100R84102

1984 ENVIRONMENTAL MANAGEMENT
          REPORT UPDATES:
        PROBLEM SUMMARY
                    OFFICE OF POLICY, PLANNING AND EVALUATION
                    OFFICE OF MANAGEMENT SYSTEMS AND EVALUATION
                    EtJVIROMyiENTAL RESULTS BRANCH
                    DECEMBER 4, 1984

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         1984 ENVIRONMENTAL MANAGEMENT REPORT UPDATES:

                        PROBLEM SUMMARY

                       TABLE OF CONTENTS


                                                               Page

Introduction 	   1

Problem Summaries
  Contamination of Ground Water   	   3
  Nonattainment Areas  	   8
  Surface Water Toxics 	  11
  Superfund	15
  RCRA Permitting and Compliance	17
  Need to Site Hazardous Waste Facilities	19
  Air Toxics	21
  Public Water Supply  	  23
  Pesticide Exposure and Drift 	  25
  Nonpoint Sources of Water Contamination   	  27
  Inadequate Wastewater Treatment   	  29
  PCB Contamination	31
  Marine Water Quality 	  33
  Asbestos	36
  Acid Deposition	38
  Preservation of Wetlands 	  40
  Sludge Management  	  42
  Border Problems and Indian Lands  	  43
  Growth	45
  Radiation	46
  Emphasize Geographic-Specific Problem Areas   	  47
Attachment A:  Summary of Significant Environmental
                 Problems
Attachment B:  Significant Environmental Problems As
                 Discussed By Regions

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           1984 ENVIRONMENTAL MANAGEMENT REPORT UPDATES:

                         PROBLEM SUMMARY
INTRODUCTION

     This report summarizes the significant environmental problems
the Regions identified in their 19R4 Environmental Management
Report (EMR) Updates.  The report is organized around twenty-
one generic problems derived from the unique Regional problem
descriptions.  Readers are encouraged to use the report to gain
an overall understanding of the scope and severity of national
environmental problems from the perspective of the Regional
Offices.  The individual Regional EMR Updates should be examined
for more detailed descriptions of the problems and each Region's
agenda to address its priority concerns.

Organization of the Report

     Each summary includes a map displaying the relative ranking
the Regions assigned to the problem, an overview including
significant barriers to resolutions of the problem and accomplish-
ments, and a summary of the actions the Regions requested from
Headquarters.  The Region requesting the action is noted in
parentheses.  The appendices include a summary table of the
twenty-one problems and the complete list and ranking of the
unique problems identified by each Region.

Selection of Generic Problems

     The Regions varied to some degree in the way they identified
significant environmental problems.  Some of the problems were
characterized fairly broadly, such as exposure to hazardous waste
or contamination of ground water.  In contrast, other problems
were geographic specific, such as Boston Harbor water quality or
leaking underground storage tanks in the Santa Clara Valley.  In
order to keep the summary list of Regional problems down to a
manageable size, we established broad problem categories and
included each Regional problem under the appropriate category
(or categories).  The complete list of significant environmental
problems as identified by each Region is included as Attachment B.

     In preparing the summaries, we concentrated on those generic
or geographic specific problems explicitly listed as significant
problems.  Many of the Regions mentioned, somewhere in the course
of their discussions, most of the 21 problem categories.  For
the attached summaries however, we counted only those problems
which were emphasized by the Regions as significant problems.

     There was overlap in some of the Regional issue characterizations,
particularly when Regions identified problems in a geographic
specific area and also discussed the problem more generally.
Our approach was to minimize duplicate discussions by cross-
referencing where appropriate.

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Preparation of Maps Showing Regional Ranking of Problems

     While each Region was asked to rank its significant
environmental problems across media, Regions approached this
task in different ways.  Considering all of them of equal
importance, Region 3 did not choose to rank its problems.
Region 7 opted to rank site-specific problems within, but not
across media.  We therefore did not include Region 3 or Region 7
in our summary rankings except to say that they identified a
problem.  Regions 1,3,4 and 5 also included one or more items
as "emerging problems" or "other concerns."  These additional
concerns were acknowledged as identified by these Regions but
not ranked.

     The report groups the Regional rankings by thirds—high,
middle, and low.  This shows the relative importance each Region
assigned to the problem and takes into account differences in
the number of problems identified by each Region.

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 GROUND WATER PROTECTION
Overview

Protection of ground water was identified as a critical environmental
concern in all in Regions.  Six Regions ranked it as their number
one or number two problem with the protection of drinking water
supplies the most important focus of ground-water programs.
The Regions agreed that ground-water protection is an umbrella
for many other problems such as growth, waste disposal, and
protection of future sources of potable water.

     The most frequently mentioned sources of ground-water contamination
were:

     o  Hazardous waste facilities (active and inactive) ;

     o  Agriculture practices, i.e., pesticides and fertilizers,
        and practices such as irrigation return flows and
        chemigation;

     o  Surface impoundments;

     o  Leaking underground storage tanks (LUST) and pipelines;

     o  Landfills; and,

     o  Septic tanks.

Other sources mentioned included: municipal and industrial waste
treatment facilities (particularly land application);  toxic
consumer products, both properly and improperly used;  spills;
injection wells; mining and mill tailing operations; improperly
constructed or capped wells,  including water  wells, oil  and gas
wells and recharge wells;  salt water intrusion; deicing  salts;
and runoff.

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All Regions were concerned that a majority of the sources of
ground-water contamination are unregulated or "orphan" sources.
Region 2 estimated that more than two thirds of all ground-water
contamination results from unregulated aspects of sources such
as municipal and industrial wastewater systems, leachate from
landfills, LUST, pesticide use, spills, and toxic consumer
products.  Not all contamination from these orphan sources is
the result of improper use or disposal; proper use is often
the cause of significant contamination.  Very frequently,
contamination from orphan sources is also not the result of
large spills or other events but occurs as a result of very
slow, low volume spills over long periods of time.

Increased use of chemigation, i.e., pesticides and fertilizer
application by mixing with irrigation waters pumped to sprinklers
circling the central pivot, was highlighted by the Western
Regions as an emerging concern (Regions 7,8).  The usual practice
of flooding the fields under these pivot irrigation systems
may accelerate movement of pesticides and fertilizers into the
ground water.  In addition, the lack of design standards to
prevent backflows into groundwater wells and the potential
for human and animal contact raise serious concerns about this
technique.

Technical difficulties, high costs for techniques to detect
and clean up problems, and regulatory delays or gaps were
frequently cited as major barriers to ground-water protection.
The incomplete implementation of the RCRA program, costs and
difficulties of monitoring technologies, and lack of controls
and oversight of non-hazardous waste disposal were identified
as the most serious concerns.

All Regions related successes in their efforts to organize
multi-divisional Regional responses to groundwater problems
and develop a framework for coordination and development of
ground-water programs with the States.  In particular some
Regions have developed special inter-divisional programs to
study LUST detection and control.  Region 3 is completing a
ground-water data base which includes location of major aquifers,
hydrogeologic assessments, and location of major sources of
contamination.

In Region 7, the State of Nebraska is developing appropriate
control mechanisms for pesticide and nitrate application through
center pivot irrigation systems i.e., chemigation.  The
Regional Office is working with Headquarters in developing
appropriate federal controls (pesticide label restrictions, etc.)
for chemigation systems.

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Requested Headquarters Actions

   Implementation of the Ground-water Protection Strategy

     o  Revise policies, guidelines, and regulations to reflect
        the use of the ground-water strategy to manage programs
        and establish priorities.  This should include coordination
        among EPA programs (Region 4), consistent guidance and
        support for technical assistance to the States, assistance
        in developing ground-water management programs and
        data bases, and guidance for State grants
        (Regions 1,2,5,8,10).

     o  Involve the Regions to a greater degree in the selection
        of EPA research projects, in the various studies of
        unaddressed ground-water contamination sources and
        other ground-water issues, and in the various task
        forces created to establish a comprehensive approach
        to ground-water programs (Region 5).

     o  Assist in the training and recruitment of ground-water
        professional staff, as a nationwide shortage of qualified
        geotechnical personnel is hindering program development
        at the State and Federal level (Region 6).

     o  Establish a national technology transfer program for
        ground-water investigations and restoration (Region 1).

     o  Revise the allocation formula for ground-water grants
        under CWA Section 106 (Region 6).

-Superfund/RCRA

     o  Develop a more reliable statistical method for determining
        the significant changes in ground-water contamination
        data (Regions 1,2,10).

     o  Provide risk assessment methodology for "alternate
        concentration limits" to complete remedial plans at
        NPL sites (Region 6) .

     o  Ensure that resources are available to complete the
        work of the Headquarters task force to evaluate the
        environmental impact of non-hazardous waste management
        facilities; complete by the end of FY 1985 (Region 1).
- LUST
     o  Develop a Quality Assurance/Quality Control and
        effectiveness evaluation of present methods for
        testing underground storage tanks (Region 1).

     o  Select a contact in Washington who can relay current
        Headquarters and Congressional positions and policies
        on LUST to the Regional Offices and designate a
        central clearinghouse, i.e. computer information system
        on underground storage tanks (Region 1).

