IDAHO ENVIRONMENTAL
STATUS AND PROGRAM
EVALUATION -1972
REGION X 1200 SIXTH AVENUE SEATTLE WASHINGTON 98101
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IDAHO ENVIRONMENTAL STATUS
AND PROGRAM EVALUATION
1972
U. S. Environmental Protection Agency
Region X
1200 Sixth Avenue, Seattle, Washington 98101
December 1972
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PREFACE
"It is the policy of the Congress to recognize, preserve, and
protect the primary responsibilities and rights of States to pre-
vent, reduce, and eliminate pollution, to plan the development and
use (including restoration, preservation, and enhancement) of land
and water resources, and to consult with the Administrator in the
exercise of his authority under this Act" Federal Water Pollution
Control Act Amendments of 1972, Section 101 (b).
"The Congress finds . . . that the prevention and control of
air pollution at its source is the primary responsibility of the
States and local governments; and . . . that Federal financial as-
sistance and leadership is essential for the development of
cooperative Federal, State, regional and local programs to prevent
and control air pollution . . ." The Clean Air Act, Section 101(a)
and (b).
"The Congress finds . . . that while the collection and dis-
posal of solid wastes should continue to be primarily the function
of State, regional, and local agencies, the problems of waste dis-
posal as set forth above have become a matter national in scope and
in concern and necessitate Federal action through financial and
technical assistance and leadership in the development, demonstra-
tion, and application of new and improved methods and processes to
reduce the amount of waste and unsalvageable materials and to pro-
vide for proper and economical solid-waste disposal practices."
The Solid Waste Disposal Act, Section 202(a) and (b).
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TABLE OF CONTENTS
Page
INTRODUCTION 1
ENVIRONMENTAL PROGRAM EVALUATION 3
Adequacy of Authority 3
Authority and Procedure for Promulgation
and Enforcement 4
Enforceability of Air Pollution
Compliance Schedules 5
Operator Certification 6
Authorization for Reporting
Requirements 6
Conflict of Authority with District
Health Departments 6
Organizational Issues 7
The State Agency 7
Organizational Conflict with
Local Districts 7
Agency Manpower and Budget 10
Federal Assistance and Deadlines 14
CURRENT ENVIRONMENTAL SURVEY 18
PUBLIC WATER SUPPLY 21
Legislative Authority 21
State Water Supply Program 22
Current Status of Water Supplies 23
NOISE POLLUTION 27
CONTROL OF RADIATION SOURCES 29
Legislation 29
Regulations 29
Medical X-Ray Sources 30
Radioactive Material Sources 30
National Reactor Testing Station 31
Other Sources of Radiation 32
Radiation Control Staff and Budget 33
Recommendations 33
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Page
CURRENT STATUS OF WATER QUALITY 35
Spokane River Basin 35
Upper Snake River Basin 35
Middle Snake River Basin 39
Lower Snake Basin 41
Groundwaters 42
CURRENT STATUS OF AIR QUALITY 45
SOLID WASTES MANAGEMENT 53
Solid Wastes Generation - A "Mini" Look 53
Existing Conditions, Practices and
Problems—Domestic Refuse 54
Conclusions 57
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LIST OF FIGURES AND TABLES
Page
Organizational Chart 8
Comparison of Estimated Agency Budgets,
Washington, Oregon, Idaho
Selected Environmental Programs,
FY 1973 11
Recommended Manpower and Budget Levels -
FY 1974 Division of Environmental
Protection - Idaho 13
Summary of Deadlines for Major State
Actions Required in Federal Water
Pollution Control Act Amendments of 1972 16
Air Standards Implementation Plan
Development Deadlines 17
Idaho Water Supply Program Evaluation 25
Idaho Water Supply Program Evaluation (map) 26
Zinc Concentrations South Fork, Couer d'Alene River 36
Bacteria in Upper and Middle Snake River 38
Ortho Phosphorus Concentrations in Upper Snake River 40
Ambient Air Quality and Emission Sources 46
Major Areas of Air Pollution 48
Emission Inventory Summary for State of Idaho 1970 49
Suspended Particulate Sampling FY 1971 52
Point Waste Sources Primary - Commercial
Animal Feedlots 54
Existing "Authorized" Disposal Sites 56
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INTRODUCTION
Environmental awareness in the State of Idaho is high, nearly
commensurate with the environmental amenities to be found there.
Idaho State government has responded seriously to public sensitiv-
ities on the need to protect and restore its water, air and land as
useful and valuable assets. Public opinion and State governmental
response to it correspond well with the thrust of Federal environ-
mental laws and agency policies which assign to the States the first
responsibility and opportunity for action.
But the Federal presence is ever closer to Idaho environmental
decisions than before. In many instances, Federal action upon
environmental matters is now required by law, where the States fail
or are unable to act within the time frame or in agreement with
Federal abatement goals established in Federal law and regulation.
(The brief discussion of the Clean Air Act and water pollution bill
in this report illustrates this point.)
In many respects, the legislators and taxpayers in Idaho are
faced with the choice of Federal employees in Seattle and Washington,
D.C., issuing environmental abatement orders upon Idaho communities
and industries or, as the preferred alternative, empowering and
funding State employees in Boise and its field offices to make
those decisions. Both Federal and State environmental officials
would prefer the latter condition, especially since Congress has
evinced a preference for the States to administer these programs
so long as national goals are met. The purpose of this report is
to aid in reaching that position, for it does not adequately exist
now.
In scope, this report concentrates upon immediate needs which
can be identified from existing information. No new studies were
undertaken to prepare this information—although, in the case of
water quality, the unpublished results of a year's water quality
analyses in the Coeur d'Alene and Upper Snake problem area are
included in a summary. It remains important to note, however, that
the solutions to the immediate needs identified in this report will
be just that: the accomplishment of another increment in the con-
tinuing effort to attain sound environmental management in Idaho.
It is intended that these evaluations be viewed as dynamic, to be
adjusted and improved as new information is available and first
order priorities are accomplished.
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From the background of the purpose and scope of this effort,
the report begins with an analysis of the strengths and weaknesses,
in the view of EPA, of the Environmental Protection Division in the
Idaho Department of Environmental Protection and Health followed
by examples of Federal programs of assistance and imposing dead-
lines upon the State agency. A summary of the recommendations
in that evaluation follows:
1. In order to meet the requirements of Federal legislation,
the State of Idaho should streamline its methods of promulgation
of regulations and rules.
2. Authority to apply simplified procedures for enforce-
ment action and penalities should be added to the State
environmental law.
3. The IDEPH should be authorized to issue its compliance
schedules for air quality control in an enforceable form, such
as through a permit program or issuance of regulatory orders.
4. The State should authorize the establishment of a
certification program for municipal sewage works and water supply
system operators.
5. The State environmental law should specifically empower
IDEPH to require discharges of water pollutants to report to
the agency periodically on the quality of their effluent.
6. A resolution should be found to the duplication of
authority between the District Health Departments and the
IDEPH. From this analysis, it is recommended that the legis-
lature assign the District Health Departments directly to the
Administrator of IDEPH.
7, State agency capability and performance should be
improved, particularly in the areas of field technical assi^«
and monitoring for all programs and also the water pollution
permit program and planning capability, and air quality emissi
inventory and compliance schedules functions.
stance
n
ssion
8. The staffing levels of the IDEPH should be increased
from roughly 43 to at least 62.5, with a total budget of about
$1,125,000 of State and Federal funds.
The program evalutation chapter is followed by summary
environmental assessment chapters, with individual discussions
of water quality, air quality, water supply, solid wastes,
radiation and noise abatement in the State of Idaho.
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ENVIRONMENTAL PROGRAM EVALUATION
This discussion presents the major issues to be resolved in
the areas of basic agency authority, Idaho government organization,
and agency manpower and budget to improve the capability of the
Idaho Department of Environmental Protection and Health (IDEPH) to
protect and restore environmental quality. As will be seen, the
new Idaho environmental law and organization have greatly improved
the State governmental machinery in the past year. Agency manpower
and budget have not increased significantly, however, and the im-
pact of Federal legislation in air and water quality alone will
drastically increase the work requirements upon the agency in the
next few years.
Rather than proceed with a lengthy description of the legis-
lative base, organization and functional statements, it is assumed
that most Idahoans have access to or are familiar with these funda-
mental descriptors. The discussions concentrate upon the problems
which have been identified in this program review, rather than an
objective and comprehensive description. The first element of the
agency's program analyzed is its fundamental authority, the second
is the organization (for the Division itself and within the whole
of government in Idaho), and finally the central problem of adequacy
of manpower and budget is addressed. An addendum to this chapter
addresses the Federal environmental requirements, deadlines and
assistance available.
Adequacy of Authority
The basic legislation under which the Idaho environmental
program is operated was redrawn by the legislature of the State of
Idaho in 1972 in a new "Environmental Protection and Health Act
of 1972". The new Act redefines and consolidates several older
bills into a more comprehensive authorization covering water pol-
lution, air pollution, visual pollution, noise abatement, and solid
waste management, water supply and radiation control. The bill
served to streamline the State agency's organization since it
pulled several interconnected but separate programs under the ad-
ministration of one State official and consolidated three separate
executive boards with varying degrees of authority into one Board
of Environmental Protection and Health with clearly defined respon-
sibilities. Despite the vast improvements in the Idaho environmental
bill, there remain some critical improvements to that legislation
which are necessary to support and more specifically empower the
Department of Environmental Protection and Health to do what it
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must do. Of particular concern at the moment, of course, is the
approvability of IDEPH's authority to conduct the permit program
under the new Federal water pollution law. Since that determina-
tion will in many respects rest upon legal interpretation and
opinion by Idaho State counsel, a specific checklist is not provided
here. Obvious legal improvements needed to adequately empower IDEPH,
however, are discussed below in general terms.
Authority and Procedure for Promulgation and Enforcement
The State law provides cumbersome mechanisms for the promul-
gation of rules and regulations and for the enforcement of all
environmental laws against violators. Better methods should be
devised in order to comply with Federal standards and in order to
better serve the people of Idaho.
Under the present statutory scheme, the power to promulgate
rules and regulations is vested exclusively in the Board of Environ-
mental Protection and Health. The seven members of that Board reside
in the various portions of the state and frequently must travel
great distances to attend the revolving Board meetings. For this
reason, regular Board meetings are held only quarterly. In addition,
each of the Board members has his own vocation or profession from
which he cannot afford to be frequently absent. The per diem com-
pensation which these concerned citizens receive for Board meetings
cannot fully reimburse them for their time away from their own
businesses. Consequently, more frequent Board meetings, though
statutorily possible, would not seem to be a fair demand of these
people who essentially donate their time for public service.
On the other hand, rapid developments in the areas of environ-
mental protection and health necessitate a more speedy regulatory
response. Moreover, recent Federal legislation on air and water
pollution control requires the states to provide quick and reliable
regulatory mechanisms in order to qualify for local administration
of the control programs. In order to meet these demands, the State
of Idaho should streamline its methods of promulgation of regula-
tions and rules.
