ENVIRONMENTAL
 MANAGEMENT
    REPORT

    REGION 6
    SEPTEMBER 1985

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ENVIRONMENTAL
 MANAGEMENT
    REPORT

    REGION 6

      xvEPA
    SEPTEMBER 1985

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                            TABLE OF CONTENTS


Subject                                                                  Page

Part I,   The Regional Administrator's Overview	   1

Part II,  Regional Environmental  Problems	   5
   Standard Table Listing and Ranking Environmental  Problems	   6
   Growth	   9
   Ozone	  12
   Acci dential Rel eases	  16
   Muni ci pal SI udge Management Uti 1 i zati on	  18
   Leaking Underground Storage Tanks	  20
   Nati onal Border	  22
   Small Public Water Supply System	  27
Part III, Regional Recommendations for the Agency's Fiscal Year
   1987-1988 Priority List	  31
Appendix A ERI Pilot	 A-l

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Part I.
The Regional Administrator's Overview

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 The five states in Region  6  (Arkansas, Louisiana, New Mexico, Oklahoma
 and Texas)  have a combined area  of 560,000  square miles with a total
 population  of over 27  million people.  There are marked differences in
 regional climate, topography and ecosystems which require a wide range
 of State and EPA responses to adequately protect the environment and
 public health.  From the large Industrial centers to the sparsely popu-
 lated deserts, great differences are found  in demographic make-up,
 socioeconomic structure, and environmental  problems.  These differences
.combined with the rapid population growth,  present continual challenges.

 Region 6 continues to experience rapid population growth which is pro-
 jected to increase 40% by  the year 2000.  Such rapid and persistent
 growth can  make maintaining  environmental quality more difficult than
 achieving improvement in a nongrowth situation.  Although there should
 not be a compromise of basic environmental  goals and objectives, more
 flexibility is needed in program policy, regulations and statutes to
 allow EPA and the States to  bring a broader range of responses to the
 special  environmental  problems of high growth areas.

 Ozone continues to be a problem  in Region 6 with 31 counties and par-
 ishes having not attained  the National Ambient Air Quality Standard
 (NAAQS).  Both mobile and stationary sources of Volatile Organic Com-
 pound (VOC) emissions  are  continuing to increase.  EPA and the States
 will begin  to evaluate and take  corrective  action to control ozone
 generation  in nonattainment  areas.

 The Bhopal, India tragedy  has sensitized the public to episodes of acci-
 dental releases.  Region 6,  in coordination with the Regional Response
 Team (RRT), is taking  steps  to improve the  ability of government at all
 levels to respond to and,  when possible, prevent environmental emergen-
 cies.

 Progress is being made on  the many environmental problems along the U.S./
 Mexico Border.  In August 1983,  Presidents  Reagan and de la Madrid signed
 the U.S/ Mexico Agreement.  This agreement  pledges cooperation at the high-
 est level between our two  countries and designates EPA as the U.S. lead in
 this regard.  The success  of negotiations with Mexico and the securing of
 agreements  for action are  now necessary before all of the parallel actions
 required to achieve our environmental objectives can occur.

 We are implementing the Underground Storage Tank (UST) program.  The sche-
 dules for UST implementation must be met.   The control of leaking under-
 ground storage tanks is an important environmental initiative in Region 6
 as is the overall UST  program.

 The proper  management and  disposal of industrial and municipal wastewater
 treatment sludges 1s essential to preventing the return of pollutants to
 receiving waters.  More emphasis 1s needed  in this area.  EPA and the
 States in Region 6 are committed to a program of education and technical
 assistance  to improve  the  management, utilization and disposal of munici-
 pal sludges.

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Small water supply systems continue to have the most difficulty  complying
with State and EPA regulations.  EPA and the States in Region 6, through a
combination of education, technical assistance, and, if required,  enforce-
ment are making progress in improving the compliance of small water supply
systems.

There was increased consultation with State agencies throughout  the EMR
preparation process this year.  Most States agreed that growth and the
pressures of maintaining environmental quality which it exerts were major
issues.  New Mexico and Texas agencies agreed that environmental problems
associated with the international border is a major issue.   One  State
agency emphasized the need to consider economic status, demographic pat-
terns and history when searching for solutions to environmental  problems
in areas like the border with Mexico.  Individual State agencies were also
concerned about issues such as RCRA small  quantity generators, pesticides,
underground injection, loss of RCRA interim status, etc.  A more general
theme reflected in many State responses has been a concern  with  increasing
demands without parallel increases in the ability to respond. The States
for the most part agree with the need for long range planning and priority
setting which the EMR represents, but believe that to have  a real  impact
it must result in flexible and stable objectives for dealing with major
environmental problems.

There are many issues and initiatives which are not discussed elsewhere in
this report.  Some of these will be discussed very briefly  here.

Groundwater protection continues to be a high priority in Region 6. Sign-
ificant issues and accomplishments in this area are:

1)  Extensive progress has been made in FY 85 to better coordinate all
    groundwater related programs in the Region at both the  federal and state
    level.  Memoranda of Understanding (MOUs) have been developed between
    key offices at EPA and the states which deal with water supplies and
    groundwater contamination in the vicinity of industrial  or hazardous
    waste sites.  Public notification procedures are also embodied in these
    MOUs.  In addition, internal control procedures within  the Region have
    been developed to insure adequate followup and coordination  of all site
    investigations.

(2) In cooperation with HQs and the States, specific funding has been set
    aside and grants have been made to all States to develop State ground-
    water strategies or implement existing strategies.  Additional funding
    was made available for FY 85, using Clean Water Act Section  106 supple-
    mental funds.

(3) With the promulgation of the "Osage" regulation in 1984, the largest
    single UIC program on Indian lands was established and  actual permit-
    ting of injection wells began in early FY 85.  There are some 3800
    Class II (oil and gas-related) injection wells on the Osage  Mineral
    Reserve in Oklahoma.

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(4) Regional Task Forces have been established to assist the Region's
    Implementation of Groundwater Classification Guidelines and the EPA
    Groundwater Monitoring Strategy.

The improvement of surface water quality has been a long term objective  of
EPA and the States.  In many ways it is the cornerstone of other environ-
mental initiatives.  There has been an improvement in the water quality
of many streams despite increases in the volume of wastewater discharges.
Maintenance of water quality in some high growth areas has in itself been
a major accomplishment.  Many gains have occurred in the area of delegations
and an improved State/EPA partnership which have served to strengthen  the
water quality program.

Region 6 and Region 4 have worked together to issue a general permit for
oil and gas facilities in the Gulf of Mexico.  Other opportunities exist
for jointly addressing ocean program issues.  We expect that this coordi-
nation and cooperation will continue to produce environmental results
in both Regions.

An emerging administrative problem is the difficulty we sometimes encounter
when interagency cooperation is required to achieve environmental results.
The problems involved are very complex and consequently the need for coop-
eration is often poorly understood.  This lack of understanding can be
further complicated by a difference in mandates between EPA and another
agency.  Managing complex issues to achieve environmental results requires
understanding and cooperation at all  levels from other agencies if the
public interest is to be well served.  In our experience the key to achiev-
ing cooperation is clear, concise, and timely communication with other
agencies to insure that their management at all levels recognizes the  need
for the support sought.

The adequacy and reliability of data bases continues to be a problem.
Although we have made a great deal of progress, we frequently fall short
of our goal.  Given the importance of all of our data bases in assessing
problems, making management decisions, and gauging progress this problem
should have a high priority.

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Part  II.
Regional  Environmental  Problems
 DESCRIPTION OF THE RANKING AND SELECTION CRITERIA FOR PART II;

 The environmental problems chosen for inclusion in the 1985 EMR are
 those which will have a significant impact on our goal of managing for
 environmental results.  Their ranking, while subjective, is based first
 on the seriousness of the environmental  impact of the problem in Region 6.
 Public concern and the perception that EPA and the States should be taking
 action to deal with the problem were also an important consideration.
 Other considerations were health and economic impacts of the problem in
 specific areas and regionwide.  The selection and ranking was done by a
 panel which included the senior regional staff.