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     o  Develop a methodology for gaining information from
        the private sector on underground tanks, leaks, tank
        removals, and abandonments (Region 1).

     o  Develop model cost and manpower needs to implement
        effective underground storage tank regulatory programs
        at the State and Regional levels (Regions 1).

     o  Speed up the development of guidance on alternatives
        for control of contamination by oil/gasoline or chemical
        storage tanks (Region 8).

- Criteria for Ground-Water Contamination

     o  Develop a national inventory of types of contaminants
        found in ground water and aggressively pursue research
        into health and environmental impacts of the hazardous
        wastes most commonly found in ground water (usually
        volatile organics) (Region 1).

     o  Establish criteria on levels of contaminants in ground
        water which should trigger Superfund involvement (Region 1)

     o  Develop enforceable evaluation criteria/parameters
        for ground-water impacts in large wellfields (Region 4).

- Pesticides

     o  Conduct a National Monitoring Program to help define
        the extent and nature of pesticide contamination of
        ground water.  In particular, support residue monitoring
        of pesticides that are likely to migrate to ground-water
        supplies (Region 1,10).

     o  Develop policy regarding the types of control measures
        necessary to mitigate the risks from pesticide leaching.
        In particular, amend labels or cancel uses when
        monitoring data and/or experimentation indicates
        ground-water contamination from pesticides (Region 1).

   Laboratory Capacity and Methodologies

     o  Resolve laboratory capacity issues (Region 2).

     o  Standardize methodologies for the sampling and
        analysis of ground water (Region 2).

   Drinking Water

     o  Develop national drinking water standards for toxic
        organics and continue to support research and
        development of methods for treatment of synthetic
        organic chemicals routinely found in drinking water
        supplies (Region 2).

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     o  Develop health advisories and/or Drinking Water
        Standards in a more timely and consistent manner for
        use by EPA and the States in responding to contamination
        incidents (Regions 1,5,6).

     o  Complete verification of the results of the Surface
        Impoundment Assessment (SIA).  Develop guidance for the
        States to implement the SIA recommendations (Region 8).

     o  Complete decisions on recommendations for sole source
        aquifer designations pending in Washington (Region 2).

     o  Make the Sole Source Aquifer (SSA)  regulations final.
        Strengthen the criteria defining which federally
        funded projects can be reviewed in the SSA process,
        including any direct federal actions.  Develop guidance
        clarifying State role in SSA activities (Region 8).

- Underground Injection Control

     o  Provide increased support to the Underground Injection
        Control Program so that unaddressed hazardous waste
        wells can be permitted or closed as soon as possible
        (Region 5).

     o  Expedite evaluation of problems in Class V wells,  and plan
        needed actions to protect them (Region 10).

- Geographic Specific Problem Areas

     o  Approve an area-wide approach to address the South Bay/
        Santa Clara contamination problem.   HO support for one or
        more multi-site cooperative agreements for the South
        Bay area and a commitment by HQ for adequate contract
        support is needed (Region 9).

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    NONATTAINMENT AREAS
                            *Rankings are for ozone only.
Overview

Ozone

Several Regions identified ozone as one of the most significant and
persistent environmental problems.  Regions 4,6,8, and 9 ranked
ozone in the top third of their problems.  All Regions continue
to experience exceedances of the air quality standard to one
degree or another in major urban areas and even in selected
rural areas as well (Region 6).  Region 9 (L.A.-South Coast Air
Basin) and Region 1 (Connecticut) reportedly have the most severe
ozone episodes.  Sources of ozone problems include auto emissions
and stationary sources of Volatile Organic Compounds (VOC) and
hydrocarbons (HC), with the proportion of the problem attributed
to each source type varying by area.  Regions 1 and 4 attribute
part of the problem to the transport of ozone and its precursors
from upwind urban sources.

Several Regions (1-9) report establishment of local I/M programs
to control emissions from autos.  VOC control programs are also
being implemented to control stationary sources, with many Regions
focusing on high levels of enforcement and compliance to ensure
adequate control (Regions 1,5,9).  Region 2 completed the first
stage of modeling to determine needed percentage reductions in
VOCs to reduce ozone.
Carbon Monoxide (CO)

Five Regions (2,4,7,R, 10) listed
problem, largely in urban areas
exposures to exceedances of the
CO among the top third of their
placed CO in the middle third of
largely attributed to auto emiss
number of autos, poor meteorolog
landscape constraints and traffi
to formation of CO "hot spots".
 CO as a continuing air quality
with potential for high population
standard.  Regions 4 and 8 ranked
problems, while Regions 2 and 10
 their lists.  The CO problem is
ions, with factors such as large
ical mixing  (Region 10) and urban
c patterns (Regions 2,4) contributing

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In addition, Region 10 identified lack of public recognition of
the CO problem as an obstacle to dealing with the problem.

I/M programs appear to have strong results with bringing areas
into attainment (Region 10).  Region 2 reports that CO hot spot
studies were recently completed in New York and New Jersey.
Region 8 has supported ride-sharing efforts in Colorado with
grants and has coordinated a ride-sharing campaign with GSA for
federal employees in Colorado.

Particulates (TSP)

Regions 5,7,8, and 10 discussed TSP as a major or growing problem
in their area.  Region 8 ranked particulates among the top third
of its problems.  Regions 5 and 10 placed the particulates in
the middle third of their lists.  Concentrations of older, heavy
"smoke stack" industries, reliance on coal, and a variety of
smaller sources (e.g., fireplaces, wood stoves, street cleaning,
re-entrained and fugitive dust) are primary sources.  Region 8
considers TSP its most widespread air problem, affecting both
large urban areas and many smaller towns.  Regions 8 and 10 see
difficulty in controlling nontraditional sources (fireplaces,
construction, wood stoves, etc.) as a major barrier to TSP
attainment.  Region 10 notes that some emission reductions
have been offset by growth in emissions from residential wood
burning.  Furthermore, some communities in Region 10 are
experiencing problems with TSP for the first time due to wood
stoves.

In Region 8, several communities have begun to address wood
burning issues on their own with the Region supporting a wood
burning survey and workshop.  In Region 10, TSP primary standard
nonattainment areas have been reduced in size, with other areas
approaching or attaining compliance.  Steps are being taken at
the State/local level to reduce wood burning emissions.

Sulfur Dioxide (SO;>)

Three Regions (5,7, and 8) expressed concern about SO2 violations.
Regions 5 and 8 ranked it in the middle third of their problems.
Region 5 stated that exceedances which were usually found in
small areas of Wisconsin are in recent months occurring in other
areas of the Region.  SO2 remains a pollutant of concern because
of wider use of high sulfur Midwest coal by industries and electric
utilities, and its association with long range transport and acid
deposition.  Region 8 is also concerned with the effect of energy
facility development on certain Class 1 PSD areas.

Lead

Regions 7 and 10 consider lead emissions a problem with respect
to localized areas associated with particular sources (smelter
and lead refineries).  With controls being worked out for such
sources, Region 10 views most remaining emissions originating
from burning leaded gasoline; however the lead standard is now
being met.

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Requested Headquarters

Ozone

Overall, the Regions expressed a strong need for technical and
policy guidance regarding some of the more complex issues sur-
rounding controlling and determining compliance of categories
of ozone sources.  The requests included development of control
technology guidance (CTG) for Group III source categories
(Region 5), guidance on requirements for control of major non-CTG
sources (Region 5), and development of approaches for further
control of mobile, minor stationary, and area source emissions
(Region 9).  Other requests included developing monitoring methods
for hydrocarbons (Regions 6,9), support for various modeling
activities (Regions 1,6,9), development of auditing guidelines
and compliance procedures especially for I/M programs (Region
4), developing guidance and procedures on RFP in order to
assure attainment (Region 8), and consider post-1987 long-range
attainment plans (Region 9).

Carbon Monoxide (CO)

Recommendations for actions include support for the most stringent
new car and truck CO emission standards technically feasible
(Region 2), clear guidance on use of cost-effective "hot-spot"
control strategies (Region 4), and support for sanctions for
failing to implement I/M (Region 10).

Particulates (TSP)

Regions specifically want a PM^o transition policy issued, as
well as technical support for PM^Q SIP development and attainment
demonstration.

Sulfur Dioxide (S02)

Region 5 asked that Headquarters resolve outstanding issues
affecting establishment of SO? emission limitations, e.g.,
running vs. block averages, changes to guidelines or air quality
models.

