UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION I
DATE:
SUBJ:
FROM:
TO:
September 17, 1964
Mane
Update - Region I
Michael R. Deland
Regional Airinistrator
Alvin L. Alr:
Deputy Administrator
We are pleased to subrit to you the Environmental Management
Report Up-cte fror. Region I. Vie hope you will find the doc-
ur-.ent useful for Agency planning and budgeting processes;
it will certainly be useful to me in directing our Region I
initiatives and activities over the next year.
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ASEM:??? REPORT UPDATE -
TABLE OF cn.Tsr
Part I - Rr.'s Qverviev — Executive Surr.ary
Part II. Rgc'ional Environmental Problens
Issue 01 - Ground Kater Protection
Issue 02 - Boston Harbor
Issue 03 - Toxics
Issue 44 - Lone Range Transport:
• Acid Rain
0 Ozone
Issue «5 - New Bedford Harbor
Issue $6 - Hazardous Kaste Ferrr.itt.in5 and Ccrpliance
Issue $7 - Asbestos anc Pjblic Health
Issue
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Par
t j. Regional A*.inistrator'« Overview - Executive Sirrrary
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FfcftT I Regional Administrator's Overview
A. Krrr SIGNIFICANT ENVIRONMENTAL PROBLEMS
v«?v Er. = laf>d is faced with a variety of different and sometimes connected enviror.-
rsr.'.e". ar.f public health problems. In this Environmental Management Report we
explore New England's most significant environmental problems and propose actior.s
that Region I and Headquarters should initiate to resolve them. While many of
these problems are shared by other parts of the country, some are unique to New
rr.=lar.f. In all instances, however, public concern is extraordinarily high and
de-anl for actior. is growing.
Recion I is building a forirddable environmental protection presence in New England.
We incorporate strong and balanced enforcement and compliance efforts into all our
activities. We invite citizens, environmental and business groups, states and
other federal agencies to participate in our deliberations and become partners in
solutions. And, we pursue improved resource distribution, planning and adjr.inistrativ
mar.agener.t practices to enhance our capacity to manage for environmental results.
Tr.e following is a brief description of the ten highest priority issues in Regior.
I. Tr-.is list is presented in order of priority.
Ground Water Protection - Ground water is one of New England's greatest natural
resources. This rich resource supplies drinVing water to approximately 20% of our
j.^pulo'-ior. and fully three-fourths of our conounity water systems rely on ground
water.
Yet, our ground water is in peril - threatened by a variety of contamination
sources, including leaking underground storage tanks, pesticides residues, surface
iir.pDur.d.Tients and leachate from landfills.
T-7 = *.?r. Harbor - Current sewer discharges from 43 Massachusetts cities and towr.s
throughout the Metropolitan District Commission's Boston Harbor facilities create
the most serious water pollution problem in New England. The discharges regularly
close beaches, cause disease in fish and other organisms and threaten the public
health.
Boston Harbor is a great public resource. We cannot allow its use as a public
sewer to continue. In the next twelve months, the "Year of Decision", we and the
Coirjnor.wealth of Massachusetts will maVe a series of critical decisions that will
determine the fate of this resource for'the long term.
Toxic Substances - Complex toxic pollutants in the air, water and land has become
a serious national challenge. Exposure to toxic substances can cause serious
health effects and long term environmental damage.
Public apprehension over toxic substances stems from the our inability to adequate-
ly assess health implications associated with exposure to low levels of contaminant:
and awareness that many of these substances are suspected carcinogens.
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Lor.g-Kanoe Transport; Reid Rain and Ozone -
AcidJRain - Long-range transport of acidic deposition is contributing to aquatic
and forest changes throughout New England. The three northern New England
states are most threatened by this phenomena because of geologic characteristics
which cannot effectively neutralize the acidity in the deposition.
The New"England environmental community, states, news media and general public
have a heightened awareness of the problem, and are deeply convinced that touch
action to reduce emzj.ssi.on levels is essential to the solution of this problem.
Ozone - Hew England has the nation's second most severe problem of elevated
episodes of czor.e. Jr. 1953, Cor.necticut, where the protlem is most severe,
suffered through 46 days when the ozone level exceeded the standard. Solutior.
to the region's ozone problem will require inter-state and inter-regional
cooperation since emissions from the Vashington-Philadelphia-Sew York corridor
cotriine with local em.r.issions to form our ozone hazards.
Key Bedford Harbor - The inter-media nature of the problems that we face at Suner-
fund sites has led to the development and coordination of inter-prograir. responses.
The Nev Bedford Harbor site is an excellent example of a multi-media problem that
requires integrated technical, public interest and management responses.
Nev Bedford Harbor and the surrounding environment is extensively contaminated
with PCEs. The presence of PCBs and heavy metals in the Harbor has lead to great
concern for public health, fishing bans and closing of large commerical fishing
areas, and loss or delay in the development of the Harbor's tremendous recreational
a:-.d economic potential.
HazaieouE Waste Management Facility Permitting and Comp lice - The issuance of
Resource Conservation and Recovery Act permits to treatment, storage and disposal
facilities is a high priority for Region I and the New England states. Failure to
call for'permit applications and issue permits unnecessarily endangers ground
water, soil and human health.
Asbestos and Public Health - Much of the building stock in New England is old and
ir.ar.y of our schools and public buildings contain asbestos insulation and/or decora-
tion. Our greatest environmental and public health concern centers on renovation
and demolition, because much of the work being conducted is in violation of one or
more provisions of NESHAP. and the risk of human exposure is thereby significantly
increased. Since asbestos is a known human carcinogen with no known safe level of
exposure, our concern is considerable.
Nationaj Municipal Strategy - Region I is aggressively pursuing major enforceir.er.t
actions to improve municipal compliance rates, construction of needed wastewater
treatment plants and implementation of a regional pretr eatment program. Our
goal is to achieve marked improvement in water quality across New England, espe-
cially along the coast.
Marine Water O.ua5_itj£ - Outer Continental Shelf oil exploration on George's Bank.
dredging of waterways in southern New England and the cumulative effect of lono-
term point and non-point source discharges to our estuaries are New England's
greatest marine water quality concerns.
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In vne next year, we will focus our efforts on five of the highest priority marine
ar-ri estuarine resources in the northeast United States - Boston Harbor, New Bedford
Harbor, Narragansett Bay, Buzzards Bay and Long Island Sound.
K^r.-rcint Source Pol lution/Confined Sewer Overflows - The New England environment
is confionted by every forir. of non-point source pollution. Urban runoff, improper
construction practices, on-site waste disposal systems, agricultural activities
a-= forest.- management activities all contribute to serious cumulative imparts or.
o.^r environmental resources.
r~**Mr!ed sewer overflows froir. major city and small town sewer systems result in
significant discharges of untreated wastewater during periods of wet weather.
rr e— jer.'ly, coriined sewer overflows result in the closing of shellfish harvesting
areas and inhibit the 'complete cleanup of important rivers.
B. w^'IOSM. ACCO.PZ.lSHy.ENTS
We are proud of our accomplishments over the past year in Region I. You will soon
rereive a Region I publication disrussir.g Region I's achievements in greater
detail thar, is possible here. What follows are a few highlights selected froir. that
dorument.
r
Zr.T cr cer.ent has been our nuri>er one priority in Region I. Over the past year we
to-_-V. more than 250 formal enforcement actions, including notices of violation,
-'etrative orders and penalty assessments, and civil and criminal court cases.
Some results of these vigorous enforcement efforts are:
o TVS hundred tons daily of sewage sludge are no longer being dumped into Saler.
Harbor.
o Residents of Canob Park in Richmond, Rhode Island, have clean drinking water
today instead of water contaminated with service station gasoline.
o School systems and communities in New England are newly attentive to their
responsiblity to protect school children froir. asbestos, after Region I assessed
the nation's first civil penalties for violations of the asbestos-in-schocl
regulations.
o Fegaon I prepared the first federal criminal environmental case filed in
Massachusetts in the past ten years. The case involved violations of PCB
rules and falsification of information reported to EPA. The company entered
a plea of guilty in May of this year.
o The nation's first Superfund liability trial against seventeen defendants
continues in U.S. District Court in Concord, New Hampshire.
o Federal judges approved an EPA proposal that a portion of a large civil
penalty assessed against the City of Providence for air and water pollution
violations be used to fund an environmental health study that will benefit
the people of Rhode Island.
The pace of these and other enforcement efforts in this Region means that by the end
of the year Region I will have achieved the highest level of enforcement actions in
its history.
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Our record on the program side is one we're also very proud of. A few of our accom-
plishments over the past year are outlined below.
o To date, we have put over $50 million of Superfund money to work to clean up
Ney Encland's abandoned and! uncontrolled hazardous waste sites.
o We have spent more than $150. million to help local governments across New .
England improve surface water quality conditions through the construction
of wastewater treatment plants.
o Our six New England states are in the vanguard in developing groundwater pro-
tection strategies and were instrumental in the development of EPA's ground-
water prliry. Kerion 1 has actively supported state efforts in this area
through its program grants, training sessions and pioneering efforts in
er.erginc national issues, such as the control of leaking underground storage
tanks.
o New automobile inspection and maintenance programs are in place in Connecti-
cut ar.fi Massachusetts, the result of EPA-state cooperation.
o We reestablished relationships with our various constituencies in New England,
meeting with the Congressional delegations, the governors, state environmental .
directors, the press media, and environmental and industry and business
groups to heighten public awareness of the environmental issues facing this
Kegior., and to er,co\^rage widespread participation in solving then.
We have not lacV.ef environmental challenges, and we have working on behalf of the
New England environment a group of highly competent, dedicated and able professionals
A significant increase in our resources this year enabled us to hire a number of
well-trained engineers, scientists and attorneys at the staff level. We were also
able to bring or. several outstanding individuals to fill key policy positions;
these individuals complete our senior staff and add new strength and experience to
the senior management team.
C. EMERGING ENVIRONMENTAL PROBLEMS
We are conw.'itted to looking ahead, interpreting current trends to identify new
probler.s before they are widely known. Dartmouth College, funded by EPA, will
complete in October an assessment of how demographic, economic and social forces
in New England will affect our Region's environment in the next decade. For exar.rle.
a growing population, principally in rural areas and small towns, and a flourishing
economy confined to create emerging envirorunental problems that the Agency should
begin to address now. What follows is a brief description of some of the issues
that we are most concerned with.
