EPA
.910/
1980.1
MONTANA / EPA
V
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MONTANVENVIRONMENTAL PROTECTION AGENCY
AGREEMENT
Agreement on the Management and Administration
of Montana's Environmental Programs
for Federal Fiscal Year 1981
September 1980
U.S. Fjwironrnentol Protection Age&oy
Librai-y. Room 2404 FM-211-A
401 M Street, S.W,
Washington. DC 20460
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Approved:
The undersigned hereby execute this Agreement on the Management and Administration
of Montana's Fiscal Year 1981 Water Pollution Control, Safe Drinking Water, Air
Quality, Solid Waste Management, Radiation and Pesticides Programs.
State of Montana
L
Thomas L. Judge
Governor
State of Montana
V Date
A. C. Knight, M. D., P.C.C.P.
Director, Department of Health and
Environmental Sciences
Date
W. Gordon McOmber, Director
Department of Agriculture
SEP 15 1980
Date
Environmental Protection Agency
oMi Admi
Admini s trator
Date"
Ivan W. Dodson, Director
Montana Office
7
x
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TABLE OF CONTENTS
Page
Introduction 1
State Environmental Overview ...... 1
Decentralization 2
Montana EPA Office 3
Public Health 3
Prevention 3
Energy Development 4
Program Environmental Summaries 5
Water Quality 6
Air Quality 16
Solid Waste Management and Hazardous Waste
Disposal 19
.Pesticides 20
Radioactivity 21
Toxics 22
Fiscal Year 1980 Accomplishments 23
Water 23
Air 25
Solid Waste 25
Pesticides 26
Radiation 27
Hazardous Wastes 28
National Environmental Policy Act 28
Toxics ... 28
Public Participation 28
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TABLE OF CONTENTS
(continued)
Page
Priorities 29
Water 29
Air 29
Solid Waste Management 30
Pesticides 30
Radiation 30
Resource Summary for Montana-EPA Programs 30
Priority Accomplishment Strategies 33
Air 33
Water 34
Solid Waste 39
Pesticides 41
Radiation 43
Media Work Plans 45
Air : 46
Water 51
Solid Waste 73
Pesticides 78
Radiation 81
Categorical Programs 82
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INTRODUCTION
Governor Thomas L. Judge, in his 1980 State of the State Address,
said:
IT/ time is the best teacher., the lesson of the last year was
that Montana is no longer an isolated fortress, but a
neighborhood in a complex world. For years, this state was
a mystery - a wild and beautiful place lost in the prairies
and mountains between the Mississippi River and the Pacific
Coast. Recently, however, this shield of isolation has been
rediscovered^ development is flourishing on the energy
_. frontier and our-coal, water and other resources are being
subjected to intense pressures.
The Departments of Health and Environmental Sciences (DHES) and
Agriculture (DOA) are among the State agencies charged with protecting
Montana's natural resources. As the federal counterpart to the DHES and
DOA, the U.S. Environmental Protection Agency (EPA) has been charged with a
Congressional mandate to administer various environmental programs.
Through grants, research, monitoring, technical -expertise and other
areas of cooperation, DHES, DOA and the EPA have taken lead roles in
helping Montanans improve their quality of life.
The workload created by these diverse programs prompted EPA to inau-
gurate a novel approach to planning and management. The approach involves
a comprehensive Montana/EPA Agreement (MEA), the aim of which is to con-
solidate all applications and narratives into one document. The result has
been a reduction in paperwork and duplication of effort, and more efficient
program management.
f
There has been little format change in the State programs addressed in
the 1981 MEA, the programs include DOA's pesticide program and the DHES's
air, water, radiation and solid waste management programs.
The elements of the MEA consist of; (1) an overview of the state's
environment; (2) identification of objectives; (3) strategies to accomplish
priorities, and (4) detailed work plans consisting of narrative descrip-
tions of activities and resource commitments.
STATE ENVIRONMENTAL OVERVIEW
Clearly, the major objectives in environmental programs are to control
pollution and to protect public health and the environment. Both state and
national legislation.contain many references to these objectives.
The references include:
Montana Pesticides Act:
The purpose of the statute is the control- of pesticides
for the protection of man and his environment, including
water, air, food, animals, vegetation, pollinating insects
and shelter...
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Clean,Air Act of Montana:
> iy'->,"• ••'•
. . .to achieve and maintain such air quality as will
protect human health and safety, and, to the greatest
degree practicable, prevent injury to plant, animals,
and property?...
Federal Clean Water Act:
It is the policy of the Congress to recognize, preserve,
and protect the.primary responsibilities and rights of
States to prevent, reduce, and eliminate pollution, to
plan the development and use (including restoration,
preservation, and enhancement) of land and water
resources. . .
•
Montana Solid Waste Management Act:
. . .control of solid waste management systems is intended
"to conserve natural resources whenever possible" as well
as to protect the public health and safety.
Determining the methods and. approach to meeting these objectives is
the business of federal, state and local environmental agencies. These
organizations are in turn responsible for ensuring that all concerned
parties are given the opportunity to participate in the decision-making
process.
Decentralization
Recently there has been a shift from the overcentralized form of
decision making and management, to a more responsive decentralized organ-
ization. Congress, working through the EPA and with cooperation from the
states, has been expanding the philosophy that a decentralized organization-
can produce better results. Federal grants that enable states to assume
program responsibilities are examples of that philosophy.
An important aspect of decentralization is delegation of responsi-
bilities. Considerable progress has been made in delegating major program
responsibilities from the EPA to the states, with Montana aggressively
pursuing the delegation of most federal environmental programs. Prom a
legislative perspective, the State has most of the required authorities
covered in the MEA. Due to a lack of adequate financial and human re-
sources, however, delegation of current EPA responsibilities continues to
be a phased process. The completion of the delegation agreement for the
Municipal Wastewater Facility Construction Grants Program under 205 (g) was
a major effort achieved in Fiscal Year (FY) 1979. The implementation of
that agreement was completed in FY 1980. Refinements to the original
agreement will be the major initiative for FY 1981.
Three additional program areas will receive attention during FY 1981.
1. Hazardous Waste Management
A delay in adopting the final EPA regulations precluded
the State from assuming responsibility for the program.
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The regulations were promulgated on May 19, 1980.
Most of the State legislative requirements have been com-
pleted. The State is expected to receive interim author-
ization from EPA during FY 1981.
2. Prevention of Significant Deterioration (PSD)
The State had adopted regulations to assume this program.
S Negotiations with the EPA will be conducted during the
next several months to ensure that federal guidelines are
met. Approximately 25 PSD permits will need to be issued
! during FY 1981. By FY 1981 there will be little or no
direct EPA permit issuance.
3. Noncompliance Penalties for Air Quality Violations
During the 1979 Legislative Session authority was granted
for the State to assess penalties against stationary sources
that violate provisions of the State Implementation
Plan (SIP). Because of the potential magnitude of this
legislation, the State will wait for the development of
regulations by EPA. EPA will work closely with the State
to facilitate delegation and provide appropriate assistance
when needed.
* Montana EPA Office
^ In an effort to strengthen working relationships between EPA and the
* State environmental programs, the Montana Office of EPA was formed in 1978.
This decision to localize EPA's involvement has, in most instances,
supplemented state program efforts and for other situations it helped
alleviate state resource problems. Other additional assets have included
the removal of many logistical problems, reduction of the need for formal
communication and increased accessibility for the public to the.EPA staff.
Public Health
The common denominator in most environmental programs is public
health. Ever increasing amounts of harmful substances are being identi-
fied. The impact of these substances on the health of the public continues
, to be a concern. The reduction of public exposure to dangerous pollutants
continues to be a high priority. Several studies have been initiated by
the State addressing public health issues. The statewide Montana Air
7 Pollution Study (MAPS), the Butte Radiation Study and the -Pesticides Drift
Study in the Kalispell area are a few of the noteworthy efforts. For FY
1981, the State and EPA will again establish as a chief objective, the
identification, evaluation"and control of pollutants that endanger public
health.
Prevention
As a state, Montana has built a reputation for its-commitment to
preserve the quality of its land, water and air. When reviewing the State
of Montana's environment, it becomes apparent that the state does not
suffer from widespread and serious environmental degradation; a testimony
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to the effectiveness of the State and its citizens in carrying out their
commitment. Stationary air sources, point sources from water and solid
waste/hazardous material disposal problems are known, and solutions are in
the process of being proposed. The State and EPA cannot, however, take the
position that threats to Montana's environmental integrity are under
control. The prevention aspect of the environmental programs is particu-
larly important to Montana. As an example, the production and export of
energy has been steadily.increasing (Figure #1). With energy development
comes accompanying environmental impacts that require regulation. For the
future, Montana, like every state that feels the pressure of conflict
between natural and human needs, will have to guard against unplanned and
unexpected threats to its environmental integrity. Therefore, an addi-
tional major objective of the State and EPA will be the vigorous enforce-
ment of existing environmental legislation with an emphasis on new sources.
Energy Development
The apparent national rush to discover, extract and exploit new
energy resources could prove to be, economically, socially and environ-
mentally devastating. As our nation continues to develop and revise
policies and programs directed to alleviate the energy crisis, Montana and
its energy rich neighbors are being looked to for the bulk of the increase
in domestic energy production.
The energy resource potential of Montana alone is immense. Coal
reserves are measured in billions of tons. Potential oil and natural gas
reserves are counted in billions of barrels and trillions of cubic feet.
Hydropower on our river systems produces thousands of megawatts. .
As the debate continues over which energy source — oil, natural gas,
coal, solar, geothermal, hydro, nuclear, wind or some exotic type —will
solve our country's problems, one possibility appears almost certain:
Montana, with its abundant resources, will play a major role in achieving
the national goal of energy independence.
This assumption is gaining credibility by:
— Congress1 Recent Energy Mobilization Board legislation,
— Department of Energy's synthetic fuel program proposals
and coal production targets,
— Department of Interior's resurrected coal leasing program,
— coal consuming states' recent attacks on Montana's coal.
severance tax,
— wilderness controversies.and
— by various other legislative and judicial attempts aimed
at simplifying and expediting extraction and utilization
of Montana's abundant energy related resources.
