitoring  and modeling.

    a.  Support additional   research to better quantify current  land and  water
        based ambient  concentration  and  loading  data  for   air  contaminants.

    b.  Support additonal  research for improving atmospheric deposition models
        and measurements of atmospheric participate concentrations,  as  well
        as to  improve  the  accuracy  and precision of  atmospheric deposition
        samplers.

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                                    -98-

    c.  Support  additional   research  to  identify   sources  and  loadings  of
        important atmospheric contaminants,  so  they  can  be  controlled.

    d.  Support  research  on  control strategies  and  costs  relative to  water
        quality impairment by atmospheric  deposition.

    e.  Support research to  improve  our understanding of the  health  effects
        of substances input  to the  Great Lakes  by  atmospheric  deposition.

2.  Review Sec. 112 of the U.S. Federal  Clean Air Act  with  the  view to  revis-
    ing secondary  standards  to  apply   to  all   environmental  problems,  thus
    providing an additional  approach  to  prevention of  water pollution  from
    atmospheric sources.  Aspects  of environmental  quality  to  be  considered
    in establishment  of  air pollution  control  requirements  could  include:
    impacts on vegetation, animals and  agriculture; airborne transport  char-
    acteristics;  air  pollution  control  technology;  and  economic  and  social
    and other effects of any  proposed standards.

Other Federal Agency Actions:

1.  The U.S. Fish  and Wildlife Service  should  be encouraged to  monitor fish
    habitat changes on Great  Lakes  softwater tributaries  in  Minnesota,  Wiscon-
    sin and Michigan with the  view to determining the impact of  sulfage/nit-
    rate deposition on Great  Lakes  fisheries.

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                                      -99-

ALDICAR8 CONTAMINATION OF GROUNDWATER  - WISCONSIN

  Overview of Environmental  Problem:

  In the  fall  of 1979,  the University  of  Wisconsin at  Steven's  Point  began
  finding residues of  TEMIK 15G  in  water  samples  taken  from  drinking  water
  wells in the potato growing areas of  Portage County.  The monitoring  project
  was conducted because  of  similarities of pesticide use  and  soil types  with
  areas of Long  Island,  N.Y.  TEMIK  contamination  on Long  Island caused  the
  U.S. Environmental  Protection  Agency  and the  manufacturer  of TEMIK  (Union
  Carbide) to  initiate  a  sampling  program to  assess the  scope  and  risk  of
  shallow groundwater contamination  in  potato  growing  areas  similar  to  Long
  Island.

  Since the  fall  of  1979, the Wisconsin Department  of  Agriculture, Trade  and
  Consumer Protection (WDATCP),  the Wisconsin  Department  of Health and  Social
  Services (WDHSS),  and  the Wisconsin  Department of  Natural  Resources  (WDNR)
  have begun  a joint  nonitoring  program for  drinking water  wells  in the  Central
  Sands area.  Trends  of  the  analyses,  to date,  have  shown  periodic  TEMIK
  residue levels   above  the  in  ppb  limit  as  prescribed  in U.S. EPA drinking
  water guidelines.   Through these joint  ventures, the WDATCP  has  1) placed  a
  one year moratorium on TEMIK 15G use  in sections  of 7 counties, 2) proposed
  an Emergency Rule on TEMIK to  restrict  usage, change application timing,  and
  to decrease dosage  rates.  Public  hearings on the  proposed rule were held  in
  Stevens Point on November 1st  and  2nd and in Madison  on November 4,  1982.
  The final rule  has  been sent to the  legislature  for  promulgation  by March  31,
  1983.  With recent  analyses completed  for other pesticides in  groundwater in
  the Portage County  vicinity,  potential for  environmental hazards exist.   Up
  to 13 other pesticides have been found at  residue  levels  near  or  at exisiting
  water quality guidelines or standards  for  drinking water.

  Barriers:

  1.  Defining extent of the problem and monitoring.

  2.  Provision  of  alternative   drinking  water  source  for   those  affected.

  3.  Suitable alternatives  to Aldicarb  (TEMIK 15G) to minimize  economic  impacts
      and improve political  acceptance of a  permanent  Aldicarb  ban.

  State/Federal Actions:

  1.  Multimedia cooperation - i.e., drinking water,  groundwater,  and pesticides
      programs must continue interaction.

  2.  Ensure that adequate and unimpeachable analytical capabilities are  avail-
      able.  The WDNR has used the USEPA Beltsville, Maryland laboratory  facil-
      ities and the results  have  been challenged by the University of Wisconsin.

  Headquarters Actions:

  1.  Development of  significant levels  advisories.

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                                     -100-

UNREGULATED TOXIC SUBSTANCES - MULTIMEDIA

  Overview of Environmental  Problem:

  There is a  growing  awareness that  toxic  substances  in the  air,  water,  and
  land media  present  a far more complicated set  of pollution concerns  that  any
  confronted  to  date.   Complicating  this  is  that  the  more  scientists  learn
  about toxic  substances,  the more  regulatory agencies   realize  that  control
  mechanisms  applied  at  present  are  inadequate  with  respect  to  comprehensive
  environmental protection.

  The'emerging issue  of  unregulated toxic  substances  is multi-dimensional.   The
  information base necessary  to develop  an  understanding  of  the  nature  and
  extent of toxic substances problems is incomplete.  Another dimension  of  the
  emerging toxic  substances  problem  is the  complex area  of hazard  and risk
  assessment.