• New Englandf-rs are very concerned with the growing effects of pesticides use and
its impacts on human health as it percolates Into the ground water that we drink
and drifts along in the air we breathe. Pesticides application,.designed to con-
trol one dimension of our environment, is spilling over into others. As a
result, our concern for the complex and confusing problem of pesticides contam-
ination is increasing.
• As we tighten our homes to make them more energy efficient and convert more home
heating systems to wood and coal, we are asking questions about the quality of our
indoor air.environments. We spend most of our time indoors, where air quality is
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frerurntly lower than outside - what long-term health effects does this hold?
What are the appropriate policy alternatives?
• The expar.dir.g hig>.-technology economy of Sew England prompts concern over the
direct and indirect environmental and public health impacts of-these industries.
How will planned releases of new genetically engineered organisms effect put-lie
health and how are exotic chemicals used in the r.esearch and production of high-
tec^, ology' components effecting our environment?
Tr.e horizon of emerging environmental and public health problems is expanding as
fast as our curiosity and ability to consider their existence grows. EPA should
invest time and effort now to discover these problems, exploring their consequences
ar.i debating alterr.at.ive policy responses. All the while, however, we car.n-t. ICE*
sight of the older problems already stacked hi-gh.on our plate.
Tr.is Environmental Management Report communicates not only our. perception of the
most significant environmental problems facing New Englanders but it also carries
a comr.itment by Region I staff to take actions to address these problems. In
t'r.at sense, the EV.K describes Region I's vision for fulfilling our part of the
fcaer.rv's mission to orotect the nation's environment.
Michael K. Deland
*•»•*: orB3 Ai-ir.istrator
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Fart II. Recior^l Envirornental Problens
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Region I
Issue ti
GKX2O VRTER PROTECTION
I. PKJ3LE.M STATEMENT
J^prox irately 20% of New England's population (nearly 3 million
people) depend on ground water as their sole source of water supply.
.Kcreover, 2,026 corrr.ruty water systens (77%) utilize ground or
. er the past 10 years
there has been steadily mounting evidence that New England's shallow
f*Tjifiers are vulnerah'le to contamination fror, a variety of sources.
These include: uncontrolled hazardous waste sites, landfills and
surf are irpo;rv3-«nts (s-cne of wh.ich have already beccne Superfund
sites), pesticides, and le^.ing undergrDiind storage tarte ILL1?!).
SLE.X ASSS55KZ2.T
c.
Be eke round; New England has soil types especially susceptible to
the leacr.ins of cor.ta.-.inants through the surficial geology to the
bedrock layer. The soil tends to have high penneability. This
cojpled with the generally high ground water table, allows foreign
n=t£rials sjch as spent solvents, pesticide residje, and petroleur.
procjcts to q-jickly penetrate the soil layer and reach the ground
*--=ter. In the case of uncontrolled hazardous waste sites, the
wastes were disposed of improperly. With, pesticide residues however,
the the way in which the pesticides were applied were, in most
cases, proper. Leaking underground gasoline storage tanks result
prir.arily frcr, the installation of bare steel tanks, unprotected
asainst corrosion, fifteen or irore years ago. The er>=rging probler;
of leakage fron landfills and surface inpoundnents , regulated under
the RCSA statute, are primarily due to siting without taking ground
water into consideration, and inproper design. Many landfills have
accepted hazardc>js waste fror, sr.all quantity generators in the past.
In addition, ccroercial and household wastes often contain s~all
quantities of hazardous raterials which, in aggregate, can be signi-
ficant. This presents a special probleri for the Agency because
ur.der R2?A subtitle "D", landfills are controlled by the States, not
ETA, and the States in genera] do not have the resources to urviertake
an effective regulatory process.
b. GeoprapMc Score: Ground Water contaninat ion is a Rc^ionwide
Existing arc potential prot'ltsr. with conta-.inat ion frcn hazardous
wastes apjx-ars to be nost dcir.inent in tossachuseits and Coanecticut
(practically all the land disposal syslerx in New England are in
ticse two states). Connc-cticut , Ksine, Knswichivsetts and Rhode
Island have had i>roblwns with pesticide residue, and fV^ine, based on
prelir\inftry infoi-rr^tion, apfoars to have the nost far-reaching
threats of contami nation frcn lea>dng storage tanks.
Major Injects Oontaninants will render both current And potential
^oufoi-s of dr'nking water uniotable. In avVMtion, health risks fror.
Ufc toxicit of these cont A-^inants ray cause a seven? ini-oct on the
toxicity of these cont A-^inants ray cause a seven? ini-oct on the
condition.
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d. Public Concern; Public concern is very high fron the health-related
aspect of this problen.
e. Ksjor Sources; Unprotected steel gasoline tanks belonging to either
ncjor oil ccrpanies, sr.all oil ccr.panies or individual station
owners; potato fields and tabaceo fields; lagoons; landfills;
drons/tanks; piles; sludges; leachfields.
•
f. CDntar.ina.-its of Concern; Benzene, ethylbenzene, toluene and xylene
(tarv:s); ajdicarb, ethylene dibror.ide (Q2) and carbonfaron (pesticides);
volatiles, heavy metals, PCB's and sludges/oils (surface inpoundrier.ts,
landfills, druns/tanXs sludges, leachfields).
g. Expected Er.virorr.ental Results; Protection of current arc pot.er.ticl
sources of drinking water supply, as well as ecologically vital ground
waters.
III. REGION AGEN1A
a. Past Res?or.ses;
• Active coordination with the New England Interstate Water Pollution
Cor.trol Ccrr.ission to brine the various states together and create
a forjT: for technical and regulatory discussions.
• Fomation of an interdivisional L.U.S.T. ccrr.ittee to collect and
sh^re ir.forration and assist the region and states in forr.jlating
L.U.S.T policy.
e Investigation b-y regional laboratory personnel into neans of
detecting leaking anoerground storage tanks.
• Verified selected positive sanples frcr, pesticide residues.
• Supported state activities by supplying technical background on
toxicological and health effects frcn pesticides.
• Supported state activities by providing infornation on treatment
techniq'jc-s, recent pilot studies, and national incidents of pesticide
corita~:ination.
• Initiated a pesticide sanpling prcyrar. at 50 sites in the Connecticut
River Valley assessing the extent of contar.ination and the
total population impacted.
• Surface Impoundment Asessnent inventoried inpr»urkt>?nts and assessed
ir potential to oontenr.inate ground water (late 1970's).
Inventory conducted in the late 1970's.
• Established the Office of Ground Water Protection to txonJinate the
several ground water prograns within EPA's stalutoiy e-.'thority.
• Included ground water protection as an issue in each Now England State
Statc-EPA Agreenent.
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• Establish the Regional Ground Water Steering Garr^tee to develop
overall policy and oversee the Ground Water Office
• Ground water contamination plumes studied at more than half of the
National Priority List sites.
• A 20-acre slurry wall and clay cap installed at the Sylvester site
'•in Nashua, New Ha-rpshire to lijr.it further ground water contar.ination.
• A 9-s^jare ir.ile hydrogeblogic study of Wbbum, Massachusetts
assessed the conta-.ination of an aquifer which once supplied two
IT,ajor municipal wells; feasibility studies on aquifer restoration
are underway.
b. Reromgnded Regional Actions;
e Develop detection technique for leaking tanks currently being
investigated by the Regional lab, and utilize in actual field
cases; this will uncover current problems and may be used by the
states or. a wider scale; no state involvement during developr^ent
stage; finalize results try Sunnier, 1985.
e Continue to provide a source of information for the states in
their regulatory developrent; this will facilitate control progrars
at the State level; ongoing.
0 Investigate and develop new data and information on underground
storage tanks; work directly with states in ongoing effort.
0 Present a L.U.S.T. technical conference to apprise all interested
parties, including states, of the current technology available to
help monitor the problem; ccrplete within next six months.
* Provide oversight of significant agricultural pesticide
use and coordinate findings with other regional programs;
this will help identify pesticide residue problens unique
to the region and provide data useful to the registration
process; the stales will be active in this effort by providing
inforr^tion; conduct during FY-1985.
c Develop policy to provide technical assistance and e-nergency
response measures in support of state actions involving pesticide
contaminated public water supplies; this will aid the states in
decisions involving the closing of .wells and the establish-
ment of esTt-rgency procedures; develop during FY-1985.
• Assure that the Region develops effective coordinating procedures for
ground water management.
0 Assure that the States also develop effective coordinating
for ground water
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c. Barriers to Qverccne;
0 Lack of comprehensive regional data on the number and age
of underground storage tanks.
0 The trer^endous costs to the oil corpanies to rectify the
problem, and the possibility of passing these costs on to
• -.consjriers.
• Utilization of existing pesticide enforcement laboratories would
sigr.if icantly reduce the start up costs associated with a ittsjor
monitoring effort.
c Recognition that pesticide residue monitoring should be assignee a
mjch higher priority than in the past.
e Resources needed to develop and inplement a National Konitoring
Plan (NVJ3), which would provide baseline data to assess enviromental
results, are unavailable. In addition, state funding to support
the state/federal partnership in ir£ler*nting the NM? is not
available.
e Widespread lack of understanding of clean-up technologies and the
de;ree of clearr-up attainable in aquifer restoration program.
e Deta currently available on health effects of nany hazardous
co-pounds is insufficient to set standards for clean-up and aquifer
restoration.
c The public does not trust government's ability to establish "hcv clean
is clean" criteria.
• At present, there is virtually no EPA oversight or financial support
of State Solid Waste Programs; the effect is that rost landfills
in New England will continue to pose a threat to ground water quality.
IV. HLIDPJASTERS ACTIONS NEEDED
c Develop a Ojality Assurance/C^jality Control and effectiveness evaluation of
present rr-ethods for testing underground storage tanks. (Office cf Toxic
Substances)
• Select a contact in Washington who. can relay current Headquarters and
Congressional positions and policies on L.U.S.T. to the Regional Offices.
(Office of Ground Water Protection)
• Develop a methodology for gaining information from the private sector
on tanks, leaks, removals, and abandonrwnts. (Office of Tfcxic Substances
and Office of Ground Water Protection)
• Designate a central clearinghouse (i.e. ccuputer information system.) for
collecting and sonriarizing existing data and statistics o" underground
storage tanks. (Office of Ground Water Pi election)
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c Develop a model cost and manpower needs to urplement effective underground
storage tank regulatory programs at the state and regional levels.