Lead

Region 10 requests support for Region-initiated final rulemaking
on emission limits applicable to the Idaho lead smelter.
                               in

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   SURFACF WATER TOXICS
                                           REGIONAL RANKNG
Overview

All regions reported toxics in surface water as a significant
problem.  Four of these ranked the problem in their top 3 issues
(Regions 1,4,5,6).  Although many lakes, harbors, and miles of
streams were identified as having the potential for toxics
problems, the full magnitude of the problem has not been completely
defined.  In particular, the Regions expressed concern over the
possiblility of surface water contamination from hazardous waste
facilities and Superfund sites (Region 1 New Bedford Harbor;
Regions 2 and 3; Region 4, particularly Florida NPL sites).
In characterizing the problem, the Regions outlined several
sources and contaminants.

     o  The Regions perceive the majority of toxics problems
        as coming from point sources (Regions 2,3,4,6,7,9).
        Industrial (including petrochemical, refining and
        chemical manufacturing) and municipal effluents are
        the main sources.  Heavy metals from industrial effluents
        were specifically discussed as major contaminants of
        concern in Regions 2,3,6 and 8.  Although treated to
        BAT, these effluents may still cause toxicity problems.

     o  Nonpoint sources of toxics in surface water were also
        discussed in some Regions (2,4,7), and attributed to
        agricultural runoff and abandoned mines.

     o  The textile industry in Region 4 (N. Carolina), is of
        high concern because of discharge of toxic disinfectants.

     o  Several Regions framed the surface water toxics problem
        not only in terms of surface water degradation, but as
        an intermedia problem which should be addressed accordingly
        Region 5 was concerned with the contamination of water
        from "atmospheric deposition" and Regions 1,3, and 6
        suggested an integrated approach to deal with toxics
        in air, water, and land.
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    The extent of the toxics problem in surface water is best
    exemplified by the number of specific geographic areas
    affected and the variety of problems described below.

     o  Kesterson Reservoir in the Central Valley of California,
        essentially an evaporation pond for agricultural drain
        water, has a high concentration of selenium, resulting
        in a high incidence of waterfowl deformaties and
        mortalities.

     o  Chesapeake Bay has documented impacts on shellfish,
        finfish, and recreational activities, stemming from
        toxics in Baltimore Harbor and the Elizabeth River.

     o  River reaches in New York and New Jersey have fishing
        bans in place because fish are contaminated with PCBs
        and/or pesticides.

     o  Mississippi has identified Rll miles of streams and
        12,763 acres of lakes in one Mississippi Delta Basin
        (Yazoo) that are impacted by toxics from pesticides
        runoff.

     o  Sport and commercial fishing bans or advisories
        resulted from DDT and PCBs in Lake Michigan.

     o  Regions identified significant levels of chlorinated
        dioxins, PCBs, and dibenzofurans in fish-eating
        birds in Green Bay and Saginaw Bay.

Several Regions have gone beyond just recognizing toxics in
surface water as a problem and have implemented a toxicity based
testing policy for review of NPDES permits (Regions 1,2,4).
New York State has documented decreases in toxics in Lake Erie,
Conewango Creek, and Buffalo River through a toxics monitoring
program.

Region 6 is working on identification of specific water bodies
which receive toxic discharges, and identification of pollutant
sources whose permits will be revised to minimize/eliminate
toxic discharges.

Requested Headquarters Action

-  Criteria Development

     o  Develop further criteria for water toxics, including
        trace elements (Regions 1,2,6,9).

     o  Develop standards for NPDES permit process to ensure a
        consistent procedure to draft acute and chronic effluent
        limits (Region 1).

     o  Reassess priority pollutants on a continuing basis and
        develop mechanisms for updating criteria (Region 2).
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     o  Provide ORD support to develop sediment criteria,  study
        causes and effects of toxic pollutants and improve
        technology to monitor marine biological impacts of
        pollution (Regions 1,10).

     o  Provide information on additional toxics to aid States in
        adopting their own water quality standards for toxics
        (Region 2).

     o  Develop guidelines for the amount of toxicity which
        will still allow streams to meet a lower classification
        (Region 1).

-  Technical Assistance

     o  Provide NEIC/OECM technical enforcement assistance
        (Region 3).

     o  Develop sampling and analytical protocols for toxics
        (Regions 5,6).

     o  Re-evaluate Agency's role in regulating agriculture,
        particularly under the Clean Water Act (Region 9).

     o  ORD needs to initiate efforts to better coordinate their
        work with the Regions and provide results, particularly
        of field work, in a significantly shorter time (Region 5).

     o  Emphasize the priority water bodies approach to water
        quality management and control (Region 5).

     o  Provide additional guidance on procedures and requirements
        for review and re-evaluation by States every 3 years of
        water quality standards and wasteload allocations  (Region 5)

   Resources/Management

     o  Recommend that Congress increase the State 106 program
        grant by 25 percent in order to increase monitoring,
        permitting, and compliance (Region 5).

     o  Improve coordination between Headquarters compliance,
        permits, and ambient monitoring programs to identify,
        evaluate, and control toxicant problems.  Resources
        from all three programs, particularly monitoring,  need
        to be directed to this effort (Region 5).

     o  Continue to implement the current pretreatment program
        (Region 5).

     o  Maintain funding to the States to carry out sufficient
        monitoring to identify and define toxic pollutants
        (Region 2) .
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Is Section 24 of CWA - encouraging implementation of the
WQS regulation by withholding 201 construction grant
funds - an ongoing requirement?  Region 3 supports a
decision to make it ongoing.
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        SUPERFUND
                                        REGIONAL RANKING *
Ten Regions discussed problems with hazardous waste in the
context of Superfund, citing ground-water contamination as the
primary environmental threat from hazardous waste sites.  The
public relies on groundwater for private/ municipal and agricul-
tural water supplies (Regions 1,2,4,5,7,R ,10 ) .  The high level
of public concern regarding uncontrolled hazardous waste sites
increases the need for quick action (Regions 5,10).  The public
is especially concerned, not only because of the immediate
threat these sites represent to public health, but also because
many contaminants found at these sites are potential carcinogens
or mutagens, and may cause serious long-term health effects.

Administrative problems due to the complexity of regulations
and the resource intensiveness of control actions were discussed
by Regions 1,2,5, and 8.  Information currently available is
inadequate to depict accurately the full extent of the hazardous
waste problem and the contract lab backlog often seriously delays
badly needed site investigations (Regions 2,5,8).

Specific issues discussed by each Region are indicative of the
extent of the problem.

o  Toxic air emissions from CERCLA sites is of concern to Region 9
   after the discovery of underground toxic and hazardous gas
   migration into private residences adjacent to the BKK landfill
   in West Covina, CA.  Region 9 has called for reports document-
   ing investigations of other hazardous waste sites in the
   Region.  Although the reports are not in yet, similar findings
   regarding the extent of toxic air emissions at other sites
   are expected.
 * Region 1 refered specifically to the New Bedford Harbor NPL site.
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 o  Past hazardous  waste  disposal  practices continue  to  haunt
    residents of  Reqion 10.  The scope  of  the  threat  is  only partly
    known:   More  than 800 potential  sites  -- up from  760 a  year
    aqo --  have been identified; about  5  to 10 percent are
    expected to present major problems. The basic  industry in
    the Pacific Northwest is extraction of natural  resources;
    this has lead to hazardous waste sites in  rural areas
    as well as in population centers.

 o  Heavy industrialization and agricultural activities  have
    contributed to  Region 5 having 137  NPL sites, or  over 30
    percent of the  uncontrolled hazardous  waste sites on the
    proposed National Priorities List Update.   The  Reqion has
    over 3,700 abandoned  hazardous waste  sites that are  not on
    the NPL, but  still may present a threat to human  health or
    the environment.  The significant increase in the number of
    potential problem sites was a  concern  of several  Regions,
    particularly  Regions  5 and 10.

 o  The three main  problems in the cleanup of  sites in Region  2
    have been: difficulties in obtaining  both State  and Federal
    funds up until  1982;  the complexity of regulatory reguirements
    under the National Contingency Plan, which was  not completed
    until late 1982; and  the need  to develop engineering solutions
    to complex environmental problems before cleanup.

 Reguested  Headquarters Actions

 o  Revise  and streamline the National  Contingency  Plan  to
    provide more  flexibility on options for response. Evaluate
1    the potential for delegation to  Regions of the  authority to
i    select  some remedial  actions at  sites  on the NPL  (Regions  2,10)

;o  Accelerate training,  both of new employees and  longer-term
    employees (Region 10) .

 o  Provide additional contract lab  capacity to analyze  samples
    in order to fulfill the requirements of the Superfund program
    (Region 2,5).

 ')  Prior to delegation of various Superfund authorities to the
    Regions, ensure adequate guidance is  in place and develop
    additional enforcement guidance  where  needed (Region 5,10).