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                                                    Region 6
                                      1985 Environmental Management Report
                                       Significant Environmental  Problems
Relative Ranking
of Environmental
Problems
GROWTH:
Growth
Geographic
Scope
Reglonwide
Major
Source
Numerous
Major
Impacts
Adversely affects
Level of
Public
Concern

Contaminants
of Concern

OZONE:

Ozone non-
attainment
In urban
and rural
counties
Texas,
Louisiana,
& Oklahoma
ACCIDENTAL RELEASE:

Potential for
major upset
episodic
release of
toxic sub-
stances
into the air
Regional
Vehicles and
Industiral
facilities
emitting
volatile
organic com-
pounds (VOCs)
and nitrogen
oxides (NOX)
Industrial
facilities
which manu-
facture/use
toxic chemi-
cals
                                                       Moderate EPA's
                                                       ability to main-
                                                       tain all aspects
                                                       of environmen-
                                                       tal quality
Exposure of
millions of
residents to
ozone levels
exceeding the
national
health standard
Moderate
Adverse health
effects/risks
to citizens
from exposure
to airborne
contaminants
                                                          High
                                                                          Numerous,
                                                                          affecting  all
                                                                          media
Ozone
                Cancer
                causing
                non-criteria
                pollutants

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Relative Ranking
of Environmental Geographic
Problems Scope
Major
Source
Major
Impacts
Level of
Public
Concern
Contaminants
of Concern
MUNCIPIPAL SLUDGE MANAGEMENT UTILIZATION and DISPOSAL:
Public health not Regional
adequately pro-
tected by failure
Land application
of municipal
sludge
Pathogens
1n sludge
and odors
Medium
Pathogens
odors
to use appropriate
treatment techni-
ques for municipal
sludge

UNDERGROUND STORAGE TANK (UST):
Underground
Storage Tanks
(UST) which
are currently
Leaking
Regional ,
as well as
National
Petroleum
facilities
(e.g. gas
station)
UST Interim
prohibltation
implementation
National
Lack of guidance
documents for UST
owners/operator
National
The need for work-
shops and training
for the UST owner
Regional
Facilities
that plan to
install an
UST after
May 7, 1985
All UST facili-
ties in regu-
lated community
Contamina-
tion of
water supply
& presence
of dangerous
ignitable
vapors

Reduces the
chances of
newly
installed
UST's to
leak in the
future

With the con-
venience of
obtaining
guidance from
EPA the UST
owner will
have more
incentive
to comply
with UST
requirements

Reduce the
chances of
newly
installed
UST's to
leak in the
future
                                                                         High
Moderate
to High
Moderate
to High
                                     Moderate
                                     to High
                                                                    Petroleum/
                                                                    Chemical
                                                                    substances
Same as
above
 Same as
 above
                 Same as
                 above

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oo
Relative Ranking
of Environmental
Problems
NATIONAL BORDER:
Transboun-
dary Move-
ment of
Hazardous
wastes




Need for Con-
tingency plann-
ing for environ-
mental emergen-
cies Involving
oil and Hazard-
ous substances


Geographic
Scope

100 KM on
each side
of the U.S.
Mexico
border with
Texas & New
Mexico (1200-
length of Rio
Grande)









Major
Source

1) Industrial
Facilities
2) Transpor-
tation
3) Unknown




1) Internation
2) Regional
3) State
4) Local
5) Industry




Level of
Major Public
Impacts Concern

Illegal Moderate to
Transpor- High
tation
& Disposal





Reduction
of adverse
Impacts to
public
health wel-
fare A envir-
onment as
result of pre-
planning
Contaminants
of concern

Hazardous/
toxic wast







Oil and hazard
ous substance







            Water Quality
            in Rio Grande
            Impact of A1r
            emissions in
            Ciudad Juarez,
            Mexico on air
            quality in
            El  Paso, Texas
El Paso
Juarez
air basin
            SMALL PUBLIC WATER SUPPLY SYSTEM:
            Quality of drink-
            ing water
            served by
            small  systems
Regionwide
1) Untreated
   and inadequa-
   tely treated
   wastewater
2) Pesticides in
   agricultural
   run-off
1) Automobile
   emissions
2) Small manu-
   facturing
   facilities
   (particularly
   brick plants)
3) Burning of
   various fuels
   by heating
Low-compliance
with drinking
water regula-
tions (standards)
1) Residents of
   Rio Grande
   valley (U.S.
   & Mexico ex-
   posed to risk
   disease
2) Aquatic
   life, pesti-
   cides in
   fish, approx.
   500,000 El
   Pasoans and
   1-million
   residents of
   Juarez breath
   air that Mexico
   fail to meet
                                                                           Bacteria,viruses
                  High on Ameri-
                  can side; has
                  been brought
                  to the attent-
                  ion of the
                  officials 1n
                  Mexico
Pesticides,
ozone, carbon
monoxide, lead
particulates
sulfur
                     Low
Rural and
smal1 towns
people con-
suming contaminated water
Bacteriological
Turbidity

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                                GROWTH
1.  Problem Assessment:
The five States of Region 6 --  Arkansas,  Louisiana, New Mexico, Oklahoma
and Texas -- lie at the heart of the "Sunbelt".   Growth of  population and
Industrial activity in and around metropolitan areas  throughout the Region
has been tremendous.  More than 27 million people now live  in  Region 6,
and population is expected to increase  by almost  40 percent by the year
2000.  Almost all of the metropolitan areas in the Region are  growing at
rates faster than the national  growth rate.  Three of the ten  largest
cities and two of the ten largest Metropolitan Statistical  Areas  (MSA) in
the country are in the Region.   Houston and Dallas-Fort Worth  were the
fastest growing large metropolitan areas  in the country from 1980-83, at
15 percent and 14 percent annually,  respectively.  Of the 21 MSA's in the
U.S. growing at an annual rate of 15 percent or more,  nine  are located in
Region 6.

The population and industrial  growth phenomenon in Region 6 is burdening
the environment in virtually every medium, by increasing:

- demands for fresh water, which strains  the ability  of water  supply
  systems to maintain quality and quantity;
- sewage discharges, which stress treatment facilities, often  where the
  assimilative capacity of receiving waters is limited, and which encour-
  ages proliferation of inadequate individual on-site or residential
  septic systems;
- developments in urban areas and around  water supply reservoirs  near
  urban centers, which generate non-point source  discharges;
- pumping of groundwater resources,  which results in  salt water intrusion,
  increased susceptibility to contamination and surface subsidence;
- energy exploration and development and  their attendant pollution poten-
  tials; - mobile sources of air pollution,  principally automobiles, in
  metropolitan
  areas resulting in difficulty in attaining and  maintaining ozone and
  carbon monoxide standards;
- sources of air emissions from industrial expansion, which add sources
  of pollution in attainment areas adjacent to non-attainment  areas;
- the development of lignite coal fired power plants, with  the associated
  discharges of S02 and particulates, and other potential impacts;
- potential for exposure of the population to toxic air pollutants in
  growing population centers;
- hazardous waste produced by an increasing number of generators;
- the movement of urban population into surrounding agricultural  areas
  resulting in higher residential exposure to pesticides;
- the need for coordinated response to accidental releases  of  hazardous
  material because of increased industrial activity,  concentration of
  people near industrial and transportation corridors, and  development
  in the vicinity of hazardous waste handling facilities;
- development, which threatens environmentally sensitive  areas such as wet-
  lands, fishery nursery areas, and floodplains.

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The general public does not view growth  per  se  as  a  significant problem.
Moreover, appreciable concern for potential  environmental  problems  asso-
ciated with growth tends to elude the  citizenry until  the  problems  become
actual, and either the advantage or necessity of confronting  a particular
dilemma becomes apparent.  The resolution  of these environmental concerns
is dependent, in large measure, on the sensitivity and commitment of  local
governments to the environmental  effects of  population increases.