(Office of Ground Water Protection)
• Support residue monitoring of pesticides that are likely to migrate to
gr:>jndw3t.er supplies. Soil and elliptic conditions favorable to pesticide
residue and accumulation migration, especially for degradation-resistant
* pesticides, should be considered. (Office of Pesticides Programs)
• Ap.en: labels or cancel uses when monitoring data and/or experimentation
indicate ground water contamination fror, pesticides. (Office of Pesticides
Programs)
0 Develop policy regarding the types of control Treasures necessary to
ir.it igate the risks frcr. pesticide leaching. Also, develop a plan on
how to iir.plen>ent various control measures, (office of Pesticide Prograr-s
and Office of Ground Water Protection)
c Conduct a National Monitoring Program to help define the extent and
nature of the pesticide program. (Office of Pesticide Program)
0 Develop health advisories and/or Drinking Water Standards for use by
E?.-. aro the states in responding to cor.ta-r.ination incidents. (Office of
Drinking Water)
• Ensure that resources are available to cor^lete the work of the
Headquarters task force to evaluate the environmental ijnpacts of non-
r.arardojs waste nanagerient facilities; ccrplete by the end of FY-1985.
(Office of Sclid Waste)
c Aggressively pursue research into health and environmental ir-pacts of
the hazardous wastes most ccrronly found in ground water (usually volatile
organics). (Office of Research and Development)
* Establish criteria on levels of contaminants in ground water which
should trigger Superfund involverent. (Office of Drinking Water)
• Develop a national inventory of types of contaminants found in ground
water shojld also be established and priority ccnpounds identified.
(Office of Research and Eevelopnent)
c Establish a national technology transfer progra-r for ground water
investigation and restoration. (Office of Research and Development)
0 Revise policies, guidelines and re-gulations to reflect the use of the
ground water strategy to manage progra-ns and establish priorities.
Issue Co-ordinal or: Bruce Rosinoff
(8-223-3981) Water Kanagcsnent Division
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Region I
Issue «2
BG6TCI; HASBOK
I. PFD31EM SIATEHSNT
The vater quality- of Bc» ton Barter is degraded by the daily discharge of
600 r.illior. gallons of wastewater and 2500 wet tons of sludge frori the
Metropolitan District Ccnr.ission's (KX's) two wastevater treatnent plar.ts
which often fail to meet NPDES permit conditions. In addition, the
• ccriin.ed sewer syster. overf lovs discharge untreated wastewater at sane
' 110 locations along the Harbor's edge to create serious near shore
environmental and health problems.
II. PROBLEM ASSESS!^*!
a. Be cV. ground - The KX is a Massachusetts state agency that provides
wastewater collection and treatnent to 43 greater Boston corrur.i-
ties with a ser\'ice pop'olation of over 2 million or about 40% of
the total state popjlation. It operates two oot-roded, overloaded
prirary treatment plants (Nut Island — 1952 and Deer Island — 196B)
and tvo Coriined Se-^er Overflov (CSO) treatnent facilities (Cottage
Farr- — 1971 and Prison Point — 19E1). Historically, the agency has
been underfunded and understaffed, conditions which have consistently
cor.tribjtec to operational problera experienced at the facilities.
b. Geographic Scope - The treatnent plant and sludge discharges have
an ir^ert on the water quality of the harbor and in the vicinity
of the islands in the harbor which are being proposed as a Boston
Harbor Islands State Park. The CSO discharges ir^pact the entire
near shore area frcr. the Town of Vfinthrop to the north to the
City of Quincy to the Sojth and the city beaches.
c. Kcjor Irpacts - Tne discharge of inaSequately treated wastewater
frcr. the "treatnent facilities and untreated wastevater frcr, the
CSO's are aesthetically offensive, create a risk to the public
health, result in periods of closed sviiming beaches during the
recreational bathing season, closed shellfish harvesting areas
and potential environmental da-age to the aquatic environment.
Direct contact with the conteninated waters can result in a
variety of illnesses attributable to waterborne oganisrs, eye
arv: ear infections and a general feeling of disccr.fort. Con-
sjr.pt ion of cor,tci-.inatc is onxised
to treatment facilities at Deer Island ard o^xiccs any expansion
or ui»jre>f?ing of that facility. The residents also cyrose the
construction of slurtje incineration facilities at D»-cr Island.
Tlie rc-sitk-nts of the City of Qmncy object to any cxi\insion of
tie Nut Island trtaUTH.-nt facility.
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Among the options being evaluated in upgrading the KDC's treatment
facilities is locating treatment works on Long Island which is
owned by the City of Boston. TTie City Administration has voiced
its objection to the use of Long Island for wastewater treatment
facilities. Notwithstanding the opposition to the various options,
the residents of the ccrrvunities bordering the harbor aggressively
see>: the abatement of pollution in the harbor.
Or. the other hand, residents of the inland ecmunities served by
the KX, while sympathetic to the harbor cleanup, strongly oppose
needec increases in user charges and the assessrient of a share of
the capital cost for construction of upgraded and new treatment
facilities.
Public participation in the Boston Harbor cleanup effort has been
intense with many public meetings scheduled and scne 15 advisory
groups and carrr.ittees meeting on different issues involved in
correcting the Boston Harbor problens.
e. tejcr Scorces - T^ie most significant sources of the protler, are the
discharge of sludge an3 inadequately treated wastewater frcr the
two treatment facilities and the untreated discharges frcr. the CSOs.
A considerable portion of the overload to the syster-. is attribjted
to high infiltration./ inflow into the sewerage syster. which, especially
during rainy weather, res-jits in loads exceeding the capacity of the
trestr>ent works.
Past studies have indicated that 34 CSOs discharge continually.
These discharges are generally due to sewer blockages, accxrulated
sedinents within the pipes which reduce their capacity, improperly
functioning regulators within the syster. and tidegate failures.
f. Co-nta-inants of Concern - Ihe pollutants in the discharges to
Boston Harbor include total and fecal colifom bacteria, floating
materials, oil, grease, suspended and settleable solids, bio-
cher.icol oxygen demand, nutrients, PCBs and heavy metals.
g. Expected Environnc-ntal Results - Correction of the problens contrib-
utir»g"to"p6l"lution of the'harbor will result in improved aesthetics
of the harbor and of all the beaches in the area, reduce beach clos-
ings frcr, once or twice a week to once per bathing season, possibly
allow reojjening of closed shellf ashing areas, irprove water quality
wMrh would reduce risks to the public health, improve the quality
of t)»e fish and increase the rc-creat ional potential of the harbor,
its beaches and the proposed Boston Harbor I si amis State Park.
III. REGIONAL AGENT*
a . Past Pfrsjonses
• Six EPA M-iinistrative On^re have been issuod since August 8,
1980.
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0 Ccrfletion of a Draft Environmental Irpact Statenent (DEIS) in 1976
on the Upgrading of the Boston Metropolitan Area Sewerage Systen.
The reccmendations were controversial and led to the preparation
of a Supplemental DEIS (SDEIS).
0 Completion of a Sludge Managenent EIS by EPA in 1979 and issuance
of a Record of Decision in 1980 directing continued environmental
evaluation of sludge incineration and exa-.ining further the
feasibility of composting.
• Issuance by the KDC of a Sludge Management Update Report in 19E2
focusing on alternate disposal methods of composting, incinera-
tion anc ooea.-. disposal.
• Irplerentation by the MX in 1983 of the ijmediate upgrade of thc-
Deer Island and Nut Island facilities to correct chronic opera-
tional problens.
0 Initiation of corrective measures in 1963 by the MDC and the
Boston Water and Sewer Ccrr.ission on priority CSO projects.
* The filing of a lawsuit in 19E3 by EPA against the KDC for viola-
tions of monitoring and reporting reouirenents. The case was
settled with the MDC agreeing to ocrply with the monitoring and
reporting recrjirerents and paying a civil penalty of $15,000.
* Institution of a lawsuit in 1983 by the City of Quincy against
the KDC because of pollution of Quincy Bay by the Nut Island
Treatr^nt Plant. EPA has participated in this suit in a
"friend of the court status." .The court has issued a ruling
outlining a 10-year plan to clean up the harbor.
e Institution of a separate lawsuit in 1983 by the Conservation Law
Foundation against EPA, the MDC and the Massachusetts Division of
Water Pollution Control (DKPC) alleging deficiencies in required
administrative and regulatory reviews. This legal suit has been
stayed.
e EPA issuance in June 19B3 of a .tentative decision denying an KDC
application for a waiver frcn secondary treatment requir orients
under Section 301(h) of the Clean Water Act.
e MDC sulr.ission in June 1984 of an application for EPA reconsidera-
tion of the 301(h) waiver based on a reexanination of the water-
quality impacts which led to the denial.
• Issuance in June 1984 by the Ccrnonwealth of Massachusetts of a
Sli>3gc- Managtarent Strategy listing ccnijostiny as the preferred
option with ocean disposal and incineration as the secoivi and
third preferences, respectively.
• Ccripletion in October 1984 of the SDF.IS on site options for the
Ujjyrafling of the Boston Mvt-iopolit-an Area Sc-wci ajc Systtsn to
supplement the DEIS issued in 197B.
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• Continuation by the MX of facilities planning development and
prosecution of design for Deer Island and Nut Island facilities,
relief sewers, pur.p stations and interceptors and CSO facilities.
0 Suhr.issiop. of legislation to the State Legislature by the
' •• Governor of the Comonwealth of Massachusetts creating a Metro-
politan Water Resources Authority' having the responsibility of
providing water supply services and sewage collection treatment
and disposal services to the cities and towns now served by the
MDC.
* Other Studies by the Department of Environmental Quality Engineer-
ing (DDQE) and the MDC address:
- The feasibility of reducing the anoint of infiltration inflow
into the MDC's sewer systars.
- Develocnent of incentives to encourage MDC neriber oorrvonities
to recjce their flows to the treatment systems.
- Staffing and financial structures to deterr.ine the MDC's ability
to operate and rar.age the wastewater collection and treatrent
syster.s.
- Existing and needed rate structures for adequately financing the
corist ruction, operation, r^intenance and future replacer*ent of
the KDC's wastewster collection and treatment systens.
e Based on planning and design acccr.pl i shed to date, the approx irate
costs for the r^jor ccr.ponents of the harbor cleanup are:
Prir^ry/Ocean Discharge $660K
Secondary /Harbor Discharge S760K .
