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
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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).
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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.
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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
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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).
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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.
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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).
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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
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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).
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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
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-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
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-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
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-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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