2.  Regional Agenda/Barriers:

     a.  Regional Actions and/or Plans - EPA, Region 6 will work to in-
crease the awareness of State and local  governments  and elected officials
as to the nature and extent of prospective environmental problems.  By anti-
cipating environmental problems,  governments at all  levels may be able to
lessen the risks to the population and reduce the  costs of corrective
actions by incorporating environmental concerns into their planning efforts.

     b.  Extent of State Participation - EPA, Region 6, will  provide  infor-
mation to the States on the potential  environmental  effects of the  growth
phenomenon.  We will request the assistance  of  appropriate state agencies
in providing such information to local governments and elected officials at
all levels.

     c.  Timing requirements - Dealing with  growth as  an environmental pro-
blem will be required for the forseeable future.

     d.  Barriers - The principal barriers are: 1) the pervasiveness  and com-
plexity of the problem; 2) the number  of entities  with which  activities must
be coordinated; 3) the difficulty in promoting  any initiative which might  be
viewed as land use control; and 4) the involvement of  interest groups which
sometimes yield an influence wholly out  of proportion  to their real or
supported constituencies.

3.  Headquarters Action Needed:

     a.  Specific Action Requested - EPA,  Region 6,  requests  that:  1) head-
quarters provide support in time and resources  in  developing  and implement-
ing policies geared toward providing information to  state  and local govern-
ments and elected officials  on the environmental  effects  of  growth;  and
2) statutes and regulations be drafted or  amended  to allow EPA flexibility
in administering its programs to productivelu address  anticipated problems
due to growth rather than being limited  to dealing with the resultant effect
once growth has occurred.  Environmental critics and observers should
appreciate that the unparalleled growth  which continues to transform  the
Southwest often establishes the preservation of the  status quo in relation
to the environment as the equivalent of  measurable progress elsewhere.  The
Region, therefore, needs a degree of flexibility in  the application of cer-
tain traditional indicators of environmental results.
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     b.  EPA Offices and Programs Involved  -  EPA,  Region  6,  forsees  all
EPA offices and programs to be involved,  some  continuously.

     c.  Timing Requirements - Dealing with  growth  as  an environmental
problems will be necessary as long as present  trends continue.

4. Environmental Reuslts:

     a.  Changes Seen from Previous Actions  -  No  changes are  evident.  How-
ever, it is important to remember that preservation of the status  quo may
actually represent positive results.

     b.  Environmental  Objectives - EPA seeks  to  maintain  environmental
quality and achieve improvements in the environment where  such  gain  is a
reasonable expectation.

     c.  Expected Environmental  Results -  Developing specific measureable
results expected from the regional  agenda  and  the requested headquarters
action is extremely difficult for this parameter.  This is due  to  the fact
that:  1) growth does not lend itself readily  to  EPA or State government
influence; 2) growth affects a wide range  of programs  in varying degrees
and often at unpredictable times; and most importantly, 3) the  preservation
of the status quo in high growth areas may be  the equivalent  of measurable
progress relative to areas with stable populations. However, certain en-
vironmental impacts, as measured through the various media trends  analyses,
could possible be evaluated to determine relationships by  the growth  of
levels of contaminants, and, to some extend  our ability in controlling such
factors.
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                                 OZONE
1.  Problem Assessment:

Region 6 has an ozone problem that needs  further  national  guidance and
must use unique approaches to protect the health  of citizens  regionwide.
This will be a resource intensive effort.

There are currently 31 counties/parishes  in  Region  6 that  are classified
as nonattainment for the ozone National Ambient Air Quality Standard
(NAAQS).  (See Figure 1.)  Six urban areas (Dallas, Tarrant,  and  El Paso
Counties in Texas, East and West Baton Rouge Parishes in Louisiana, and
Tulsa County in Oklahoma) are classified  as  post  1982 nonattainment areas
and received calls to submit State Implementation Plan (SIP)  revisions by
February 24, 1985.  Harris County, Texas  which  is also an  urban nonattain-
ment area, has been given an extension to demonstrate attainment  by
December 31, 1987.  Eighteen counties/parishes  are  considered rural ozone
nonattainment areas and are not now subject  to  SIP  revisions  that require
attainment of the NAAQS.  A call for a SIP revision was made  for  another
potential rural nonattainment area, Denton County,  Texas,  with the re-
vision due in October 1985.  The remaining areas  are urban nonattainment
areas which are expected to be redesignated  to  attainment. They  are:
Nueces County in Texas; and Bossier, Caddo,  Jefferson, St. Bernard, and
Orleans Parishes in Louisiana.

The major components of the ozone problem are hydrocarbons (HC) and nit-
rogen oxides (NOX) emitted by automobiles and Volatile Organic Compound
(VOC) emissions from stationary sources.   Region  6  suspects that  the lack
of continuous compliance from major stationary  sources and increased auto-
mobile emissions because of a high rate of tampering and misfueling are
major contributors to the continuing ozone problems in Region 6.

Listed in Table 1 are the 18 ozone nonattainment  areas in  Region  6 which
are classified as rural nonattainment areas  because they lack central city
populations of 200,000 or greater.  The official  EPA position in  the past
was that they exceed the NAAQS because of the impact of emissions from
nearby urban areas.  In January of 1984,  the policy was revised to consider
the potential of a rural nonattainment area  causing its own nonattainment.
In Region 6, we believe some of these areas  are generating their  own
problems.  For example, in 1982 Jefferson County, Texas had VOC emissions
totaling 103,800 TPY.  By comparison, Dallas County, an urban nonattainment
area, had VOC emissions of 82,400 TPY during that same year.   The petroleum
Industry and other sources of VOC emissions  in  the  Gulf Coast area have
created this unique situation in Region 6.
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                                                                                                   7
Figure 1.   Ozone nonattainment areas
           1n Region 6

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                                Table 1
                 Rural Nonattainment Areas  in  Region 6

Orange Co., TX        Ascension Par., LA                Grant Par., LA
Jefferson Co., TX     Iberville Par., LA                Beauregard Par., LA
Victoria Co., TX      St.  James Par., LA                Lafourche Par., LA
Brazoria Co., TX      St.  John the Baptist  Par.,  LA    Lafeyette Par., LA
Gregg Co., TX         Calcasieu Par., LA                St. Mary Par., LA
Galveston Co., TX     Point Coupee Par.,  LA            St. Charles Par., LA

2.  Regional Agenda:

     a.  Regional Action/Plans - 1)  A major initiative  will be required to
determine if the problem is due mainly to emissions from  automobiles or
stationary sources.  Also, the impact of  source upsets  and malfuctions will
be evaluated so that corrective measures  can be incorporated into the SIP
control strategy development process.  2) Additional ozone modeling will
be performed to determine the extent of VOC controls necessary.  3) A set
of criteria to determine ozone self-generation in rural areas has been
devised by Region 6.  OAQPS reviewed the  criteria and suggested modifica-
tions.  Region 6 intends to identify self-generators by criteria based on
air flow patterns, ozone contamination from other areas,  and natural ozone
levels.  Then, Region 6 will call  for SIP revisions for VOC controls in the
identified counties/parishes.  4)  Region  6  plans  to finish categorizing the
rural counties and discussing the results with the states by Fall 1985.
5) Calls for SIP revisions have been issued by Region 6 to the affected
states for the urban areas.  6) Additional  HC  and NOX data collection efforts
are underway in a 1985 special summer monitoring  study.   7) Development of
mobile source control programs, such as anti-tampering  programs, in all post
1982 non-attainment areas when needed.

     b.  Extent of State Participation -  1) Texas cooperated with EPA in
monitoring for nonmethane hydrocarbons (NMHC)  in  eight  nonattainment areas
in FY 1984.  In the case of the post-1982 urban nonattainment counties,
these data were used in ozone modeling by Texas to obtain the amount of VOC
reductions required of Dallas, Fort Worth,  and El Paso.   Texas currently
estimates these reductions to be 52.8%, 51.5%, and 10.5%, respectively.
Louisiana worked with a private contractor  to  estimate  VOC reductions needed
in the Baton Rouge area.  In FY 1985 Texas  and Louisiana  are cooperating in
another, similar NMHC monitoring effort.  Oklahoma is revising preliminary
ozone modeling for Tulsa by working with  a  private contractor during the
Summer of 1985.   2) FY 1986 air grants will require the  states to study
the impact of source upsets/ malfunctions on attainment,  as did the FY 1985
grants.

     c.  Timing Requirements - A call for SIP  revisions is expected to go
out in late 1985.However, it may not include all affected rural areas due
to the Region's limited resources.  Some  will  need to be  addressed in 1986.

     d.  Barriers - 1) Texas and Louisiana  may take serious issue with our
rural ozone classification criteria.  Any controls ultimately proposed
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may be difficult to Implement because of increased resistance  to  tighter
controls on industries.  (2) Modeling difficulties may delay control
estimates as would public protests over the  proposed  control strategies.