Sludge Managenent/Prijnary $ 67K
Sludge Ka-iageient/Secondary $107M
CSD Corrections $111M
Interceptors, I/I, Separations $577K
0 EPA has awarded $169 million in construction grants to the KDC for
planning, de-sign and construction of facilities which directly and
irdirectly relate to Boston Harbor.
b. Rr-cciTfrnded Rc^gional Actions
0 Sch»c-dule public hearings in Novenher 19S4 on the SnriS with final
decisions r.a.^e in Mnrch 1985. TCiis action will result in EPA
identifying sites for the MDC's wastewater treatment facilities
wtiicli will have the least inverse enviromental
• Evaluate the MDC's resulrntted 301 (h) waiver applicat'or. with a
final decision made in Mnrch 1985. n>is dt-cision will determine
the level of trealjnent re*^uired for the MOC's waste-water facility.
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0 Require implementation by the MX of interim sluc3ge disposal
approaches to terminate the existing sludge discharge to Boston
Harbor. lY.is action would eliminate a source of pollution to
the harbor and result in improved water quality.
•••Require implementation by the KX of a perranent long-range solu-
tion to the disposal of sludge generated by he hDC's wastevater
treatrent facility.
• Preparation of the sludge jnanagement EIS in cooperation with the
KDT arc con currently with prose-cot ion of the cor.post marketability
study and preparation of the facilities plan for sludge niar,age-
ment facilities.
0 Develop a revised legally enforceable schedule reflecting final
EIS and 301(h) decisions as well as actions necessary for the
ultirate elimination of pollution fror, Boston Harbor.
e Continue to track hOC progress and ccmunicate problems on a
recjlar basis to senior na.-.aaenent to assure ccr.pliance with
established schedjles.
e Continue the timely processing of required EPA actions related
to the award of construction grants, and other Clear. Water Act
rec'-irerients, for Boston Harbor related projects.
c. Barriers to Cverccne
e State construction grant allotnent inadeq-jate to cover hOC needs
in a timely fashion.
• Lack of EFA policy on ocean dor.ping of sludge.
* KX track record in operation and maintenance is weak.
6 The public and ir.any elected officials are unwilling to accept
ar,y i.-.ports associated with potential projects.
0 Resolution of CSG correction jurisdiction and responsibility
bc-twc-cn KDC and ineriaer camunities.
IV. HTADOUAW^RS ACT10TS NEEDED
• Issue a
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0 Expedite any needed concurrences on EPA's final decisions relative
to the KDC's 301(h) waiver reapplication. (OK)
•.Pursue regulatory reforms to address "big city"' finding problerss
. throogh tfe use of set aside or carryover acoour.ts. (OK)
Isc-je Coordinator: Alfred Pelcq-jin (223-3909) Water Ka.-agenent Division
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Region I
TOXICS Issue 13
I. Probler. Statement
Toxic Substances - The nost difficult problem, facing EPA and the states
todey involves toxic pollutants in air, land or water. Toxics includes a
vide range of substances that may cause health effects ranging frcr,
cancer to birth defects to nervous syster. disorders. Toxics can include
ccrron building iraterials such as asbestos, volatile solvents used for
cleaning, waste raterials durped into landfills and industrial discharges
pjrpe-5 into rivers.
Specific problems include: 1) addressing air toxics emissions, 2) reducing
toxic industrial discharges, 3) protecting underground sources of drinking
water frcn toxic contamination frcr. controlled and uncontrolled solid and
hazardous waste disposal sites, 4) identifying the risks of toxic substances
prior to their irarketing and abating risks of currently "in use" substances
such as those found in industrial or consumer products, 5) addressing
interrtedia contar-.ination probler= and 6) assessing and responding to
intermedia irparts frcr, toxics on huran health.
II. Procler Asses snents
Air - Few toxic pollutants are currently regulated by EPA. State agencies
in New England are developing guidelines for controlling hundreds of air
toxics. Currently, state programs address only six criteria pollutants
for which federally prcrulgatec standards exist. Cbnpounds that states
intend to regulate include heavy netals and organic compounds vhich may
be erdtted fron large industrial sojrces or sr.all sources such as dry
cleaners or degreasers. The need to aodress pjblic concern has been a
rejor factor in state agencies' decision to develop air toxics control
prograns. States need assistance in identifying and controlling sources
of air toxics.
Water - Toxic substances, primarily petals, have been discharged to New
England waters since the early days of the Industrial Revolution. Treat-
r-c-r.t processes have been developed to rertve these cher.icals, but even
industrial and nanicipal effluents treated to B&7 levels can cause toxicity
problems in the waters where they are discharged. This is pait icularly
true throjg>iout the New England states where plants have historically
located on sr-all sLrea-is with very little capacity for diluting the
vastes they receive. Tt»o effects of these toxic discharges can be seen
in the rcOu-x-d q-j*lity of downstream biological conunitics and elevated
levels of six-cific dicsr.icflls at potential drinking water intakes. Region
J has institutc-d a review of all NPDE5 pewits to ensure that water
quality standards in the receiving waters will not be violated. The goal
of the policy is to increase the nur^er of river miles which nc*t water
quality standards.
Drinking Water - The prohlein of toxic pollutants contwninatins drinking
water sources, particularly gixwnd water, is an existing anJ continuing
threat throuylout Nt» England. De-cause of the geological configuration,
ground water in Now Eiqland lies close to the surface, thus ir.aVing it
more susceptible to inlets frcm disjxTsal practices, laixMills, land
icat ions and discliarges.
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Ey exA~.ir.ing the documented contamination incidents, we find the majority
cf the affected areas are located in less densely populated areas (less
than SOD people per square mile), tony tines the severity of the contan-
innation is difficult to quantify because of two major reasons: one being
the fart that the contamination probler. often occurs in private systens
v.jich ctfc unregulated and secondly, even if the syster. was protected by
statutes i there is insufficient scientific data and knowledge to substan-
tiate the assessment.
'Since it is difficult to assess the health irplications of exposure to
lr.- le-'els of contar.inants, there exists a high level of public concern.
Another fact in heightening the level of public concern is that often the
co-.*_a- i-ar.ts are suspected carcinogens such as industrial solvents, e.g.
tetrarhloroethylene., dichloroethylene, and trichloroethylene.
Intermedia Toxics - Although the range of potentially toxic substances is
q-.-ite broaf, regulation of toxics as a whole involves sane curon probler.5
and uncertainties. Data needed to naXe good regulatory decisions is
often inconplete or rissing. Testing has been done for only a srall
r*1:- c*r-,tage of the estirated 60,000 cher.icals in the rarket place. Most
tests are based on aniral studies using high doses, and extrapolation to
hj-£r£ exposed to lev- doses is qjite corplex. Exposure assessments to
oetcrr.ine the s^ope of the affected population can be expensive and time
cc-vs.r.inc. Vital statistics that Treasure morbidity and mortality and
. i.-.w nc>ji(3 be used to do epideru'o logical studies are often inconplete or
risking. All of these problems and nore are comon in atterpts to under-
stand and ranage hj-an exposure to toxic pollutants.
Toxic Substance Control Act (TS2A) enacted in October of 1976 gave
E?A broaf powers to control the ranufacture and use of toxic substances.
Currently only polychlorinated biphenyls (PCBs) and chlorofluorocarbons
tCFC's) are ca-prehensively controlled. Asbestos reporting requirenents
have been imposed for schools. These are, of course just a few of the
rar.y toxic substances that have found their way into the environment
through norral use. tore controls are necessary. One of the rajor
proble-is in developing regulations to control the manufacture and use of
toxic substances is the availability of data to perform risX/benefit
analyses.
Interrt-dia problems are by their nature difficult to deal with. For
ex.ar^le, industrial donp sites ray be releasing toxics and coors to the
a-.Ment air; toxics ray also be leaching to groundwater and con ta-.ina ting
drinking water sullies. Air stripping to rercve toxic onjanic cher.icals
frcr. polluted water may be a source of anbient air toxic contar-ination.
All proyra". offices need to be aware of practices, regulations or clean-up
ntasures t>at ray be transferring a toxic problem from one pc\3ia to an-
other.
In addition, EPA's current organization nafces a thorough urtfcrs land ing
ard coordinAt«3 response to toxics difficult. Trtal hn-.vj cxiveure^to a
toxic pollutant is rarely consick-reJ. Statutes, rtyulations, organization,
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and grants were established to respond to problems in isolation frcr> each
other. Risk assessment and management have energed as tools that could be
used to create more consistent program, but they have not been used to a
great extent. Dealing with these uncertainties and cutting across these
boundaries to create a consistent and effective regulatory prograTi is a
major challenge facing EPA.
III. Regional Agervfa
a 5 Past Responses
Air:
• Participated in air toxics advisory corr.ittees in Massachusetts aid
Connecticut (ongoing)
• Sponsored a workshop on air toxics emissions inventories
• Conducted ambient nonitorinc at states' request
Water:
• Reviewed KPDE3 perr.its for preservation of water quality standards
in receiving waters (ongoing)
0 Developed acute toxicity testing policy for review of NPDES perr.its.
States participated in policy develop->«-.t througy-. New England Interstate
Water Pollution Control Corr.issior, (19E3)
DrinXing Water:
0 Maintained close ccrr.unication with the Waste Kanajenent Division
by establishing a merorandjr. of understanding to address o\'erlap?ing
activities (ongoing)
• Coordinated with state counterparts to establish a sir.ilar nerorandjr.
of unders tending
0 Providc-d health assessrer.ts arc advisories
Intemedia:
• Established a regional toxics coordinating corr.ittee to act as a
clearinghouse for multir»«3ia issues, to coordinate division activities
and to provide a foruri for identifying overlaps and resolving
inconsistencies
• Encouraged dovel current of an integrated environmental itvvi>3cnent
a-:. in Rvodc- Island
b) Reccnnended Regional Actions
Air:
• Provide sup-»rt for state air toxics projrans through risX asscss-»?nt
worV^>»cps, and air toxics monitoring suj^xsrt.
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e Increase ability to respond to air toxics health effects question.
v - *•«>»••
Tl.- .5;. •
• Develop a prograr. to attack problem of sedijnent conta-ination
•a.'»5 subsequent leading to the water colurvi.