    Standardize methodologies for  the sampling and  analysis
    of ground water (Region 2) .

 o  Conduct a survey nationwide to ascertain if there are other
    sites generating hazardous air emissions similar  to  that in
    Southern California (Region 9).
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     RCRA PERMITTING
     AND COMPLIANCE
Overview

Seven of the ten Regions discussed RCRA permitting and compliance
as a significant problem.  Siting of new facilities was discussed
in five Regions, and air toxics related to RCRA sites was discussed
in two Regions.  Both are presented as separate issues in this
packet.  The Regions are well under way in authorizing RCRA to
States; most Regions are issuing Part B permits; and the Regions
have solid figures on the number of facilities expected to close
due to current regulations (about 50% in Region 8 alone) .  The
perceived ambiguity of closure regulations makes this process
difficult.  The Regions discussed several permitting and compliance
concerns, outlined below.

   o  Contamination of ground water and/or surface water from
      improperly disposed waste was the major concern.  Several
      Regions discussed the need to accelerate monitoring of
      ground water and the need to develop analytical methods
      for determining possible contamination (Regions 1,2,3,4,8,
      and 10) .

   o  Permitting and compliance of treatment, storage and disposal
      facilities (TSDFs) was mentioned as a resource problem in
      Regions 2,4, and 8.  In Region 2, of 700 TSDFs, RCRA permit
      applications still need to be reguested for 550 .  Training
      and lab resource problems are leading to a shortage of work
      years to implement the National Permit Strategy.

   o  The high public concern over Federal Facility compliance
      with federal regulations was discussed by Region 8.  They
      have 2,290 Federal Facilities and have investigated many of
                                17

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      these for storage and disposal problems.  Approximately 42
      installations were identified as having major or minor
      problems.

   o  Many Regions are finding the process of meeting the January
      1985 deadline for Final Authorization of State RCRA programs
      resource intensive.  Problems arise at the State level with
      legislatures and other State agencies.  The difficulty of
      assessing the State's past performance and capability to run
      the hazardous waste program presents another obstacle for
      the Regions.

Region 1 has made significant progress in this area:  they have
developed an enforcement response policy (implemented in all
six States) which establishes the appropriate action for various
classes of violations and sets out those enforcement time frames
necessary for timely actions; State and EPA field surveillance
shows that the most serious RCRA violations, those with the
greatest potential for harm, have been corrected.

Requested Headquarters Actions

   o  Additional resources are needed to accelerate the permitting
      of TSDFs (Region 2).

   o  The Test Methods for Evaluating Solid Waste (SW 846) need
      to be verified (Region 2).

   o  Enforcement policy guidance should be produced and
      clarification provided where needed (Region 9).

   o  Better cross media coordination and resource distribution
      are needed to address air and water issues (Region 9).

   o  Development and issuance of revisions to the land disposal
      regulations should be accelerated.  Policy guidance should
      also be issued concurrently with the regulations to ensure
      effective and timely implementation (Region 5).

   o  A long-term, broad based training program should be
      established to address training and skill mix problems
      (Region 5).  The need for training is greatest in:
      1) orientation of new employees to the RCRA program;
      2) permitting; 3) ground water monitoring requirements;
      and 4) procedures for closure of a facility.

   o  The environmental impacts of non-hazardous waste land
      disposal facilities should be considered.  The Subtitle
      D program should be reestablished in FY 86 and beyond
      (Region 5).

   o  Determine whether federally funded, state, or privately
      funded activities at CERCLA sites require RCRA permits
      (Region 4).
                               18

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  NEED TO SITE HAZARDOUS
     WASTE FACILITIES
                                                                  • MGH
                                                                  QMDOU
                                                                  BUM*
                                                                  5 HOT RANKED
                                                                  D NOT EMPHASIZE!
Problem Assessment

Five of the ten Regions discussed siting of hazardous waste
facilities as a significant problem in their Regions.  Regions
2 and 9 ranked the problem fourth and sixth, respectively,
and the other Regions discussed it in the context of RCRA
permitting and compliance problems.

o  Capacity was the major concern, with Regions discussing
   the current low capacity (Regions 5,8,9), and anticipating
   a capacity problem in the future because of the increase
   in generators of hazardous waste (Regions 2,4,5,9).
   Movement of Superfund site waste to RCRA facilities, and
   banning some waste from certain RCRA facilities will
   further strain current facilities (Region 2).  Region 8
   has only one operating commercial landfill; excessive
   reliance on one waste facility in California has caused
   that site to stop accepting hazardous waste.

o  Regions 2,4,5,8, and 9 noted the problem of local opposition
   to siting of new facilities, or expanding old facilities,
   as a major factor affecting future capacity.  New York's
   attempt to site a State-sponsored facility met insurmount-
   able public opposition; thus, no Region 2 State has current
   plans for State-sponsored hazardous waste facilities.

Some Regions have had success in encouraging siting of new
facilities.  For example, since 1981, Region 9 coordinated
the Southern California Hazardous Waste Management Project,
involving eight counties, to accelerate siting of new facilities
Each county has agreed to accept facilities appropriate in scale
and type to its own share of the Region's overall volume of
generated wastes.  A Regional siting agreement is expected
in January 1985.  Region 9 urges that EPA Regions play a
role in facilitating the siting of environmentally sound
treatment facilities to reduce the current dependence on
land disposal.
                              19

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Requested Headquarters Actions


o  Define the Agency role in facilitating the siting of
   environmentally sound hazardous waste and disposal facilities
   and resource recovery facilities.  HO needs to provide an
   alternative to illegal and improper disposal (Region 2).

o  A program of public relations and education would reduce
   some of the opposition and the resulting burden on State and
   federal resources needed in issuing a permit (Region 4).

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        AIR TOXICS
                                                               RANKING
                                                               •HWH
                                                               BMOOLE
                                                               BLOW
                                                               5 NOT RANKED
                                                               DMOT
Overview

Several Regions (1,2,4,5,6,7,9) listed toxic air pollutants as a
significant environmental concern.  A major part of the problem
is the lack of hard facts needed to make regulatory decisions.
This concern is compounded by an inability to assess the problem
accurately due to the lack of routine detection methods, the
multitude of potential sources and toxic chemicals, and the
lack of information on the health effects of low level exposures.
Nevertheless, public concern over air toxics has been a major
driving factor in pushing several State agencies to develop
air toxics assessment and control programs on their own.

Potential sources of toxic air emissions include:  industrial
and chemical processes, landfills, Superfund and hazardous
waste sites, municipal incinerators, aerial pesticide
applications, and small industrial sources.  Region 9 identified
specific problems with toxic air emissions from waste facilities
(both hazardous and non-hazardous waste sites) and CERCLA
sites.  Certain Class I and Class II landfills in Southern
California have been found to  be sources of high concentrations
of airborne toxic pollutants in the local area (particularly
vinyl chloride).

Few toxic air pollutants are currently regulated by EPA under
the NESHAPS program.  EPA is exploring alternatives to  NESHAPS
to control air toxics, focusing on supporting State/local
efforts to regulate specific sources, relying on State/local
authority rather than Federal  standards.

Regions have attempted to support State efforts  in air  toxics,
including sponsoring workshops (Region 1), aiding  in  developing
toxic emissions  inventories  (Regions  1,2), and supporting  air
monitoring studies and evaluations of selected areas
(Regions 1,2,4).
                                21

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Requested Headquarters Actions

Regional requests for Headquarters actions center on clarifying
Federal and State roles in the regulatory area and filling the
many information gaps.  Specific requests include:

o  Provide information on risk assessment methodology and risk
   management to Regions and States (Regions 1,5,9);

o  Conduct research on health effects at low levels of exposure,
   monitoring methods (Regions 1,2,4,5,9);

o  Develop a standardized protocol for determining aggregate
   risk from exposure to multiple chemicals (Region 4);

o  Accelerate development of emission standards for RCRA and
   CERCLA sites (Region 9): and

o  Consider changes to $112 of the CAA regarding vinyl chloride
   and other toxic VOC emissions from landfills (Region 9).
                               22

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    PUBLIC WATER SUPPLY
Problem Assessment

In many Regions drinking water supplies rely on ground water
as the water source.  The concern of all the Regions over the
contamination of ground water by toxics thus overlaps into the
area of drinking water (see discussion of ground water for further
detail).  However, several Regions framed the issue not only as
a ground-water problem, but as a monitoring and treatment issue
in drinking water (Regions 4,7,10).  Concerns over violations of
MCLs were also expressed by several Regions (2,7,8,9).

o  Regions 2 and 9 have found that poor operation and maintenance
   of water systems has led to bacteriological contamination of
   drinking water, and, in Region 9, a problem with cholera in
   the Truk Islands of the Trust Territory of the Pacific Islands.

o  In Region 5, VOCs in community water wells led to removal of
   at least 50 wells from routine service.  Region 7 documents
   efforts to lower levels of TCE in finished water through
   temporarily discontinuing use of a contaminated well field in
   Des Moines and attempts to purge a contaminated aquifer in
   Liberty, Missouri.  Monitoring for VOCs will continue.

o  Region 8 will target its oversight efforts to Utah, which
   experienced a poor bacteriological MCL compliance rate (57.5%
   of all systems with no violations; national average is 95%)
   exceeded only by Virgin Islands, American Samoa, Northern
   Mariana Islands, Guam, and the Trust Territories of the Pacific

o  Region 5's State and federal drinking water programs have
   analyzed 26% of community water wells for VOC compounds.  At
   least 19% of those wells have been shown to contain some VOCs.
                                23

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Requested Headquarters Actions

o  Increase research and development efforts to develop surrogate
   methods of detecting VOCs in drinking water, and reduce  the
   costs of testing samples (Region 5).