Montana has helped, and will continue to help, meet our nation's
energy needs.. But water flowing through- turbines to generate electricity,
burning coal turning water to steam to drive huge generators and the conversion
of coal to synthetic natural gas or liquid cannot be accomplished without
some inescapable and often unmitigatable environmental, social and economic
costs. Montanans demand and expect to have a major role in determining
those costs.
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The State and EPA are committed to working together to develop consis-
tent policies and applying mitigative measures to utilize Montana's
resources without foregoing the amenities of clean air, pure water and
productive lands. Without federal, state and local involvement and coor-
dination, energy development in Montana could proceed with a rapidity and
concentration that could overwhelm the ability of citizens and government
agencies to adequately respond, control and mitigate the adverse impacts
associated with increased energy development.
JS
n
O
1000
900-
800.
700-
600.
500.
400.
300 .
200 -
100.
0
$¥•
im
£*"£
P
m
Hydro
Natural Gas
Crude Petroleum
Coal
I
Total Production
4
T 1 •!! f i » • • • •«»• ••
1960 . 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77
Figure 1 Production of Energy in Montana, By Type of Fuel, 1960-77
Program Environmental Summaries
The environmental problems in the State of Montana are as diverse as
its geography. For this reason the precise definition of problems is an
evolutionary process. As more resources and expertise become available,
the more thorough problem definition becomes.
Presently most physical and chemical surface water quality conditions
are generally known throughout the state. Comprehensive biological moni-
toring is underway, with statewide coverage scheduled-for, completion by
1982. Lake classification work under an EPA Section 314 grant is also
underway, with completion scheduled for 1981. Fisheries classification
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work has been recently completed by the Department of Fish, Wildlife and
Parks (DFWP). The inventorying of drinking water supplies has been a
continuing effort, with the majority of supplies investigated during 1978-
79.
In Montana, as throughout the United States, a major emphasis is being
placed upon the proper management of hazardous wastes. During fiscal year
1981, a comprehensive investigation will be undertaken to determine the
extent of the hazardous waste problem and to establish the mechanisms to
properly deal with that problem. The principal mechanism will be the state
acquiring interim authorization to maintain a hazardous waste program in
Montana. Through the next fiscal year, the extent of the solid waste
problem will continue to be evaluated through such means as the open dump
inventory.
Mr 'quality problems related to sulfur dioxide (SO2) have been de-
fined. Total suspended particulate (TSP) problems have been located;
however, determining the causes, impacts and control techniques will
require continued effort. Carbon Monoxide. (CO) problems exist in at least
three major cities. In order to determine the extent of the CO problem,
additional data must be collected and modeling performed. More information
needs to be collected to establish the extent of the lead problem. New
source impacts, related to energy production and mining, on air quality are
unknown and will require more monitoring and evaluation to prevent signi-
ficant deterioration.
Groundwater data have historically been limited. The major initiative
for FY 1981 will be EPA's inventorying of the underground injection control
techniques and groundwater resources.
Human exposure to elevated levels of natural radioactivity has been
defined, particularly in mineralized areas of Western Montana. Studies to
determine the extent, magnitude and sources of these exposures are under-
way.
The assessment of pesticide problems has been confined to areas where
accidents and misuse have been reported. A generic study of baseline
conditions to determine the presence of pesticides throughout the state
remains to be done. Air and soil sampling in control areas began in 1978
and 1979, and will continue in 1980, with new areas established as the
equipment becomes available.
Summaries of available data by program area follow:
Water Quality
Montana has some of the highest quality water in the United States.
This is exemplified by the fact many streams support excellent fisheries.
The Montana DFWP in a recent inventory estimated that there are 10,181
miles of streams that are classified as being "substantial," "high prior-
ity" or "highest value" for fishery resources (Figure 2).
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Figure 2 Major Streams and Basins
St. Mary's Rive
rias River,--'
Kootenai Rive
Clark Fork River
Flathead Rive
Sun Rive
.Smith Rive
Missouri River
Yellowstone River-
Little Missouri Rivel
- Montana, however, is not without its water quality problems. Accord-
ing to information compiled by the Montana Water Quality Bureau (WQB), DFWP
and U.S. Forest Service (USFS), an estimated 4,015 miles of streams in
Montana are being degraded by nonpoint source pollution and dewatering, and
may not meet 1983 water quality objectives.
It must be noted that degradation does not necessarily mean a viola-
tion of Montana's Water Quality Standards has occurred, rather it means
some beneficial use is being affected.
Nonpoint source problems are by far the most prevalent in Montana.
Activities associated with agriculture, mining, urban development and
silviculture are the most significant contributors. Of these activities,
agriculture by virtue of its geographic extent, is the most prevalent.
When considering the agricultural problems relating to nonpoint source
pollution, stream dewatering due to irrigation, increases in salinity and
sedimentation are the most critical. In a previous study by the1DFWP,
excessive irrigation withdrawals adversely affected fish in 285 stream
segments. The most common water quality problem in Montana is sedimen-
tation. According to the DFWP, 364 stream segments are experiencing
sediment increases at some point due to channel alteration, bank encroach-
ment and overuse by livestock.
Although logging of federally and corporately owned forests does
degrade surface water, those operations are usually managed with the
intent of reducing adverse environmental impacts. However, a major portion
of Montana's forests, about 3.1 million acres, are owned by private,
non-corporate land holders. Without strong silviculture management
programs, future harvest could result in substantial water quality degrad-
ation.
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There have been 133 water polluting mining operations (most are presently
not being worked) identified in the Statewide 208 area alone. The exact
extent of mining throughout Montana and its impacts are not fully known.
In an effort to constantly update the quality of water in the state's
river basins, a water quality monitoring program has been in operation for
several years. The present ambient monitoring network includes three
permanent WQB stations and 13 U.S. Geological Survey (USGS) stations.
Chemical and physical data are monitored monthly. This information is
generally used to determine background and trend data that enable water
quality personnel to ascertain which streams are not meeting the require-
ments for supporting aquatic life and recreational use. Periodically,
intensive surveys are made when information is needed for permit reviews,
construction or program planning.
Point source discharges degrade water quality, but the WQB has iden-
tified and requires permits for all known discharges. Major industrial
discharges are sampled or inspected at least twice each fiscal year; while
major municipal discharges are inspected or monitored at least once a year.
A status report of the permits issued is included in the section devoted to
permits.
Drinking Water
The initial Montana law relating to public water supplies was origi-
nally enacted in 1907. This law was revised in 1977 and again in 1979 to
enable Montana to receive and retain delegation for administration of the
"Federal Safe Drinking Water Act" (PL 93-523) enacted in 1974. Montana's
program covered about 250 community water systems prior to 1978. The
present program regulates all systems which have a least 10 service con-
nections or serve at least 25 individuals daily for at least 60 days a
year.
The current inventory, as submitted to EPA on January 1, 1980, listed
609 community water systems and 1,147 non-community water systems. The
following presents the information available from the inventory for the
community water systems:
Summary of Community Water Systems in Montana:
Surface Water Systems;
10,000- - 75,000 population
1,000 - 10,000 population
100 - 1,000 population
25 - 100 population
Total
Ground Water Systems;
10,000 - 75,000 population
1,000 - 10,000 population
100-- 1,000 population
25 - 100 population
Total
No, of Water'
Systems
7
31
17
Ji_
61
2
32
190
316
540
Population
Served
290,000
93,000
9,000
600
392,000
22,000
69,000
56,000
14,000
161,000
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Consecutive Water Systems;
10,000 - 75,000 population
1,000 - 10,000 population
100 - 1,000 population
25 - 100 population
No. of Water
Systems
0
7
0
0
Total
Population
Served
0
13,000
0
0
13,000
The surface water systems provide water completely or in part from
surface sources. Consecutive water systems are ones that purchase all of
their water from other water systems and do not have any sources of their
own.
The table presents a number of interesting items, for example:
1. The largest community water system in Montana serves a population
of 72,000 (based on the 1970 census). It is anticipated that the
population figure will be higher at the completion of the 1980 census.
2. Only one percent of Montana's community water systems serve
more than 10,000 persons. However, this one percent of the systems
serves 55 percent of the people who obtain water from a public water
system. The "small system strategy" currently under development by .
EPA will impact over 99 percent of Montana community water systems.
3. Fully 87 percent of Montana community water systems serve fewer
than 1,000 persons. This 87 percent of the systems provides water to
only 14 percent of the population obtaining water from a public
water system.
4. Ten percent of all community systems are surface water. The
systems supply water to 70 percent of the population. More than
88 percent use groundwater . One percent purchases water from another
water system.
From a quality standpoint, Montana's drinking water is considered
generally good in the western part. Those supplies in the eastern part,
particulary groundwater, would be considered poor. The exception in the
western part are the surface supplies which are high in turbidity. In the
eastern part of the state, the communities using surface supplies with few
exceptions, have water treatment facilities capable of providing quality
water. However, the groundwater supplies are generally high in total
dissolved solids. Some of the smaller supplies have fluorides and nitrates
which exceed the maximum concentration limit (MCL). The following information
identifies, on a statewide basis, the fluoride, nitrate, arsenic, selenium
and turbidity problems in the state.
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Community Public Water Supplies Which Exceed MCL's:
Supply
Ashland
Circle
Lambert
Richey
Highland Park,
61endive
Spring Grove Tr. Ct.
Cheeks Tr. Gt.
Alta Tr. Ct.
Miles City
Bills Trailer Villa
Greenstar Mob. Hm
Village
Wagon.Wheel Tr. Ct.
W & R Mob. Hm Village
Fairview
Wagon Wheel Tr. Ct.
Forsyth
Flaxville
Rapelje
Coffee Creek
Denton
Three Forks
Rapelje
Constituent
Fluoride
Nitrate
Arsenic
Selenium
Reported
Level .
(ag/1)
3.9
5.2
4.1
4.4
3.8
3.1
3.8
2.57
2.74
2.96
2.58
5.23
5.5
34.0
13.0
14.0
13.0
0,06
0.036
Maximum
Contaminant
Level (MCL)
2.4
10.0 as NO--N
0.05
0.01
Community Public Water Supplies which utilize surface water and have
exceeded the maximum contaminant level of 1.0 N.T.U. for a monthly average.