• ... *
c Develop chronic toxicity testing
• Assess practical effectiveness of toxicity policies
• Deterr.ine effect of toxicity policy on affected strearis through work
of the states on field validation Drinking Water:
• Provide contaminated source treatment technical assistance
' Provide technical assistance for State Health Advisory Programs
0 Provide techr.ica! and resource support to states in gathering
information or, toxic substances
e Provide technical assistance to Superfund Endangement Assessnents
Intermedia:
e Strengthen the Regional Toxics Coordinating Corr.ittee with a rore
forral structure and nancate frcr. the Regional Adr.inistrator ar>d
Deputy Regional Adr-.inistrator
• Expand toxics integration and coordination efforts with state and
interstate agencies
• Develop a regional policy on risk assessment and risk management
• Give greater consideration to use of an intemedia envi-
ronn&nt&l r^nage.'^er.t approach in certain areas.
c) Barriers to Overcome
* Lack of resojroes, standards/guidelines and general
data continue to hinder resolution of toxics problens
• Lack of incentives for regional managers to consider
intern«3ia infracts and risk
• Current resistance anong divisions to coordinate where
intermedia effects exist
IV Ht-aa^uarters Actions Needed
Air:
• Provide Pinions and states with infornation on risk
assessment meUiodology and risk nana^»3-.fnt
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• Expand air toxics emissions factors program (QftQPS)
• Expand toxics monitor ing progran
0 Provide guidance on reducing toxic er.issions, including dioxin,
. r.^r-iripai resojrce recovery facilities (Q^OPS)
•
Water:
* Develop further criteria for vater toxics (Criteria and Standards
Division)-
e Develop sedirent criteria (Criteria and Standards Division)
• Develop standards for N?D£5 perr.it process to ensure consistent
procedure to draft acute and chronic effluent limits (OZ?, OURS)
e Develop guidelines for relationship between the arroont of toxicity
v* ich will still allow streams to meet a lover classification
(Onlr, .
Drinking Water:
* Provide resojrces for regional toxicoiogists to evaluate toxic
related health effects in every medium. Provide guidance on evaluating
health effects of ner.itored artient levels
0 Direct and/or sponsor research on the health effects of comonly
detected organics and their possible synergistic effects (DDK, OfO)
• Develop fe3eral regulations and/or guidance to control or elir.inate
orgar.ic contamination in drinking water (ODK: Criteria and Standards)
• Develop health advisories for derrval exposure to organic oonpoonds
in driaXing water used for bathing (CCK; Health Advisory Progra-)
Intermedia:
• Strengthen prograr. coordination in Headq'jarters
• Incorporate intermedia coordination in workload models and operating
guidance
• Develop a uniform approach to assessing multimedia problems IORD)
0 Develop controls on the irAnufacture and use of toxic substances via
TSCA St-ction 6 auttority (OTS)
Issu£_Coordinator: Karyaret McDonoughi Air Kvnagis^ent Division
(223-4B70)
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n I
Issue 14
LC*JG RA.'C£ TRAJJSPOKT - ACID RAIN
I. Procler. Title
•Acid Rain" is a tern used widely throughout New England to describe a set
of er.virornental probler.s of concern to the scientific ccmunity and the
purlic. Acidic deposition is contributing to aquatic and forest changes
throughout in New England. Although the Northeast is the most severely
?*f«>ct.e<3 area, the problem is national due to its long range transport
aspects, which are not addressed effectively under the state-specific,
artier.:. sta.-vSari's fra~»eworV. of the existing Clear. Air Act.
II. Probler, Assessment
A. Scope, Impacts, and Public Concern
"Arid Rain" is a hojsehold word throughout New England, and evidence is
proving that the wet and dry deposition of acidic materials is da-aging the
rec ion's enviroment. Scne lakes and streans are reaching pH (acidity)
levels that cannot support freshwater ecologies. Many aquatic ecosysters
are being threatened, especially in our three northern states, because much
cf our geology cannot effectively neutralize the acidity of deposited
- •'•* •»• and nitrogen oxides (50Xr NO*). Other dar.age has been monitored in
our forests, particularly at the higher elevations where airborne pollution
beccr~s acidic in clouds. EPA, the environmental camunity, and the public
ere worried because the relatively large changes in these norrially
stable environments nay be extrensly difficult to reverse.
Although the sr.all, airborne particles of acidic precursors can directly
iripeir'visibility, rost effects beccne apparent only after these materials
have ccrtined with water to becone sulfuric and nitric acids. Increased
vater acidity is known to cause material deterioration, such as rock weather
ing or materials da-age. It also increases the ability of ground water to
leach metals and other cher.icals frcn soils.
er the Clean Air Act, each state develops its own implementation plan
(SIP) to nc-et the national a-hient air quality standards for NOj^ and SC>2
set by EPA. For the most part, these SIP's have been adequate to r*?et the
« of the
SO^i unissions in New EnglaraJ. Of our six stMcs, only Veiront can attribute
more t>»an one third of its unissions to otlier miscellaneous sources. In
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Kassachusetts and Coanect icut , electric power stations account for more
than half the SOx inventory; area sources (principally cars) account for
more than half of the NOx inventory in every state.
Upwind states also contribute to acidic deposition. In 19B1, New England
sources er.i'tted less than 3% of the U.S. SOx and NI>x inventories (665,000 and
596,000 tor.s respectively). New York State's SOx emissions (1,035,000 tons)
'are greater than the emissions fror. all New England sources. She annjal SOx
inventories of several, individual, ir.idwestern states are ten times greater
than the New England state inventories. Baldwinville Station in Illinois
erittef over 253,020 tons of SOx *n 19E1* as did the four other electric
generation stations' ir. Ohio, Indiana, anc Illinois which rank in the top
five. In Indiana, coal-burning electric power stations contribute more
than 80% of the SO- emissions, 1.49 million tons out of a total of 1.84
Trillion tons.
(see attached charts)
C. Expected Enviromental Results
If anc when a.-. arid rain control plan is inplenented, sulfate and possibly
nitrate deposition will decrease, anc this should er.able our ecosystem to
stop acidifying and hopefully return to their natural state. The recreational
and ccmerciaa activities that depend on our forests and lakes, such as
fisheries, will no longer be in as much jeopardy. Acid rain controls would
also help solve other environmental problems such as visibility iripairnent
and a-~ier.t levels of fine particulates.
III. Recional Agenda
Because E?A does not believe that we know encogh about acid rain to propose
controls at this tine, najor research projects, like the National Acid
Precipitation Assessment Program (NAPAP), are studying the effects and
mechar.isrs of acid deposition. The Region participates in a national task
force that is studying the inplenentatior. issues which would arise under an
acid rain cor.trol program. Through the SLA's and KLSCAJ>:( we are working
with states in t.v«e region to characterize the probler:., anc coordinate the
exchange of inforr.at.ion, and enco.u-a-ge regional strategies.
a. Past Responses
Research
• LaV.e Survey -- Bc-cause we do not know the extent of the d00 lakes nation-
wide as or»e of the NAPW projects. Sax? 500 of those are located in New
England. Tltt: pilot proyracn for our laXcs was completed in June.
• Purest Research — Rc-seardiers have disixweivd t>v»t forest dictack is
occurring in the uppor elevation nounl^in forests of New FinjlAnd and
otlitr parts of the U.S. B<.-cajse UK-SO forests me often cloud -cove red,
enviroirental acidity levels are high. ILwver, the efft-cts of acid rain
on forests are difficult to isolate U.-MUSC of other d.f-wjc factors, e.g.
drought, disease, ozone, heavy metals such as lead.
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• Response Rate to Acidic Deposition -Lakes and their watersheds are
intercoanected through carp lex physical and biological 'systers. It way
not be the total acidic deposition that acidifies a particular lake
but an increase in the rate of deposition. If this direct response
r»:-rhar;isr. is accurate, we ray have scne tine before additional irreparable
harm will be done. On the other hand, if watersheds contain a lir.itec
arour.t of neutralizing capacity (buffering) and historical acidic
Deposition has depleted scne of that capacity, a delayed acidification
response could be triggered by continued deposition at the sane or
even lower rates. Scne of the N?*?«? laboratory and field studies are
trying to answer this question.
Task Force
• The Region participates in the national task foroe that is investigating
the irrlerentation issues associated with an air pollution control
prograr. that would track tons of SOj reduced.
* E?n's Task Force has prepared an outline and statenent of critical
prograr. issues that will be discussed with state agencies and the
public shortly.
• The outline and report of this Task Foroe planning work is being used
to set priorities for further efforts.
' Region I alsD participates in the local Acid Rain Task Force sponsored
by NESCA'JV. and NEIVJPCC, the Northeast air and water directors groups.
We report on research findings and ocryliance activities.
b. Reccmended Actions
• Continue to follow and report on the lake survey. Final Phase One
sampling will be conducted in October. A second phase of the lake
survey will sarple streams, soil, fish life, and other biota. The
results of this project will provide a basis for long terr. acid rain
monitoring stations.
• Continue to participate in studies to establish a dry deposition
iron i tor ing technique.
• Continue to participate on local and national task forces. Encourage
our regional groups to propose control strategy development studies
that can be forded by a ncv Congressional appreciation (52.6n) for
this purpose. Work on unission data bases and control strategies can
begin almost ir.ix'diately.
C. Barriers to Overcome
* Resources
• Interstate differences in program, politics, emissions an3
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• Uncertainty about da-rage causes and mechanises. Also, there are few
standard measurenent techniques or quality assurance procedures for
monitoring acidic deposition or its imparts.
TV*. -Headquarters Actions Needed
Continue full support of K^?A? projects, ensuring that adequate resources
are ccrr.itted to long-terr. research projects and environmental mor.itoring.
Tre OF.T arid rain bjdoet r.ust be fully funded and monitored.
* A monitoring methodology for dry deposition must be developed. Other
research results must be used to develop control plans.
0 EPA must use our regulatory review and approval experience to guide
program. plan-ing. Headquarters must assure efficient coordination of
acid-rain issues. Ine Office of Air and Radiation must continue to
analyze issues and control options.
9 E?A should taV.e irr-ediate steps to irprove the procedures for developing
e-issior. data beses and for ap?ro\'ing then.
* EPA should prcr^ide a fonrr: for discussion of strategies anc research
findings by different govemnent and industry1 groups.
0 E?A sho-old also enco-jxage regional strategies and innovative institutions
that co-jld iryler«nt control plans on a regional or national basis.
• OA?. nust na>.e state support and regional inplenentation assistance
available.