3.  Headquarters Action Needed:

     a.  Sped fie Action Requested -  Long range  guidance  needs to be  pro-
vided to address nonattainment and its appropriate solutions.   Specific
guidance has been, and will  continue  to be,  required  for  modeling.  A
National Policy for reasonable available control technology will  continue
to be required.  Also, uniform regulations across the Nation need to  be
developed.

     b.  EPA Offices and Programs Involved - Office of Air Quality Planning
and Standards, Control Programs Branch, and  Office of Mobile Sources.

     c.  Timing Requirements - Guidance should be given to Region 6 by
early 1986 in order for it to effectively evaluate new SIP revisions  that
are required to demonstrate attainment by December 31, 1987.

4.  Environmental Results:

     a.  Changes Seen From Other Previous Actions - More  stringent statio-
nary source controls and I/M programs are planned for several  urban areas
of Region 6.  Stationary source controls akin to those in effect  in the
Houston area may be necessary for the industrialized, self-generating rural
ozone nonattainment areas of Texas and Louisiana.

     b.  Environmental Objectives - The object of additional controls is
attainment of the 03 NAAQS by the end of 1987.

     c.  Expected Environmental  Results - Attainment  of the NAAQS by  the end
of 1987 is doubtful in Houston and Dallas Fort-Worth.  Reduction  of the magni-
tude of the ozone maxima may occur with these additional  hydrocarbon  controls.
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                          ACCIDENTAL  RELEASES
1.   Problem Assessment:
The Bhopal, India incident has raised a  number  of  concerns  from  the public
as to EPA's preparedness in a similar toxic  release situation.   The new
air toxics national strategy,  entitled "A Strategy to  Reduce  Risks to
Public Health from Air Toxics", addresses such  accidental releases by
focusing on reinforcement of emergency preparedness and  response capa-
bilities at all levels of government. Due to the  heavy  concentration of
petrochemical industries which manufacture and/or  use  toxic chemicals in
Region 6, the Regional office is initiating  a program  with  involved States
to increase awareness of episodic releases in terms of preventability and
response, and to provide for increased coordination among involved Federal,
state, and local agencies.

2.   Regional Agenda:

     a.   Regional Actions and/or Plans  - It is anticipated that the
Regional initiative of addressing episodes of accidental release will result
in a clearer definition of this potential problem  and  increase preparedness
capabilities.  This action is being taken in coordination with the Regional
Response Team to ensure that effective,  up-to-date contingency plans are
being maintained, and to address the roles and  responsibilities  of the State
agencies in an emergency episode.

     b.   Extent of State Participation  - The Region 6 States will be
evaluating their state regulations which require reporting  in instances of
major upsets or accidental releases.   In addition, they  will  be  conducting
in-depth inspections of selected sources having the potential for major
accidental releases of toxic substances.

     c.   Timing requirements - This project, as outlined,  is expected to
be completed under the FY 86 air grant objectives.

     d.   Barriers - Pending the outcome of  the in-depth inspections,
possible barriers may include limited enforcement  action, due to statutory
limitations, which may be taken in cases such as those involving reporting
violations.

3.   Requested Headquarters Action:

     a.   Specific Action Requested - The national strategy for  air toxics
has defined a direction in which the program will  be moving;  however, the
Regions need a clearer definition of their role in implementing  the provi-
sions of the strategy.  A question of funding and resources also exists in
terms of carrying out these strategy initiatives.   If  the focus  in the
future will be on building State capabilities to control toxics  as is
planned, Regional expertise must be augmented as well  in order to provide
1) technical support to States and 2) public information on pollutants
and actions taken by States.


                                   16

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     b.   EPA Offices and Programs Involved -  Office  of  Air Quality
Planning and Standards, Office of Solid Waste  and Emergency Response,
Federal Emergency Management Administration, Coast Guard.

     c.   Timing Requirements - In order to implement the  strategy im-
mediately ,~gTiTolincT^oF~tFie~iregional  office is needed as soon  as  possible.

4.   Environmental Results:

     a.   Changes seen from previous  actions - No previous action has been
taken to address this particular problem.

     b.   Environmental Objectives -  Objectives from  this  project include
1) enhanced capability in terms of emergency preparedness  and  responsive-
ness of Federal, state, and local  governments, 2) identification  of  exist-
ing gaps in state upset/release reporting requirements,  and 3) possible
enforcement action against facilities violating reporting  requirements.

     c.   Expected environmental  results - The outcome expected will be
the realization and awareness of the  potential in our Region for  an  en-
vironmental emergency, and in the event of a major accident, what mecha-
nisms can be utilized to abate such an occurrence and prevent  future ones.
                                   17

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                     MUNICIPAL SLUDGE MANAGEMENT
                       UTILIZATION AND DISPOSAL

1.  Problem Assessment:

Sludge management, utilization, and disposal  problems vary in complexity
and magnitude.  Growth of municipalities and higher treatment levels
required to protect water quality creates additional  demands  for waste-
water treatment facilities that generates more sludge each year. Ineffec-
tive solids removal by wastewater treatment systems pass sludge into  the
receiving waters.  Inadequate sludge management programs create environ-
mental problems.  Emphasis on sludge management is not equal  to the
emphasis on wastewater management.  While sludge problems are regional  in
scope, they are usually site specific.  The site specific problems occur
in the humid gulf coastal area as well as in the dry and arid locations.
The communities range in size from small  rural  communities to large metro-
politan cities.

Major sources and causes are municipal wastewater treatment facilities,
industrial processes that discharge to municipal systems, ineffective or
non-existent sludge management programs,  inappropriate technology, and lack
of pretreatment.  Sludge contaminants of concern are pathogens and toxic
substances, including hazardous wastes and heavy metals.

Major impacts are possible contamination of food sources, ground and  sur-
face waters, transmission of disease, odors,  files, and fear  of the unknown.
The level of public concern generally is low, however, when ineffective
sludge management programs result in contamination, public concern becomes
high.  Also, public concern becomes high on an individual basis when  sludge
is introduced for the first time in the local enviroment without adequate
public participation and education.  Relevant jurisdictions are States and
local governments.

2.    Regional Agenda/Barriers:

     a.  Regional Actions and/or Plans -  Region 6 has issued  a strategy and
guidance for municipal sludge management, co-sponsored and participated in
State workshops.  A continuous public information/education program on
sludge management is maintained for engineers,  local  governments, equipment
manufacturers, sludge generators and handlers working through university
and agricultural extension/cooperative systems.  The Region provides  over-
sight of State implementation of the EPA National Policy on Municipal  Sludge
Management.  This includes field inspection and evaluation of construction
grant projects and participation in follow-up enforcement where applicable.

     b.  Extent of State Participation -  All  States have been delegated the
Municipal Sludge Management and Disposal  Program for Construction grants pro-
jects.  Each State has a municipal Sludge Management Coordinator.
                                   18

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     c.  Timing Requirements -  A sludge management,  utilization, and dispo-
sal program for each fiscal  year is planned,  including  specific objectives
to be accomplished with budgets and dates  for accomplishing  the objectives.

     d.  Barriers - The major barriers are public  misunderstanding and mis-
information and State codes  which are too  restrictive in  land application
and reuse of sludge.