A solution to this problem which other states have successfully
used is a combined process involving both the Administrator of the
Department and the existing Board. Under such a system, the Admin-
istrator would be authorized to adopt such rules and regulations
as are necessary and appropriate to fulfill the legal responsibil-
ities of the Department. These rules and regulations would be
subject to challenge by any affected party pursuant to existing
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administrative procedures and would also be subject to the scrutiny
of the Board. Upon adoption of any rule or regulation, the Admin-
istrator would be obligated to submit copies to the Board. If a
majority of the Board made a timely written objection to any rule
or regulation so promulgated, the operation of that rule or regu-
lation would be suspended pending consideration by the entire Board
at its next regularly scheduled meeting.
This system of promulgation is particularly commendable since
it combines the best of both worlds. It takes advantage of the
speed and expertise available to the Administrator while preserving
the benefits of review and supervision by the Board.
Similar problems exist in Idaho in the mechanisms for enforce-
ment against violators of environmental laws, rules and regulations.
A major discharger of pollutants in violation of agency regulations
might properly be granted 21-day notice of public hearing, written
decision by the Board of Environmental Protection and Health, and
a specified period for corrective action before the courts are
employed against him. However, these provisions are too prolonged
and costly to be effective against a small or intermittent dis-
charger, and are therefore seldom invoked. As one astute Idaho
analyst stated it, "When a pickup backs up to the Snake River and
dumps a load of garbage in the river, it just doesn't make sense
to say, 'I'll gi've you 21 days to stop that.1" The humor in his
example dissipates, however, when considering the need for the
State environmental agency to possess authority to immediately
halt, or at least penalize, intermittent dischargers of oil,
animal carcasses, sewage from tank trucks which pump septic tanks,
or larger municipal or industrial discharges which periodically
result from failures in treatment systems, and similar discharges.
Authority to apply simplified procedures for enforcement action
and penalties should be added to the State environmental law.
Enforceability of Air Pollution Compliance Schedules
Under its present authority, the IDEPH cannot develop fully
enforceable compliance schedules as required by the Clean Air Act.
More precisely, the cumbersome procedures presently provided would
be so time-consuming as to quickly exhaust the total staff and
executive time of the Department and Board if applied to each of
the entities for which air quality compliance schedules must be
set under the Federal act. In the redesign of the legislated en-
forcement authority to the IDEPH, specific attention should be
directed to authorization for the agency to directly issue its
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compliance schedule requirements for air quality control in an en-
forceable form, such as through a permit program or issuance of
regulatory orders.
Operator CertiTication
The State should authorize the establishment of a certification
program for municipal sewage works and water supply system operators.
The certification program has potential as a mechanism for up-grading
skills and salary rates commensurate with experience and expertise
in this little known profession. The operator of a sewage treatment
plant is responsible for the treatment efficiency of what may be a
multi-million dollar facility. The considerable investment by the
public can be negated by -improper plant operation and, more posi-
tively stated, the need for advanced or enlarged treatment facilities
can sometimes be avoided by operating existing facilities at peak
treatment efficiencies. Similarly, the operator of a municipal
water supply system can provide, if adequately trained and expe-
rienced, more effective health protection to the citizens. The
intent of such a certification program is obvious. As with teachers
and others, a certification of professional achievement can serve
to motivate members of that profession toward higher levels of
performance of their services.
Authorization for Reporting Requirements
In a manner similar to that presently authorized relative to
air emissions, the state environmental law should specifically
empower the Department of Environmental Protection and Health to
require dischargers of water pollutants to report to the agency
periodically on the quality of their effluent.
Conflict of Authority with District Health Departments
A final point with regard to the agency's legal authority
should be made. The legislation creating the District Health
Departments in Idaho tends to cloud the authority and responsibility
of the Department of Environmental Protection and Health in many
respects. The District Health Departments were established as
nearly autonomous local boards and empowered to assume authority
over environmental (and health) matters at their discretion. In
practical application, the Districts have suffered from lack of
funds to enter into the responsibility for sewage treatment and
air pollution, although they do exercise some authority over solid
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wastes management. The potential for contradiction or preemption
of State priorities, policies, and orders is, however, a legal
cloud upon the State's environmental protection agency which should
be removed.
Organizational Issues
The State Agency
Subsequent to the enactment of the new Idaho environmental law
in 1972, the Governor proceeded from the few major organizational
elements set by that bill (i.e., a Division of Environmental
Protection within the Department) and created within that division
a new organizational alignment as described in the adjacent -figure.
The most significant feature is, of course, the placement of all
the environmental programs into one, coordinated unit—as opposed
to the several separate heads (for water, for air, etc.) reporting
individually to the department head and responsible for separate
individuals in the field. Add to this the Governor's feature of a
strong, expert and experienced central operations force complemented
by integrated regional, or field, forces in three locations of
Idaho's vast geography, and it is clear that efficiencies and im-
proved public service are provided in the structure of Idaho's
environmental programs. The Governor has thus structured the State
environmental program in a manner which should enhance achievement
of the dual objectives of (1) State-wide accomplishments in envi-
ronmental protection in priority order and with equity among like
abatement requirements, yet (2) implementation of the State-wide
program in a manner which allows normal operations to be conducted
by those closest, most familiar, and most accessible to the public
and environmental problems in the geographic area assigned.
Organizational Conflict with Local Districts
Unfortunately the smooth internal lines of communication are
complicated and their effectiveness lessened by the District Health
Departments. The District Health Departments appear, to an outside
observer, to be an organizational and governmental anomaly. The
seven local departments are autonomous, that is, they do not report
to a central body for policy direction or coordination. They are
operated by appointees of the member county commissioners. The
county commissioners also provide the operating funds for the
Districts by levying a tax for that purpose (which amount is matched
by a statutory percentage from State funds). The costs of the
Districts thus add another tax upon the public in addition to those
tax revenues already being channelled into environmental protection
(and health) by Federal, State and local governments.
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GOVERNOR
1
DEPARTMENTAL
SUPPORT SERVICES
ADMINISTRATOR
BOARD OF ENVIRONMENTAL
PROTECTION AND HEALTH
FISCAL PERSONNEL, PAYROLL.
LEGAL COUNSEL. PUBLIC
EDUCATION & INFORMATION,
ADMINISTRATIVE, CLERICAL,
SECRETARIAL, LABORATORY
I
ASST ADMINISTRATOR
ENVIRONMENTAL
PROTECTION
DIVISION
DIRECTOR
AIR & WATER
PROGRAMS
ASST ADMINISTRATOR
PERSONAL HEALTH
SERVICES DIVISION
OFFICE OF INTERGOVERNMENTAL PROGRAMS
DIRECTOR
REGIONAL OPERATIONS
DIRECTOR
CATEGORICAL
PROGRAMS
POCATELLO
BRANCH
BOISE BRANCH
LEWISTON
BRANCH
DISTRICT HEALTH DEPARTMENTS
Panhandle
Coeur d Alene
North Central
Lewiston
Southwestern
Caldwell
Central
Boise
South Central
Twin Falls
Southeastern
Pocatello
District Seven
Idaho Falls
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Continuing the problems of overlapping of jurisdictions, the
counties themselves are charged with ultimate service responsibility
in some areas, for example, solid wastes management. A conflict
of interest is thus institutionalized whereby the District boards
act as a regulatory body for the county officials who appoint them
to their board positions and who provide their operating funds and
salaries. These conditions must be frustrating to all involved:
the public, the counties, the District boards, the IDEPH. The
frustrations result from unclear and potentially conflicting re-
sponsibilities. A citizen of Idaho with complaint or concern about
a refuse dump, for example, may be shuffled from his municipal
offices, to the county offices, to the offices of the^District
Health Department, to the regional office of the IDEPH, back to the
county, etc., etc., and yet not find a satisfactory response or
fully responsible official to address on the issue. Likewise, a
responsible official of any of the governmental units cited does
not relish the necessity to "pass the buck" on environmental and
health matters.
The system therefore creates unnecessary friction among State
and local employees who are serving for a common public purpose.
Potential for inequities in regulation and enforcement of environ-
mental control exists; an aggressive District board might require
abatement measures in one county while similar or worse conditions
in a neighboring district go unregulated. Uniform criteria for
priorities and consistency in enforcement are unlikely under these
conditions.
A resolution must be found to the inherent duplication of
authority between the District Health Departments and the IDEPH.
Several alternative courses of action are undoubtedly possible,
and should be explored for their relative effectiveness. From
this analysis, it is recommended that the legislators and executive
branch decision-makers in Idaho consider direct legislative change.
The legislature should assign the District Health Departments
directly to the Administrator of the Department of Environmental
Protection and Health. The legal cloud would be removed from the
authority of the Department, and the burden for resolution of the
problem would be lifted from the shoulders of the Department,
thereby reducing the potential for dissension and enhancing the
acceptance of the new system.
To summarize the organizational discussion, then, the internal
organization of the environmental programs of IDEPH appears greatly
improved and the program well organized for action upon the environ-
mental problems in Idaho in a responsive way. The single, major
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structural improvement remaining is clearly the need to resolve
the duplication of the Districts with the Department.
Agency Manpower and Budget
One method of weighing the relative adequacy of the IDEPH's
manpower and budget is a comparative one. The adjacent table of
comparison shows that, in terms of State funds devoted to five
selected environmental programs, Washington spends over four and
a half times and Oregon over three and a half times as Idaho. Ex-
pressed in terms of State funding of the agency on a per capita
basis, however, Idahoans are doing relatively well: Washingtonians
spend roughly 67 cents per person, Idahoans 66 cents, and Oregonians
(known nation-wide for the vigor of their environmental programs)
spend 88 cents per person for all the selected programs.
A comparison of the salary rates in the three States shows
them to be roughly even. Therefore, the low dollars per man year
in total program costs in Idaho, ($16,200), as compared to Wash-
ington, ($22,560), and Oregon ($17,850), indicate a personnel -
intensive program typical of most smaller State agencies. In other
words, the budget dollars avail able—after salaries—for travel,
supplies and equipment are very low in Idaho, imposing program
performance constraints.
As was verified in the program evaluations, the staff of the
IDEPH have insufficient time or budget to conduct the numbers of
inspection, monitoring, and field study necessary to properly
operate the programs. This is likely the most significant defi-
ciency in the State's program and bears true through all of the
agency's environmental programs.
--Water quality surveillance, intensive basin water quality
evaluations, inspections and monitoring for compliance with State
permits and orders are admittedly minimal.
--Air quality surveillance, study and compliance monitoring
are similarly deficient. (Significantly, the agency was forced to
contract out the development of the State air quality implementation
plan and studies to characterize the sources of high participate
levels in several areas of the State and to inventory emission
sources rather than undertake the efforts themselves.)
--Water supply system evaluations are impossible with the low
staff levels available, so that the agency must rely on information
supplied by the system operators. Such self-reporting is an
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COMPARISON OF ESTIMATED AGENCY BUDGETS, WASHINGTON, OREGON, IDAHO
SELECTED ENVIRONMENTAL PROGRAMS, FY 1973
State Federal Total M-Y
Washington:
Air pollution control $ 524.9 $350.0 $ 874.9
Water pollution control 1,295.0 285.5 1,580.5
Solid wastes management 63.0 120.0 183.0
Water supply 215.0 -- 215.0
Radiation control 179.0 15.0 194.0
$2,276.9 $770.5 $3,047.4 135.1 22.56
Per capita 670 89j£
Oregon:
Air pollution control 431.4 61.3 492.7
Water pollution control 875.6 218.4 1,094.0
Solid wastes management 133.0 22.4 155.4
Water supply 243.6 — 243.6
Radiation control 174.0 — 174.0
$1,857.6 $302.1 $2,159.7 121.0 17.85
Per capita 88|z! 103£
Idaho:
Air pollution control 87.6 81.7 169.3 10.5
Water pollution control 253.4 110.6 364.0 22.6
Solid wastes management 53.2 29.2 83.4 5.1
Water supply 43.5 — 43.5 2.7
Radiation control 35.0 — 35.0 2.0 16.20
$ 472.7 $221.5 $ 695.2 42.9
Per capita 66£ 98£
aThe estimates shown are calculated ones developed from available budget
information and checked for rough accuracy with the State agencies.