0 EPA shoold reccmend and unple-Tient an acid rain control prograrr. as soon
as possible.
lEEue Coordinator; Sarah Siron, Air Kanage-Tent Division
(223-4561)
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NEW ENGLAND S02 INVENTORY ;
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S02 EMISSIONS
CQ TOTAL
W
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Region I
Issue 14
LON3 JVJCE TRVEPOKT - OZQM: IN NEK ENGLAND
I. Procler Statener.t
Attainment of the one hour ozone standard (,12pjr.) continues to be one of
the nsjor enyiromer.tal probler.s here in New England. In Connecticut,
where the protler. is nost severe, there were 4€ days in 19E3 when the
'orone standard was exceeded and levels were recorded as high as .246 ppr:..
Ozone is forr*ec when volatile organic corpounds (VOC) and nitrogen
oxides (NOX) che-.ically react in the presence of sunlight. The reaction
tire varies, but usually it is on the order of 3 to 6 hours, and the peak
ozone levels occur anywhere frcr. 60 to 600 ir.iles fror. where the VOC and
NDj; originated. This transport phenomena ineans that emissions frcr. the
V; a= h in? ton/Pr.i la delphi a/New York corridor contribute, along with local
e-.issior.s, to ozone fomation in New England. As a result, New England
has the second nost severe ozone episodes in the nation.
33. Prowler assessment
T;J= ozorie standard is being violated essentially everywhere in the three
southerr. states of Connecticut, Massachusetts and Rhode Island. It is
also being violated in southern New Hanpshire and southern Kaine. Using
rs's. supplied by the Anerican Lang Association, EPA estirates there are
over 1.95 ir.illion people in these areas that are "at ris>:" when there
is an episode. The "at risk" group includes:
e infants less than 2 years old
c people with e-pheser^, bronc.w;itis or asthna
c people over age 65
The effects of ozone on hunans are well aocunented. Sane of the adverse
health synptons associated with ozone are: shortness of breath, coughing,
ryoVing, bumLng eyes, and redooed resistance to infection. Even in healthy
adults, high levels of ozone r-ake exercise difficult and scnetires irpos-
sible. Ozone is also responsible for reduoed growth in sere vegetation,
including crops, anc cracking in rubber products.
tost of the "at risk" pop-ilation is aware when t-here is an ozone procle-.
Tr,e nt-.-sr-^r^rs* raaio and TN all report when levels are expected to be
above the standard and warn the *at risk" group to stay indoors and do
r.inir^l exercise. During these high ozone periods, the frequency of
hospital erorgency visits for respiratory problems usually increases.
EPA has chosen to control ozone by focusing its attention on reducing VOC
uiissions. VOC emissions are about e^jxwlly split between irv^ustrial
sources ard robile sources (principally cars). 1^)e imlustrial sources
include Ue gasoline r.arVeting industry (from bulk tennirvals to gasoline
stations), coaling facilities (paper, fabric, metal, can, coil), chty.ical
nanufacturers, arri users of i'«grcasers and other solvents. ETA has
worV.cO with the stales to dexeloj) controls for over 25 categories of
irrfjstrial sources. A^ditior«ny, other sources which car.it o\-er 100 tons
per yoar are rc^uirc-d to reduce emissions Uirough the ivV^ition of control
equiprient or conversion to less polluting processes.
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Mobile sources are also being controlled. The Federal Motor Vehicle
Emission Control Progran has resulted in significant redactions in VOC
frar, new cars, while the Inspection and Maintenance programs in
Connecticut. Massachusetts and Rhode Island are designed to help insure -
that vehicle emission controls are maintained in good working order.
However, there have been problers getting sources to ccr.ply with existing
.regulations, ana there are people who are tar.pering with their autonobile
er.ission control devices. For exar'ple, just two tank fulls of leaded
gasoline will poison the catalyst in the catalytic converter and make it
ineffective.
Region I is in the process of transferring responsibility for the VOC
program frcr. the planning stage to the inplenentation and enforcenent
stage. Once EPA has established a strong ccnpliance program with .the New
England states, we expect to see the VOC emission levels reduced to the
levels projected in the attainment plans, and we expect ozone levels to
drop belov the standard. However, that goal is still several years away.
III. Regional Agenda
• States have developed plans (SIPs) to attain reduce VOC er.issions
e E?A has worked with states to develop SIPs and to approve SIPs
• Region has initiated a Task Force to identify and resolve problems
related to irplenentation of the Stationary scarce control strategies
in SIPs.
The Task Force is developing an enforcertent strategy - the next step
is to to discuss possible strategies with the State Air Directors.
• It will be several years before all sources must be in ccnpliance.
Kovever, there are over 50% of the sources which should be in ccr.pli-
ance now, and we hope to work with states to determine ccnpliance. We
are planning a series of workshops over the next year to train the in-
si>rctors on particular source category ccr.pliance inspection techniques.
1/K pragrar.s in Connecticut and Massachusetts are also an integral
pe>rt of the VCX reduction strategy and we are working with these states
to assess their prograns.
Headquarters Actions
Since ozone is a regional air pollution problem rather than a source-
sp»?cific problem, we have requested that hea&jiwrters continue to fund
the Northeast Corridor Regional MOoling Project (NKCR!*?) which was
designed to assess how the emissions fron tlx? entire East Coast are
interacting. Unfortunately, headquarters has infonrcd us they will not
provide this support.
Tne technical issues involved in determining compliance for each industrial
source are ecrplex and hoAVjiwrtei-s ncc-ds to continue to provide teclnical
assistance in UK.»SC deteiiriinations.
Issue Coprdiryitor: John Hani sen, Air ftvia-jjvnt Division
"" ..... (223-5130)
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Region 1
Issue « 5
KT.: BEDF3FC HAP33?.
Ir.pl enervation of the Superf und Progrer. will be a rrajor environmental issue
in FY36 ah3 following years frcn technical, enviromental and legal points
ot view. Iriplerentation of the program at the many eligible sites in
Roc i or. I will be ar. extraordinarily ccrjrlex undertaking, involving not
orly the Superfine Progra-. but also ii^ecting decisions and actions
undertaken by a niJ7,be r of other EFA nedia programs.
Such issues as CERCLA compliance with other enviromental statutes,
especially F3sA and implementation of the National Groundwater Strategy
will require much nore intensive multiprcgrar. involvement than in the
pest. EPA needs to develop the inter-program relationships to assure
CESJLA decisions reflect the view of our expertise in drinking water,
sir pcllutior, arc grants administration. Further, sites such as New
B-iford Ksrbcr which discharges to and ir.pacts Buzzards Bay, ray beccne
dirertly involved in general interest problers (e.g. the Congress ionally
r=-c5ted Bay study).
Of particular concern will be those sites at which EPA studies will be
csr-irludinc and decisions will be r.ade on the extent of rer»edy during
FYC6. In Recior, I we expect to be addressing 25 sites during that
period. TVie fol loving sites are exp&cted to be those for which decisions
or. extensive remedy will be rade during 1986:
Ct: Beacon Heights Kass: Charles George (final) Me: O'Connor
Kellog-Deering
Yaworski
Laurel Park
Old Southington
RI:' Davis
Sta~:ina Kills
Iron Horse Park
New Bedford (final)
Wells G fc H
Cannon - Bridgewater
Cannon - Plynouth
Silresim
Kes'terr, Sard (final) Vt: Springfield
Saco
NH: Dover
Sonersworth
Kearsarge
S. Kur.icipal
Tinkhan
Savage
Koefe
Tnere will continue to be a high level of public concern about the problens
at Suj-r-rf a-*3 sites and continued activity by citizen's groups designed to
both, -.stij^j] ate and encourage incrc-asod Agency activity in the clcan-up
and to provide public eanrents on prcvose>d clean-ups to the Agency.
In edition, iriplu-cntation of tJie cxj*-cted reautiioi iziation and great
exj^ansion of the Sui*rfund Progrcn will be otning into focus in fY86.
nore de-tailed df-scription which follows of New a^forf Harbor,
possibly one of the nost canplic«*l«3 Suix?rfund sites in the ccxintry,
illustrates Ute caiplexities and issues involved, and is presented to
illustrate the tyi*-s of problems that caji be expected to occur at a mnber
of other sites by tlje time 1986 arives.
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I. Probler Statenent
New Bedford Harbor arc the surrounding environment is extensively corjtar.irict.ee
with PCBs. Technically and environment ally the New Bedford situation is
extraordinarily ccrplex. K^ti-necia contamination and exposure pathways
include: ambient air; surface and ground-waters; soils; sediments; food chain;
and ind-jE trial plant sites. Nev Bedford is a National Priority List (NFL)
site for Superfunc action.
There is a high level of public concern with the probler., manifested by the
esuci-lishnent of several citizen groups created to focus public cements to
the Agency. There is consistently high attendance at public meetings and
the agency has received a large number of corrents fron the public on
proposed planning activities.
II. Prohler
Ear?', ground: Poly chlorine ted byphenyls (PCEs) were used by two electrical
Cbperitor F^e.-jfa-turers, the Aerovox Cor.pany and Cornel 1-Dubilier Incorporated,
in New Bedford, tessachusetts over a period of tine spaaning several decades
up until the late 1970's. As a result of poor disposal practices, PCB
contamination in the New Bedford area is widespread.
Upland sites of contar.ination include Sullivan's Ledge and the New Bedford
K-i-.icipsl Landfill, which received approximately 500,000 pounds of PCBs,
rainly as reject capacitors. PCBs were also directly discharged by the
ccrpariies to surface waters resulting in high concentrations of PCBs in
S€-fir>er,ts. Secinent concentrations in the Aerovox mudflats range frcr, 500
to over 1000 ppr., with a reported iriaxinin value of 190,000
Historically, the New Bedford Kastewater Treatment Facility received PCfc
conta-inated waste frcr. the ccrpanies via their wastewater discharges to
t-he plant. Currently, an estir.ated 200 to 700 pounds per year of PCBs are
being discJ.arged frcr, the Clark's point outfall because of residual con tar. i -
nation in the sc^er lines. An unXjiown additional anount is contributed
frcr. 27 ccrtined sewer o-v'erf lows which discharge to the Acushnet River and
Buzzards Bay. _
As a result of direct and irrfirect discharges of PCBs into the estuary,
elevated levels of PCBs in fish tissue have been xeixnted. This led to a
fishing Lan being imposed on over 18,000 acres of the harbor. The FXxx3 and
Drug A'l'.i nisi rat ion (FDM has set a max. unum limit of 5 pjr-, in fish for
hur-ian core u-ipt ion. Migratory fish taken frcn the an>a have levels as high
as 16 \>\r, ar*3 bottom feeding fish, excluding eels, up to 57 pjw. Lobster
sa-iples have been reported as high as 51 Pi^i in the ir\nor bailor. The
closing of large areas of cor.nercial fisheries has had an AlvciFe wipftct on
the local fishing industry. OUicr a^K-erse ijni>acts inclvx^c dolaying projv>sed
harbor develo^rient projects, delaying planned maintenance anJ develoii>?ntal
dredging projects, loss of recreational potential of the hfliior, arv! possible
public health ard welfare effects. TJx?re is also conoern for the presence
of hc-avy metal contaninants in the New Bi^foix! area. Although little is
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currently kr>^>— about their occurence and distribution, the history of
hea\y metals in the area parallels that of PCBs and will, therefore, be
included in future Superfund Investigations.