o  Develop maximum contaminant levels (MCLs) or health advisories
   for VOCs in water;  refine treatment methods such as aeration
   towers and granular activated carbon to remove VOCs (Region
   10) ."

o  Provide the Regions with more information relating to health
   advisories (Region 5).

o  Develop low-technology,  energy efficient treatment methods for
   small systems (Region 10).

o  Relax low-priority water monitoring reguirements to reduce
   costs of lab work for small systems (Region 10) .
                                24

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PESTICIDE EXPOSURE AND DRIFT
                                             REGIONAL RANKING
Overview

Drift and misuse problems stemming from pesticide use were
discussed in seven of the ten Regions. (Four of the Regions
ranked it as a mid-level priority.)  Presented below are several
issues discussed by the Regions identifying specific misuse
problems, contaminants of concern, and potential impacts.  For
more detail on each of these issues see the problem summaries
discussing nonpoint sources, surface water toxics, and ground
water.

o  In Regions 5,7, and 8, improper application may be leading to
   pesticide contamination of ground water.  Regions 7 and 8
   specifically discussed new methods of chemigation (applying
   pesticides through irrigation) as a major concern.  In
   Region 5, Aldicarb was detected in the ground water in
   Wisconsin, at concentrations ranging from 10 to 111 ppb.

o  Damage to wine grapes in Washington from 2,4-D, and damage
   from dessicants used for weed control were two drift problems
   stemming from aerial pesticide application (Region 10).
   Although the air toxics issue is not generally characterized
   as a pesticides problem, several Regions discussed pesticide
   drift in the context of an air toxics problem (Regions 4,5,6,7)
   Region 4 is currently involved in studies designed to help
   define the severity of the air toxics problem: a multi-county
   study on the transport of aerially applied pesticides in
   the Mississippi Delta, and a study planned for the Kingsport,
   Tennessee area.

o  Region 5 noted that aerial applications led to the highest
   number of violations within the Region (42%), and four of
   the five States in Region 6 have determined that drift of
   pesticides into nontarget areas is a priority problem.
                               25

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   In addition to traditional enforcement actions, the States
   in Region 6 are using innovative enforcement techniques,
   e.g., preseason inspections of commercial applicators to
   caution them about drift (Arkansas), increasing penalties
   for misuse (Louisiana), and publicizing applicator license
   suspensions and relocations (Oklahoma).

o  Region R cited disposal of unused pesticides and of rinsates
   from washing pesticide equipment as a major concern.
   Insufficient labeling of precautions and procedures has led to
   disposal problems for homeowners as well as large applicators.

Cooperative monitoring of pesticide use in the Missouri "Boot
heel" by EPA and State personnel has resulted in a significant
decrease in complaints in Region 7.  Thus, a problem mentioned
in their 1983 EMR is no longer considered a problem.

Requested Headquarters Actions

o  Establish standards and consistent label directions and
   precautions; continue and strengthen the Label Improvement
   Program (Region 5).

o  Continue funding and national direction to strengthen
   State use compliance and certification programs (Regions 5,6).

o  Test and anticipate the environmental behavior of pesticides,
   especially the various volatile formulations of phenox
   pesticides and persistent insecticides such as endrin and
   heptachlor.  Establish background levels and a wildlife
   monitoring program for various residues to assess effectiveness
   of environmental programs (Region 10).

o  Raise the priority of interagency, interdisciplinary training
   and contacts — such as with the U.S. Customs Service and
   the U.S. Department of Agriculture's Animal and Plant
   Inspection Service — to enhance program effectiveness at
   little additional cost (Region 10).

o  Raise the priority of work to monitor pesticide residues
   (Region 10).

o  Re-evaluate the Agency's role in regulating agriculture.
   The 1977 amendments to the CWA exclude EPA from issuing permits
   for return flows from irrigated agriculture (Region 9).

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     NONPOINT SOURCES
           OF
   WATER CONTAMINATION
                                           REGIONAL RANKING
Overview

All ten Regions mentioned nonpoint sources (NFS)  as a major
problem in contamination of water, although the extent to
which different Regions discussed it varied widely.  Regions
1,3, and 6 discussed nonpoint sources as a major problem.
The other Regions discussed nonpoint sources,  but did not
rank the issue among their top priorities.

  o  Agricultural practices were cited as a major cause of
     NFS contamination in nine Regions.  Region 3 cited
     agricultural nonpoint sources as the leading cause of
     contamination in the Chesapeake Bay.  Region 8 reports
     that 90% of their surface water quality problems are
     due to nonpoint sources, particularly stock raising
     activities.  They are conducting several activities to
     help alleviate the problem:  a model implementation
     project in agriculture, rural clean water projects in
     several areas, and a lake watershed project.  The St.
     Albans Rural Clean Water Project on Lake Champlain in
     Region 1, and the Westport Massachusetts River Estuary
     Rural Clean Water Project, have enrolled selected farms
     in use Best Management Practices for manure handling
     and cropping.

  o  Erosion, sedimentation, siltation and turbidity due to
     large scale construction (Regions 1,3,4), forest management
     practices (Regions 1,4), and urban runoff (Regions 1,3,6,9)
     were cited as major surface water problems due to nonpoint
     sources.  Contaminants of concern include nitrogen,
     phosphorus, metals, including iron, and other toxics,
     often carried with silt.
                              27

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  o  Abandoned/inactive mines were cited as a problem in
     Regions 3,4,8 and 10, resulting in acidic water, dissolved
     solids, and metals in surface water.

  o  Residual wastes from septic tanks were cited as a concern
     in Regions 1,6 and 10.

  o  Possible ground-water contamination from nonpoint sources
     was cited as a growing concern in Regions 1,3,6, and 7.
     Sources of contamination include agricultural sources,
     landfill leachate, and LUSTs.

  o  A project proposal using aerial mapping to conduct a study
     by Fish and Wildlife Service on the dynamics and ecology of
     the San Francisco Bay-Delta system will assess nonpoint
     sources in Region 9.

Reguested Headguarters Actions

  o  Enunciate a clearcut NFS Policy and Implementation Program
     (Regions 1,6,8) .

  o  Work with Federal agencies and national organizations DOI,
     DOA) to reach the diversity of interests involved in controlling
     the sources of nonpoint pollution; agriculture, forestry,
     construction, and transportation (Regions 1,3,4).

  o  Ensure that Federal projects, grants,  and loans incorporate
     RMPs (Region 1).

  o  Furnish model legislation, guidance, and technical assistance
     to build up state-local-private sector capability (Region 1).

  o  Refocus existing  agricultural cost-sharing programs to  support
     water guality objectives (Region 1).

  o  Recognize NPS impacts to ground water as a priority concern
     of the Agency's ground-water strategy (Region 3).

  o  Review funding programs for NPS management.  If no additional
     funding sources are to be developed, existing programs
     [106, 205(j)] must continue to stress NPS management with
     provisions for either incentive awards or reguirements  for
     a reguired percentage for NPS programs (Region 3).

  o  Reflect the importance of NPS management in the development
     of accountability parameters for the Agency management
     system — SPMS (Region 3).

  o  Issuance of Water Quality Management (WQM) regulations
     should include NPS (Region 6).

  o  Work on planning  and development of Federal salinity control
     projects.  Develop innovative approaches to salinity control
     (Region 8).


                                28

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  INADEQUATE WASTEWATER
       TREATMENT
                                            REOOKAL RANKJNG
Overview

Contamination of surface water by inadequately treated wastewater
was discussed as a problem in seven of the Regions (1,2,3,4,5,7,8).
Most problems were characterized by inadequate treatment facilities,
either outmoded or overloaded, or operation and maintenance
problems.

     o  In Region 5, problems in the Great Lakes are cumulative
        because only one percent of the pollutants leave via
        the St. Lawrence River.  Nutrient enrichment leading
        to accelerated eutrophication is one of the major
        concerns, along with Combined Sewer Overflows (CSOs).

     o  In Region 4 minor facilities were designated major
        problems leading to low D.O. and bacterial contamination
        in small streams and coastal areas.  The 62 paper
        mills in Region 4 also present problems of low D.O., high
        sediment oxygen demand, and excessive color.

     o  High fecal coliform levels in swimming and shellfish
        areas were discussed by Regions 1,2,4, and 7.  Levels
        are often so high as to require closing of recreational
        swimming areas and shellfish beds.  As one example of
        efforts to correct these problems, a grant was awarded
        to Puerto Rico to fund a waterborne virus study.  Under
        the study, twelve sewage treatment plants and five water
        treatment plants will be sampled and analyzed for specific
        viral and/or bacterial and parasitic agents.

     o  Untreated waste from CSOs (from 110 locations in Region
        1), presents a problem in several regions.  Region 1
        has documented 34 CSOs which discharge continually into
        Boston Harbor because of sewer blockages, accumulated
        sediments in pipes and tidegate failures.
                               29

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Requested Headquarters Actions

     o  Pursue regulatory reforms to address "big city"
        funding problems through the use of set aside or
        carryover accounts (Region 1).