Culbertson
Bozeman
Canyon Ferry
Devon
Tiber County Water District, Conrad
Fort Peck
Rainbow Dam
Ryan Dam
Harlem
Helena (Ten Mile System)
Neihart
Reman
White Sulphur Springs
Community Public Water Supplies which use surface water and do not monitor
turbidity. ,-.
East Glacier --•"'
Hill County Water District, Hingham
Power
St. Ingatius
Sheridan
Troy
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Nearly all of the community public water supplies are now monitoring
for bacteriological quality on a regular basis and the maximum contaminate ,
levels for coliform bacteria are rarely exceeded. Of 576 community supplies
only about 15 have not yet begun a regular bacteriological monitoring program.
- The inventory of noncommunity public water supplies was completed
at the end of 1979 and about 40% of these supplies have begun taking
bacteriological samples on a quarterly basis.
A program for. radiological monitoring is now being developed and will
be implemented over the next 1-2 years. This program will include all
community supplies.
Construction Grants . -
A federal grant program was initiated in 1956 to assist municipalities
in the construction of sewage treatment facilities. The State has assisted
the EPA and predecessor agencies in administration of this program by
establishing needs and priorities, and reviewing project applications and
preliminary and final plans. Federal grants on projects have increased
from 30 percent to 75 percent (85 percent where the project uses innovative
or alternative treatment mechanisms such as land disposal) of eligible
project costs.
Using the priority system developed by the WQB and approved by EPA, a
priority list is drawn up at least once a year. Grant monies are then set
aside for the top communities on the list.
v
The grant process is presently divided into three steps. Step 1,
called facilities planning or Section 201 planning, is a detailed planning
effort aimed at providing a recommended solution to a community's parti-
cular sewer and treatment problems. Included in this plan is: an analysis
of the existing sewer system and treatment facility; a probe of the town's
anticipated development and growth trends; a comparison of the economics
and effectiveness of all treatment alternatives, and an environmental
assessment of'the solutions. Finally, the most cost-effective, environ-
mentally sound and socially acceptable alternative is selected.
If the plan receives the approval of the reviewing governmental
agencies, after local public participation.and a hearing, a grant may be
awarded to provide for Step 2 expenses.
Step 2 deals with the design and preparation of plans for the selected
sewage disposal facilities. Following governmental approval of plans and
specifications, a grant may be made to provide for Step 3 expenses. The
majority of the project costs are associated with this step — construction.
For some projects, one grant may be given that combines steps 2 and 3.
Numerous delays have been encountered in the construction grant
program since passage of PL 92-500 (Water Pollution Control Act Amendments
of 1972). This act, in addition to providing greater federal funding, also
required EPA to develop new regulations. PL 95-217 (Clean Water Act of
1977) again.authorized additional monies and changed the requirements. The
facility planning program must now go into much greater detail on alter-
natives, particularly land disposal options. It has taken consultants time
to adjust to the new planning requirements, and states and EPA, therefore.
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have fallen behind in their re view... To help overcome this deficiency and
provide for more state control, WQB has applied to EPA for a greater
delegation of administration of the program made possible by Section 205 (g)
of PL 95-217. The legislature has approved additional manpower (six
positions) and authority. Pursuant to a delegation agreement signed
during PY 1979, the State began hiring staff for this program on July 1,
1979.
The agreement identified specific activities to be performed by the
State and EPA. It also identified the available and projected federal
funds, Figure #3. Over a five-year period approximately 100 Step I, 150'
Step II and 150 Step.Ill grants must be awarded in order to utilize avail-
able funds for needy projects. This is an average of 20 Step I, 30 Step II
and 30 Step III grants each year.
Wastewater Discharge Permit Program
Montana's wastewater discharge permit program began in 1968. With
passage of PI 92-500 (Water Pollution Control Amendments of 1972), a
federal wastewater discharge permit program was also initiated, in 1974
Montana applied for and received authority from EPA to administer this
program, thus minimizing duplication of effort. EPA established wastewater
discharge limitations for the various categories. Where these limitations
will not allow the meeting of water quality standards (including nonde-
gradation of high quality waters by new discharges or existing industries),
stricter limitations .are imposed.
Tables #1 and #2 list the various categories of major and minor indus-
trial wastewater discharges and their present status with regard to compli-
ance and enforcement. Most of the projects shown as inactive have eliminated
their discharges to surface waters and therefore, do not need a wastewater
discharge permit. .
Table #3 lists the status of the municipal discharges. Montana's five
largest cities (Billings, Great Falls, Butte, Missoula and Helena) all have
treatment facilities capable of meeting effluent limitations except for
chlorine residual and fecal coliform bacteria. There are discharge limita-
tions on chlorine residual because of its toxic effect on aquatic life, and
meeting these limitations sometimes does not allow the municipality to meet
the fecal coliform limits. Billings is presently experimenting with chlori-
nation at the secondary clarifiers which may give acceptable results. Some
coliform limits may be.revised based on. receiving stream flows and will
still meet Water Quality Standards.
Many of the communities meeting discharge limitations still have
treatment facility needs. For example, Helena, Kalispell and Missoula all
need improvements to their sludge disposal systems. Helena and Kalispell
have serious odor problems due to present sludge disposal practices, but
are implementing land injection as an interim solution. The discharge
standards for sewage lagoons were relaxed by EPA and, hopefully, this will
allow many of the smaller communities to meet effluent limitations with a
minimum amount of improvements.
It should be noted that essentially all dischargers (including those
not in compliance) have constructed substantial treatment facilities during
the last 25 years. The large percentage of noncompliance of major indus-
trial dischargers versus the low percentage of minor dischargers is par-
tially due to .their more complex treatment facilities and greater bureau
review on those that have the potential to do the roost serious stream
damage.
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A'-M.., . lisSJri -,
Figure 3
TOTAL FEDERAL FUNDS APPROPRIATED TO
MONTANA CONSTRUCTION GRANTS (xlO6)
Total Cumulative Funds
Available
Funds Obligated During
That Fiscal Tear
Funds Previously
Obligated (cumulative}
FY74 FY75 FY76 FY77 FY78 FY79 FY80 FY81 FY82
Table 1. Status of Major Industrial Wastewater Discharge Permittees
Category
Total No. Active Inactive
Substantially
In Compliance
Not
In Compliance
Major
Smelter
Railroads
Plywood Mills
Oil Refineries
Slaughter Plants
Sugar Refineries
Paper Mills
Generating Plants
3
1
1
4
1
2
1
2
. 3
1
1
4
1
2
1
2
0
0
0
0
0
0
0
0
2
0
1
1
1
2
1
2
1
1
0
3
0
0
0
0
(see
(see
(see
note 1
note 2
note 3
below)
below)
beltnr)
Totals
15
15
10
1. Anaconda-Warm Springs - Sot meeting all permit limits, but with adjustments
in pH control at Butte will probably meet limits.
2. B.N.-Livingston - Permit limit violations. Enforcement action taken. On
schedule to comply by 7/1/80. ;
3. Exxon- Permit limit violations. Enforcement action,Ttaken. Compliance schedule
submitted.
Farmers Union - Compliance schedule submitted, mot met. Enforcement action pending.
Phillips Petroleum - Permit limit violations. Order sent.
-13- ••
-------
Table 2. Status of Minor Industrial Wastewater Permittees
Minor
Fish Farms
Irrigators
Active
-13
0
In
Compliance
Not in
Compliance
Notes
13
0
0
0
Considered nonpoint
sources under Fed-
eral legislation.
below
Feed Lots
Oil Wells
Mines
Smelters
Dairies
Railroads
Lumber &
Plywood Mills
Oil Refineries
Highway Projects
Sand & Gravel
.-Slaughter Plants
Cement Plants
Chemical Plants
Generating Plants
Industrial Sewage
Treatment Plants
Miscellaneous
Totals ' •:. .
;88-
7
23
1
.1.
7
1
1
26
'.'tf-
0
2
1
1
8
7
. 190
. 88
7
23
i
1
6
1
1
26
••'•'T. -
0
2
1
1
8
7
189
0 See note 1 I
0
0
0
0
1 See note 2 1
0
0
. 0
0
0
0
0
0
0 Mt. Power D*
0
-1_
1. Includes 41 smaller feed lots active on state permit program, but not included
as part of federal permit program.
2. Compliance order issued to BN Whitefish for recent permit violations. •/.
-14-
-------
Table 3. Status of Municipal and Federal Wastewater Discharges
Sewage Treatment
Facilities
Municipal & State
Federal & Indian
Totals
Substantially
In Compliance
Major Minor
9 75
30
Not in Compliance
With Secondary Treatment
Standards
Major Minor
16** .50'
1 4
105*:
17
54
Water Treatment Facil-
ities Wastewater
Disposal
Municipal
Federal & Indian
10
1
4
0
Totals -:,,.11*" 4
*About 1/2 of these have no surface water discharges.
**En£orcement Action against Bozeman by EPA in Federal
District Court.
—15—
-------
Looking to the issuance of new permits, the WQB expects many appli-
cations from new mining operations, most of which will be for high quality
waters. There will also be applications from saline seep areas for dis-
charge of saline waters. It is highly unlikely that many of these saline
discharges will be allowed, due to their potential impact on surface waters.
There will also be several permit applications for highway contractors to
pump water from forms used in bridge pier construction. Applications are
expected from new energy developments such as power plants, synfuel plants,
and alternative energy sources as well.
The WQB's major jobs in the permit area will be assuring that per-
mittees are complying with existing permits, and to get the new applications
processed. As an aid in processing large numbers of applications in such.
categories as bridge cofferdams, suction dredge mining, and feed lots,the
WQB is attempting to develop general permits in these areas. - — -
Air Quality
The Big Sky Country is truly what its name implies, yet there are
places where the quality of air is a fragile resource. The plains east of
the Rocky Mountains provide few obstructions to the sea of air that flows
across the land, but in western, southern and central Montana, where
various mountain ranges form valleys, air sometimes is trapped in layered
inversions, causing degradation.