  A final  dimension is the.regulatory and  control  programs  designed to  manage
  toxic substances.   There  are  programs  in   all  media, under  a  variety   of
  environmental legislation,   designed,  at  least  in  part,  to  address  toxic
  substances  from the  time of their proposed introduction  into commerce,  through
  their use,  to the time of their disposal or discharge.  Federal  laws addressing
  toxic substances in  the  environment  include the  TSCA,   FIFRA,  CAA,  CWA,
  SOWA, RCRA, and CERCLA.

  Barriers:

  1.  The   various  listing  processes  for  designating  toxic substances  in  all
      media are delayed  because of  limits  in the  technical data base.   Invento-
      ries of the types  and  volumes of substances are either outdated  or incom-
      plete.   Monitoring and   surveillance  of  the  sources  and   environmental
      occurrence of  substances  is  expensive and time-consuming and therefore,
      incomplete.  There  is  also a  lack  of  standardized  analytical procedures
      to support effecting  listing  and deli sting  decisions.

  ?.  The  capacity to perform  the  necessary  number  of  formal  risk assessments
      in a timely manner limits the Agency's ability to properly  regulate many
      toxic substances.   At  both the  State and Federal  levels there are severe
      resource limitations   to  accomplishing   the  necessary  number   of  risk
      assessments in  a scientifically  sound  manner.

  3.  Legislative deficiencies contribute to  the  unregulated  toxic substances
      problem.   For  examples,  the  RCRA contains several  loopholes,  mentioned
      above,  which reduce the  universe  of  regulated  hazardous  wastes.  In  the
      TSCA, the creation  of  an  essentially Federal program reduces our capacity
      to establish cooperative programs with the States which could expand  the
      scope and depth  of  regulatory control  over  toxic substances.

  4.  Staff at the Regional   and  State levels  are frequently lacking in suffi-
      cient expertise  to scientifically define toxic substance problems.  This
      limitation in  turn  adversely affects our ability   to  devise defensible
      control strategies  and  limits.

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                                   -101-

5.  An integrated management strategy  --  for  intra-agency,  inter-agency,  and
    Federal/State coordination  —  does not  exist.   Further,  the  practical
    linkages of  various  elements  in any  toxic  substances  management  system
    have not yet been  fully defined or operationalized.  The  present system --
    actually a  set of  systems  under the various  envirnnmental  laws  —  lacks  a
    unifying superstructure necessary to upgrade multi-media  toxic management.

State/Federal Actions:

1.  Define  and  document  data  base and data  base managment shortcomings  and
    needs.

2.  Define  and document to the maximum extent possible the  nature  and extent
    of the "unregulated" toxic  substances  problems  in  all media.

3.  Evaluate capacity  to  define, document, assess and control toxic  substances
    in the environment, and accordingly adjust management structures and  pro-
    cedures consistent with individual  program requirements.

4.  States should define any assistance or support needed from the Region on
    toxic substances regulation and control.

5.  Region V, within the context  of Federal  legal  requirements  and  a national
    strategy for addressing unregulated toxic substances,, needs  to develop  a
    Regional implementation strategy   which  considers  Items  1.-  4.   above.

6.  ? Any other suggestions?

Headquarters Actions:

1.  Identify any  gaps or weaknesses  in  legislation  and propose appropriate
    legislative remedies.

2.  Develop  and  disseminate  as  rapidly   as  resources  permit  cross-Agency
    information on chemical  regulatory  activities.  This includes  as a  minimum
    the followi ng:

    -  EPA Chemical  Activities  Status  Report  (EPACASR)

    -  Chemical/Industry File

    -  Exposure Assessment Library

    -  Risk Assessments Underway

    -  Chemical Information Resources  Handbook
       0  Chemical Regulation  and Guidelines  System (CRGS)
       0  Chemical Substances  Information  Network
             (Special Briefing Possible)

    -  Integrated Priority Pollutants   (IPP's)

-------
                                   -102-

    -  Contracts Coordination
       0  Extramural  Activities  Report  (EAR)
       0  Contract Coordination
            (Existing/Past Studies)

3.  Develop integrated  toxic substances  strategy  for  the Agency,  including
    enunciation of policy and policy guidance.

4.  Continue  support  to the   State  Integrated  Toxic  Substances   Program.

5.  Provide technical assistance on  subjects  such  as the  following:

    -  information sharing
    -  intermedia transfers
    -  toxic substances substitutes  analyses

fi.  Provide coordination with other  Federal.agencies.

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                                     -103-
MIJNICIPAL COMPLIANCE  WITH THE  CLEAN HATER  ACT

  Overview of Environmental  Problem:

  Assumptions were made that the 1983 goals  of  the  Clean  Water  Act would  be
  met and that the activities  under the Act  would wind  down.  It was  assumed  that
  funding could' be curtailed because munipalities were  becoming self sufficient.
  This did not occur  and municipalities are  confronted  with financial  difficult-
  ies for environmental and  other issues.

  Barriers:

  1. The necessary municipal  infrastructures did  not  get  established.  Funding
     is being curtailed, while the demand  still exists.

  2. Municipalities have not taken the necessary  steps, such  as short  and long
     term financing,  to bolster the infrastructure.

  3. Lack of short term financing has resulted  in insufficient  Operations and
     Maintenance funding and practices at  a  large number  of facilities.

  4. Lack of long term financing has resulted in  no capital for replacement/
     repai r/growth.

  State/Federal  Actions:

  1. Continue increased attention on municipalities  through technical  assistance
     and enforcement  activities to address the  immediate  problems.

  2. Continue to develop and implement a municipal  compliance strategy to ident-
     ify case specific needs,  short and long tern.

  Hpadquarters Actions:

  1. Continue development and  implementation of the municipal compliance  strategy.

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U.S.  Environment?.! Protection  AgencjJ
Region V, ; '
      -,.  "                13*
     .^ ' -/  '               ,-- ^9 %f

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