Adjustments from actual budget figures were made in an attempt to arrive
at comparable program budgets; i.e., local funds were not included, non-
comparable program functions were excluded, and management and administrative
costs were distributed on a roughly proportional basis over the selected
program costs.
NOTE: These are comparisons of the three State budgets prior to enactment
of the Federal Water Pollution Control Act Amendments of 1972. Both
Oregon and Washington are requesting increases by their legislatures
to allow them to meet the workload imposed by that Federal law.
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essential part of a comprehensive water supply program but a poor
substitute for regular inspections, technical assistance to and
training of system operators, and periodic full system evaluation
to determine the adequacy of the design of new systems or the
adequacy of maintenance at existing systems.
—The solid waste management program is now being operated
almost exclusively from Boise, with the few man-years available
devoted to development of State-wide regulations, inventory devel-
opment by mail, and similar operations which the staff themselves
would recommend be supplemented by field personnel performing tech-
nical assistance, inspection and evaluation.
--Radiation sources in the State are being sufficiently regulated
by the two professionals in Boise, but inspections and compliance
in the medical X-ray area have been inadequate. Over a hundred
medical and dental X-ray machines in Idaho have never been inspected.
--Given these examples, it seems unnecessary to add that no
noise level measurements have been taken in Idaho, since the program
authority has not been exercised to-date.
--Finally, even though the State's pesticide use regulation
program operates from the State Department of Agriculture, it seems
a disservice to the public that regular samples for pesticides in
the waters of this intensively agricultural State are not now being
collected and analyzed by the State environmental staff.
This point has been belabored for purpose. The citizens and
legislators of Idaho should be fully aware that, while they empower
and organize the State environmental program, these features alone
will not result in adequate environmental protection unless the
agency is concurrently staffed and funded at levels which allow
environmental monitoring and field inspection for preventive and
compliance purposes. Sound and reasonable State regulations,
policies and abatement orders will fail if they proceed from inad-
equate data to characterize the problems to be resolved or if the
State agency fails to assure compliance with the preventive and
abatement actions it requires.
Other increased functional capabilities and performance are
also needed in both the air and water programs. In the case of
water, the planning and permitting functions are now only minimally
provided, and should be increased to meet the requirements of the
new Federal Water Bill. In the case of air, the staff capability
for emergency episode response, completion of the emission inventory,
and development of compliance schedules is now too low. Program
staff increases to meet these needs and the surveillance emphasized
above are the basis for the recommended levels in the following table.
12
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RECOMMENDED MANPOWER AND BUDGET LEVELS - FY 1974
DIVISION OF ENVIRONMENTAL PROTECTION - IDAHO
Regulations and standards
Planning
Environmental engineering
and assistance (field)
Compliance and environmental
monitoring (field)
Laboratory
Administrative support
Enforcement (legal services)
QJ i—
to ^
3 0-
4
3
7
6
4
3
1
28
•r- rs
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Federal Assistance and Deadlines
The IDEPH is presently operating with $300,000 in Federal
grants to support its program efforts. The funds become available
from selected grant programs in Federal law which provide program
support grants in air pollution control (Section 105, CM) and
water pollution control (Section 7, old FWPCA) and planning funds
(Section 3(c), old FWPCA) for water pollution abatement. In
addition, two local governments in Idaho are conducting solid waste
planning efforts with $172,700 in Federal grant support, and $4.4
million is available to assist Idaho communities in the construction
of municipal sewage treatment works.
Federal technical assistance is available to the IDEPH both
directly, as in the case of intensive water quality studies in the
Upper Snake Basin during the past year, and through program coord-
ination efforts. Staff coordination in the industrial waste
discharge permit and municipal construction grants programs will
be accomplished by the assignment of Federal employees to work in
the State offices in Boise. Technical studies to characterize the
sources of high air particulate levels in Idaho are presently under-
way with Federal contract moneys. And water quality evaluations
are being concentrated in the Coeur d'Alene area at the present to
improve the data base for abatement program development for that
intensively polluted stream.
The nature of the Federal role has been altered in recent
years by the establishment of Congressionally mandated deadlines
for achievement of air and water pollution control objectives.
Congress has set broad constraints upon the planning options open
to the State governments for water and air pollution. National
goals in air quality have been set for the entire nation and are
to be achieved by mid-1975. Similarly, in the amendments to the
Federal water pollution control legislation in 1972, the Congress
set national goals for achievement of water quality satisfactory
for recreation and fish and wildlife by 1983. An interim date of
1977 is set for achievement of best available treatment technology
at all dischargers.
These sorts of broad national policies place severe burdens
upon the State environmental programs for specific actions within
a very short time frame. The laws provide Federal responses very
quickly where the States are unable or fail to act. Two summary
tables of major state actions required by the Federal water and
air pollution laws follow. They summarize very briefly require-
ments contained in the two long and complex laws and supplemented
15
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by hundreds of pages of Federal regulations under which the State
and Federal programs are administered. A careful reading and
understanding of those two lists alone should give a sense of the
wide range and quantity of workload presently falling upon the
staff of the Division of Environmental Protection (in air and water
alone).
16
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SUMMARY OF DEADLINES FOR MAJOR STATE ACTIONS REQUIRED IN FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS OF 1972
DEADLINES* MAJOR ACTIONS LAW SiCTION
303(a)(2)
402(b)
Previous legis.
106ff)(3)
1972 Mid-November
After mid-December
December 31
1973 Mid-February and
July 1 annually
Mid-February and
periodically thereafter
Submit for approval intrastate water quality standards already in effect.
Submit information to qualify for permit authorization.
FY 72 and earlier construction grants funds must be obligated.
Submit report on status and plans for water pollution control programs fnr program grant.
Mid-March or
thereafter
Mid-April
Mid-June
Mid-July
Mid-October
1974 Mid-April
June 30
Mid-July
1975 January 1 and
anuually tlereafter
June 30
1976 Mid-July and
annually thereafter
Mid-July
Submit for approval State's continuous planning process.
Assume final permit authority or turn over State permit program to EPA if oermit
authority not approved for State.
Identify areas with substantial water quality control problems as a result of urban-
industrial concentrations or other factors.
Adopt and submit changes to existing interstate water quality standards identified ty
EPA or EPA initiates promulgation action.
Adopt and submit new intrastate standards, if any."*
Adopt and submit rc«isicns to existing intrastate standards or EPA initiates
promulgation action.
Designate boundaries (interstate & intrast.ite) and nrea-t.-ide wastevater r.inagement
planning organizations for those areas.
Submit applications for payment cr reimbursement of construction grants.
Adopt and submit revisions to new intrastnte standards or EPA initiates ptomulgation
action.**
Identify waters for which effluent limits not stiingent enough, in priority, order, and
estimate total maximum daily load for those waters, or EPA designates ther for incorporation
into State plan.
FY 73 construction grant funds must be obligated.
Areawide planning process in operation (Iccal organizations for those designated by
States; otherwise State agency for rer.ainir.g areas.)
Submit water quality inventory report.
FY 74 construction grant funds must be obligated.
Certify and submit first arcawide wastevater management plans.
Designate areawide waste management organizations.
303(e)(2)
402(a)(5)
208(a)(2)
303(a)(l)
303(a) (3) (A)
3C3(a)(2)
208(a)(2) and (3)
206(c)
303(a)(3)(C)
303(d)(2)
205(b)(l)
208(b)(l)
305 (b)
205(b)(l)
20800 (1) and (3)
208(c)(l)
*Dates indicated are approximate; in addition, some are intended to indicate the latest dates by which the indicated actions are required to
be complete under the law. In cases where the indicated actions are dependent upon the dates of other actions, the actual completion date
Eight conceivably occur at an earlier time than indicated.
**Kot relevant in the case of the States comprising EPA Region X.
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AIR STANDARDS IMPLEMENTATION PLAN DEVELOPMENT DEADLINES
JULY '72
FEBRUARY '73
APRIL '73
MAY '73
JULY '73
SIP approved or promulgation activities begun
State's first semiannual report due—progress on impl. plan
State's compliance schedules due
State's first and second quarterly reports due--air quality data
State's emergency episode control plans due (Communication package, etc.)
EPA approval of transportation controls
EPA approval/disapproval of compliance schedules
State's third quarterly report due
State emergency episode air quality monitoring network operational
State proof of legislative authority for transportation controls due
State SIP for secondary NAAQS due (18-month extension)
AUGUST '73
IDAHO 18 MONTH EXTENSIONS—SECONDARY STANDARDS
Particulate matter
Sulfur Oxides
Eastern Idaho
Eastern Washington-Northern Idaho
Idaho Intrastrastate
Metropolitan Boise
Eastern Washington-Nor them Idaho
Eastern Washington—Northern Idaho Interstate
State's second semiannual report due
State's fourth quarterly report due
EPA promulgation of compliance schedules, if required
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CURRENT ENVIRONMENTAL SURVEY
Idaho is in most respects fortunate in the quality of her
environment. With the single, notable exception of the Kellogg,
Wallace, Mull an area, neither her air nor her water is grossly
polluted. Her problems of solid waste disposal are localized,
and their potential severity mediated by low population density
and low relative degree of industrialization. Her domestic water
supplies are abundant and generally of good natural quality.
But the very excellence of Idaho's environment imposes a
handicap upon the State's environmental protection activities. By
the nature of the State's situation, it is imperative that the
major thrust of its programs be in the direction of protection, of
conservation. Yet national policy, environmental technology, and
the bulk of the institutions that have developed from them are
focussed almost exclusively upon abatement practices.
Idaho, then, must wrestle with the problems of preserving the
general excellence of her environment, and of making improvements
in gray areas where the interaction of man-ls activities with natural
conditions may be pollution, but may be natural phenomena; and she
must do it with crude tools suited to the circumstances of New York,
or Ohio, or South Carolina who will, if they are fortunate, have
improved in a decade or two their physical environment to a point
that faces them with problems of the complexity and uncertainty
that face Idaho today.
The imperatives of the situation demand that Idaho's environ-
mental programs must be of high quality, sophisticated, innovative.
Because her environment is so much better, her environmental activ-
ities must go beyond the minimum, gross force efforts appropriate
for more polluted jurisdictions. She must be a pioneer, developing
procedures that the rest of the nation may apply in the future.
The brief survey of environmental conditions in Idaho that
follows reflects in some degree the complexity of the environmental
questions that persist in Idaho. It reflects, too, the variety of
the activities gathered together in the State Department of Environ-
mental Protection and Health. The environmental background is
described--!argely in terms of deviations from established
standards—in sections dealing with air pollution and water pol-
lution. In the cases of radiation and public water supplies
(administrative and procedural matters directed to public health
maintenance) and solid wastes management, the emphasis is
19
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programmatic, with special attention to weaknesses in terms of
authority or resource allocation that impinge upon the conduct of
programs. In the case of noise pollution, where neither an objec-
tive description of conditions or a program exists, the emphasis is
developmental; that is, it focusses upon steps that may be taken
to initiate effective noise pollution control programs.