     o  Complete the Best Conventional  Technology guidelines
        for paper mills.  The guidelines should include  BOD
        and color limits, possibly based on new treatment
        technology (Region 4).

     o  Address the problem of minor municipal facilities by:
        1)  providing additional resources to the Regions, or
        2)  redirecting existing resources (now focused on
        majors) in such a manner that the Regions can devote
        some effort to addressing this  problem.  Invest  more
        attention and resources to direct technical assistance
        and training in operation and maintenance (O&M)  of
        municipal wastewater treatment  facilities (Region 4).

     o  Expedite any needed concurrences on EPA final decisions
        relative to the Boston Metropolitan District Commission
        301(h) waiver reapplication (Region 1).
                              30

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     PCB CONTAMINATION
Problem Assessment

Contamination of ground and surface waters from PCBs was discussed
as a problem in six Regions.  Three of these Regions discussed
problems in detail, citing PCBs in underground mines
(Region 8), facilities using PCBs located in drainage areas
(Regions 1 and 5), and improper storage and disposal practices
(Regions 1 and 5).

o  In Region 1, New Bedford Harbor is contaminated with PCBs from
   two electrical capacitor companies.  Multi-media contamination
   has led to its designation as an NPL site.  Impacts include
   fishing bans, sewage lines contaminating outfall, and sediment
   concentrations ranging from 500 to 1000 ppm. (50 ppm is
   considered the maximum acceptable level.)

o  PCB transformers left in mines in Region 8 are presenting a
   significant problem.  The Eagle Mine in Gilman, Colorado, had
   3000 Ibs. of PCBs removed under a Superfund removal action.
   If these had not been removed, they may eventually have been
   covered with 400 feet of water, contaminating surface water
   in the area.

o  Over half of the facilities inspected in Region 5 have been
   found to be in violation of PCB oils storage and disposal
   regulations.  Approximately 8,000 facilities in the Region
   are subject to PCB regulations, 700 of which will be inspected
   during the next two years.

Requested Headguarters Actions

o  Address cleanup of PCB spills to an acceptably safe level
   through a uniform National policy (Region 5) .
                                31

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o  Issue final rules for addressinq transformer fires and
   transformers in private buildinqs (Region 5).

o  Continue funding for research and development of methods for
   analyzing environmental samples for PCBs (Region 5).

o  Provide R&D for methods to break down PCBs into a non-toxic
   form.  This would be most important to treat in-situ sediment
   contamination (Region 5) .
                                32

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   MARINE WATER QUALITY
Overview •

Regions 1,2,3,9, and 10 expressed concern with estuarine and
marine water quality.  Two general categories of problems were
identified: 1) estuarine water quality problems from industrial
and domestic waste effluents, combined sewer overflows (CSOs)
and nonpoint source runoff, and 2) ocean disposal of dredged
materials and sludge.  (See issues on inadequate wastewater
treatment and nonpoint sources for additional discussions.)

Major environmental impacts include:

     o  Closure of shellfish grounds, beaches, and introduction
        of pathogens (Regions 1,2,9,10);

     o  Damage to fisheries (Regions 3,9,10); and

     o  Sediment contamination from metals and toxics
        (Regions 2,9,10) .

Special concerns raised by Regions with regard to estuarine
and marine quality were:

     o  Major sources include malfunctioning wastewater treatment
        facilities, CSOs, nonpoint source runoff, sewage sludge,
        dredging activities, and oil transport and distribution.
        Boston Harbor is a major marine area of concern (Region 1)

     o  inadequate treatment facilities are leading to water
        quality violations in the New York Metro area and  Puerto
        Rico.  Alternatives to ocean sludqe disposal have  not
        been  implemented due to  institutional and regulatory
        problems (Region 2).
                                33

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     o  Valued resources of the Chesapeake Bay are declining.
        Oyster harvests and landings of freshwater-spawning
        fish have decreased.  This trend parallels an increase
        in nutrients and toxicants and the loss of submerged
        aguatic vegetation (Region 3).

     o  Urban runoff and pesticide/herbicide residues from the
        Central Valley are affecting San Francisco Bay.  Water
        guality and sludge disposal problems exist (including
        high concentrations of heavy metals and trace organics
        in bottom sediment) in waters off Southern California.
        A shortage of landfill capacity is seen as a barrier to
        cessation of ocean dumping.  Regional concern exists
        regarding long-term water guality impacts from outer
        continental shelf (OCS) oil and gas development (Region 9).

     o  Public concern has increased over high rates of abnormalities
        and cancer among bottom fish and bacterial contamination
        of shellfish near urban areas (Region 10).

Several actions have been undertaken to address marine water
guality problems.  These include:

     o  Support of several state and local actions aimed at
        improving wastewater treatment facilities which discharge
        into Boston Harbor (Region 1);

     o  Establishment of a Oeepwater (106-mile) site in the New
        York Bight for ocean disposal of sludge for a five-year
        period (Region 2);

     o  Signing of the Chesapeake Bay Agreement and development of
        a strategic plan to clean up, manage, and preserve the
        Bay (Region 3);

     o  Comprehensive Southern California regional studies to
        reduce emission of wastewater solids (sludge) significantly
        and to describe the most viable wastewater reclamation
        projects (Region 9);

     o  OCS Task Force and State/EPA agreement to develop and
        implement joint "environmental action" strategy.  Also
        included is development of a new 5-year general NPDES
        permit for OCS discharges which includes BAT/BCT effluent
        limitations set by Regional office (Region 9);
        Work in conjunction with Puget Sound Water Quality
        Authority to coordinate action program (Region 10);
and
     o  Implementation of Commencement Bay Action Plan, which
        identifies polluted areas and sources and tells how to
        remedy damage and prevent future problems (Region 10).
                               34

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Requested Headquarters Actions

o  Establish the control of combined sewer overflows as a Federal
   priority (Region 1).

o  Issue Agency policy on ocean dumping of sludge (Regions 1,9).

o  Issue guidance on acceptable interim sludge disposal methods
   pending final decisions on ocean dumping (Region 1).

o  Coordinate a mutual assistance program with other Federal
   agencies involved in oceanographic or estuarine research
   (Region 1).

o  Complete the ocean dumping regulations and criteria, including
   requirements for incineration at sea, and for a balancing
   of the impacts of ocean- and land-based disposal options,
   as stipulated in NYC v. EPA (Region 2).

o  Develop a strategy to provide for a well coordinated, integrated
   marine program (Region 2).

o  Develop an overall multi-media sludge management strategy
   (Region 2).

o  Provide guidance on water quality criteria and standards for
   toxics and other conventional parameters in marine estuarine
   waters (Region 10).

o  Describe point and nonpoint source control measures to be
   taken for each priority water quality problem area (Region 10).
                                35

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         ASBESTOS
                                                              RANKING
                                                              • HIGH
                                                              QUBOU
                                                              0UJW
                                                              BNOTMNKEO
Overview

Five of the Regions (l,5,7rlN10) discussed risks from exposure
to asbestos, most often in the context of the larger problem of
existing chemicals and pesticides.  All of the Regions discussed
problems with exposure and compliance in school buildings although
several also discussed problems with:

     - Exposure due to demolitions and renovations of buildings
       containing asbestos (Region 1 and 7);
     - Exposure as a result of presence of friable asbestos in
       public buildings (Regions 7 and 8); and,
     - Exposure to workers in asbestos producing or processing
       facilities (Region 10).

The control of asbestos exposure is complicated because the
current regulations are under two major laws, the Clean Air Act
(NESHAPS regulations for asbestos in building demolitions or
renovations) and TSCA (Section 6 rule for Asbestos in Schools).
All Regions reported difficulties in compliance.  Region 1 concluded
that the majority of all asbestos demolitions or renovations is
done in violation of one or more provision of NESHAPS.  Region
7 reported that a recent survey estimated that 20% of all public
and commercial buildings nationwide contain friable asbestos.
The Regions expressed concern over lack of resources to assist
building owners in achieving compliance.

Several Regions reported continued success with their school
asbestos technical assistance programs.  For example, Region 1
reported success in sponsoring an asbestos renovation/demolition
workshop for State inspectors.  Region 7 is continuing technical
assistance for specific facilities including the St.  Louis
Airport (Lambert Field), State Office Buildings in Des Moines,
Iowa and Kansas City, Mo., an oil refinery (with 6,000 miles of
asbestos pipe), and an air traffic control center.
                           36

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Region 1 also completed a Memorandum of Understanding with the
Regional OSHA Offices which includes exchange of information on
all notifications and inspections conducted by both agencies to
assist in improving compliance with the asbestos NESHAPS.