Past Responses:
f Negotiated a Consent Agreement with Cornel 1-Dubilier Electric (CDE) to
ta'-.e remedial actions at their facility. CDE has completed the major tasks
ojt-iinec in the Agreement.
• Negotiated a Consent Order with Aerovox Incorporated to characterize
deir site, suir.it a plan for on-site rer»edial actions, and ir.plenent the
plan. Aerovox has completed the onsite renedial activities.
e Conducted a cor.prehensive nulti-nedia field investigation in the New
5t-f ford ares to nore clearly delineate the probler. areas.
* Issued an Administrative Order to CDE to clear, out oor.tar.inated sewer
lines in the vicinity of their facilities.
" Issued ar: Administrative Order to the City of New Bedford to provide
technical assistance to CDE during the sewerline project for monitoring of
the effluent and sludge frcn the sewage plant for PCBs.
Expected Environmental Results:
A successful resolution of the problems in the New Bedford area will have
ir.ar.y positive effects on the area including:
0 Protecting the health and welfare of the public.
e The return of ccmercial fishing to scne of the PCB inpacted areas.
e Ccrrencing previously proposed r.a intenance anc developmental dredging
projects.
0 Restoration of the recreational potential of the harbor.
• Protecting the environn&nt of the New Bedford Karbor/Bazzards Bay syster..
i1 1 Regional Agenda/Act ions
• Finalized the RA'P in August, 1984.
• CcnpleU-d draft feasibility study for the Acushnet River Estuary Hot
Spot; rek-ased for public review in August, 19B4.
• Filed suit in Federal District Court against Potentially Re
Parties.
• Contiriue aggressive ongoing Co^nunity Relations Pixigi am Owst has
solicited input frcrri the public and also infoiTK«d them on present and
prcjosed activities. Initiated bilingual monthly fact sheet.
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• Continue operation aid develop-ent of data r.angenent"systeri developed
for New Bedford Harbor.
0 Massachusetts Departrient of Environmental O'Jslity Engineering (fo
DE£I) will continue to coordinate the actions of other state agencies
involved in the New Bedford cleanup.
0 MA DDQr will play a specific role in the selection of renecial
alternatives.
• Under the Superfund statute it is the states' responsibility to provide
the Agency with off-site disposal areas. The Agency is working closely
with the state to investigate potential off-site disposal areas. However,
to date no specific disposal sites have been selected.
Barriers to Cverccne:
• There could be significant political and corrunity relations problers
in selecting disposal sites for higMy contaminated dredge spoils, should
dredging beccne a selected renefial alternative. The MA DDQE has infernally
indicates that there are no acceptable upland disposal sites. The ccmur.ity
has expressed concern over the potential ij^pact of this problem.
0 Cost estir.ates for renedial actions for cleanup of Hot Spot areas of
the Harbor range fror. 525 - 80 million. Estirotes for the remainder of
the Harbor will likely be at least as high.
0 Tne problems of environmental complexity, tiding, and to scne extent
finding have been cverccne by dividing the area into specific sub-sites
which can be Independently jranaged. Each sub-site has milestones for
remedial investigatins, feasibility studies, ircplenentation and funding
allocation requests. While ccnpletion of all renedial actions taken
under this strategy will take several years, the agency will be able to
steady progress towards an overall "cleanup" of the area.
0 Althojgh EPA has taken the position that CERCLA actions do not req-jire ET
envirorrrmtal perr.its or EIS's, Ne-» Bedford Harbor actions could be 6"^er those pe-nrdt prograns. Such determinations
coold int&ct the tir.ing as well as the ultirate acceptance of the selected
action.
•The extensive- involvenent of other EPA prcgran offices may present institutional
barriers to rapid dtcision naking, to the extent that those prograns are
asked to concur in CEKCLA decisions.
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IV HcBJrjarters Actions Needed
Prcvide tvr-ical prograr. support for this Soperfund site. The Office of
Waste ?racra.-.E Enforcement coordinates enforcenent activities, anc the
Office of Brtergercy a.-v: Remedial Response provides prograr. guidance and
tt.-jj.ical support.
Re-gior. I will suirit to Headquarters the proposed Record of Decision afte:
fir,=liz£tion of the feasibility study for the Acroshnet River Estuary Hot
Spot. The Recion reqjests a reasonable turnaround tine frcr, Head^jarters
fo: 6 response or decision on the proposed Record of Decision.
Issje Coordinator: Gerard Sotolongo (223-1951), Kaste Karagnent Division
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fcecion 1
Issue t6
WASTE PER^TTING AND COMPLIANCE
A. Hazardous Waste Management Facility Perr.itting
IA. Problem Statenent
Beginning in FY-B2 Region I and the states in a cooperative effort formally
initiated calling hazardous waste facility Part "B" perr.it applications.
During FY-83 and 84 the states and Region I worked together to review
perr.it applications and point out deficiencies to applicants so that
ccr^lete applications could be developed. Also during FY-83 and FY-84
Region I authorized all of the six New England States to make perr.it deri-
sions in lieu of EPA while EPA provided technical support for the energinc
state perr.it program
IIA. Probler. Assessment
a. Background; The permit prograrr. was designed to first bring under regula-
tion"the nost environmentally significant facilities in the Region (ie
off-site commercial facilities, incinerators and land disposal facilities),
Because of the complexity of the facilities; the necessary learning
period for both the regulated can-unity and the regulators and the tine
necessary for development of inplenentation guidance in the fomative
years of the prograr, the issuance of perr.its has been a resource
intensive and difficult task.
b. Geocrsphic Scope; She greatest concentration of major facilities are
"locatecln"the"nore highly industrialized states of Coanecticut, Massa-
chusetts and Rhode Island. A high level of public concern is generated
by p&rr.it development activities for comercial facilities, incinerators
and landfills. Often the public's concerns are related to probler-iS
which cannot be directly addressed by EPA RCRA regulations such as
location, traffic patterns, air enission standards and regulation of
recycling or Connercial processes.
c. Major Irpacts; Of prinary concern to the Region and the state agencies
"Is the aSa*. (-rent of or corrective action of ground water contar.inatior.
thru tJ-ie application of technical stark3a:-ds via the pei-it requirements.
In this area of concern the lack of groand water nonitoring data and
poor quality of the data that has been generated has ha,-perec5 our efforts
to identify and solve problens.
IIIA. Regional Agenda
a. Past Responses: Tte Region has nv»de a najor effort during FV-83 and
tV-84'to tailor state requests for Part "B" appli cat ions for the land
disposal facilities. -HK? exix-cted results of applying the RCKA regula-
tions to existing land disiosal operations is that those land disposal
facilities which did not or do not operate hazai-JcKis WAste land dispos-
al as their principal business will close their land disix»s«l facility
in accordance.with an aj>pxt^t<3 closure plan under the direction of the
state envirorr.ental »jencies. T\ie ris^ining land disio&al facilities
which will continue to opiate can be regulated by allying technical
Standards Uirough the permit pixxx-ss i3urir»3 the latter part of the decade.
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Hrogress in R3A perr.itting in Region I since the beginning of the
program is shown in Table I.
. . ••
J.VA .Hr-*.; garters Action Needed
s must address in the near future the national ground water
policy and strategy in concert with the national permit strategy and
siete gro-r*: vattr policies and strategies. Everyone agrees that more
erphasis in control of ground water contamination is necessary through
perrr.itting disposal facilities. However, with the linited resources
available , it is not clear that a resource intensive permit strategy
viil achieve the goals of effective ground water managertent.
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S&T
In=
Disposal
SiT
Inc
Disposal
S&T
Jnc
Disposal
-3-
Table I
Region 3 RZRA Perrdt Actions F*-E2 thru FY-B4
Cirvjlative
FY-S2 arvS P3 Perr.it Actions
Withdrawn
Called Received Draft Issued Closed
69 33 10 32
7 4 001
19 6 001
Only FY-84 Perr.it Actions
Withdrawn
Called Received Draft Issued Closed
15 6 615
0 0 000
2 0 404
Cumulative
Thru 7/1/84 Perrit Actions
. Withdrawn
Called Received Draft Issued Closed
84 39 7 1 37
7 4 001
21 6 405
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B. Hazardous Waste Compliance Monitoring and Enforcenent
IB. Procler. Statement
During Fi>84 Region I continued its RCRA Subtitle C compliance and
enforcener.t efforts while at the sane tine inplenenting an enhanced state
er^orce-tnt oversight program. TY.is latter initiative is intended to
better define the Federal/State enforcement relationship under RUvA by
establishing acceptable levels of enforcenent response for certain types
of violations, the result being a consistent and aggressive state enforce-
r-e-.t ar>: E=.~. prccrar. recionvide. T^e following statistics reflect EPA's
enforosrter.t efforts for FY-84 (as of July 31, 19B4):
Inspections conducted 14B
S300B Conplaints issued 14
S300B Final Orders issued 13
5300B Penalties assessed 5223,127
§3033 penalties collected $ 44,820
level of state inspection and enforcement activity has steadily
increased since the Itove-iber 1953 effective date of RCRA as a result of
their assj-.ing the ccr.pliance nor.itoring and enforcenent lead after
receiving Phase I authorization frcn EPA. The following are regionwiae
state enforcement statistics for FY-84 (as of July 31, 1964):
• Inspections conducted 1,030
* Enforcement actions initiated 272
In the area of state oversight, Region I developed an enforcenent response
policy which establishes the appropriate action for various classes of
violations, and sets out those enforcenent tine franes necessary for
such actions to be considered tinely. We have irplenented this policy
in all six New England States, and initial indications are that it has
more than net its intent of swift, effective and consistent enforcenent
actions at both the state and federal levels. EPA Washington is in the
process of developing a national RCRA enforcenent response policy and
will use the Region I approach as a basis for that effort.