3.  Headquarters Action Needed:

     a.  Specific Action Requested - Provide  personnel  and financial assist-
ance in conducting seminars/workshops and  assure timely publication of regu-
lations and guidance.

     b.  EPA Offices and Programs Involved -  Offices of Municipal Pollution
Control, Water Regulations and Standards,  Solid Waste,  Water Enforcement and
Permits and the Water Engineering Research Laboratory.

     c.  Timing Requirements -  Same as Regional.  Each  fiscal year will have
a plan to achieve National and  Regional objectives and  goals.

4.  Environmental Results:

     a.  Changes Seen From Previous Actions - Increased beneficial use of
sludge.  States and communities are more aware of  EPA's Sludge and Manage-
ment Policy of maintaining or improving environmental quality and protect-
ing public health.

     b.  Environmental Objectives - Increased compliance

     c.  Expected Environmental Results -  Increased beneficial reuse of
sewage sludge while maintaining or improving  the environmental quality and
protecting public health.  An indicator of environmental  results would be
the number of tons beneficially used as related to total  tonage generated.
                                   19

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                     Leaking Underground Storage  Tank
                                  (LUST)
                                 Program


1.  Problem Assessment:

Leaks and spill occuring from an  Underground Storage Tank  (UST)  have been
contaminating the soils and groundwater for many  years.   It was  not until
recently that EPA discovered just how serious the problem  was.   It is esti-
mated that there are over 2 million USTs operating in  the  United States
and 200,000 are currently leaking.   The above figures  do not  include USTs
which have been abandoned with substances still  remaining  inside.  In some
cases the contamination of UST leaks (especially  gasoline) became so ser-
ious that entire buildings and community areas became  a hazard zone due  to
explosive vapors and contamination of water supplies.  Due to the serious
nature of UST spills, on November 8, 1984, the Hazardous  and  Solid Waste
Amendments were passed by the President.  In Subtitle  I, of the  amendments
addresses the regulatory requirement for USTs storing  regulated  substances,
including petroleum.  The implementation of the entire UST program will
take approximately 4 year.  Certain timeframes have been  set  during the
4 years period in which the EPA,  the States, or owner/operator of UST will
have to meet regulatory deadlines for implementing the program,  (e.g.
notification requirements, interim prohibition, development of tank stan-
dard, corrective action requirements etc...).

2.  Regional Agenda/Barriers:

     a.  Regional Actions and/or  Plans - Region 6 keeps in constant con-
tact with the State agencies which have been designated by the Governors
of each State to receive the notification of USTs made by  the owner/opera-
tor.  Any changes or new developments that may occur  in the UST  program  is
transmitted to these State agencies.

Region 6 provides assistance to owner/operators  of USTs for the  Interim
Prohibition requirements.  The Prohibition requirements became effective
on May 7, 1985 and it prohibits the installation  of an UST unless:  1) it
will prevent releases due to corrosion or structural  failure  for the opera-
tional life of the tank; 2) it is cathodically protected  against corrosion,
constructed of non-corrosive material, steel clad with a  non-corrosive
material material, or designed in a manner to prevent the  release of or
threatened release of any stored  substance; and 3) the material  used in  the
construction or lining of the tank is compatible  with the  substance to be
stored.

The owner/operator of an UST can  be exempt from  the above  requirements if
soil test conducted in accordance with ASTM Standard  G57-78 or another
standard approved by the EPA, show that soil resistivity  in an Installation
location is 12,000 ohm/cm or more.  Any violaiton of  the  prohibition require-
ments will result in Regional Enforcement Action  by the EPA.
                                   20

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     b.   Extent of State Participation -   The Region will  consider the
possible scheduling of training workshops  on the implementation of the UST
program.  It will be the intent of the workshop to inform the  UST community
of certain UST requirements which they must meet.   The Region  will  also  pro-
vide speakers for States and private organizations holding seminars which
includes the UST program.  These seminars  must be non-profitable or have
enough attendance from different organizations tobe advantageous for EPA to
provide a speaker.

     c.   Timing Requirements - Region 6 will  be reviewing Grant proposals
from the State agencies that were designated to receive UST notifications
for FY 86 appropriations.  7 million dollars has been authorized for FY  86
and Region 6 will receive an allotment for $625k.   The amount  appropriated
to each state will depend on the need of each State.  Some of  Region 6
allotment can be used for contract activity that supports the  UST program.

     d.  Barriers - None known at this time since the program  has not begun.

3.  Headquarters Actions Needed:

     a.  Specific Action Requested - The major problem in the  implementation
of the UST program is the lack of guidance.  Headquarters must furnish guid-
ance manuals in a timely manner so that UST facilities will have less trouble
in complying with the UST requirements.  In addition, personnel involved in
the UST program should be readily available for seminars and workgroups.

     b.  EPA Offices and Programs Involved - Currently Headquarters staff  is
in the task force stage.

     c.  Timing Requirements - Many UST facilities are still uninformed  of
some of the recent requirements of the UST program (e.g. interim prohibita-
tion).  A wider form of communication should be used to inform these facili-
ties of the current and future standing of the UST program.

4.  Environmental Results:

     a.  Changes Seen From Previous Actions - None since program has not
started yet.

     b.  Environmental Objectives - To ensure that the UST program fulfills
its purpose, there must be high incentive  for UST facilities to comply with
the requirements.  To accomplish this, EPA must be ready to offer guidance
and recommendations for any request of assistance.  In addition, timely  and
efficient implementation of the UST timeframes is necessary in order to
resolve the problems of contamination that USTs have been casuing for many
years.

     c.  Expected Environmental Results -   The ultimate goal of the UST  pro-
gram is to reduce hazardous waste and petroleum leakage from these tanks.
                                   21

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                            NATIONAL BORDER
1.  Problem Assessment:

In August, 1983, Presidents Reagan and de la Madrid  signed the  U.S.-
Mexico Border Environmental Agreement pledging cooperation at the  highest
levels of both governments in the protection and improvement of the envir-
onment along the border.

This agreement designated EPA for the U.S.  and the Secretariat  for Urban
Development and Ecology (SEDUE) for Mexico as the two agencies  in  charge
of further coordinating and implementing the agreement.   Three  technical
workgroups for toxics, water, and air, composed of representatives of
these two Federal agencies, have identified priority issues for each envir-
onmental media in a 100 kilometer zone on each side  of the border.

The Rio Grande forms a common international  border between the  U.S. and
Mexico for approximately 1,200 miles from El Paso to Brownsville,  Texas
where it empties into the Gulf of Mexico.  Basin population is  approxima-
tely 2,580,000 people in Texas and Mexico (1980). For the most part,  the
population is concentrated in municipalities on both sides of the  river in
the upper and middle reaches, with the addition of numerous farms  and
farming communities in the lower valley.  Municipal  facilities  and oil and
gas production, storage, and transportation facilities are also located
along the river.  The EPA/SEDUE technical workgroups have identified the
following as environmental concerns of highest priority.

The workgroup on toxics has listed the need for contingency planning for
accidental releases of oil and hazardous substances  as well as  the trans-
border movement of hazardous wastes as a primary concern.  The  water
quality concerns in the Rio Grande, as identified by the  workgroup on  water,
include raw sewage discharges in the Nuevo Laredo and El  Paso-Juarez areas,
elevated pesticide levels in fish tissue and sediment, and frequent viola-
tions of water quality standards in some segments.