Requested Headquarters Actions

  o  Provide additional resources for expansion of enforcement
     and technical assistance.  Consider resource allocations
     based on the number and age of buildings in each Region and
     the rate of demolitions and renovations (Regions 1 and 5).

  o  Evaluate the risks, costs, and benefits of expanding  the
     asbestos program to other public buildings.  Appropriate
     technical and operational guidance should then be developed if
     this program is undertaken (Region 5).

  o  Provide definitive guidance necessary to assist the Regions
     and schools, which have few resources, in correcting  asbestos
     problems (Region 5).

  o  Perform an overall national assessment of the progress in
     compliance inspections and success rate in resolving  actual
     school asbestos problems through the existing regulatory
     process (Region 5).

  o  Publish regulations on asbestos in public buildings;  provide
     additional resources for implementation (Region 8).
                                37

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      ACID DEPOSITION
                                                                RANKING
                                                                • HWH
                                                                BMBOU
                                                                2 LOW
                                                                SNOTMNKCD
                                                                QNOTOfVHASIZB
Overview

Five Regions (1,2,5,7,8) discussed acid deposition as a problem
or potential problem of concern.  Regions 1,2,5, and 8 described
the extent to which areas in their Region have been, or potentially
could be, affected by both wet and dry deposition.  These effects
include chemical changes to lakes and streams, growth reduction
in forests (particularly at high elevations) , and damage to
buildings and monuments.  The pollutants of concern are sulfur
oxides and nitrogen oxides.  All 5 regions discussed local sources
as having some local impact, but concern was also expressed
regarding upwind sources, particularly from the Midwest.  Some
Northeastern States are in the process of reguiring tighter
controls on local emissions of acid deposition precursors.  The
estimated cost and associated impacts on electrical utility
rates and employment, along with the current inability to document
precise source/receptor relationships, have effectively inhibited
regulatory action, particularly in the Midwest.

Many efforts are planned or are underway to assess the magnitude
and extent of the problem and, in some cases, to control certain
aspects of the problem.  Regions 1,5, and 8 have participated in
lake surveys.  Region 2 has supported research efforts in New York
and New Jersey and efforts to reduce SO2 emissions in New York.
Region 5 has produced a series of papers documenting estimated
costs of the most probable control scenarios for the 17 largest
S02 sources in Ohio and the probable effects on utility rates.
Selected States in Region 5 have taken or will take steps to
reduce SO2 emissions.
                                3R

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Requested Headquarters Actions

Requested actions focus on continued research to fill data gaps,
assess effects, and explore and support possible control alternatives
to mitigate potential effects of acid deposition.  Specific requests
include:

o  Continue full support of National Acid Precipitation Assessment
   Plan (NAPAP) projects, ensuring that adequate resources are
   committed to long-term research projects and environmental
   monitoring.  The ORD acid rain budget must be fully funded
   and tracked (Regions 1,5).

o  Develop a monitoring methodology for dry deposition.  Other
   research results must be used to develop control plans.  EPA
   should take immediate steps to improve the procedures for
   developing and approving emission data bases and for approving
   them (Region 1).

o  Guide program planning through EPA's regulatory review and
   approval experience.  Headquarters must assure efficient
   coordination of  acid-rain issues.  The Office of Air and
   Radiation must continue to analyze issues and control options
   (Region 1).

o  Provide a forum  for discussion of strategies and research
   findings by different government and industry groups (Region 1).

o  Encourage regional strategies and innovative institutions
   that could implement control plans on a regional or national
   basis.  OAR should make state support and regional implementa-
   tion assistance  available (Region 1).

o  EPA should:  continue the Agency's multifaceted approach
   to determine causes/effects of acid deposition and emission
   reductions necessary to reduce acid deposition in sensitive
   areas (Region 2)j develop or modify Regional scale models to
   predict acid rain effects (Region 8); and coordinate action
   to mitigate interstate transport (Region 2).

-------
 PRESERVATION OF WETLANDS
                                             REGIONAL RANKING
Overview

Five of the ten Regions addressed preservation of wetlands in
their EMR updates.   Of those Regions that ranked the issue,
four ranked it in the lower third of significant problems.
The major concern was loss of valuable wetlands and the
resultant impact on wildlife (Regions 4,5,7).

o  Region 2 estimated a loss of 40% of New York and New Jersey's
   coastal wetlands since the 1930's.  Significant losses of
   inland freshwater wetlands continue, particularly in headwater
   areas covered by the Corps of Engineers' nationwide permits.

o  Increased turbidity, erosion of topsoil, pesticide and
   nutrient contamination, and flood management problems have
   resulted from wetland loss in several regions (Regions 4,5).

o  Urban sprawl (Region 2), water development projects (Region 8),
   and agricultural conversion (Mississippi Delta - Region 4)
   continue to destroy wetlands:  protection regulations do not
   adequately address two major aspects of the problem,
   drainage projects and piecemeal destruction.

o  In Region 4, a "Blue Ribbon Panel" sponsored by the Vicks-
   burg Corps of Engineers conducted an inventory of existing
   bottomland hardwood wetlands in the Mississippi River
   Basin and determined acreages under Section 404 jurisdiction.
   The next step will include two preliminary studies to assess
   water quality effects from clearing and agricultural
   conversion.
                              40

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Requested Headquarters Actions

 o  Evaluate and initiate discussions to revise and update the
    1976 EPA/Corps/Dept.  of Justice Memorandum of Understanding
    on Section 404 enforcement (Region 2).

 o  Improve relations with the Corps of Engineers (Region 4).

 o  Increase efforts in areas of public involvement and national
    publicity relating to wetlands values (Region 4).

 o  Develop and implement programs designed to facilitate
    wetlands protection.   (Region 5).

 o  Assess options to protect wetlands against harmful but
    currently unregulated practices (Region 5).
                               41

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     SLUDGE MANAGEMENT
                                           REGIONAL RANKING
Overview

Four Regions (1,2,6,9) discussed problems associated with sludqe
management and disposal.  Region 6 expressed an overall concern
with sludge management, particularly with ineffective solids
removal by wastewater treatment systems and the consequent passing
of "sludge" into receiving waters.  Possible major impacts identified
by Region 6 were contamination of food sources, ground and surface
waters; transmission of disease; odors; and flies.

Regions 1,2, and 9 were principally concerned about sludge from
POTWs and its effect on marine water quality and aquatic life,
including contamination of shellfish beds and fisheries.  This
specific aspect is discussed within the overall context of the
marine water quality issue.

To address the sludge problem, Region 6 has a designated Regional
Municipal Sludge Management Coordinator.  Region 6 has also
issued a Regional strategy and guidance for municipal sludge
management.

Requested Headquarters Actions

o  Proceed with timely publication of regulations and guidance to
   support EPA Policy on Municipal Sludge Management (Region 6).
                                42

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     BORDER PROBLEMS
     AND INDIAN LANDS
Overview

Three Regions (6,8,9)  outlined significant environmental  problems
relating to pollution across borders.  Regions 6 and 9  expressed
concern with the transport of pollutants from Mexico, while
Region 8 discussed potential increases in pollution from  development
in and around Indian lands.

Region 6 listed several multimedia concerns.  These included
impacts of air pollutant emissions from Mexico, impact  of raw
sewage discharge from Mexico into the Rio Grande, transportation
of hazardous wastes and toxicants across the border, and  need
for a Mexico/U.S. International Contingency Plan to deal  with oil
and hazardous substances pollution incidents.  In addition,
there is concern over radiation contamination of steel  products
in Ciudad Juarez, Mexico.

Region 9 is concerned with the discharge of raw sewage  from
Tijuana, which eventually impacts the beaches of South  San Diego,
and the discharge of raw and partially treated sewage and industrial
wastes from Mexicali into the New River, which eventually reaches
the Salton Sea.

The U .S ./Mexico Agreement for Protection and Improvement  of the
Environment in the Border Area was signed in August 1984.  The
Agreement provides that both governments shall undertake, to the
fullest extent feasible, to adopt appropriate measures  to
reduce and eliminate sources of pollution in their respective
territories which affect the border area of the other.  Work
groups have been convened in both Region 6 and Region 9 to address
selected problem areas.

Region 8's concerns center on energy or mineral resources
development adjacent to or on Indian reservations.  Such  development
could produce air guality problems (e.g., PSD violations) on

                                43

-------
reservations and neighboring lands.  EP^ grants are being used
by Indian tribes for baseline data collection,  regulation,
development and redesignation studies for PSD areas.

Reguested Headguarters Actions

Region 9 reguested continued budget and policy support for the
implementation of the U.S./Mexico Agreement.

Region 6 had three specific requests:

   -  Continued emphasis through EPA*s Office of International
      Activities (OIA) and the State Department for the effective
      involvement of Mexico in carrying out the Agreement;

      Establish an OIA system to notify the Region of international
      shipments of hazardous wastes; and

      Review the policy on air quality attainment dates for
      international border areas.

Region 8 reguested support for work with Indian tribes to implement
a program which begins to identify and assess environmental guality,
especially under the PSD program.

-------
         GROWTH
                                                               QMOOU
                                                               Bum
                                                               BNOTMNKCD
                                                               QNOTQMUSIOC
Overview

Regions 6 and 8 expressed concern over activities associated
with growth and development and their impacts on environmental
quality.  In Region 6, population and industrial growth is
resulting in increased pressures on the environment in virtually
every area, including water quality and quantity, air quality,
environmentally sensitive areas, and multimedia public health
concerns.  Region 8's concerns are focused on the development
of the vast energy resources available in the region.  Such
development, if improperly done, can exact a significant
environmental cost.