In addition to inversions, man also plays a part in altering air
quality. In urban areas throughout the state, such things as street dust,
smoke from fireplaces and industrial emissions contribute to lowering air
quality and visibility. In rural areas the largest contributors to air
quality degradation are unpaved roads and mining operations.
An assessment by the Air Quality Bureau (AQB) of air quality through-
out the state revealed the following information:
TOTAL SUSPENDED PARTICOLATE
Columbia Falls
Missouia and
Missoula Area
East Helena Area-
Butte Area
Great FalIs Area
olstrip Area
Billings Area
-16-
-------
Designated Area
Colstrlp Area
Columbia Falls
Missoula
Missoula Area
Billings Area
Great Falls Area
Butte Area
East Helena
Does Not
Meet Primary
Standards
X
X
X
X*
Does Not
Meet
Secondary
Standards
X
. X
X
X
Reasons
Street Oust and Strip Mining
Street Dust
Street Dust, Smoke From
Fireplaces and Industry
Unpaved Rural Roads and Industry
Street Dust
Street Dust
Street Dust and Mining Operation
Street Dust and Industry
*£PA designation replaces state designation
Lead
Anaconda Area
Designated Area
East Helena Area
Anaconda Area
Does Not
Meet
Primary
Standards
X
~
Reasons
Smelter
Smelter - Still Being
•Evaluated
-17-
-------
SULFUR DIOXIDE
East Helena Area
Anaconda Area
Laurel Area
Designated Area
Laurel Area
East Helena Area
Anaconda Area
Does Not
Meet
Primary
Standards
X
X
X
Does Not
Meet
Secondary
Standards
Reasons
Refinery
Smel ter
Smel ter
CARBON MONOXIDE
Great Falls
Missoula
Designated Area
Bi 11 i ngs
Missoula
Great Falls
Does Not
Meet
Primary
Standards
X
X
X
Reasons
Exhaust From Motor Vehicles
Exhaust From Motor Vehicles
Exhaust From Motor Vehicles
-18-
-------
Only the towns arid areas mentioned do not meet primary or secondary
air quality standards, the rest of the state presently meets the standards,_
Additionally, the entire state meets the standards for photochemical
oxidants and nitrogen oxides.
Solid Waste Management
And Hazardous Waste Disposal
The disposal of solid wastes has become a major, complex problem in
Montana. Due to its complex nature it also relates to air, water and land
pollution. In the future, the solid waste problem will become more expen-
sive, expansive and complicated. It is becoming clear that concerted
efforts of all levels of government, as well as the private sector, must be
employed to ensure proper waste management. >
Our society consumes enormous quantities of material and energy which
in turn generates an exceedingly large volume of waste. Currently, approxi-
mately 600,000 tons of municipal solid waste are being generated per year
in Montana, and given the well-established waste generation rates, by 1990
nearly 870,000 tons of waste will be generated per year. This waste is
being disposed in more than 250 identified municipal disposal facilities
and numerous undisclosed indiscriminate dump sites.
In addition, from state surveys it has been established that approxi-
mately 200,000 tons of potentially hazardous wastes are generated each year
in Montana. This volume of hazardous waste includes pesticides, heavy
metals and other industrial chemical wastes. Furthermore, a large number
of "empty" pesticide and other toxic chemical containers of all sizes are
discarded annually.
The state now possesses sufficient regulatory authority to control
solid waste disposal. As required by the 1977 "Montana Solid Waste Manage-
ment Act," the Solid Waste Management Bureau (SVJMB) currently is licensing
all solid waste management systems in the state. This licensing procedure
assures that all such systems will provide a basic public service and not
degrade the environment. To date, a total of 147 waste management
systems have been licensed by the bureau.
In response to action taken by the 1977 Montana Legislature, the SWMB
is providing both technical and financial assistance to local government
entities for the development of waste management systems.
Legislative amendments enacted in 1977 give the DUES control over
hazardous wastes, including licensing authority for hazardous waste trans-
porters. Also in 1977 the SWMB published a survey of hazardous waste
generation, storage, treatment and disposal. This survey included 236
industries as well as other generators of hazardous waste, such as hos-
pitals, pesticide users and septic tank service companies. The bureau is
now developing its hazardous waste program, but will not begin licensing
hazardous waste facilities until FY 1981.
" Currently no licensed hazardous waste disposal facility is located in
Montana. This situation does not pose an immediate problem because of the
availability of such sites in neighboring states. However, with the inaugu-
ration of a statewide hazardous waste program the difficult task of siting
a hazardous waste disposal facility may have to be initiated in Montana.
-------
The bureau has given and continues to render technical assistance to
local governments, businesses and small industries concerning hazardous
waste management needs and problems. Possible alternatives for collection,
storage and disposal of small quantity hazardous wastes are presently being
evaluated. Special arrangements for wastes from laboratories, retail
establishments, pesticide users and small, industrial generators may be
necessary to alleviate the burden of hazardous waste disposal in sanitary
landfills and to prevent illicit hazardous waste disposal.
A number of instances of improper waste management have been inves-
tigated in the last few years. The SWMB has begun to establish a working
relationship with the industrial community which may be regulated under the
forthcoming hazardous waste regulations.
Pesticides
Montana is primarily an agricultural state and as such requires the
use of pesticides to help manage a multitide of pest problems. Based on
data collected from commercial applicators (1978), it is estimated that
from 2.8-3 million acres are treated commercially each year. There are no
accurate statistics available for private applicators, but generally the
private applicators treat smaller acreages, do spot treating, and field
margin treating. In most years, private applicators would probably apply
pesticides to 1.5-2 million acres.
The Environmental Management Division, DOA, has a responsibility to
serve Montana's agriculture, but is also mandated to protect the environ-
ment and the health of the state's citizens. To do this, the use of pesti-
cides must be closely monitored. Toward this end, the Environmental Manage-
ment Division administers a pesticide applicator certification program and
an enforcement program. Both programs are now administered by the Enforce-
ment Division of EPA to achieve consistency and continuity of purpose
between the two programs. Since their inception, the programs have signi-
ficantly reduced the amount of pesticide contamination in Montana despite
the fact that the number of certified commercial and private applicators
has increased significantly since 1976 (Figures 4 & 5).
Recertification of some of the categories of commercial applicators
was implemented this year. Credit is given to the applicators and dealers
for each course they attend so that they can accumulate 100 points during
the four-year recertification period (Figure 6).
The basic elements of the pesticide programs include education,
enforcement, monitoring and sampling.
Several fish kills in the state (1979) resulted in the promulgation of
regulations restricting the use of aquatic herbicides through 1981. In-
spections of aquatic applicators and enforcement of these regulations^will
be a priority item during this grant period.
In the area of education, efforts will be made to assist private
applicators to do a better job in the areas of safety, calibration and
disposal. Appropriate enforcement actions will be taken on violations.
-20-
-------
PESTICIDE ftPPUCATWS
(CERTIFIED}
,1200
10000
2000
890
"(313)
Tic Me.IK Mm . rM.
1876 1977 1973 I97Q 1530
GOO
203
U2W
Figure 4
5i?6 Bfe &t
Figure 5
RECERTIFICttlOa TRAIKI'K
(DEALERS i WPUMTOS)
DEALERS
SEES TBE«T
OKIWHTAI t
Tlffif
«»!AL
IRESBHCH
SO IOC 150 200 250 500 550
FY 15SO
Figure 6
The recent recurrence of energy-related problems has resulted in an
increase in practices such as no-till and chemical fallow management
systems. Monitoring of soil and plant residues will be conducted.
Efforts in the areas of monitoring and sampling are currently concen-
trated in establishing basic information concerning the consequences of
spray drift on urban areas and establishing a network of control plots
throughout the state.
An air monitor was set up in the Flathead Lake area to determine the
amount of aerial drift that occurs during the annual spraying for fruit
crop and potato pests. The information derived from the monitoring will
give DOA personnel a basis for ascertaining the effects of the spray on
residential and urban areas over a several year period.
Several test plots have been established in. the state to provide
baseline information on the effects of pesticides in the environment. Soil
and air samples from each site will enable DOA personnel to determine
concentrations of pesticides, and will give them something with which to
compare future samples.
Radioactivity
Elevated levels of radioactivity are currently being studied in two
parts of Montana by State and federal agencies.
The DHES has been studying elevated radioactivity in water wells and
geothermal springs in the Alhambra area since it was discovered in 1976.
The latest studies by the DHES and U.S. Geological Survey have been sus-
pended while the State turns its attention to the recently, discovered
elevated levels of radiation in the Butte area.
-21-
-------
The DHES has independently been investigating the radiation levels in
Butte for more than two years. Although a variety of studies are still in
progress, it appears that the elevated radiation levels are due to a
combination of natural and displaced radioactive materials.
Although the DHES studies have been funded by the state, EPA has
assisted in the effort by sending a radiation scanner van to Butte for
several days, loaning the DHES indoor radon sampling units and flying over
the area with radiation detection equipment.
In addition, the EPA has provided the DHES with the loan of both gamma
and radon progeny detection and measuring equipment. Through its Las Vegas
laboratories, the EPA has given extensive technical support in the forms of
laboratory radioanalyses and supplying and reading dosimeters used to
measure radon progeny concentrations.
Toxics
Asbestos
A voluntary program for the detection and correction of potential
health hazards due to deteriorating friable asbestos was begun by EPA
in the spring of 1979.
The Montana EPA office with support from the Region VIII office has
distributed information concerning the asbestos in schools program. A
contract person detailed to the Denver EPA office visited schools in Helena,
Missoula, Great Falls, and Billings during the summer of 1979. Some
on-site inspections were made to determine the presence of friable asbestos.
Federal legislation requiring the correction of health hazards created
by friable asbestos in schools and public buildings was signed by the President
this year. Compliance will be mandatory at some future date. Financial
assistance will be provided where remedial measures are required.
The State Air Quality Bureau will provide analysis of samples sent
to Helena at no charge. The Region VIII office again has contract support
available to assist in providing information to schools and to perform
on-site inspections. This resource will be made available during FY 81.
Disposal of asbestos containing materials will be coordinated by the
State Solid Waste Management Bureau (SWMB). The SWMB will designate a site
or sites that have adequate operation and maintenance practices to provide
protection of public health and the environment.