In addition, El Paso and Ciudad Juarez have a common air  basin. The rela-
tively high elevation (3700 feet to approximately 7100 feet) means that
combustion of fossil fuels is less efficient, hence  "dirtier,"  than compar-
able combustion at low altitudes.  The situation is  complicated by the
presence of an international border.  In Ciudad Juarez emissions from
relatively old, uncontrolled automobiles, small manufacturing facilities,
and burning of wood, cardboard, and other "dirty" fuels contribute signi-
ficantly to the particulate, lead, sulfur dioxide, carbon monoxide, and
ozone ambient concentrations.  Approximately 500,000 El Pasoans and 1-million
Juarez residents are affected by these concentrations. The National Ambient
Air Quality Standards (NAAQS) for ozone, lead, carbon monoxide, and total
suspended particulates are regularly violated in El  Paso, and the  sulfur
dioxide standards are endangered there.
                                   22

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           [,,/U^/MEXlCAN BORDER ili
       AREA OF ENVIRONMENTAL CONCERN
  CALIFORNIA
U)
                                 NUEVO LEON

                                    TAMAUUPAS-

-------
Region 6 has been coordinating  with the States of Texas and New Mexico
to address these issues.

    2.  Regional Agenda/Barriers:

         a.  Regional  Actions and/or Plans - Region 6 will continue working with
    the border cities through the  States  to work toward the resolution of the
    problems identified by the  three U.S./Mexico technical workgroups.

    In the area of contingency  planning,  Region 6 is working with the Texas
    Department of Water Resources  (TDWR)  to insure that the City of Laredo, a
    border community,  has an effective plan to respond to environmental
    emergencies resulting from  accidental discharges of oil and hazardous
    substances and that the various response plans—industry, city, State, and
    Federal— are coordinated to insure an effective and expeditious response.
    This effort is being  undertaken as a  pilot exercise with the intent of
    conducting similar exercises in the future with other cities along the
    U.S./Mexico border.

    The Region, working through the State, has implemented a study to iden-
    tify the international shipments of hazardous waste from the EPA hazardous
    waste manifest system.  Region 6 intends to establish a communication link
    with SEDUE to exchange information concerning transborder movement of
    hazardous waste.   The Region also plans to develop a bi-national pilot
    training program to provide information to the U.S./Mexican customs and
    border patrol  officials to  effectively implement the environmental re-
    gulations and laws regarding transborder movement of hazardous waste.  EPA
    is presently consulting with the U.S./Mexico Customs Service to develop
    the training program  and to spotcheck imports/exports.  Through the know-
    ledge gained, the Region's  long term  plans include making suggested regula-
    tory/ legislative changes and  amendments to the U.S./Mexico Environmental
    Agreement.

    The EPA/SEDUE workgroup for water recently reached a tentative agreement
    regarding acquisition and sharing of  water quality data for the Rio Grande.
    There was also agreement on the need  to better define water treatment
    requirements for facilities discharging to the Rio Grande from both
    countries.

    Relative to addressing the  air pollution problems along the border with
    Mexico, the Region anticipates a better Mexican effort in monitoring and
    emissions inventory for the El Paso/Juarez area as a result of recent
    training in air monitoring  sponsored  by Region 6 and provided through the
    EPA/SEDUE Air Workgroup in  June, 1985.

    The Region will work  with TACB to effect the most stringent inspection/
    maintenance program practicable and will continue to provide training and
    engage in technical discussions with  SEDUE and enter into cooperative
    monitoring/emission inventory  work in order to better characterize sources
    in the Juarez area.
                                       24

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     b.  Extent of State Participation   -  TDWR  is  an  active  participant  in
the contingency planning efforts along  the border.  The proposal  to  develop
a joint study for defining water quality problems  and needs  for the  river
has been discussed with TDWR which has  expressed a willingness to participate.

The Texas Air Control Board (TACB) is participating in the solution  of the
air problem by developing strategies, timetables,  and new regulations to
decrease hydrocarbons and carbon monoxide  emissions in El Paso.   Specifi-
cally, El Paso ozone and carbon monoxide State  Implementation  Plan (SIP)
revisions are expected from TACB by September 1,  1985.

     c.  Timing Requirements - El Paso  ozone and carbon monoxide  State Imple-
mentation Plan (SIP) revisions are expected from TACB by September 1, 1985.

     d.  Barriers - To a large extent,  the success of the Region  in  imple-
menting solutions to the various problems  comprising  the national  border
issue hinges on the success of negotiations and agreements between the two
countries at the international level.  Because  Mexico's government is
essentially a centralized form of government, it is sometimes  difficult  for
the Region to coordinate actions at the local level.   Region 6 will  continue
working with the border cities through  the States  toward the various goals
established by the the U.S./Mexico technical  workgroups.

Potential problems relative to meeting  the goals of the water  program
include difficulty in securing agreement and actual implementation of con-
trols once a study is complete and needs are better defined  along with fund-
ing for data acquisition and water quality studies in fiscal years 1986  and
1987.

Anticipated problems in the air program revolve around the fact that there
is no indication that Mexico's efforts  will parallel  TACB's  preliminary  SIP
revisions for carbon monoxide which are intended to result in  attainment by
the end of 1987.

3.  Headquarters Actions Needed:

     a.  Specific Actions Requested - Headquarters clarification  is  reques-
ted on attainment of NAAQS's along international  borders when  an  adjacent
foreign city significantly impacts American territory. In addition,  special
appropriation, similar to the Great Lakes  program which focuses attention
on unique problems along the Canadian border, is needed. Special  monies
for the U.S.  border problems would be  used for such  efforts as air data
collection, binational technical training, water quality studies,  etc.

     b.  EPA Offices and Programs Involved - These include:  Office of
International Activities, Office of Air Quality and Standards, Office of
Solid Waste and Emergency Response, and Office  of Water.

     c.  Timing Requirements - Guidance from Headquarters must be forth-
coming before December 1987 on the issue of foreign impact upon El Paso,
particularly if the NAAQSs are still  violated in El Paso at  that  time.
                                   25

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4.  Environmental Results:

     a.  Changes Seen From Previous Actions -  Revisions  recently  proposed
by TACB press for vehicle inspection/SIP  maintenance as  well  as additional
industrial controls will provide for speeded reductions  of hydrocarbons
and carbon monoxide.

     b.  Environmental Objectives - The primary  objective of  the  water
pollution workgroup is to insure that wastewater discharged into  the  Rio
Grande from both sides of the border is adequately treated, thereby lowering
the health risk to users of the river and to define and  implement, to the
extent possible, methods of controlling pesticide pollution of the water,
sediment and aquatic life.

Attainment of the NAAQSs for ozone and carbon  monoxide by December 31,  1987
is an air objective.  Quick reductions in ambient lead and particulate  levels
are added objectives.

     c.  Expected Environmental Results - Expected environmental  results from
contingency planning efforts for oil and  hazardous substances incidents
along the border will occur primarily from the fact that the  potential  ramifi-
cations to the public health and welfare  and environment should be minimized
as a result of pre-planning.

Regarding the movement of hazardous waste across the border,  Region 6 ex-
pects over the next year to be able to estimate the volume and type of
hazardous waste involved in transborder movement from the hazardous waste
manifest forms.  Also, Region 6 expects to be  able to estimate manifest
violations and increase enforcement of the regulations through the spot-
checks at the border.  The increased enforcement will lead to more enforce-
ment actions.

The preliminary TACB SIP revision strategies for El Paso will demonstrate
attainment by the end of 1987 only if comparable pollution reductions are
realized in Ciudad Juarez.  In light of current economic and  social realities
in Mexico, such reductions are presently  highly doubtful.  Localized  improve-
ments in lead, sulfur dioxide and particulate  levels will probably occur in
El Paso areas adjacent to stationary sources for which more stringent controls
will be required by Texas SIP revisions.
                                   26

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                  SMALL PUBLIC WATER SUPPLY SYSTEMS
1.  Problem Assessment:

The Public Water System Regulatory Program involves 15,649 public water
systems in five Region 6 States.  Of these, the majority of the systems
and a majority of the problems occur in small  systems (i.e. those serving
less than 3,300 people).  These include 89.4%  of the 8,011 community systems
which serve a resident population.  The regional  population (See Attachment
1) involved is only 17% of the total, but the  problems of small systems
are numerous and worthy of the public health concern.