20
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PUBLIC WATER SUPPLY
Legislative Authority
Basic health regulatory authority over public water supplies
is provided in Idaho Code 37-2102: domestic water to be protected.
Sections 39-112 authorize the State Board of Health to establish
rules and regulations to control water quality to be used for public
water supply; and Section 39-113 to control means of collection,
treatment and distribution of drinking water.
General regulations governing protection of public water
supply were issued in November 1964. These regulations adopt the
1962 U. S. Public Health Service Drinking Water Standards and pro-
vide that water systems be maintained in accordance with these water
quality standards. Additional standards cover design and construc-
tion of facilities for collection, treatment, storage and
distribution of water for public use. A public water supply system
is defined by the General Regulations as one which furnishes,
water for drinking or general domestic use in incorporated
municipalities; or unincorporated communities where ten (10)
or more separate lots or properties are being or intended
to be served.
The statute creating the DEP&H transferred the functions to the
new agency.
In addition to the general comprehensive appropriative water
rights section of the Code which are of importance to public water
supplies, Section 42-238 requires that minimum well construction
standards be adopted to protect groundwater from contamination.
Regulations which were adopted in 1968 require that public water
supply wells shall meet all State Health Department requirements.
The enabling legislation and the 1964 rules and regulations
are generally adequate to permit operation of an acceptable public
water supply program. Updating the regulation to reflect interim
changes, clarification of the definition of a public water supply,
adoption of procedures to regulate proliferation of water supply
systems in congested areas, and legislation establishing a manda-
tory operator certification program are, however, desirable
elements to improve the water supply programs' legal base.
21
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State Water Supply Program
Funds expended for public drinking water protection in Idaho
are inadequate to support a comprehensive program. The water supply
effort in FY 1971, including field work, administration, and labo-
ratory support, operated on a budget of approximately $33,000.
Nationwide studies by the Water Supply Programs Division indicate
that an adequate State drinking water program would require an
annual expenditure of $450 per system. For the 274 systems in
Idaho, then, expenditures exclusive of laboratory support should
total $125,000.
Total professional staffing for water supply activities within
the DEPH is presently three-quarters of a man-year. Evaluation of
the program indicates that many important activities are not being
performed, or are being performed superficially. Evidence of this
fact is illustrated in a 1971 survey which found that the length
of time since the last sanitary survey of public water supply sys-
tems averaged seven years, the range being from current to seventeen
years.
On the basis of data developed as a result of the community
water supply study, at least four man-days annually are required
per supply to provide surveillance service such as plan review,
surveys, report writing, review of operations and water quality
reports, training, etc. For the 274 Idaho supplies (using 220 man-
days/year) the required professional staff would be five man-years.
Assuming adequate clerical support at a ratio of one clerical to
three professional, an additional 1.7 man-years would be required
to support the professional staff.
State files show letters of instruction have been written to
purveyors periodically advising them of the State's minimum require-
ments for bacteriological sampling. Staff manpower limitations
have precluded adequate follow-up work, however, and compliance
with the bacteriological sampling frequencies has not been attained
by many supplies. This is particularly true of the smaller supplies
which in general receive less surveillance and have more facility
deficiencies than larger systems. Because the bacteriological
sampling program is essentially the only continuous surveillance
provided for smaller supplies, it is doubly important that suf-
ficient bacteriological samples be submitted.
Follow-up to unsatisfactory bacteriological samples is not
consistent throughout the State, and is in some cases completely
lacking. The practice is particularly significant in isolating
22
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specific problems. More rapid reporting of unsatisfactory samples
to the water supply operator and follow-up by DEPH engineers will
be required to improve the surveillance program and provide a de-
sirable degree of health protection.
It is estimated that the State currently expends approximately
$10,500 per year for bacteriological and $6,500 per year for chem-
ical testing of public water supplies. These figures are based on
laboratory cost estimates provided by the State. An adequate water
quality surveillance program for each supply has been defined by
the USPHS to include a complete chemical analysis each year and
bacteriological sampling at a rate based on population served. Cost
estimates for laboratory support for that level of surveillance of
the 274 supplies in Idaho are approximately $12,000 for bacterio-
logical analysis and $13,000 for chemical analysis.
Both bacteriological and chemical laboratory operations were
reviewed and found in a 1971 survey to be in general compliance
with the provisions of Standard Methods. (The major laboratory
deficiency was observed in the installation at Idaho Falls, where
the laboratory is deficient in space and personnel with relation
to the level of effort. Requests for $90,000 in funds for con-
struction of a new building and additional equipment have not been
met.)
Current Status of Water Supplies
Idaho's 274 public water supplies serve an estimated 490,000
persons, about 70 percent of the State's population. In 1971, DEPH
and EPA conducted a survey of 28 public water supply systems serving
103,000 persons. These systems were selected to provide a repre-
sentative sample of the variety of system types and sizes found in
Idaho. That survey indicated that:
Four systems did not meet bacteriological quality standards
on the basis of samples taken during the survey.
Ninteen systems failed to make sufficient bacteriological
determinations during the 12-month period prior to the survey to
provide a satisfactory probability judgment of adherence to
standards.
One system did not meet mandatory chemical standards for
drinking water quality;
23
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Seven systems did not meet one or more of the recommended
chemical drinking water quality standards;
Fourteen systems needed physical improvements at the source of
the water supply;
Ten systems had either less than desirable treatment facilities
or less than desirable protection of the source;
Eleven systems had deficiencies in distribution facilities or
their operation;
Twenty-seven systems did not have cross-connection controls
sufficient to eliminate potential distribution hazards;
Twenty systems had only part-time operators; and only eight
systems employed operators who had received formal water supply
training;
Nineteen systems did not meet standards for bacteriological
evaluations; twenty systems did not meet standards for chemical
evaluations (i.e., did not conduct determinations at the appro-
priate frequency);
Twenty-two systems had not been inspected by a representative
of DEPH within the previous twelve months.
Only a single documented instance of a public health incident
traceable to substandard drinking water in the State of Idaho over
the last decade has occurred (periodic summer dysentery in Rockland
during the late nineteen-sixties, culminating in an outbreak of
gastroenteritis in June 1970). However, it is clear that the
status of public water supplies and their regulatory protection is
such that the potential for other, and more widespread, incidents
is present.
24
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PARAMETER
28 PUBLIC SUPPLIES SURVEYED
PERCENT OF SYSTEMS NOT MEETING REQUIREMENTS
BACTERIOLOGICAL QUALITY AND/OR SAMPLING FREQUENCY
BACTERIOLOGICAL QUALITY (2)
CHEMICAL QUALITY - MANDATORY (2) • 4
- RECOMMENDED (2)
FACILITIES
SOURCE PROTECTION
SOURCE PROTECTION OR TREATMENT
DISTRIBUTION SYSTEMS
FLUORIDATION:(3)
ADEQUATE FACILITIES (2)
FEED RATES TO ASSURE OPTIMUM HEALTH BENEFITS (2)
MONTHLY CHECK SAMPLES (I)
CROSS - CONNECTION CONTROL
BACTERIOLOGICAL SURVEILLANCE (1)
CHEMICAL SURVEILLANCE (4)
SANITARY SURVEYS (5)
OPERATORS TRAINING
(I) DATA FROM PERIOD 12 MONTHS PRIOR TO SURVEY
(2) DATA FROM SAMPLES COLLECTED DURING SURVEY
(3) EIGHT FLUORIDATED SUPPLIES OPERATIONAL
(4) REQUIREMENT - CHEMICAL SAMPLE WITHIN 3 YEARS PRIOR TO SURVEY
(5) REQUIREMENT - SANITARY SAMPLE WITHIN I YEAR PRIOR TO SURVEY
FIGURE 3 IDAHO WATER SUPPLY PROGRAM EVALUATION
-------
ooundary
L9_
bonner
.26
22
6
7
kootenai I
20
1 BOISE
2 LEWISTON
3 GRANGEVILLE
4 ST ANTHONY
5 ST MARIES
ABERDEEN
ARCO
8 COUNCIL
9 POT LATCH
10 RIRIE
11 HORSESHOE BEND
12 HAGERMAN
13 FRANKLIN
14 LAPWAI
17
18
19
bemswah shoshone
15 HAZELTON
16 FIRTH
ARIMO
ROCKLAND
MOYIE SPRINGS
20 ATHOL
21 MIDVALE
22 EAST HOPE
23 CASTLEFORD
24 STANLEY POND W.A.
25 MURPHY
26 HOPE
27 HOLLISTER
28 EUGENE OUTLOOK W.A.
canyon
1
24
28
11 X" X^-f-v. >
ii r fv,^ v-v/s x
J iblaine
| el more Icamas «-_
h--~r-
' Jefferson ! tet n
i .__>—U
j-j|Eonneville
r '—^--, in
'bingham m , ~,**
19-L—
. ..
bearlake
IDAHO WATER SUPPLY PROGRAM EVALUATION
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NOISE POLLUTION
The Federal noise control law requires the EPA to set source
emission standards for certain new products. Particular attention
is to be given to construction, transportation and electronic
equipment and to motors and engines. EPA is also to set source
emission standards for railroad and motor carriers and to
recommend additions or changes in aircraft noise controls. States
and municipalities, then, continue to have major noise control
responsibility, including that for source emission standards for
any new products not legislated by the Federal government, operating
standards for any sources already on the market or in use, ambient
standards, zoning codes, performance standards, building codes,
and—most critically—land use planning. It is obviously the
decision of each State as to how much authority it exercises and
how much is to be left to other political subdivisions. Generally,
zoning and building codes are considered local responsibilities.
In some situations, operating emission standards and land use
planning, particularly in regard to transportation planning
(including airport development) are considered State level legis-
lative functions in most jurisdictions.
Idaho has need for both preventative and abatement noise
control programs. With a substantial proportion of its land mass
of a wilderness nature of outstanding utility for recreation,
measures should be taken to control the threat to the wilderness
by recreational vehicles. In addition to wilderness areas, existing
and potential developed areas can be protected by proper land use
planning and proper location of noise-sensitive uses and noise-
generating uses. Throughout already developed areas, noise problems
seem to be primarily the result of faulty planning. Property
juxtaposed to airports, industry, and highways has been zoned for
residential use. The very activities that are incompatible and
need to be deliberately separated have been thereby encouraged to
be neighbors. Building permit issuance criteria should include
consideration of the existing noise environment of the site and
what effect the particular project will have on the noise environment
if completed. Building codes might then cope with a noisy site by
requiring specific acoustical treatment.
In many States, the legislature pursues enabling legislation
directing a State agency such as an environmental health unit to
particular noise sources that require standard setting or some other
27
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regulatory mechanism. It is then up to the agency to determine the
extent of the problem and decide which areas to control and what
regulatory mechanisms will be used. A few State legislatures have
set a maximum sound level standards directly. Further, State legis-
lation can require consideration of noise in all comprehensive
planning, transportation development, zoning and performance
criteria utilized by municipalities.
As the very least, State enabling legislation should be
developed and a State noise control office should be established
to determine the extent of the noise problem and appropriate control
methods, and to report its findings to the State decision-makers
in preparation for further action.