Polychlorinated Biphenyl (PCS)
The EPA sent copies of the Federal Register that discusses disposal
and marketing of PCB to all known persons and businesses that use PCBs in
Montana. The EPA plans to continue to inform, sample and help mitigate PCB
problems. A seminar was held to inform the public and private sectors of EPA
regulations.
-22-
-------
Fiscal Year 1980 Accomplishments
The following information reflects major state or EPA accomplishments
during PY 1980:
Water
Wastewater Discharge Permit and Enforcement Program
- A backlog of approximately 60 expired permits was eliminated,
not including 40 permits for small feed lots.
- Approximately 90 new permits were issued.
- Approximately 110 complaints were received and processed.
- Fourteen Violation Report Forms were sent to the DHES Legal Division
requesting assistance.
- Eight Notices of Violation and Orders to Take Corrective Action
were issued.
- Four civil complaints, including requests for assessment of civil
penalty and corrective action, were filed.
- Four civil complaints were settled, resulting in corrective actions
and collection of $19,800 in civil penalties.
- One complaint with a civil penalty is pending resolution.
- Approximately 120 preliminary enforcement letters were sent and
included notices of violation of permit requirements and requests
for corrective actions.
- In approximately the last four years.the enforcement program has
resolved 13 actions resulting from episodes which were significant
enough to prompt the filing of civil complaints, including requests
for assessments of civil penalties.
- Total civil penalties collected to date amount to $146,650.
- The enforcement program has initiated actions which resulted in
the issuance of 52 administrative notices for abatement, corrective
measures, injunctions and orders to show cause.
Water Quality Management Planning
- Statewide 208 plan approved.
- Water, .quality management agreements signed with BLM and USFS.
- Conservation. Districts prepared and submitted to WQB water quality
management plans.
-23-
-------
- Six water quality tours were conducted in cooperation with.
Conservation Districts.
- Muddy Creek project manager hired and water quality monitoring
program initiated.
- Prickly Pear Creek reclamation effort initiated.
- Numerous, public information and education.activities.
- 305 (b) report completed.
- Northwest Loop biological monitoring report completed.
- Musselshell River Physical Features Report completed.
- Five valleys Region Water Quality Report completed.
- MSU Subdivision Groundwater Study completed.
- Developed waste discharge permit process for saline seep drainage..
- Benthic biological/salinity study completed for USGS and BLM in
the southern Fort Union Region of Montana.
- Revised Water Quality Standards drafted and public hearing held.
- Prepared draft non-degradation rules.
Construction Grants
- Full staffing with the exception, of Clerk/Typist.
- Substantial delegation (except Step 3 inspections, constructability/
biddability) inclusive of clerical tasks and preparation of
preliminary environmental assessments.
- Total obligations of 17.2 million dollars.
- Initiation of monthly WQB/EPA training sessions. .
- FY 1980 Priority List was revised. ^
- State received a variance from Bureau of Economic Analysis popula-
tion projections and the statewide projection was disaggregated.
Drinking Water
The inventory of small community and noncommunity public water supplies
(PWS's) has been essentially completed. Follow-up inspections have been
made on most of the public water supplies inventoried.
The inventory of public water supplies has been stored on the Model
State information Service computer system along with all the chemical
data on each PWS.
-24-
-------
Chemical analyses have been completed on nearly all community PWS's.
Nitrates have been done on about 50% of the noncommunity PWS's.
Assistance was given to PWS's having operational problems.
Regulations regarding plan review have been revised (but not yet
presented to the Board of Health) .
A complete new.system of record keeping has been put into effect.
New enforcement procedures have been initiated. Enforcement actions
have begun against communities which appear to be willfully violating
drinking water regulations.
Nearly all community PWS's have been placed on regular bacterio-
logical sampling programs. Approximately 400 of the noncommunity supplies
are also on sampling schedules.
Air
The AQB processed 105 construction permits to assure that new air
pollution sources comply with all air quality rules and standards. The
bureau performed 17,250 laboratory analyses on 4,150 samples to evaluate
the effects and levels of air pollution. It analyzed 149,000 hourly field
samples to investigate the air pollution levels throughout the state.
The AQB enforced compliance with air quality rules through 150 field
surveillance actions.
Montana's ambient air monitoring network was reviewed.
Solid Waste
Hazardous Waste Management
The SWMB currently is developing draft revisions of the administrative
rule for the "Montana Solid Waste Management Act." It is contemplated that
by October the rule will be revised and adopted by the OHES. These modifi-
cations will put Montana's regulations substantially in accord with federal
regulations and place the state in the position to apply for interim
authorization from EPA. In conjunction with the advancement of necessary
regulatory authority, the bureau has initiated the development of required
procedures for maintaining a state hazardous waste management program.
These procedures include a manifest system to track hazardous wastes from
their generation to disposal, a permit priorities mechanism and a sur-
veillance/enforcement program.
During the past year, the bureau was extensively involved in the
Pierce Packing Company PCB incident. This included the coordination of
disposal for contaminated foods, feed and livestock and the maintenance of
records on destruction/disposal. In addition, bureau staff worked with EPA
in establishing standard practices and guidelines for"disposal. The bureau
verified 169 disposal actions involving 114 feed companies and livestock
producers.
-25-
-------
Continued surveillance has been maintained of the Department of
Livestock's scabies control program. This program has disposed of approxi-
mately 150,000 gallons*of toxaphene solution at 16 different locations.
Continual efforts have been made to refine the state emergency re-
sponse program especially with respect to developing internal response
procedures and equipping the team.
Specific disposal problems and sites have been evaluated in seven
cases involving industrial waste disposal.
Solid Waste Management
As of June 1, 1980, the bureau issued 147 licenses to solid waste
management systems throughout the state. Of these licenses, 93 are perma-
nent and 54 are conditional. This licensing process is being utilized
extensively to gather baseline data for the open dump inventory.
In addition, the 1977 "Solid Waste Management Act" allows the bureau
to issue state grants to local government entities to conduct detailed
areawide waste management planning. The planning grant program has encom-
passed more than 40 percent of the state. This planning effort is of
considerable assistance in conducting the open dump inventory. Currently,
completed inventories have been made on 15 disposal sites.
State statute has required the bureau to develop and implement a
comprehensive solid waste management plan. This plan has been completed -
and adopted according to state laws. During the last few months, bureau
staff have spent considerable time, with the cooperation of the state EPA
office, in preparing modifications in that state plan. It is anticipated
that a revised state plan will be finalized and submitted for EPA approval
before October 1, 1980.
Pesticides »
The Montana DOA accomplished the following EPA funded program activ-
ities by April 30, 1980 and projects the end-of-year accomplishments.
Dealer Stock Inspections
Formulation Plants
Pesticide Applicator Inspections
Commercial Applicator use observations
Market place Inspections
Pesticide accident Investigations
.Special Investigations
Efficacy Studies
Private Applicator Survey
Private Applicator use observation
Collection and Analysis of Samples:
Formulation
Samples
Analysis performed
Residue
Samples
Analysis performed
PCB and pesticide samples received
from EPA
Mid-year
FY 1980
87
3
214
14
71
2
2
6
310
721
144
468
79
End-of-year
FY 1980
188
3
360
50
600
60
6-10
10
360
40
330
250
100
-26-
-------
Updated Quality Assurance Manual for Pesticide Analysis.
Installed and trained personnel in the use of the GC/MS system for confir-
mation analytical work.
Developed new analytical techniques for analysis of various biological and
environmental samples.
Certification Training
Commercial applicators (new) 43
Private applicator (new) 449
Continuing Certification Training .
Dealers 320
Seed Treaters . 158
Aerial applicators 4<7
Demonstration and Research 14
Ornamental and Turf • 58
Related Pesticide Activities
The Environmental Management Division of DOA provides pest management
services to producers, industry, government agencies and the general
public'. These services include establishing integrated pest management
programs for specific cropping systems, recommendations on use of pesti-
cides, identification and surveillance of pests and the evaluation and
resolution of the effects of pesticides on agriculture and the environment.
The division also registers 3,100 pesticide products prior to their use in
the state: licenses 740 pesticide dealers; licenses 1,350 applicators and
their employees (300); licenses 8,886 private applicators; and regulates
the sale of pesticides at the retail level. These services are provided by
personnel located in Helena and in the six district field offices. The
department's laboratory provides analytical regulatory and service analysis
to other departmental programs and to the general public. Thus, a more
comprehensive pesticide regulatory and service program .is provided to
Montanans by combining the state and federal pesticide laws and pest
management laws than would be provided by each program separately.
Radiation
A year's data regarding radon daughter concentrations was completed in
approximately 150 Butte homes utilizing Radon indoor Progeny Integrating
Sampling Units (RIPISUs) supplied by the EPA.
Radon daughter concentrations in approximately 1000 Butte homes and
100 Anaconda homes were estimated by use of the grab sample method.
The area of. Butte primarily affected by elevated radon and radon
daughter concentrations was identified and mapped.
The .effectiveness of air cleaning devices were studied to determine
their usefulness for reducing indoor radon daughter concentrations.
-27-
-------
Hazardous Wastes
The Asbestos in Schools Program was established. Guidance was given
to all school districts during implementation.
National Environmental Policy Act (NEPA)
In meeting EPA's review responsibility under NEPA, the following EIS's
were reviewed:
Colstrip 3 and 4
Northern Tier Pipeline
ASARCO Troy Mine
Kootenai Falls
- Spring Creek Mine
- Numerous Forest Service P.U.
- Numerous BIM- Projects
- Missouri Breaks Grazing
In an effort to identify potential environmental issues and remove
assessment deficiences related to the construction grants, program con-
ferences were held with Bozeman/ Missoula, Hamilton, Bridger Bowl and
Kalispell.
Toxics
EPA has developed an integrated toxics strategy. The state has
assisted in determining which chemicals are to be considered in the strat-
egy and which federal facilities in the state should be examined through
this program.
The integrated strategy was tested in the summer of 1979 when the chemical
PCB — polychlorinated biphenyls — leaked from a broken electrical transformer
into-animal meal prepared by the Pierce Packing Co., Billings, resulting
in a united effort by EPA and states in Region 8 to trace the extent of
the contamination and take corrective actions.