Many small public water supply syterns have difficulty in complying with
State drinking water regulations for a variety of reasons.  They either
fail to comply with maximum contaminant levels (MCL's) for health related
contaminants in their drinking water, or they  fail  to sample or otherwise
monitor as required by State and Federal regulation.  These may be indica-
tive of more severe problems in some instances.  Where these problems are
persistent, a system may be supplying drinking water which is either unsafe
or is of unknown quality, evidenced by a failure to adequately sample and
analyze the water supply.  A summary of the results of a recent analyses
(FY 79-84) is presented in attachment 2.  It indicates a progressive upward
trend in overall compliance for public water systems.  However, there con-
tinues to remain a significant number of non-compliant small water systems.

2.  Regional Agenda/Barriers:

     a.  Regional Actions and/or Plans - In cooperation with the States,
other agencies, associations,  and Headquarters, the Region is partici-
pating in extensive training and technical  assistance programs for
small systems personnel.  Technical assistance and compliance programs
are based on priorities aimed at major reduction to persistent
violations.

     b.  Extent of State Participation - The States have primary enforcement
responsibility (primacy) for the public water  supply supervision program.
They participate with EPA in development of priorities for regulatory
operations, training, and technical assistance directed toward elimination
of persistent violations to drinking water regulations.

     c.  Timing Requirements - The State activities are being further stream-
lined by the adoption of specific timetables to assure "timely and approp-
riate" response to each situation.  In the particular case of persistent
violators, each involved system will be tracked quarterly according to a pre-
set compliance/enforcement plan.

     d.  Barriers - The principal barriers to  bacteria and turbidity com-
pliance are operation and maintenance problems within the systems and lack
of commitment by the operators.  In small systems the economics are such
that the operator is only working part-time to cover all phases of the
system.  These problems are addressed through  operator


                                   27

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         SIZE   DISTRIBUTION
                    ATTACHMENT 1
                 OF    COMMUNITY   HATER
                           IN    REGION   6
                                     SUPPLY   SYSTEMS
00
         SIZE CATEGORY;
          (population)
VERY SMALL
 (<500)
                             No of CHS
    SMALL          MEDIUM            LARGE
(501-3,300)     (3,301-10,000)   (10,001-100,000)
                                               VERY LARGE
                                              (>100,000)
                  Population served
         NO OF CHS'S;
         % POPULATION
           SERVED:
  4,824
    3.4%
2,335
 13.5%
                      516
                     12.2%
 306
32.3%
  30
38.7%
8.011  (Total)

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                                     ATTACHMENT 2
                             REGION 6 POBLlt RATER SUPPLY
                PERSISTENT VIOLATOR AND TRENDS IN  STATE COMPLIANCE RATES
                                      COMMUNITY
                                        FY 84
Persistent Violators - Percent
te
FY 83
v 0.0
I 1.0
1.5
0.2
( 0.9
% PWS
Bact. MCL
FY 84
0.0
0.8
1.3
- 0.3
0.9
With No
T
(0.75)
(0.75)
(1.50)
(0.70)
(0.75)
Violations
Bact. M/R
FY 83 FYJJ4
1.6
0.0
2.2
10.6
10.3
for
1.8
0.0
1.9
3.2
10.3
the Year

_T_
(7.0)
(0.0)
(7.0)
(9.5)
(9.0)

                                                      Turb. MCL

                                                 FY 83   FY 84
                                                   0.0
                                                   0.0
                                                   0.0
                                                   0.0
                                                   0.6
                                             'Turb. M/R

                                            83   FY 84
                                          0.1
                                          0.0
                                          2.7
                                          7.2
                                          1.6
                      1.8
                      1.0
                      2.8
                      7.7
                      1.6
                  (2.0)
                  (0.0)
                  (2.0)
                  (5.0)
                  (2.0)
   Bact. MCL

Arkansas
Louisiana
New Mexico
Oklahoma
Texas

Bact. M/R
Arkansas
Louisiana
New Mexico
Oklahoma
Texas

Turb. MCL
Arkansas
Louisiana
New Mexico
Oklahoma
Texas

Turb. M/R
Arkansas
Louisiana
New Mexico
Oklahoma
Texas

FY 79
89
85
85
87
92
Reg. ~55

78
88
32
34
64
Reg. 61

98
100
82
100
95
Reg. ~W

97
97
85
80
92
Reg. 91
FY 80

  92
  86
  85
  86
  93
 ~5T
                                       FY 81
                  FY 82
FY 83
FY 84
 99
100
 91
100
 96
T  - TARGET
 MCL  - Maximum Contaminant Level
 M/R  - Monitoring  and Reporting
92
92
92
85
95
83
97
63
56
71
73
99
100
85
100
97
"97"
96
100
91
87
92
~9T
Bact.
Turb.
95
90
90
84
94
91
97
70
56
67
72
99
98
83
100
97
-9T
97
100
89
92
96
~9T
- Ba
- Tu
                                                            93
                                                            98
                                                            74
                                                            66
                                                            69
                                                           TT
                                                            99
                                                           100
                                                            86
                                                           100
                                                            98
                                                            95
                                                           100
                                                            92
                                                            92
                                                            96
                                                           ~9T
97
94
91
88
94
~ST
90
98
76
79
66
~7T
99
99
86
100
99
~99~
93
99
69
89
95
TT
(93)
(93)
(92)
(89)
(93)
(79)
(98)
(75)
(65)
(75)

,( 97)
(100)
( 97)
( 97)
( 97)

(100)
( 92)
( 92)
( 92)
                                           29

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training and certification programs to upgrade the competence  and  pro-
fessionalism of the operator and through technical assistance  visits  by
State engineers to identify system deficiencies and stress  the need for
quali ty control.

The barriers to chemical  quality problems are public acceptance, the
non-acute nature of the hazard,  the technology of treatment, and the
ultimate costs of a solution.  These barriers are particularly evident
in the small system with a limited budget, reliance on a single source
of supply, and lack of highly-skilled personnel.  These problems are
best addressed through the development of regional water systems,  use of
alternate water sources,  or application of low-cost treatment  technology.
In many cases these solutions must await new technology.

A newly developing barrier in many States is the need to reduce monitor-
ing activities in response to budget cuts by State legislatures.

3.  Headquarters Action Needed:

     a.  Specific Actions Requested - EPA Region 6 requests headquarters  to
support State and Regional actions by initiating and completing Phases  I-IV
of the Revised Regulations process; strengthening health effects guidance
on existing and new toxics; reviewing required monitoring frequencies and
apply appropriate changes; and developing appropriate guidance for enhancing
State and Federal public water supply enforcement actions against  violators,
particularly the small system strategy.

     b.  EPA Offices and Programs Involved - The Office of Drinking Water
(ODW).

     c.  Timing Requirements - All of these actions need to be initiated
and completed during FY 86 and FY 87.

4.  Environmental Results:

     a.  Changes Seen From Previous Actions - Compliance among small  systems
in Region 6 has improved significantly over the past several years since  EPA
and the States have set priorities based on number of violations and  concen-
trated efforts on the reduction and possible elimination of persistent
violators.

     b.  Environmental Objectives - The protection of the public health of
rural and small town populations through the enhancement of water-quality
from small systems.

     c.  Expected Environmental  Results - Safe drinking water  from small
water systems.Environmental results indicators will be the reduction  in
numbers of bacteriological and turbidity persistent violators  and  the popu-
lation served by the systems brought into compliance.
                                   30

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Part III.
Regional Recommendations for the Agency's
Fiscal Year 1987-1988 Priority List
                    31

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We recommend changes In the priority list:
1.  Add the UST program to Priority List because it is a problem which
    affects millions of tank owners.
2.  Place as #8 and lower all from #8-23 by one.
3.  Add as priority #25 the following:
    Perform a complete review of all agency data bases and prepare a report
    on their reliability and utility for making management decisions to
    achieve environmental  results.
                                   32

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Appendix A.
Environmental Results Indicators Pilot
                 A-l

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                              PILOT  ERI  No.  I

                        OZONE  in METROPOLITAN AREAS
Region Sis one of the fastest growing  Regions  in  the county and has at
least maintained the ozone levels in their  fastest growing cities.