28
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CONTROL OF RADIATION SOURCES
Effective control of hazards from all sources of ionizing and
nonionizing radiation is a formidable task. The basic requirements
for comprehensive control of radiation hazards in Idaho are (1) a
strong legislative enabling Act, (2) comprehensive regulations,
(3) a technically competent and adequate staff, (4) frequent inspec-
tions, firm compliance and enforcement actions and (5) an environ-'
mental surveillance capability.
Legislation
Idaho passed the Radiation and Nuclear Materials Act in 1967.
This is commendable, strong legislation. It states the policy of
protecting the public health and provides sufficient authority for
the promulgation and enforcement of regulations designed to minimize
and control the hazards from all sources of radiation not under the
control of the AEC. The Act provided for Idaho to assume regulatory
authority over certain radioactive materials, sources and special
nuclear materials formerly under control of the Atomic Energy Com-
mission. In 1972 the basic Act was amended to provide for regulation
of nonionizing sources of radiation.
The Act provided Idaho with very important authority in regulat-
ing such major radiation sources as medical fluoroscopic, radiographic
and theraputic X-ray machines, dental X-ray machines, all other X-rays
used in any of the healing arts, radium and all other radioactive
materials. In both medicine and industry, source materials such as
uranium and thorium, special nuclear materials such as plutonium,
uranium and the multitude of nonionizing sources such as microwaves
and lasers are regulated. In fact, the State of Idaho has statutory
authority to maintain regulatory control over practically every source
of radiation in the State with the exception of the NRTS (National
Reactor Testing Station), which is under the jurisdiction of the AEC.
The total number of sources under Idaho's jurisdiction is approximately
1500.
Regulations
In 1968 the Idaho Department of Health adopted Rules and Reg-
ulations for the Control of Radiation in the State of Idaho. These
are comprehensive regulations, adequate to protect the public health
and safety from radiation hazards. The regulations are broad in scope,
applying to all persons who receive, possess, use, transfer, own or
acquire any source of radiation, except those few facilities regulated
by the AEC. The regulations provide for the licensing and registration
of ionizing radiation sources and establish standards for protection
against radiation. They have separate, specific requirements for
industrial radiographers, users of X-rays in the healing arts, users
29
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of sealed radiation sources in the healing arts, and for stabil-
ization of mill tailings piles. The regulations are sufficient
to protect against radiation. They may be amended periodically
to conform to AEC regulations, EPA guidance and to remain con-
sistent with information and recommendations from recognized
expert sources.
Medical X-Ray Sources
Recognized authorities agree that diagnostic medical and
dental X-ray exposure is by far the most important contributor
to population dose from man-made sources of radiation. It can
reasonably be estimated that over 90 percent of all man-made
radiation to which the population of Idaho is exposed results
from medical X-ray exposure. The major effort of radiation
control should be directed to reducing exposure to the lowest
practical level from medical and dental X-ray exposure.
There are over 800 medical X-ray machines in Idaho and they
are currently increasing at a rate of about 20 units per year.
Each of these X-ray machines should be registered and routinely
inspected for compliance with applicable provisions of the reg-
ulations. Based upon recommended inspection schedules for
various types of X-ray use, there should be a minimum of 350
inspections each year. Including the follow-up compliance visits,
the number of inspections for medical X-ray units could total
400 each year to provide adequate protection.
Radioactive Material Sources
The authority to assume and perform regulatory control over
radioactive materials and specified quantities of source and
special nuclear materials was transferred to Idaho from the AEC
in 1968 through an agreement between the State and the AEC.
Because of this formalized agreement, radioactive materials
have received a high proportion of total staff attention. There
are presently 91 radioactive material licenses in Idaho. For
each of these, the license application must be reviewed and
evaluated, and issued with written conditions specifying kinds
and amounts of materials. Inspections must be made to determine
compliance with the regulations and licensing conditions. All of
these efforts consume considerable time. The number of radioactive
material licenses has increased from 35 in 1968 to 91 in 1972. This
is a growth rate that places continually increasing demands on the
small State regulatory staff. Since 1968 over 400 licensing actions
have been conducted by the staff. As a part of their compatibility
program, the AEC reviews the radioactive materials part of Idaho's
radiation control program. Over the years, they have found that
the program's licensing, inspection and enforcement actions are
generally adequate to protect the public from the hazards of rad-
ioactive materials.
30
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National Reactor Testing Station
The largest single radiation facility in Idaho, the National
Reactor Testing Station, is under the jurisdiction of the AEC.
Because of its size and complexity of operation, a more detailed
description of NRTS is thought to be appropriate.
The NRTS was established in 1949 by the AEC to promote reactor
development by building, testing and operating various types of
nuclear reactors, allied plants and equipment. By 1971, 49 reactors
had been built at NRTS and 16 were still operating or operable.
There are also 23 related nuclear facilities at NRTS including the
storage of high level radioactive waste.
The NRTS is situated on a desert plain in southeastern Idaho
at an average elevation of 4,865 feet. The station is comprised
of 571,800 acres of sagebrush and basalt fields and the boundary
stretches 39 miles from north to south and about 36 miles wide in
its broader southern part. Boundaries are 29 miles west of Idaho
Falls, 32 miles northwest of Blackfoot, 50 miles northwest of
Pocatello and 7 miles southeast of Arco, Idaho.
Although annual precipitation in the NRTS area has averaged
only 8.5 inches, underlying the desert plain is a huge natural
underground reservoir of water in the basaltic lava rock. The
lateral flow of this water is about one billion gallons per day
Aquifer water is supplied principally from the North Fork of the
Snake River. Additional water comes from the Big and Little Lost
Rivers and Birch Creek, which start in the mountains to the north
and sink into the porous soils of the NRTS area. The underground
water seeps slowly at a rate of 10-20 feet per day to the south
and west, emerging in numerous springs along the Snake River between
Milner and Bliss, Idaho.
Major programs currently underway at the NRTS fall into five
categories. One program provides test irradiation services from
the two operating high-flux test reactors, the ETR and ATR.
Another program operates the Chemical Processing Plant (ICPP) for
recovery of uranium from highly enriched spent fuels. A third
major program is that of light-water-cooled reactor safety testing
and research. The Loss of Fluid Test (LOFT) and the Power Burst
Facility (PBF) are the important projects in the reactor safety
program. Other significant programs include the operation of the
Experimental Breeder Reactor II and the operation of the Naval
Reactor Facility.
The NRTS conducts extensive radiation surveillance activities.
Radioactivity is released to the atmosphere and the Snake Plain
Aquifer. In its environmental monitoring program, the Health
Services Laboratory measures the levels of radioactivity in air and
31
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groundwater samples and measures the gamma radiation exposure at
onsite locations, communities near the NRTS boundary and distant
background locations. The concentration of suspended airborne
particulates and dust fall rates are also measured.
The NRTS surveillance results indicate that radioactivity in
air, water, food and other media were a small fraction of accept-
able standards.
The Idaho Radiation Control Program maintains a limited lab-
oratory and field capability for environmental surveillance.
Currently, the operation has been reduced to a stand-by status.
Therefore, the State does not collect and analyze environmental
media from the general area of the NRTS site.
Other Sources of Radiation
A unique source of environmental radiation is the basic ore
processed in Idaho's phosphate industry, which is intermixed with
natural uranium.
Analyses of ore samples collected from two phosphate processing
plants showed the polonium-210 content to be between 12 and 24
picocuries per gram. During the process to drive off the organics
and increase the relative phosphate content of the ore, approximately
85 percent of the polonium is lost as an atmospheric contaminant.
This calculates out to about 27 curies/year of polonium from the
combined effluents of the two plants. Although alpha radioactivity
from this source has been detected in the atmosphere as far as fifty
miles from the plants, the highest concentration above background was
found to be approximately 1 percent of the maximum permissible con-
centration. In addition to the atmospheric releases of polonium-
210, the large volumes of resulting waste material must be contained,
controlled against removal and, if warranted by conditions, stab-
ilized against wind and water erosion. Also the extent of any in-
plant occupational exposure, the pathways and possible
reconcentrations from the use of processed fertilizers should be
determined.
Another source of environmental radioactivity is the radon con-
centrations in the numerous underground mines located in Idaho. Any
excessive concentrations of radium daughters, primarily radon, indicate
a need for more ventilation. The U.S. Bureau of Mines and the Idaho
Mine Inspection Office are the enforcement agencies for radon levels in
mines, but the radiation control program has an interest in knowing
the number of mines, the magnitude of the exposure problems, and in
making independent radon concentration determinations to assure pro-
tection.
Another source of environmental radiation is the two uranium
tailings piles in Idaho, one near Lowman, the other near Salmon.
32
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These piles of waste material contain low-levels of uranium and
thorium decay products, especially radium. They contribute insig-
nificantly to population dose, but they must be guarded against
removal, as their use for fill material under buildings could create
a major problem. The piles must be contained and stabilized against
wind and water erosion if local conditions warrant such action.
Until recently, the Radiation Control Program was authorized
to regulate only ionizing radiation sources such as radioactive
materials and X-ray machines. Now the State can control both
ionizing and nonionizing radiation sources. It is estimated that
there could be as many as 600 nonionizing radiation sources in
the State. These sources consist of microwave ovens, other uses of
microwaves, lasers, infrared, shortwaves, ultraviolet light and
ultrasonic sound. No reliable inventory of the numbers and kinds
of nonionizing sources exists in Idaho and the extent of the hazard
from these sources is not fully documented. No program activities
are being conducted currently in the nonionizing radiation area
because of insufficient program funds.
Radiation Control Staff and Budget
The Idaho Radiation Control Program consists of only two pro-
fessionals operating on a meager total budget of $39,000. Both
staff members are highly competent through education, technical
short course training and experience. Although the number of
medical, dental and industrial X-ray machines, the number of radio-
active material sources, environmental radiation problems, re-
sponsibility for nonionizing radiation sources and administrative
management duties have all increased, the staff has decreased from
three and one-half man-equivalents fn 1968 to two staff members.
The division of staff time by program area is approximately
one man in the radioactive materials licensing and inspection
program, one-half man-equivalent in the medical X-ray program, and
one-half man-equivalent for all other aspects of operations.
Because of the inadequate staff, radioactive waste materials are
being sufficiently regulated but inspections and compliance in the
medical X-ray area have been consistently inadequate. To illustrate,
only 200 of 400 dental X-ray machines and 50 out of 400 medical
X-ray machines were inspected during last year, with even fewer
inspections in some past years. Over one hundred medical and dental
X-ray machines have never been inspected. The two man staff is
dedicated to its work and is trying exceedingly hard to do the job,
but they are simply spread too thin to do all that is required and
necessary.
Recommendations
The Idaho Radiation Control Program budget should be doubled to
33
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provide $78,000 annually. In addition, $20,000 in non-recurring
funds should be provided for needed radiation laboratory instruments.
The agency should employ an additional health physicist to
strengthen the medical and industrial X-ray area.
The environmental radiation surveillance program should
employ a laboratory health physicist and should be modernized and
expanded. The program should operate at the minimum level necessary
to provide Idaho with an independent assessment of radiation levels
in environmental media around the NRTS. No effort should be made
to duplicate the extensive surveillance already being conducted by
NRTS. The enlarged surveillance program should also provide lab-
oratory support for radioactive materials inspections, environmental
monitoring of tailings piles and the natural contaminants of phos-
phate mill ore.