EPA's Montana Office worked closely with state officials to identify
contaminated livestock and feed, then monitored the safe disposal of both.
Steps were also taken to safely dispose of the source of contamination.
The result of the Pierce Packing episode prompted the EPA to conduct
a PCB Industry Seminar in Helena in the fall, followed later by a two-day
seminar sponsored by the DHES and Interagency Regulatory Liaison Group (EPA,
Food and Drug Administration, U.S. Department of Agriculture and Consumer
Product Safety Commission). Both were instrumental in educating Montanans
and people from throughout the region in how to identify PCB sources and
what to do in emergency situations.
Public Participation
Public participation implemented for FY 81 was sought by a questionnaire
to state and local governments, public interest groups and private citizens.
The questionnaire requested participants indicate their desired involvement
in five categories of the environmental decision-making process. Approximately
200 responses to the questionnaire disclosed the following results:
-28-
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List of' selected priorities 158 .
9Draft Montana/EPA Agreement 156
Final Montana/EPA Agreement 194
Participation in a public meeting 51
Survey to determine priorities beyond FY 81 79
In addition to sending interested persons and parties a list of the
priorities and the draft and final .MEA , a survey was conducted in September
to involve the public in helping determine the priority issues for the FY 1982 MEA.
PRIORITIES
1. Water . '
.Total delegation to the DHES of the administration of the municipal
construction grant for sewage treatment (205 (g» program.
Development of an instream flow strategy which addresses water
quality concerns.
Continued improvement of the record management system used in
the Water Supply program including a maximum contaminant level
compliance review process and follow-up enforcement action.
Timely issuance and reissuance of permits and initiation of necessary
enforcement actions to insure compliance.
2. Air
SIP Implementation and Development
- Anaconda sulfur dioxide (SO2)
- Missoula carbon monoxide (CO)
- East Helena Lead
Source Surveillance
- PSD and new* source review
- Inspection of A-l (Class A) Sources
- Emission Inventory Update
Monitoring
- Implement National Air Monitoring Station (NAMS) and State
and Local Air Monitoring Station (SLAMS) Networks
- Operate Quality Assurance Program
- Audit continuous emissions (CE) monitors
- Audit quality assurance (QA) programs for company-owned monitors
-29-
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3. Solid Waste Management
Development and implementation of a comprehensive state hazardous
waste management program.
Closing or upgrading of existing open dumps by the implementation of
the State Solid Waste Management Plan and application of appropriate
state regulations.
4. Pesticides
Maintaining and improving the established quality of the pesticide
enforcement and laboratory program with appropriate analysis.
- Perform inspection of all phases of pesticide manufacturing
and uses throughout state.
- Approve, inspect and monitor aquatic herbicide applicators
and applications.
- Provide direct assistance to private applicators in the
problem areas of safety, calibration and disposal.
Maintain the established pesticide certification and training program.
5. Radiation
Butte Radiation
- Reduce radon levels in dwellings in Butte.
- Implement study to determine contributing factors to elevated
radiation levels in Butte.
- Implement study utilizing passive track etch dosimeters to
determine soil radon exhalation rates and to accomplish long
term measurement of indoor radon concentrations.
RESOURCE SUMMARY FOR MOOTANA-EPA PROGRAMS
The resource summary for all Montana - EPA programs (or media) is
shown on the Resource Summary Table (Table 4). Following this table,
each program is discussed. The highest priorities within each program
are emphasized in the narrative discussion. Detailed work plans which
specifically address all program elements within a medium follow the
narrative.
-30-
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TABLE 4
RESOURCE SUMMARY TABLE
Air
Program
State 105 grants
Water Quality
Water/Wastewater Opr. Cert.
State 106 Grants
Section 208 Grants
Clean Lakes Grants
205(g)
Drinking Water
State PWS Grants
State UIC Grants
Solid Waste and Hazardous
Waste Grants
Pesticides
State Enforcement Grants
State Cert. Tr. Grants
Radiation
Federal
Grant $
550,000
0
330,000
376,868
332,000
331,000
323,600
74,200
212,000
450,000
20,000
State
Resources $
394,714
i
14,982
91,000
69,000
275,000
0
107,000
13,520
107,541
20,000
Work
Years
32.34
0.5
13.2
8.18
0.25
10.5
10.5
5.6
21.55
1.02
Work
Years
3.8
2.4
1.4
.35
3.2
1.1
2.4
1.2
.05
81,804
Categorical Programs
Noise 27,272
Toxic Substances
Indians . 180,000
Flathead Study 355,000
Federal Activities EIS Review
Emergency Response
Quality Assurance
2.6 0.3
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PRIORITY ACCOMPLISHMENT STRATEGIES
Air
Implement SIP
PSD
Air Quality Monitoring
Transportation Control Plans
Development of State Implementation Plan For Lead
Water
Wastewater Discharge Permit And Enforcement Program
Drinking Water
Instream Flow Activities
Construction Grants
Solid Waste
Hazardous Wastes
Open Dump Inventory
State Plan Revision
Facility Planning And Implementation
Pesticides
Enforcement
Certification
Radiation
Butte Radiation Program
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PRIORITY ACCOMPLISHMENT STRATEGIES
AIR
Implement SIP . '
All nonattainictent plans except the Missoula carbon monoxide (CO) plan.
were essentially approved in FY 1980. The approval for Missoula will come
during FY 1981. Therefore, the work done in 1981 will be important towards
achieving attainment of the National Ambient Air Quality Standards by 1982.
Goals outlined for 1981 must be met if attainment is to be achieved by
1982.
A part of SXP implementation is the state's compliance and enforcement •
program for stationary sources. Continued emphasis will be placed on major
source inspections since the Clean Air Act no longer allows for continued
noncompliance of major sources through variance procedures. Significant
violations by major sources in most instances will have to be dealt with
through court actions and, if appropriate, by the imposition of noncompliance
penalties. .
PSD
Montana did not receive PSD delegation during FY 1980 from EPA. How-
ever, prior to delegation, EPA and Montana will enter into an interim
agreement which essentially provides for Montana to perform the PSD analyses.
).
As part of the permit requirements, industries will be required to
conduct baseline monitoring and diffusion modeling relating to their
proposed activities. The Air Quality Bureau will be required to review the
proposed monitoring networks and modeling techniques as well as the results
of those .efforts. This could take considerable time since each permit will
requife"much public involvement and could result in a considerable amount of
contr6versy~both~technical and political. Supplemental EPA financial and
technical assistance will therefore be essential to meet these added needs
and to insure the successful implementation of the PSD.program.
Following promulgation of a visibility regulation by EPA (as required
by Section 169A of the Federal Clean Air Act) the state will adopt a rule
to deal with visibility requirements in Class I areas.
Air Quality Monitoring
The accurate measurement of Montana's present and future air quality
plays an important role in existing and future SIP revisions. The location
and impacts of new sources and proper technical and impact analyses are
essential for the continued protection of Montana's pristine air quality
and to accommodate orderly industrial growth.
The state has completed a review of its air monitoring program and has
prepared and submitted a Network Review Report to EPA. Modifications-to
the existing network will be carried out according to the schedules set
forth in that report.
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Transporation Control Plans
The transportation control plans for the Billings and Missoula areas
are being developed to determine attainment of the air quality standard for carbon
monoxide. A schedule for updating the plans has been developed. Upon comple-
tion of the necessary work/ the plans will be resubmitted to EPA.
Billings plan requires updating emission factors. In addition, the
Billings City-County Planning Agency has develped some traffic information
which it feels may affect the modeling results. Consequently, the modeling
will be done again using this revised data. Whether or not the control
strategy has to be revised will depend on the outcome of the modeling. If the
modeling shows higher levels of CO than the initial modeling effort, it may
be necessary to revise the proposed solution to the problem; otherwise the
original control strategy should be adequate.
In Missoula, both the modeling data and the model itself are suspected of
being inadequate. In addition, there is speculation that Missoula may have a
CO problem in the winter months which is attributable to wood stoves and fire-
places. The modeling for the transportation related problem will be redone
and the control strategy revised as appropriate. An additional CO monitor has
been provided to the Missoula Air Pollution Control Agency to investigate the
possibility of areawide problems.
The Federal Highway Administration, the State's Department of Highways
and local planning agencies must be involved if SIP strategies are to be com-
pleted in an expeditious manner. Because of the long time delays in imple-
menting transportation changes, the process began in early 1980, with com-
pletion scheduled for 1982. Regular meetings among the involved groups will
be held to insure communication and progress.
Assuming that Great Falls is designated nonattainment for CO, in all
likelihood a local governmental agency will have the responsibility to develop
the control plan for achieving attainment of the standards. A close working
relationship between the Air Quality Bureau and the designated planning agency
will be maintained to insure timely development and implementation of a plan,
should one be required.
Development Of State Implementation Plan For Lead
Based on EPA requirements, lead implementation plans will be developed
for the East Helena and Anaconda areas. Both plans will be developed under
contracts using EPA funds. Major contract activities will include develop-
ment of an inventory for stack and fugitive emissions, followed by modeling
of the emissions. Hi -volume sampling data indicate violations of the
National Ambient Air Quality Air Standard for lead in East Helena, but no
violations have been recorded in the Anaconda Area. The implementation
plan is required for Anaconda because of "potential" lead emissions from
the Anaconda Company smelter.
WATER
Wastewater Discharge Permit and Enforcement Program
The general priority of the Montana Pollutant Discharge Elimination
System (MPDES) is to administer and enforce an effective" was tewater discharge
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permit program. This is an ongoing program in which permit applications
dischargers are reviewed and, if appropriate, permits are issued. Major
dischargers which have the greatest potential to affect public health or
substantially affect the quality of a stream receive the highest priority
in the program. The minor dischargers, most of which can affect a stream
locally, are also important and receive review, but not as detailed as
major dischargers. However, because of their large numbers, minor permits
do consume large amounts of time. This might be somewhat alleviated if
certain of these categories.can be handled by general permits. The DHES
intends to pursue that possibility.