Region 6 plans to address growth as an environmental problem.
The Region will work with State and local governments to implement
appropriate planning measures in many areas to accommodate
growth and prevent significant degradation.  Likewise, Region
8 is continuing to emphasize environmentally sound energy
development through existing regulatory programs, cooperation
with State and federal agencies, and development and review
of Environmental Impact Statements.

Requested Headquarters Actions

Region 6 requests support in time and resources in developing
and implementing policies geared toward early action in
addressing growth related issues.
                              45

-------
        RADIATION
                                                             RANKING
                                                             • MGH
                                                             BMDOU
                                                             13 LOW
                                                             B NOT RANKED
Overview

Regions 7 and 8 expressed concern over existing and potential
radioactive hazards.  Both Regions described specific, potentially
hazardous, exposure concerns regarding active or abandoned
radioactive waste disposal sites.  In addition, Region 8  identified
indoor radon progeny, uranium mills, and low- and high-level
radioactive waste disposal as significant environmental problems.

In Region 7, a detailed radiological field study of two of the
three sites of concern was conducted.  In Region 8, the Office of
Radiation Programs sponsored a study of measurement techniques
for radon progeny elements using Butte, Montana as a  site for
pilot testing.

Requested Headquarters Actions

None identified.
                               46

-------
    EMPHASIZE GEORGRAPHIC
    SPECIFIC PROBLEM  AREAS
                                            REGIONAL RANKING
                                                                  UNKING
                                                                  • HKH
                                                                  BMOOLE
                                                                  3 LOW
                                                                  SNOTMMOD
Overview

Region 2 identified the Niagara Frontier as an area where a
coordinated multimedia geographic-specific approach to a serious
pollution problem will provide the best vehicle for controling
toxics.  After a series of studies, EPA worked in conjunction
with State, other Federal, and Canadian agencies to establish
a Niagara Frontier Agenda.  By establishing such an agenda, EPA
is focusing on and giving priority to State and Federal regulatory
programs to control the discharge of toxics into the Niagara River
Region 2 considers the Niagara Frontier an excellent example of
the geographic approach to toxics integration: the Region is using
its authorities under a number of media-specific statutes to
achieve overall environmental results.

Similarly, Region 9 views a geographic-specific approach as an
effective means to address environmental problems which cross
over program and political jurisdictions.  Such an approach also
allows the relevant control agencies to focus efforts on solving
the specific environmental problems rather than carrying out
activities to meet programatic targets.  Region 9 cites the
work in the Santa Clara Valley as a good example of a multi-
jurisdictional, cooperative effort to  solve environmental
problems in a geographic  specific area.

Other Regions which identified a  specific geographic areas in
their list of significant environmental problems were: Region  1
(Boston Harbor, New Bedford Harbor), Region 3  (Chesapeake Bay),
Region 5 (Great Lakes), Region 6  (U.S. Mexico Border) and Region
7  (approximately 70 local sites).
                                47

-------
Requested Headquarters Actions

o  Designate the Niagara Frontier as the next Integrated
   Environmental Management Program Project.  Provide additional
   legal, technical and community relations resources for the
   Region to dedicate to the Niagara Agenda (Region 2).

o  Identify use of coordinated multimedia geographic-specific
   approaches as an EPA priority (Region 9).
                               48

-------
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                                                       Attachment B


    SIGNIFICANT ENVIRONMENTAL PROBLEMS AS PRESENTED BY REGIONS


Region 1

   1 - Ground Water Protection

   2 - Boston Harbor

   3 - Toxics

   4 - Long Range Transport:

         o Acid Rain
         o Ozone

   5 - New Bedford Harbor

   6 - Hazardous Waste Permitting and Compliance

   7 - Asbestos and Public Health

   R - National Municipal Policy

   9 - Marine Water Ouality

  10 - Combined Sewer Overflows and
       Nonpoint Sources

    Emerging Problems:  Pesticides
                        Indoor Air
                        High-tech Industries


Region 2

   Ground Water

      1 - Superfund Sites on the National Priorities List
      2 - RCRA Treatment, Storage and Disposal Facilities
      3 - Other Sources of Ground Water Contamination

   Residual Wastes

      4 - Need to Site Hazardous Waste Treatment and Disposal
          Facilities and Resource Recovery Facilities
      5 - Need for Proper Disposal Options for Sludge, Dredged
          Materials and Industrial Wastes

   Air Pollution

      6 - Ozone in Metropolitan New York and in New Jersey Statewide
      7 - Carbon Monoxide in Metropolitan New York and in Urban Areas
          of New Jersey
      8 - Air Toxics
      9 - Acid Deposition

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                                 -3-

 Region 5

    1 - Hazardous waste management and response

          o Superfund
          O RCRA

    2 - Control of toxics in water

    3 - Groundwater protection

    4 - Violation of primary air quality standards

          o Ozone
          o Sulfur dioxide
          o Particulates

    5 - Toxic substances-existing chemicals:  PCBs,  asbestos,
        and pesticides

    6 - Protection of drinking water supplies (VOCs)

    7 - Acid deposition

    8 - Air toxics

    9 - Water quality of the Great Lakes

   10 - Preservation of wetlands

     Emerging Problem:  Leaking underground storage  tanks

Region 6

   1 - Growth

   2 - Ozone

   3 - Toxics

   4 - Ground Water Quality Problems

   5 - Pesticide Drift

   6 - Nonpoint Sources

   7 - Sludge Management

        o Municipal
        o Industrial

   8 - Leaking underground storage tanks

   9 - International border problems

-------
                                -2-

   Surface Water Quality

      10 - Toxic Contamination of Selected New York  and  New
           Jersey Waters

      11 - Conventional Pollution from Municipal Dischargers in the
           Metropolitan New York City Area and in Puerto Rico

   Other Regional Priorities

      12 - Wetlands Protection

      13 - Persistent Violations in Public Water Supply  Systems
           in the Virgin Islands

      14 - Niagara Frontier Agenda

Region 3 (not in priority order)

   Chesapeake Bay

   Surface Toxics

   Groundwater

   Nonpoint Source Pollution

   Ozone

     Emerging Problems:  Indoor Air Pollution
                         Dioxin Homologues and Polychlorinated
                           Dibenzofurans
                         Inter-Regional (III,IV,V)  Environmental
                           Issues
                         Low Level Pollutants fromm  Multiple Sources
                         Delaware Bay - Marine Policy

Region 4

   1 - Toxics in Groundwater

   2 - High concentrations of ozone and carbon monoxide  in
       large metropolitan areas

   3 - Toxics in surface waters

   4 - Air toxics

   5 - Destruction of wetlands

   6 - Bacterial contamination and low dissolved oxygen  levels
       in small streams and coastal areas

-------
                                -4-

Region 7 (ranked within media, not between media)

   Hazardous Waste
       o 25 issues

   Toxics and Pesticides

       o Asbestos
       o Pesticide Drift in Iowa

   Radiation

       o Former AEC Operations
       o Farmers Chemical Co.
       o W.R. Grace Co.

   Air

       o 19 issues

   Water Quality

       o 25 issues

   Water Supply

       o 5 issues

   Wetlands

       o Rainwater Basin, Nebraska

Region 8

   1 - Hazardous Waste Control

   2 - Ground-Water Contamination

   3 - Urban Air Quality

   4 - Nonpoint Source Water Pollution

   5 - Toxics

       o Asbestos
       o PCBs

   6 - Acid Deposition

   7 - Pesticides

   8 - Radiation

   9 - Drinking Water Quality

  in - Municipal Discharges

-------
                                -5-

   11 - Indian Lands

   12 - Wetland Protection

   13 - Federal Facilities

   14 - Energy Development

Region Q

   1 - Ozone NAAQS Exceedances in the South Coast Air Basin

   2 - Ground Water Contamination from Leaking Underground
         Storage Tanks - Santa Clara Valley

   3 - Toxic Air Emissions from Waste Facilities and
         CERCLA Sites

   4 - Public Water Supply Systems in the Trust Territory
         of the Pacific Islands

   5 - Water Pollution in Mexican Border Area

       o Tijuana
       o Mexicali

   6 - Siting of New Hazardous Waste Facilities in California

   7 - Oceans and Marine Waters

         o San Francisco Bay
         o Southern California Bight
         o OCS-Oil and Gas Development

   8 - Water Ouality Impacts from Agricultural Drainage in
       San Joaquin Valley and Sacramento Delta

Region 10

   1 - Exposure to Hazardous Waste

   2 - Water Supply:  Contamination of Ground Water and
         Drinking Water Supplies

   3 - Toxic and Hazardous Materials in Marine and Estuarine
         Sediments

   4 - Pesticides and Toxic Substances

   5 - Lead Pollution

   6 - Air Pollution:  Carbon Monoxide and Ozone Air

   7 - Air Pollution:  Particulates

   8 - Microbiological Contamination of Estuarine and Shellfish Areas

   9 - Fishery Damage from Contaminated Waters

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    t  i   ro
Dc   20180

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