The Idaho Radiation Control Program should begin to determine
the magnitude of the problems arising from the increasing number
of nonionizing radiation sources. The first step should be the
completion of an accurate inventory of the numbers, .types,
location and use of all nonionizing radiation sources. Regulations
should then be adopted for the most critical sources.
34
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CURRENT STATUS OF WATER QUALITY
In general, the waters of the State of Idaho are of excellent
quality, in spite of intense use and a degree of river regulation
that approaches that of the arid southwest. Although there are many
instances of violation of water quality criteria, there is a
certain ambiguity about the bulk of them that traces to definitional
problems inherent in the State's water quality standards or to
uncertainties in the knowledge of relationships between man-imposed
circumstances and the natural geologic and hydrologic background.
Conditions are less than ideal; but they are a far cry from those
of the early nineteen-sixties, when monumental fish kills were an
annual event in the Snake River. Much remains to be done; but the
State of Idaho should be proud of the accomplishments that it has
mounted in water pollution abatement over the last decade.
Spokane River Basin
The most seriously polluted waters in Idaho are to be found in
the Idaho portions of the Spokane River system. This area has
therefore, been the focus of considerable State, local and Federal
water pollution control efforts.
The South Fork of the Coeur d'Alene River is the repository
of wastes from the Bunker Hill Company smelters near Kellogg, of
drainage from mines, leachates from tailing piles and from natural
runoff. As a consequence, heavy metals (zinc, lead, cadmium,
antimony, etc.) are found in solution in the waters of the South
Fork and lower main stem of the Coeur d'Alene River, Lake Coeur d'Alene,
and in the Spokane River in concentrations that are toxic to algae
and fish. Phosphorous concentrations are well above levels sufficient
to cause nuisance growths of algae. Coliform bacteria populations
are excessively high below the raw sewage discharges to the South
Fork and Coeur d'Alene Rivers. Below Bunker Hill, however, the
water is so high in dissolved metals that its toxicity exercises an
inhibiting effect upon populations of algae and bacteria. Largely
tolerant strains of algae suited to the harsh conditions of the
grossly polluted stream are to be found in its lower reaches.
Upper Snake River Basin
Water quality problems of the Upper Snake River are neither
so pronounced nor so extensive as they were a decade ago. They
do, however, exist.
35
-------
< cc-
DC LU
h- GO
CJ
cj
z:
N
LU
CL
UJ
CO
14 r-
12
10
8
6
2
0
0
10 15 20
RIVER MILE
25
30
35
40
ZINC CONCENTRATIONS
SOUTH FORK, COUER D'ALENE RIVER
-------
Dissolved oxygen concentrations are consistently depressed
below levels set by the State's water quality criteria in the
lower depths of American Falls and Milner reservoirs in late
summer and early fall--a function, presumably, of temperature
stratification, decay of organic bottom deposits, and inflow
of oxygen-deficient subsurface springs as well as of waste
discharges. The lower reaches of the Portneuf River are also
characterized by seasonal dissolved oxygen deficiencies created
by the combination of low flows, elevated temperatures, waste
discharges of the Pocatello area, and entry of groundwater.
Violations of the bacterial criterion would appear to be
common. Indeed, an October 1971 water quality survey found
ostensible bacterial violations predominant on portions of the
Upper Snake River during the food processing season: over 50
percent of the stream miles between Idaho Falls and Milner
Reservoir were determined to be in excess of 1,000 coliform
organisms per 100 ml. Such bacterial levels were found in
major service areas along the Snake. Considerable uncertainty
attaches to the appearance of a standards violation, however,
because of a statement of the bacterial criterion that is
profoundly unsatisfactory. Idaho uses a total coliform standard—
1,OOOMPN/100 ml—but imposes a hedge—"when attributed by
sanitary survey to fecal sources." Given the complexity of
bacterial dynamics, the interplay of naturally occurring
organisms with those occurring in sewage and from runoff of
grazing lands and the cycle of dieoff and regrowth in highly
fertile waters, it is almost impossible to determine the
correspondence of excessive bacterial population and fecal
source necessary to define a violation of standards. The
correlation may logically be implied in the case of .sanitary
sewage, but it is harder to assume in the case of industrial
wastes. What the larger significance of this may be we can
not say—no one has been able to precisely fix the public
health significance of a given population concentration of
coliform organisms, much less the ecological significance of any
such number. But the practical regulatory problem imposed by an
ambiguous definition of bacterial violation is clear. It is
almost impossible to establish effluent control requirements in
the instance of industrial sources of bacteria, in that it is
difficult to demonstrate a certain violation.
The Upper Snake River runs a characteristic green over most
of its length of passage during the warm summer months, except
where turbidity is high. Dense, floating mats of algae blooms and
colloidal plant suspensions are evident throughout the summer.
Identification of the sources and controllability of the problem
is, however, yet a matter to be resolved. Municipal wastes,
37
-------
QC
o
O ^
O
0:8
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QQ „
QQ <
O C3
CC CC.
Q- O
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1,000.000
100.000
10,000
1.000
100
10
UPPER BASIN
0
UPPER
SNAKE
OCTOBER
1971
MIDDLE BASIN
MIDDLE
SNAKE
NOVEMBER
IDAHO
TOTAL
COLIFORM
STANDARD
I I I I I I
I I
III II I
640
370
680
700
720
740
390 410
430 450
760
470
780
490
800 820
510
RIVER MILE
840
530 550
BACTERIA IN UPPER AND MIDDLE SNAKE RIVER
-------
probably enriched by phosphate-base detergents, are an obvious
source of phosphorous in the Upper Snake Basin as elsewhere in
the Nation. But there are other, and more significant, sources
as well. At Pocatello, two large phosphate processing plants
operate. The soil-laden wash wastes of potato processors have
also been measured to be a rich source of phosphorus during the
processing season, larger in sum that either phosphate processing
plants or municipal wastes. Natural runoff from the highly phosphatic
soils and from phosphate mines may well be a prime source
of phosphorus. And recirculation of phosphorous through decom-
position or organic matter settled to the bottoms of reservoirs
unquestionably adds further to nutrient loads. The problem is
complex and is of long duration.
Tributary streams of the Upper and Middle Snake Basins are
in several instances considerably more polluted than the Snake
itself. The lower reaches of the Portneuf River, as noted above,
suffer dissolved oxygen depletion, high bacteria counts, and very
high concentrations of phosphorous. Main Drain and Aberdeen Drain,
agricultural sewers flowing into Milner and American Falls
Reservoirs, are the repositories of municipal and industrial
wastes that result in dissolved oxygen deficiencies and high
bacteria populations. The lower stretches of Rock Creek carry
an enormous volume of waste from a sugar refinery as well as
drainage from Twin Falls, a potato plant, and outlying fields
and pastures. Though the slope of the creek is great enough to
permit reaeration sufficient to obviate dissolved oxygen difficulties,
its bacterial quality does not meet the State's standards, and
the stream transmits its biochemical oxygen demand, bacteria, and
turbidity to the receiving Snake.
Middle Snake River Basin
In many respects, the water quality condition of the Middle
Snake River (Milner Dam to Brownlee Dam) recapitulates that of
the Upper Snake. Excessive aquatic growths and high bacterial
concentrations are found downstream of the juncture with the
Boise River and into Brownlee pool. Depressed dissolved oxygen
concentrations in the lower depths of Brownlee Reservoir also
mar water quality that is otherwise in conformity with established
criteria. There is also—totally expectable in an irrigation
economy—a progressive increase in total dissolved solids through
the length of the Snake, though concentrations do not attain
serious levels; and instances of excessive turbidity are not
uncommon. Causes, like the violations of the criteria, are
39
-------
o
CO
H
QC
O
.20
z
o
P .15
oc
Z
UJ
o
z
o
o
.10
o:
O
I
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a.
o
MARCH 1972
LIMITING
CONCENTRATION
FOR ALGAE
BLOOMS .
1111
I I I
J I
j i
j
640 660 680 700 720 740
RIVER MILE
760
780
800
810
ORTHO PHOSPHORUS CONCENTRATIONS
IN UPPER SNAKE RIVER
-------
similar to those found in the Upper Snake area, with the exception
that there are no known, significant natural sources of phosphorous
runoff in the middle basin proper.
The Boise River contains a whole series of water pollution
conditions. Less polluted than the Coeur d'Alene River, it is
far more polluted than the Snake River into which it flows. Both
bacterial and dissolved oxygen concentrations consistently violate
established standards, and phosphorous concentrations are well
above levels required to trigger algae growth. The fact that
severe algae problems have not been found to exist in the Boise
River Basin may be due to other limiting factors such as turbidity
or hydraulic conditions. All of these problems are compounded by
excessive turbidity and elevated summer temperatures in the river's
lower reaches. Water quality deterioration begins at Boise, and
after a moderate recovery, swift and near endemic deterioration
resumes with the entry into the stream in rapid succession of the
wastes of Caldwell and of Indian Creek which carries the wastes
of Nampa. The sources of the pollution are entirely conventional,
organic municipal and industrial (largely food processing) wastes
in volumes too great for the sluggish, warmed, and irrigation-
depleted stream to assimilate. The quality of the Boise River
has swung pendulum-like from better to worse several times over
the last decade and a half as steadily increasing prevalence and
intensity of waste treatment has intermittently caught up with,
then fallen behind the rate of increase of waste production in the
most densely populated,irrigated, and industrialized watershed in
the State.
Lower Snake Basin
The major tributaries to the Snake below Brownlee Dam, the
Salmon and Clearwater River systems, are superb, almost unspoiled
waterways with the exception of high dissolved gases on the Clearwater
below Dworshak Dam. The Palouse River, a sediment-choked, bacteria-
ridden, near intermittent stream, is of abysmal quality and consistently
in violation of standards in its lower reaches. To what extent
that quality can ever be remedied is uncertain, in that the
physical circumstances governing the stream's nature (intermittent
flow, unstable soils, modest slope) are not conducive to naturally
high quality.
The lower Snake River itself is generally of excellent quality,
again, except for high dissolved gas levels. A pocket of waste
discharges at Lewiston (pulp and paper production, food processing,
municipal sewage) has a discernible, though hardly significant
effect, including,apparent violations of the bacterial standard
from time to time that are as ambiguous
41
-------
as those found upstream. Considerable concern has been expressed,
however, for the water quality conditions which will exist after
the stream is converted into a series of pools by the completion
of Lower Granite Dam. In the last half decade, too, floating
aquatic slimes have appeared in the lower Snake, occurring in the
reach of the river from Brownlee Dam to the confluence with the
Clearwater River during low flow periods. These are apparently
transmitted downstream with nutrient concentrations of the upper
river, the evidence and effect of those nutrients relaxing with
dilution by the inflows of the Salmon and the Clearwater.
A more severe problem—one common to the lower reaches of the
Columbia River system, and one that threatens to eliminate the
Columbia River salmon—is supersaturation of dissolved gasses
through the lower Snake River. Supersaturation has been documented
at lethal levels (equal to or greater than 120 percent) below
Brownlee, Oxbow, Hells Canyon, and Dworshak, Lower Monumental,
Ice Harbor, and the incomplete Lower Granite Dams during periods
of high spillway discharge. Idaho has adopted a dissolved nitrogen
criterion of 110 percent of saturation, but there is great
question as to ability to meet that criterion with present reservoir
management technology.