The bar charts for the Cities of Dallas and Houston compare the average
2nd High Ozone Values and the Yearly Average Vehicle Miles Traveled (VMT).
This shows a decrease in the ambient ozone  level as compared to the city's
growth.

Average 2nd High Values are determined  by averaging the 2nd High Values
from all the monitors within a city's limit for each year from 1980 to
1984.  The 2nd High Value is chosen  because it  is  more representative of
ambient zone level in an area.

The Yearly Average VMT is obtained from the city's Council of Government
for each year.
                                   A-2

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     DATA
Harris County
1
1980 .22
1981 .19
1982 .18
1983 .21
1984 .19

1980
1981
1982
1983
1984
2 3
.21 — .
.22 .24 .
.14 .18 .
.23 .20 .
.20 .18 .
SITE
1 2
— 0.13
— 0.16
0.12 0.16
0.13 0.16
0.12 0.09
SITE NUMBER
4567
27 .30
19 .19
21 .19
26 .28
19 .16
NUMBER
3
0.11
0.12
0.12
0.16
0.12
.26 .22
.18 .19
.19 .17
.22 .21
.16 .14
Dallas
4
0.18
0.15
0.16
0.08
0.16
8 9
.22 .24
.14 .16
.19 .19
.20 .20
.18 .17
County
ave
0.14
0.14
0.14
0.13
0.12
AVE
.24
.19
.18
.22
.17
VMT
12.0
12.4
12.9
13.4
16.0
VMT
17.5
18.3
18.8
18.9
19.4

mi 1 1 i on
million
million
mi 11 i on
million
03/VMT
billion 1.37
billion 1.04
billion 0.96
billion 1.16
billion 0.88
03/VMT
1.17
1.13
1.09
0.97
0.75
         A-3

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  0.75-
1
I
UJ
3
                        HARRIS COUNTY
            1980
1981      1982      1983

       YEARS
1984
Legend
ca OZONE
• VMT

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  1.50 n
    DALLAS COUNTY
  0.75-
1
            1980
1981      1982     1983
       YEARS
1984
Legend
E3 OZONE
• VMT

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                            PILOT ERI  No.  2

                        U.S./MEXICO AIR QUALITY
El Paso air quality trends for selected pollutants:

                   Carbon                               Sulfur
         Ozone     Monoxide     Lead    Particulates     Dioxide

1981      2.6         8         10.6      215             72*
1982      3.1        10          6.6      159             83*
1983      4.6         7          5.7      116             81
1984      3.1         9          6.7      122             66
Ozone— number of expected exceedances of NAAQs  (to achieve attainment
        the 3-year average must be  less than  or  equal  to  1.0);  new  site
        1984 yielded 19.0

Carbon monoxide— number of exceedances of the 8-hour  NAAQS (two exceed-
                  ance in one year  qualifies  an  area as nonattainment)

lead-- highest quarterly average for year (in micrograms/cubic  meter)
       (an areas in subject to a SIP call with a quarterly  average
       reater than or equal to 1.55 microgram/cubic meter)

particulates— highest annual geometric mean  (AGM)
               (in micrograms/cubic meter)
               (an area qualifies as nonattainment  with an  AGM  greater
               than or equal to 75  micrograms/cubic meter)

sulfur dioxide— highest annual aritmetic mean (AAM)
                 (micrograms/cubic  meter)
                 (an AAM greater than  or equal to 80 micrograms/cubic
                 meter is necessary for designation of an area  to non-
                 attainment)
                                   A-6

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        Pilot ERI NO.  3
Water Supply Systems Compliance
                A-7

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                                     ATTACHMENT  2
                              REGION 6 POBtK RATER SUPPLY
                 PERSISTENT VIOLATOR AND TRENDS IN STATE COMPLIANCE RATES
                                      COMMUNITY
                                        FY 84
Persistent  Violators - Percent
ite
FY
^••••••i
0.
1.
1.
0.
0.

83
•MMB
0
0
5
2
9
Bact.
FY
^••••M
0.
" 0.
1.
• 0.
0.
Ma
84
•••••I ^BIBHI
0 (0.
8
3
3
9
,0.
1.
0.
0.

T FY
*••••••• ••••••••
75) 1.
75
50
70
75
0.
2.
10.
10.

83
6
0
2
6
3
Bact.
FY
••»•••••
1.
0.
1.
3.
10.
M/R
84
•••••>
8
0
9
2
3


T
•••••••••••••i
(7.
(0.
(7-
(9.
9.
0
0
0
5
0
Turb. Ma
FY 83
0.0
0.0
0.0
0.0
0.6
FY 84
0.0
1.0
5.6
0.0
0.6
•Turb. M/R
T FY 83
d.o]
(0.0
(i.o;
ji.o!
0.1
0.0
2.7
7.2
(1.0) 1.6
FY 84
1.8
1.0
2.8
7.7
1.6
T
(2.0)
(0.0)
(2.0
(5.0)
(2.0)
   % PWS With No Violations for  the Year
   Bact. Ma
   Arkansas
   Louisiana
   New Mexico
   Oklahoma
   Texas
   Bact. M/R

   Arkansas
   Louisiana
   New Mexico
   Oklahoma
   Texas
   Turb. Ma

   Arkansas
   Louisiana
   New Mexico
   Oklahoma
   Texas
   Turb. M/R

   Arkansas
   Louisiana
   New Mexico
   Oklahoma
   Texas
                    FY 79
               Reg.
               Reg.
               Reg.
               Reg.
                     98
                    100
                     82
                    100
                     95
97
97
85
80
92
                             FY 80
78
88
32
34
64
61
92
97
44
45
64
TT
 96
 92
 80
 80
 92
"8T
T - TARGET
 MCL - Maximum Contaminant Level
 M/R - Monitoring and Reporting
FY 81
89
85
85
87
92
15
92
86
85
86
93
"BT
92
92
92
85
95
~W
                                        83
                                        97
                                        63
                                        56
                                        71
 96
100
 91
 87
 92
                   FY 82

                    95
                    90
                    90
                    84
                    94
            91
            97
            70
            56
            67
          -JT
99
100
91
100
96
99
100
85
100
97
TT
99
98
83
100
97
H&7
 97
100
 89
 92
 96
FY 83
                                              FY 84
97
91
94
89
94
"5T
97
94
91
88
94
"ST
[93)
93
92
89;
93
93
98
74
66
69
TT
90 (79)
98
76
79
66 J 	 	
[98)
75
65}
75)
-75- J 	
                     99
                    100
                     86
                    100
                     98
                                                            95
                                                           100
                                                            92
                                                            92
                                                            96
                               93
                               99
                               69
                               89
                               95
                                          Bact.
                                          Turb.
            Bacteria
            Turbidity
                  100
                   92
                   92
                                          A-8

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VO
          SIZE   DISTRIBUTION
           SIZE CATEGORY;
            (population)
                   ATTACHMENT  1

                OF   COMMUNITY   HATER


                          IN   REGION   6
SUPPLY   SYSTEMS
VERY SMALL    ,    SMALL %    ,   MEDIUM   %   .      LARGE         VERY LARGE
 (<500)        (501-3,300)    (3,301-10,000)   (10,001-100,000)     (>100,000)



 No of CMS   I	I  Population served
NO OFCMS'S:
% POPULATION
4,824
3.4%
2,335
13.5%
516
12.2%
306
32.3%
30
38.7%
                                                                                                          8.011 (Total)
             SERVED:

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