Self monitoring reports are required to be submitted by all dischargers
for review by the WQB.. Compliance monitoring of major dischargers is per-
formed by the bureau at a frequency necessary to assure accurate results.
The minor dischargers are compliance monitored when it is apparent that
analyses may be in error or the discharger is out of compliance with its
discharge limitations. Support is provided by the DHES Laboratory Division
in the analyses of samples. Inspections of treatment facilities are also
performed to assure adequate operation of facilities. Investigations are
also made when complaints are received on permittees or where possible
violations are occurring by persons not having a permit.
Compliance schedules are set forth for those dischargers not meeting
minimum effluent limitations established by EPA as stream standards are
violated. For municipalities the compliance schedules are coordinated with
the WQB Construction Grants Section so the projects which are creating the
biggest problems are given the highest priority for federal funds. Input
from the SWMB will be provided to assure that residual wastes are properly
handled.
Enforcement action is taken where effluent limitations are exceeded;.
self monitoring reports are not submitted as outlined in the wastewater dis-
charge permit, or compliance schedules are not met. Enforcement may be in
the form of a letter from the WQB, a compliance order issued by the depart-
ment or a district court action to seek compliance and a monetary penalty
where warranted.. Support is received from the DHES Legal Division and the
regional EPA office on enforcement.
Specific Priorities:
- Issue, reissue or .modify major permits ensuring that water quality '
standards are met; toxic criteria limitations and pretreatment
requirements are met; toxic criteria limitations and pretreatment
requirements are imposed; residual wastes are handled appropriately
{input from SWMB to be provided) and approprate effluent limitations
and self-monitoring are provided.
- Issue, reissue or modify other permits.
- Pursue general permit issuance, for such categories as bridge
project cofferdams, small placer mining dredges, storm water,
feed lots, and sewage lagoons.
- Process 6 (g) authorizations and Water Quality Standard (401)
certifications.
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-• Provide timely complaint response and followup.
*•<•*
- Provide compliance monitoring twice yearly of all major industrial
permittee discharges and once yearly for 10 major municipal
dischargers. .
- Compliance monitor 10 minor dischargers where self-monitoring data
is suspect - provide a quality assurance program to assure appro-
priate laboratory results.
- Provide appropriate enforcement and report to EPA, giving priority
to major dischargers.
- Provide - timely review and appropriate notification on self-monitoring
information.
- Inspect all major dischargers and 50 percent of minor dischargers
yearly using appropriate report forms.
- Pursue delegation for permitting federal facilities.
- Assist in training enforcement and compliance personnel (EPA).
The Clean Water Act enacted in 1977, allows the states administering
the Federal Wastewater Discharge Permit Program to have permitting author-
ity over federal installations. The WQB has applied for this authority.
EPA will still be responsible for dischargers on Indian reservations except
in incorporated municipalities.
The Clean Water Act requires states administering the permit program
to adopt a pretreatment program which will control certain discharges to
municipal systems. The WQB is attempting to develop a reasonable pre-
treatment program which can be feasibly implemented in Montana.
Safe Drinking Water Program Implementation
The inventory of public water supplies (PWS) in Montana was considered
to be completed by December 31, 1980, with the most recent total showing
609 community water systems and 1147 noncommunity water systems. To date,
nearly all the WQB's efforts have been expended to bring community PWS*s
into compliance and very little time has been devoted to the noncommunity
supplies. At this point there are some community supplies which are still
not in compliance and it is our aim to correct as many as possible in the
next fiscal year. At the same time the WQB will begin to shift its empha-
sis to the noncommunity supplies. The bureau has started a program to
inform them of their responsibilities under the Safe Drinking Water Act and
approximately 40% have been placed on a schedule for monitoring the bacterio-
logical quality of their water. The WQB plans to have all supplies analyzed
for nitrates next year and hopes to have most of them on a regular coliform
sampling schedule.
Major objectives for the coming year will bes •--""
- improve compliance of community water supplies for all of the
requirements of the Safe Drinking Water Act.
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- Provide enforcement through the DHES Legal Division when community
public water supplies are not in compliance with the regulations.
- Monitor and enforce the public notification requirements of the Safe
Drinking Water Act.
- Improve the bacteriological quality of those supplies not
meeting the MCL for coliform bacteria.
- Grant variances and establish compliance schedules for those systems
which need physical improvements to meet MCL's.
- Update regulations as needed.
- Conduct field investigations at approximately 90% of all public
water supplies.
- Provide technical assistance regarding the operation and maintenance
of public water systems.
- Provide training and certification for operators.
- Review plans and specifications for new supplies and improvements to
existing systems.
- Develop DHES policies to improve plan review and rewrite regula-
tions as needed.
- Provide certification for chemical and bacteriological laboratories.
- Emphasize improving the compliance of noncommunity public water
supplies.
Underground Water
Since the State of Montana has not given an indication of assuming
primacy over the Underground Injection Control Program (UIC) during FY 81,
EPA will be handling all aspects of this program. The contract with the
Montana College of Mineral Science and Technology, Bureau of Mines will be
completed at the end of FY 81. This contract will provide maps, cross-
sections and narratives detailing aquifer characteristics throughout the
state. In addition, it will provide an inventory of the various categories
of injection wells being used in the state.
At the writing of this narrative, the UIC technical regulations still
have not been promulgated. The implementation of the regulation will begin
within 270 days after final promulgation.
A petition to designate the Helena Valley as a sole source aquifer was
received by EPA during FY 80. After holding a public hearing in Helena to
v gather more information on the subject, a decision must be made by the
Region VIII Administrator as to whether or not to designate the aquifer as
a sole source. If it is so designated, all federally assisted projects
must be reviewed by. EPA to determine that they will not adversely impact
the groundwater of the area.
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Instream Flow Activities
Dewatering - the excessive and unnatural reduction of instream flows
usually caused by seasonally heavy irrigation diversions - is one of Montana's
"Big Three" water quality problems, along with sediment and salinity. More
than 800 miles of streams are known to be seriously dewatered, according to
a survey completed by the Montana Association of.Conservation Districts.
Yet, for a variety of reasons, the state has not developed a systematic
procedure for addressing and mitigating the water quality effects of
dewatering. To initiate such a systematic procedure, is the objective of
this proposal.
The DHES dewatering program will be keyed on a provision of the 1973
State.of Montana Water Use Act, which allows state agencies to apply to the
Board of Natural Resources and Conservation for reservations of instream
flows. Such reservations are subject to the rights of prior appropriators
and to the availability of unappropriated water. The DHES already has
successfully exercised this option in the case of its Yellowstone River
flow reservation. However, preparing and defending an application for a
flow reservation is a costly process. Hence, the DHES must choose its
streams carefully and objectively, to insure the optimum return on its
investment. On the other hand, DHES must proceed with deliberate speed to
get a place in line that will assure the department of not getting shut out
of the water allocation process altogether. The WQB has identified in-
stream flows as one of its top four priorities during state fiscal year
1981 (July 1, 1980 to June 30, 1981). The bureau intends to fill one of its
existing vacancies in the Water Quality Management Section with a surface
water hydrologist, who will be assigned half-time to instream flow activ-
ities. Existing bureau personnel - including two field specialists, two
water quality specialists, and a computer programmer - will have their
position responsibilities redefined so the total bureau instream flow
effort for fiscal year 1981 will be 1.94 work years. (See detailed state-
wide 208 work plan for state FY 1981.) However, additional assistance will
be needed, at least initially, to rank our priority flow reservation
streams and to determine water availability in those streams.
' The bureau envisions a three-part program on instream flows, encom-
passing A) applications for reservations, B) public information and
education and C) coordination with other agencies.
Construction Grants
Full delegation of construction grants activities with the exception
of constructability/biddability reviews will be a priority item during FY
1981. The WQB will be fully staffed by midyear resulting in considerable
improvement in grant processing and quality of projects.
The assumption of the function delegated to the Corps of Engineers
(COE) (i.e., biddability/constructability reviews) will be dependent upon
continued quality reviews by COE personnel. Should the WQB feel confident
in its own resources to perform this function, as compared to the COE, an
effort will be made to assume this responsibility prior to FY 1982.
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The 205(g) delegation agreement for FY 1980 is being developed between
the WQB and the EPA's Montana Office. This document will outline in detail
the tasks and responsibilities necessary for total delegation of construc-
tion grant activities.
Solid Waste
Hazardous Wastes
During the upcoming fiscal year, a major, priority will be the con-
tinuing development of a statewide hazardous waste management program.
Modifications in the administrative rule to the "Montana Solid Waste
Management Act" will be completed. These modifications will place Montana
in a position to assume responsibility for a state hazardous waste manage-
ment program. In addition, procedures for maintaining such a program will
be finalized. These procedures will include the adoption of a common
manifest system, institution of a permit priorities mechanism and the
establishment of a surveillance/enforcement program.
In FY 1981, an application for interim authorization for Phase I will
be finalized and submitted to EPA for approval. This application will
include a comprehensive authorization, plan. The plan will be structured in
accordance with federal requirements and will reflect the hazardous waste
section of the "Montana State Plan for Solid Waste and Hazardous Waste
Management." These documents will demonstrate the integration and coor-
dination of Montana's hazardous waste program with the Clean Water Act and
the Safe Drinking Water Act.
The State of Montana currently maintains an emergency response system
which includes a response plan and an active emergency response team. This
team is comprised of a cross section of state agencies representing a broad
spectrum of disciplines. Such structure assures that state government can
provide technical advice and direct assistance to a variety of emergency
situations. During the next year, procedures will be developed to assure
that the emergency response system can adequately provide for followup of
remedial, measures in crisis situations.
As the state's hazardous waste program is developed, measures will be
taken to assure that adequate work force resources are available. As
needed, efforts will be made to secure adequate staffing for the hazardous
waste program. In addition, the ongoing training of current staff will be
maintained. Such educational efforts will take advantage of training
programs that are offered by the federal government and institutes of
higher learning.
In all of the above-mentioned activities, a concerted effort will be
made to provide public participation. Current state law and regulation
already provide, for a formal mechanism for public review and comment in the
issuance of all permits. In addition, state law requires the DHES follow
formal procedures to insure adequate review of any action that will directly
impact citizens of the state. The level of public participation undertaken
in other activities will.depend on the degree of interest from affected or
interested persons. Public participation will rely heavily on the mass
media, direct mailings, public meetings and public hearings.