Groundwaters
Groundwater quality is not presently subject to legal
standards nor is it as definable as the quality of surface waters.
The addition of the third dimension, the concealment of the
enveloping mantle of soil, invests all matters associated with
groundwaters with a greater degree of uncertainty, a lower order
of predictability. Groundwater pollution tends to be episodic
rather than dynamic—a contaminated well is discovered from time
to time, but one can seldom relate that contamination to a source
or predict either its spread or its reversal with any degree of
confidence. In dealing with groundwaters, then, it is the
possibility of pollution and the difficulties of clean-up rather
than the demonstration of pollution which most concerns us. And
our strategy must be protection rather than abatement.
At least two, and possibly three, threats to the quality of
Idaho's groundwaters can be discerned. Subsurface disposal of
wastes, if not stringently controlled, can pollute groundwaters.
At least 5,000 well disposal sites, including sites for disposal
of irrigation tailwaters, have been identified along the Snake
Plain. The Spokane River Basin already has a serious groundwater
pollution problem. In the past, mine operators discharged
wastes directly into the South Fork Coeur d'Alene River and its
42
-------
tributaries. These wastes were spread across the valley during
flood seasons and percolated into groundwaters. Though the
practice has been stopped, old tailings deposits continue to
contribute to pollution of groundwaters by heavy metals. Similar
pollution of the great Snake Plain aquifer remains a possibility,
even though a dim one. Since the aquifer receives the wastes of
the National Reactor Testing Station, potentially radioactive,
that possibility can not be lightly dismissed. Concentration of
farm animals in feed lots and dairies presents the continuing
threat of nitrate pollution of groundwaters throughout the State.
A more specific threat to groundwater quality is to be
found in the Boise River Basin. Two distinct groundwater resources
occur in the area, an underlying one in the basaltic lava flows
and an alluvial deposit recharged by irrigation. At many places
in the valley, deep wells have been sunk to relieve artesian
pressure and drain land that has been waterlogged. Any large
groundwater development based on the artesian source could result
in its pollution by recharge from the easily polluted alluvial
aquifer's flow through the relief well channels.
43
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CURRENT STATUS OF AIR QUALITY
National ambient air quality standards include primary and
secondary standards for six classes of air-borne pollutants:
particulate matter, sulfur oxide, carbon monoxide, nitrogen dioxide,
hydrocarbons, and photochemical oxidants. Primary standards are
set at levels designed to protect public health. The more stringent
secondary standards are intended to protect public welfare against
any known or anticipated adverse effects of air pollution.
Four of these six pollutants—carbon monoxide, nitrogen dioxide,
hydrocarbons, and photochemical oxidants--are directly or indirectly
the result of emissions from the automobile. Adherence to the
standards established for these pollutants, then, is directly
related to the number of automobiles in any region. The number of
automobiles is a direct function of population density. In the
absence of measured air quality data for these pollutants in this
region where urban place population is less than 200,000, it is
assumed that the standards for these pollutants are met in Idaho.
These four automobile pollutants are not predicted to present a
threat to Idaho's air quality in the immediate future. It is
scarcely conceivable that the State's population growth could increase
the quantity of emissions fast enough to exceed ambient air quality
standards, given the expected radical improvement of unit emissions as
a consequence of current national regulations for automobiles. Over
the long run, more efficient transportation modes should eventuate at
a rate sufficient to relieve any possibility of significant
pollution.
Industrial process losses are the principal source of violations
of ambient air quality standards for sulfur oxides (SOX) in Idaho.
The association of SOX with large industrial operations makes the
sources responsible for standards violations of this pollutant
category the easiest to identify. In Idaho, the violations of
sulfur oxide standards, which occur in two regions, are the result
of emissions of a specific industry in each region. In the
Pocatello area, the degree of control of SOX emissions necessary to
45
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VIOLATIONS OF NATIONAL AMBIENT AIR QUALITY STANDARDS AND THEIR SOURCES
Air Quality Control Region
Pollutant 61 62 63 64
Particulates Violations of Violations of Violations of Violations of
primary and primary and primary and secondary
sec. stds. sec. stds. sec. stds. standards
SOX Violations of Violations of Standards met Standards met
primary and primary and
sec. stds.* sec. stds.
CO Standards met Standards met Standards met Standards met
Photochemical Standards-met Standards met Standards met Standards met
oxidants
Hydrocarbons Standards met Standards met Standards met Standards met
NOg Standards met Standards met Standards met Standards met
PERCENT OF PARTICULATES BY CATEGORY .OF SOURCE
Fuel
combustion 9.6% 4.9% 19.5% 34.9%
Industrial
process loss 52.U% 17.0% 2.9% 31.5%
Solid waste
disposal 26.7% 75.5% 74.2% 11.3%
Transportation 8.5% 2.3% 3.0% 20.9%
Other 3.2% 0.3% 0.4% 1.4%
PERCENT OF SULFUR DIOXIDE BY CATEGORY OF SOURCE
Fuel
combustion
Industrial
process loss
Solid waste
disposal
Transportation
Other
11.0%
84.0%
0.2%
4.8%
--
0.9% 74.2% 82.3%
98.7%
1.0% 0.8%
0.4% 24.8% 16.9%
__
*Attributed to a single source.
-------
achieve the standards can be achieved by applying available technology
at the Simplot Company phosphate processing plant. A program has been
identified. The control of SOX emissions from the Bunker Hill
Company Smelters necessary to achieve the standards in the Kellogg
area is a highly complex problem and may exceed the bounds of
reasonably available control technology. Control of these two
sources would bring about compliance throughout Idaho with the
sulfur oxide standards.
With respect to particulates, air quality control options are
not nearly so clear. Ambient air for all Idaho air quality control
regions contain instances where primary and secondary air quality
standards for particulate matter are exceeded. However, all sources
of particulate matter emissions are not known. Modeling studies
indicate that known, inventoried sources such as open and slash
burning, are not alone responsible for high ambient particulate
matter concentrations in certian areas; i,e., the air quality
levels predicted by a diffusion model to occur as a result of known,
inventoried particulate matter sources are not as high as those
actually found to occur. It seems very likely that high "natural"
background particulate matter levels, and emissions from unmeasured
or uninventoried sources make up the difference. It is possible
that unstable soils and high winds, agricultural activities, unpaved
roads and parking lots, fugitive dust from industrial activities,
etc. may be the predominant part of the total particulate problem
in Idaho.
Particulate matter will receive a high priority in Idaho's air
quality improvement programs. An EPA/State of Idaho study is
underway to define the extent of the particulate matter problem in
Idaho and identify the sources of particulate matter which are
contributing to ambient particulate matter values. Control
strategies for the attainment of secondary particulate matter
standards must be submitted to EPA by Idaho July 1973. (Figure 1
presents general locations of inventoried sources only.)
The Eastern Idaho Intrastate Region (Region 61), comprised of
the State's fourteen easternmost counties, contains violations of
national ambient air quality standards for both particulate matter
and sulfur oxide. Existing fluoride air quality data (a non-criteria
pollutant) is also showing high ambient air concentrations. The
area's phosphate processing industry is the prime source of
particulate matter, sulfur oxides, and fluorides. Monsanto Company
(Soda Springs), FMC Company and the Simplot Company (Pocatello)
47
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SULFUR COMPOUNDS
PARTICULAR (SMOKE
FLYASH , DUST ETC)
FLUORIDES
Moscow
Lew/ston
Springs
MAJOR AREAS OF AIR POLLUTION
-------
AIR
QUALITY KNOWN PARTICIPATES* SULFUR OXIDE
CONTROL
REGION TONS/YR PERCENT TONS/YR PERCENT
061
062
063
064
TOTALS
8,940
15,980
32,038
3,144
60,102
14.8
26.6
53.3
5.3
100 %
14,224
87,035
3,620
2,524
107,403
13.2
81.0
3.4
2.4
100 %
THESE FIGURES REPRESENT INVENTORIED PARTICULATE EMISSIONS
IN 1970.
THE SOURCES OF MUCH OF THE PARTICULATE MATTER IN IDAHO
REMAIN UNKNOWN AND UNINVENTORIED.
TO MAKE LONG-TERM CONCLUSIONS ON THE SEVERITY OF THE
PARTICULATE PROBLEM FROM THIS DATA IS NOT POSSIBLE
EMISSION INVENTORY
SUMMARY FOR STATE OF IDAHO 1970
-------
discharge particulate matter, gaseous and particulate fluoride.
compounds, and phosphorous pentoxide. The Simplot Company is the
prime source of air-borne sulfur compounds and ammonia. Contributing
also to the known particulate matter presence in Region 61 is the
burning of solid wastes in sawmill conical burners.
The Eastern Washington-Northern Idaho Interstate Region
(Region 62), comprising the four most populous and industrialized
counties of northern Idaho, experiences ambient air violations of
primary and secondary air quality standards for sulfur oxides and
particulate matter. An estimated 99 percent of the sulfur oxides
occur as a result of the operations of two Bunker Hill Company
smelters. This smelter complex is also a significant source of
known particulate matter. The confining topography of the
Kellogg Valley, which, tends to hold pollutants in place rather than
permitting them to disperse, compounds the pollution problem.
At Coeur d'Alene and in the area around Lewiston, sawmill
conical burners are significant sources of known particulate matter
although the Potlatch Forest Company's (PFI) pulp and paper mill
at Lewiston is the predominant source of known particulate matter
and odorous sulfur compounds. The PFI mill's environmental
influence is heightened by its location along the Snake River--
the river valley walls channel the winds along the air stream above
the river. Condensation of droplets on particulate matter, and
water vapor emitted by the mill intensify fog formation and
contribute to visibility problems.
Ambient air over the Metropolitan Boise Intrastate Region
(Region 64) experiences violations of secondary air quality standards
for particulate matter. Fuel combustion and industrial process
losses are the principal known source of particulate matter in
this region. In Nampa, the Amalgamated Sugar Company refinery
is the major stationary source of known particulate matter.
Industrial process losses originate largely from asphalt and
ready-mix concrete operations. Furthermore, the Metropolitan
Boise Intrastate Region, the most highly populated area in Idaho,
is the only region to experience any significent emissions from
automobiles and aircraft. During periods of severe inversion,
some reduction in visibility is attributed to exhaust emissions
from vehicles.
The Idaho Intrastate Region (Region 63) is composed of the
area not included in the other three regions. Solid waste disposal
and fuel combustion contribute the major portion of conventional
or known particulate matter emissions. Twin Falls, the only
sizeable community in this vast area, can experience some of the air
quality difficulties associated with population concentration and
consequent emissions from automobiles, industrial activities, and
50
-------
space heating. Location on a flat, cultivated, windy plain causes
Twin Falls to experience an air pollution problem in the form of
windblown dust. These factors combined cause particulate matter
levels in Twin Falls to exceed both primary and secondary ambient
air quality standards.
51
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SUSPENDED PARTICULATE SAMPLING
FY 1971
POCATELLO
TWIN FALLS
KELLOGG
BOISE
COEUR d'ALENE
DOTTED LINE
INDICATES
RECOMMENDED
MAXIMUM
LEVEL FOR
CLEAN AIR
0
20
40
60
80
100
PERCENT OF SAMPLING TIME AIR QUALITY LEVELS WERE EXCEEDED
(24-hour sampling done semi-weekly)
SOURCE: Idaho's Critical Health Indices, 1972. Idaho Department cf Health, Boise.