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As in the past, the SWMB will continue to provide technical assistance
and information to all- interested or affected persons. The extent of this
service may be found in the program accomplishments section of this document.
Finally, the abandoned disposal site identification program will
continue to be maintained.
Open Dump Inventory
Current Montana law provides mechanisms which are being used exten-
sively in conducting portions of the formal open dump inventory. The 1977
"Montana Solid Waste Management Act" requires the bureau to license all
solid waste disposal sites with some exceptions (i.e. industrial onsite
disposal of nonhazardous wastes). This licensing procedure requires
permitting by site classification. As of October 1, 1980, 147 disposal
sites will have been issued licenses (93 permanent 54 conditional). The
licensing process is especially useful in gathering baseline data for the
open dump inventory. In addition, the 1977 "Solid Waste Management Act"
allows the SWMB to issue state grants to local government entities for
purposes of conducting detailed solid waste management planning. A con-
dition of each planning grant is that a careful assessment be made of
existing disposal sites within the planning area. As with the state
licensing procedure, the planning effort is of considerable assistance in
conducting the open dump inventory.
In fiscal year 1981, major activities associated with the open dump
inventory will include the establishment of classification priorities and
the gathering of necessary information for the classification process.
These activities will be conducted in conjunction with the continued
identification of disposal sites statewide.
A major activity of the bureau will be to initiate follow-up enforce-
ment action on those facilities that are identified as open dumps and for
which, no-effort has been taken to close or upgrade.
The identification of municipal solid waste and sludge disposal sites
will utilize methods such as those previously mentioned. With respect to
industrial nonhazardous disposal sites, the identification process will
rely extensively on surveys and questionnaires that will be sent to all
major industries in the state. Because state law allows individuals to
dispose of nonhazardous waste on their own property, the physical inspec-
tion of individal industrial sites will occur only with the specific
permission of the property owner.
State Flan Revision
To reiterate, it is anticipated that a revised state plan will be
finalized before October 1. However, if complications arise in the develop-
ment of that document, it will be completed during the first part of fiscal
year 1981. ;"
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Facility Planning And Implementation
It has not been determined, to the satisfaction of the DHES, that
there is a true need for a centralized hazardous waste disposal facility in
Montana. During FY 1981, an evaluation will be made to ascertain the
quantity and composition of hazardous wastes in Montana and their geograph-
ical distribution. If a true need exists, regional collection centers will
be established where generators may dispose of wastes. Periodically, the
material will be transported to approved hazardous waste disposal facil-
ities out-of-state. Continual evaluation will be made of the volume and
type of hazardous .wastes deposited at the collection centers, and the
continued availability of approved disposal facilities out-of-state. If,
as a result of this evaluation, a need can be demonstrated, action will be
initiated to develop a centralized hazardous waste disposal facility(s)
.within Montana.
L>
Finally, the SWMB will conduct preliminary geological and water
{surface and groundwater) evaluation of. the state for the purposes of' :
siting solid and hazardous waste management facilities. '
Pesticides
Enforcement
The DOA's authority for registering pesticides, licensing and certi-
fying applicators, licensing dealers and operators, and for conducting
inspections and carrying out enforcement actions is provided for in the
Montana Pesticides Act, Section 80-8-101 through 306 MCA 1979.
The DOA proposes to continue the comprehensive cooperative enforcement
program and agreement with EPA through inspections (including use/misuse,
restricted, and general use products, records and proper licensing),
investigations, pesticide sampling, laboratory pesticide analysis, efficacy
studies and enforcement actions. These activities would be continued under
the quality assurance agreements made with EPA under, previous grants. The
DOA's pesticide specialists hold EPA credentials and have the authority to
carry out the mandates of the Federal Insecticide, Fungicide and Rodenti-
cide Act as well as the Montana Pesticides Act.
The DOA has been granted "primacy" under the policies and procedures
established by EPA. It is the intent of the department to serve as the
primary agency in conducting inspections; investigations and sample col-
lection and analysis in accordance with EPA approved procedures and to take
effective action against violators. The state has recommended some changes
that will improve the monitoring of Section 24(c)'s, Section 18fs, and
experimental use permits.
The promulgation of regulations restricting the use of aquatic herbi-
cides in Montana will require a major commitment from the DOA in FY 1981
for training,, inspecting and monitoring the sale and application of aquatic
herbicides.
The approval of a Section 18 exemption by EPA to use 1080 to control
damage caused by Columbian ground squirrels in 19 western Montana counties
will also require a substantial commitment in terms of inspections, record
keeping and use observations during FY 1981.
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Continuing efforts will be made to determine if pesticide drift is, or
may be, a contribuitng factor in causing environmental damage. Recognizing
that different pesticides products, varying carrier rates and climatic
conditions will affect drift, it is improbable that an overall, drift
policy can be developed by the end of FY 1981.
The DQA's pesticide analytical laboratory will continue to maintain .
(and improve) the quality assurance program for sample handling and analy-
sis. The laboratory will continue to provide pesticide analytical services
to SPA and other states on a.fee basis which will cover the cost of sup*
plies, materials and communications.
The cooperative enforcement agreement between the DOA and EPA will be
revised and updated during FY 1981.
Since the DOA's enforcement program is subject to yearly review and
funding by EPA, no long range objectives can be projected. All objectives
stated are for the 1981 federal fiscal year.
The allocation of personnel to the Environmental Management Division
of the DOA is 29.6 full time equivalent (F.T.E.) for FY 1981. State fund-
ing supports 13.01 F.T.E. and EPA funding will support 16.50 F.T.E.'s under
the pesticide enforcement grant. The F.T.E. in support of enforcement
grant activities will be 21.55 of. which 16.50 F.T.E. are federally funded
and 5.05 F.T.E. are state funded.
The allocation of monies is as follows: $412,607 represents the grant
monies from EPA; $107,541 is the state's matching funds; and $37,393 repre-
sents the amount allocated for indirect costs. The total combined budget
for FY 1981 will be $557,541.
The specific activities and accomplishment commitments can be found in
the Pesticides Media Work Plan.
Certification
The certification program is a federally mandated program which
requires pesticide applicators using restricted-use pesticides to comply
with state and federal certification standards. The Montana Certification
Plan was approved by EPA and has been in effect since 1976.
The strategy will be to maintain the data processing system for the
storage of qualification data for dealers and applicators and for the
issuance of certification credentials to qualified applicators as well as
to newly certified individuals entering the system.
Most of the commercial and government applicators requiring certifica-
tion have been certified, but the strategy will be to conduct at least one
general certification course (24 hours) for new applicators who wish to be
certified. Indications are that approximately 80% of the private applica-
tors desiring certification have been certified. The strategy will be to
conduct training for private applicators in those counties where the need
is expressed.
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The strategy for recertification will be to provide recertification
training for the following applicator categories: Agricultural Animal,
Agricultural, Plant, Public Health, Regulatory Mosquito and Regulatory
Quarantine. Additionally, the private applicators in Agricultural District
III will receive recertification training specific to their needs (crops,
cropping systems and pest complex present).
Under the proposed grant activities, no specific personnel will be
funded,, but grant activities will amount to 1.02 F.T.E.'s. The state share
in achieving the certification objectives will be a 50.percent match of
federal funds ($20,000).
Butte Radiation Program
-Radiation
\
The purpose of the Butte Radiation Study is to: determine the contri-
buting factors to the elevated radiation levels in Butte, ascertain the
geographical area(s) of the city most severely impacted, determine the
levels of radiation to which Butte residents are exposed, define the health
risks associated with these elevated radiation exposures and insofar.as
possible, determine methods to reduce radon and radon progeny levels in the
affected dwellings in Butte.
Under contract with EPA, the Occupational Health Bureau (OHB), DHES,
has established an ambient radon and radon progeny monitoring station at
Hebgen Park. Data accumulated at this station will be evaluated to deter-
mine diurnal and seasonal fluctuations in radon and radon progeny concen-
trations. In addition, data accumulated at this station will provide
information pertaining to the equilibrium in ambient air between radon
progeny and the parent radon-222.
As a cooperative effort, the EPA's Las Vegas Laboratory and OHB will
conduct preliminary evaluations of radon and radon progeny levels and
sources in the city of Butte. These evaluations will be accomplished
primarily through the review of existing data.
The OHB will place 150-200 track etch dosimeters in the Butte soil on
a grid basis to determine radon soil-gas concentrations. The grid system
to be utilized will be developed as a cooperative effort between OHB and
EPA. The placement of.these dosimeters will assist in identifying radiation
problem areas in the city of Butte.
OHB will measure radon progeny concentrations in approximately 100
structures utilizing Radon Indoor Progeny Integrating Sampling Units
(RIPISU's) to be provided by the EPA. Each structure will be measured for
a period of one week, four times a year at three month intervals. Infor-
mation gained by these measurements will provide a reasonable estimate of
average annual radon progeny concentrations in structures sampled.
OHB will perform radon exhalation tests on- construction materials such
as concrete, brick, sheetrock, etc., to determine the-contribution that
various construction materials are making to the elevated radon concen-
trations found in homes.
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OHB will determine radon and radon daughter concentrations in homes
using the grab sample method. This method of sampling will provide a
rapid method of determining the geographical area of Butte most severely
impacted by radiation exposure and will provide additional information
concerning the equilibrium between radon and radon progeny in structures.
Environmental samples will be collected by the OHB for radioanalysis
to be performed by the EPA Laboratory in Las Vegas. Samples will be col-
lected as requested by the EPA Project Officer.
An additional contract is being negotiated between EPA and DHES under
which EPA would supply track etch dosimeters and perform statistical
analyses of data and OHB would place and collect the dosimeters from
approximately 1000 Butte homes. This proposed contract will also make
provision for remedial action research to be performed by OHB to determine
methods that can be used to reduce radon and radon progeny concentrations
in structures.
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MEDIA WORK PLANS
Air
Water
Solid Waste
Pesticides
Radiation
Categorical Programs
-45-
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