-------
SOLID WASTES MANAGEMENT
Any attempt to characterize the nature of the solid wastes
management problems in Idaho must begin with an important
disclaimer: The nature of the solid wastes problem in Idaho is
difficult to quantitatively characterize. The State is large,
its population small and scattered, its economic base largely
agricultural. Inventorying and classifying the hundreds of
scattered disposal problems in the State is a monumental task
in itself—as illustrated by the maps in this chapter locating
only those authorized disposal areas. On the other hand, the
application of national averages, national costs estimates, and—
in some respects—the national approaches carry inherent
potential for losing the real world picture of solid wastes in
Idaho.
Idaho has but one city over 50,000 population and only
nine over 10,000. Her population density is 8.6 people per square
mile, compared to a national average of 57.5. Obviously, successful
solid waste management systems demonstrated effective for, say,
St. Louis are not likely to be appropriate for solution of the
majority of solid wastes problems in Idaho, the scattered small
towns and agricultural and forestry wastes.
Again, Idaho must innovate. Given her high sensitivity to
environmental protection needs, she must develop those approaches
which will solve her own problems which are in many ways unique to
her State. Care must be taken as she reaps the experience and
techniques of more wealthy States in addressing the solid waste
management that she takes the wisdom of those experiences and
adapts them to her economy and people.
The small staff of the IDEPH on solid waste management programs
are aware of the nature of solid wastes generated in Idaho. Their
report, Solid Wastes Management, 1970, Status Report and State Plan,
is a compilation of the best information yet available (collected
in 1966) and outlines a plan for addressing the problems it describes
Solid Wastes Generation - A "Mini" Look
If the national average of 5.3 pounds per capita per day were
applied to Idaho to estimate domestic waste alone (residential
and commercial), it could be grossly estimated that approximately
38,000 tons of this type of solid waste is generated in Idaho each
day with a total of 700,000 tons per year at the present population.
53
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STATE HYDROLOGIC BASINS
I $f$
1 H>< \
I . )' ^ \ PANHANDLE
LJ?'*"""* \ \
^iENil j, , ,> ^
ENVIRONMENTAL PROTECTION AGENCY
REGION X
STATE OF IDAHO
POINT WASTE SOURCES
PRIMARY - COMMERCIAL ANIMAL FEEDLOTS
LEGEND
• Beef cattle, 500 head or greater
D Dairy cattle, 100 head or greater
S Sheep (confined for wintering) 1,000 head or greater
[_^v^__:_
i L A T A H ! ^-"^-^
L r'
P*» ,
: /—rjic^
J J T E K/\
/ ie u T T r
\ ^\ s?
0 ' W s Y H *E E
-------
It is estimated that at least 235 tons of community refuse
are burned daily in Idaho to produce 33 tons of hydrocarbons and
18 tons of particulate matter.
There are over a thousand commercial animal feedlots in Idaho
which produce more than an estimated 15,000,000 wet tons1 of manure
in Idaho every year and, of this amount, 2,700,000 tons have to be
transported.
Sawmill and logging debris was estimated to range from a high
of 4,300,000 tons to a low of 4,100,000 tons annually in 1966.
Fruit and crop residue amounted to an estimated 3,700,000 tons
in 1967.
These rough estimates of wastes generated are given as examples
of the type and dimension of the solid wastes in Idaho. Some of
the "wastes" are undergoing re-use and/or managed disposal, as
for example the use of crop residues for cattle feed. Much is not
being put to reuse and is being stockpiled or burned.
Existing Conditions, Practices and Problems—Domestic Refuse
In the original solid wastes survey of community disposal sites
in Idaho, 271 were recorded. Since that survey, 124 sites—some not
included in the original survey—have been closed. The remaining
operations are either sanitary landfills, modified landfills, or
open dumps. Together, these account for 211 disposal sites: 23
are sanitary landfills; 27 are modified landfills; and 85 are open
dumps without burning or obvious actual or potential water pollution;
52 are dumps or modified landfills where frequent burning occurs;
and 24 are dumps or modified landfills where actual or potential
water pollution is evident. Fewer water and air pollution problems
are associated with modified landfills than with open dumps of
similar size.
•'•Roughly equivalent in terms of BOD potential to wastes from 3.6 million
people. The figure includes animal wastes in confined areas from hogs,
chickens, sheep, milk cows and beef cattle.
55
-------
STATE HYOROLOGIC BASINS
I
Mte\
•fr d I/ \ ! PANHANDLE
»i»LE«e \ ^
T'KqS&ENii L-<7j ;.
ENVIRONMENTAL PROTECTION AGENCY
REGION X
STATE OF IDAHO
EXISTING "AUTHORIZED* DISPOSAL SITES
LEGEND
TYPE OF SITE NUMBER OF SITES
} Sanitary Landfill (23)
t> Modified Landfill (27)
Open Dump (85)
-» Open Burning (52)
O Water Pollution Problems (24)
024)
C 1) S / T E R .J
-------
Totalling these numbers, we find that 124 disposal areas have
been closed and 211 operations of various types are currently in
existence. Many that have been closed are small community dumps
where the wastes are now being taken to another site. This means
that many of the remaining disposal operations, particularly the
sanitary landfills, are receiving more wastes and serving a
larger number of people than they had in the past. Figure 1
shows the distribution of these disposal sites in the State.
Conclusions
The public attitude of "use it, throw it away, and forget it"
yet prevails in Idaho as indeed it does in much of the country.
A major program thrust has yet to be mounted to inform the public,
train the personnel, develop the financing and managing organizations,
develop plans of action for sound management, and begin to develop
the financing capabilities through user charges to undertake sound
solid waste management in Idaho. Hopefully, this condition is
temporary, awaiting but the program development work and political
support to get fully underway.
Unfortunately, solid waste management yet rates as a low
priority in consideration of environmental needs and in the
allocation of manpower and dollars at the State and local levels.
While the most onerous "dumps" are being addressed, comprehensive
solid wastes management systems in Idaho are not rapidly coming
into existence.
Dump closing is commonly used as a criteria for measuring the
effectiveness of a solid waste management program. Yet dumps
represent only one part of the solid waste management systern -
the one which is most apparent. The collection element, which usually
represents 60-85 percent of the total cost for solid waste management
is not well known nor understood by the citizenry who must support,
plan and fund it.
Dumps cannot rationally be closed without regard to many
related matters including the provision of alternative sites which
will be an improvement over the site vacated. This cannot be
accomplished without some degree of planning. Questions must be
addressed and answered: Which sites should be closed, who will
close them, what will the costs be, and what will be the source of
funding (costs for equipment, manpower, transportation to and from
the site, clean up, cover material, fences, gates, signs, patrol
of the site, public information, etc.). A more valid criteria
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with which to evaluate a community's progress is to rate its
overall solid waste management program (organization, resources,
financing, enforcement, etc.) and the continuing effectiveness
of that program.
Local officials and citizen groups in Idaho are becoming
more aware and involved in the resolution of solid waste management
problems; but it is being addressed at a low priority relative
to the degree of solid wastes problems. As that priority increases,
it should be remembered that significant improvements in solid
wastes management cannot be achieved solely through enforcement.
Local areawide solid waste management plans must precede actual
development of solid waste management systems, e.g. decisions
must be made with regard to development of collection and transfer
systems, closure or conversion of open dumps to sanitary landfills,
location, design and operation of regional processing and disposal
sites, establishment of administrative organization(s), means of
funding, staffing, etc.
Officials of the IDEPH have developed an approach for the
resolution of solid wastes management problems in Idaho in the
State solid waste plan referred to earlier. A principal fact yet
to be faced—and possibly the major impediment to immediate
aggressive action—is cost. Grossly estimated, the various
planning entities at the local levels in the State should be
spending about four to six hundred thousand in the development
of short range and long range planning and implementation programs.
Planning is now underway in one District Health Department but
local planning groups have been constrained by inadequate funding
(included the Federal level) from meeting the State's goals for
completion of those plans.
Those sums pale to insignificance, however, in comparison to
the costs which the citizens of Idaho must meet to provide for
the solid wastes management systems themselves, for capital invest-
ment, operation, and collection services. With no economic analyses
at all, it is grossly estimated the bill to be met ranges into
the millions over the next five years. The cost per user,
obviously, must be a more reasonably manageable figure, affordable
on a monthly basis by most Idahoans.
Accurate estimates of costs to individuals based upon analysis
of the appropriate system for each area must be a product of the
solid waste plans repeatedly emphasized here. That approach is
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the basic strategy in the IDEPH program for solid wastes management.
But the staff of the IDEPH is yet at minimal levels, too few to
respond well to all citizen concerns much less assure the completion
of solid waste management plans throughout Idaho. Their time is
devoted to training of operators, to technical assistance in site
selection and review of site plans and specifications, to develop-
ment of those statewide regulations which will provide the standard
of performance for those charged with planning and operations, to
enforcement against those most serious dumps, and to development
of cooperative arrangement for resolution of immediate needs in an
effective way. Recommended staff increases in solid wastes manage-
ment are presented in an earlier chapter. Those figures are
presented as a beginning, to provide that cadre of experts and
administrators to provide program development in solid wastes
management in Idaho.
For purposes of emphasis, a list of programmatic achievements
intended to describe a fully developed solid waste management
program in a State agency is presented below. The principles and
ideals thus described are the desirable end to be achieved in
the next five years in the IDEPH.
Phase I - Resolve immediate solid wastes management problems:
Develop short range, interim plan-program to address immediate
problems and needs. Utilize existing technology to identify
problems and accomplish improvement to meet present State and
Federal standards and requirements.
1. Elimination of pollution from disposal sites and facilities
by closure of site or conversion and upgrading; an estimated 150-
200 dumps converted to sanitary landfills. (By 1977)
Phase II - Planm'ng-implementation programs addressing
long range problems and needs and formulating proposals for all
elements of the solid waste management systems including establish-
ment of regional organizations to administer solid waste management
program, e.g. financing, regulations and control, etc.
1. Optimization of the storage, collection, transfer, processing
and disposal systems, for all types of solid waste management
as needs, technology and resources advance.
2. Establishment of centralized-regional sanitary landfill
processing disposal sites with recycling facilities in regions
of the State.
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3. Establishment of regional systems of rural collection
drop boxes-transfer stations with recycling containers and mobile
compactors where needed.
4. Development of regional programs for management of
special wastes, e.g. hazardous wastes, feedlots, agricultural
and industrial waste, wood wastes, abandoned vehicles, tires,
oils, institutional and recreational wastes, etc.
5. Establish areawide organizations to administer solid
waste management program (support, promote/PR, financing,
legislation, rate charges, etc.).
6. Develop and adopt alternative methods and schedule for
financing region solid waste management systems.
7. Develop legislation, ordinances, interagency agreements,
standards and criteria, enforcement.
8. Develop training program for operators and middle manage-
ment personnel.
9. Develop public information/relations program for continued
support.
10. Market analysis for recycling; phase recycling into
regional disposal sites as markets are developed.
11. Develop management information system for measurement of
progress, review and updating of regional planning-implementation
programs.
GPO 796-902
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