I IB. Probler Assessrient
a . Be^rqand^ P.jch progress has been nade over the past few years in
bringing 'industries into compliance with RCRA. State and EFA field
surveillance activities have shown that the irost serious violations,
Uose with the greatest potential for environmental harm, have been
corrected. Such situations are uncovered occasionally. However,
plaaning and record keeping type violations are clearly the nost prevalent
Over the next fiscal year, compliance and enforcur.vnt attention will
focus on the ground water monitoring, financial, and closure/post
closure reqx irurvnts of RCRA. In doing so wo will address what is
considered to be the priority enforovrx-nt initiatives of the progran.
W<_- will at the sane tune facilitate the penniuinvj process via our
ground water efforts and address the facility closures which will
result, as additional permit applications are called in.
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IIIB. Regional Agenda
As has always been the case, a successful RCRA ccrpliance program is a
joint State/EPA effort. ]We expect that the result of our FV-E5 initiatives
vill be consistent and aggressive State enforcenent programs regionwide,
increasing levels of compliance with RCRA's ground water monitoring and
finar.cial rerjir^enents , and enviromentally sound clean-up actions at
those facilities who choose to close rather than receive final operating
permits. Although, as always, it vill be necessary that we and our
states exercise judicious use of our resources in order to meet these
objectives, the one area where we may nevertheless fall short is that of
analytical support for the ground water monitoring program. Sampling
and analysis of well systens in place is not only costly but the RC31A
work is in competition with other media for laboratory support which is
insufficient to meet everyone's needs. It is inportant that this issue
be resolved as soor, as possible so that we can proceed in an expedious
anc ccrprehensive namer. Kith most clear cut violations of RCRA previ-
ously addressed, what we have foand to renain are those cases most
difficult to prove and often requiring sane arrojnt of dnn., soil and
waste strear. sanpling. This will serve to further exacerbate an already
strained laboratory resource.
IVB. Heajrjarters Actions Needed
Heaaq-jarters must address as quickly as possible the short fall in
analytical resources to support the RC3Vi program. This is a probler. for
both E?A and the states and must be resolved if we are to adequately
deal with the priority R3vA enforcenent initiatives in Ftf-85.
Issue Coordinator t Richard Boynton, Kaste Kanagpent Division (223-4445)
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Region 1
Issje o 7
ASBESTOS AND PUBLIC HEALTH
I. Probier' S
This issue fpcuses on two separate and distinct, although inter-related
problems which are regulated under the authorities of two separate
statutes, ie, CAA-NESHAP and TSCA. Heightened public awareness of the
potential dereers associated with asbestos exposure , potentiated by
school districts asbestos hazard abatement program, is resulting in
significantly increased nunbers of asbestos related renovation operations.
There is sufficient evidence to support a conclusion that the majority of
asbestos derolition and renovation operations are performed in violation
of one or nore provisions of NESH&P. The increased rate of renovation
operations, which ray be done inproperly, significantly increase the risk
cf exposure to asbestos by workers, building occupants, and the general
public.
II. Procler. Assessment
a. Geocraphic_scope - The problem of potential environmental contamination
ty asbtstos, as a result of faulty work practices, is Region wide. The
affected population varies but could range frcr. several people to entire
neighbor roods in any single situation.
b. Ksjor irparts - Asbestos is a known hunan carcinogen. There is no known
safe level of exposure. Contamination of the environnent with a high
potential for horan exposure increases the risk of illness in the exposed
pop jl at ion.
c . Level of Concern - There is a relatively high public and news nedia
coricerri over the darxgers associated with. asbestos exposure, as evidenced
by nedia coverage of the subject and the nurber of asbestos-related
inquiries rade to the Regional Office.
d. Major sources - The most significant sources of environmental release
of asbestos would be renovation and derolition of public and private
buildings, and to a lesser extent frcn private dwellings.
e.Contari^nant jof concern - Asbestos.
£. Exjx-ctc-d environrfntal resuHs -Implementation of an aggressive
eriforou:*nt" iJrojraris tai-get«3 tx> Uose wlio rca^A-e asbestos from buildings
would be an increase in co-.tpliancc with applicable regulations le^ing to
the elimination of hur.an and enviroi rental exposure to this carcinogen.
311. Pc-gional Agenda
A clooe working relationship of long standing has been dcve-lopod between
the astjcstos prc^jrams untV.-r TSCA and NT.SHAP. RefeiTals of potential
violators are routinely made between Ux? two prcyitiros. However, in the
past there has U-en a disi'ioioitionatc enfoiexrvnt resix»nse policy between
the two. T)»e TSCA reulations have been a»jjrc-ssively enforced since
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-2-
prcr.ulgstion of the applicable rules. NLSKA? enforcement has been hind-
ered by both a lack of adequate resources and an inability to initiate
enforcement actions for violations of the work practice standards due to
a Suprerie Court decision which ruled that the CAA did not give EPA the
authority to pror.jlgate such standards.
An anendnent to the CAA perr.itted the reprcr.ulgation of the work practice
standards or. April 5, 1984. This action now permits the Agency to increase
its enforce-mer.t; effort. While additional resources have recently been
allocated for NLS-iA? enforcement, more are neede-d to adequately address
the situation. NESKAP - Asbestos enforcement resources need to be allocated
separately frcr. other NESrlk? activities, and be increased significantly.
Effective enforcement of asbestos denolition/renovation operations is also
ccrplicated by the delegation of only portions of NLSJRP authorities to
rost Region I states, and full delegation to only 1 or 2. The Region is
actively working toward attaining a viable progra- in each state, and has
now developed a ccr.prehensive region-wide strategy under which EPA aid the
states will increase enforcerent efforts.
The Air Kar.agerent Division, in which both TSZA and NE5HAP programs are
located, is considering a coordinated program enccr.passing both activities
under one office. Lack of adequate resources has been a deterrent to
coordination, although cooperative efforts do continue. Additionally,
the regional asbestos prcgrars jointly conducted an asbestos dero/reno
workshop for state inspectors. All states except Vemont attended the
workshop. Increased state activity is anticipated.
A viable asbestos enforcement prograr., with deronstrable results, is
possible. With adequate resources and continued cooperative and coordi-
nated efforts, the presence of an EPA enforcement posture will put the
regulated corrunity on notice, and is certain to decrease the occurence
of poor work practice operations.
Or: ar. interagency level, significant progress toward reducing huran exposure
to asbtstos during dero/reno operations was naoe this year through a hvrv-
randur, of Urnt-rstarding between the regional offices of EPA and QSHA. The
MX' sets forth a prograr. of mutual exchange of inforr.ation regarding asbestos
derolition/ renovation. EPA infoi-ns C6H?» of all asbestos Oix?rations for
wV,ich notices have been received umter the requirements of the NESHAP
regulations, anJ refers potential violations of C6*R regulations discxn-erec
during the course of an EPA investigation. Similarly, OSH& will, in the
course of regular projracnc-d and special cr^ftsis insect ions, ascertain
whether a contractor has ccr.plied with the EPA rcxjuirorients, «nJ inform
EPA if a violation is suspected.
In a non-ro«3ulaLory activity, the Rmjional TSCA aslcsto-, prcyrdn pro-ides
technical assistance, literature, and training aids to building ov-ners,
state and local ijovei ments, airf the public to enable t}x»jm to safely and
a3(*juately dc-al with asbc-stus hazards.
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TV. Hgasrjsrters Actions
Additional resources need to be allocated to the region by both the Office
of .Air, Ncsise and Radiation and the Office of Toxic Substances to allow
ar. expert ion of enforcement and technical assistance capabilities.
Kcc.>Tjarters should evaluate the possible disproportionate occurrence of
asr^stos dero/reno operations between regions, as influenced by building
size, nunber, types and age, and provide increased resources to regions
having l*rge n^-oer of asbestos operations performed regularly.
Throughout Region I, asbestos derolition/reno\Tation operations far exceed
tj-je agency- 's ability to monitor. Resources are needed now, at a tine .
wher. the potential for huran exposure to asbestos is greatest.
j'ssje Coorcir^tor; Paul Hef feman (223-05B5) , Air Kar.agenent Division
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I
K^.TIOf;^ KJMCIFAL POLICY Issue IE
I. Probler. Statement - '
The major enforcement areas are to inprove the ccr.pl iance rate of munici-
palities with their NPDES pernits and to inplenent a Regional Pretreament
Progra-r. EPA developed a National Ki-iicipal Policy (NX?) which requires
all municipalities ccnply with the Clean Kater Act by constructing
wastewater treatment plants in accordance with their NPDES perrr.it by
July 1, 19EE whether or not federal funds are available or to insure
their constructed facility is in ccnpliance with their NPDES discharge
perr.it. The NX? also requests that each State develop a State Kjr.icipel
Strategy that evaluates all municipal discharges; deterr.ines which
constructed facilities cannot meet existing penr.its; which unconstructed
facilities will not receive federal funds; and how the State will
require unfunded ccmunities to construct VMT? without federal assistance.
The National and Regional Pretreatjnent prograr. has two major priorities
the first is to have all necessary municipalities develop and implement
approve:: pretreatrient program to insure that indirect industrial dis-
charges pretreat their waste so as not to upset the municipal wastewater
treatment, cause pass through of pollutants, or inhibit sludge disposal
practices and se-condly that all indirect industrial discharges as a
r.inir.jr. ccrjly with Federal Categorical Effluent limits where appropriate.
II. Protler Assessment
Trie Municipal Ccr^liance probler, is a ccnbination of two problers 1)
that a njnber of constructed nunicipal W-.T? are not meeting their NPZES
perrdt and 2) that a nj-i>er of comanities have not constructed the
necessary treatrent facilities in order to ccrply with the requirements
of the Clean Kater Act (O£>). The KM? set up a prcoedjre to insure all
municipalities cone into ccrpliance with the OR by July 1, 19BB. Bcwever,
it specifically states that federal funds are not a prerequisite to
oonpliance. Therefore, EPA and the New England States are requiring
cat-unities to develop Municipal Cor-.pliance Plans (MCP) to determine the
type of treatrient a comanity needs and the funding nechanisrr. available
in order to cxr-.piete construction by July 1, 19BE. The goal of the
Recior. and States is to have all ir.ajor facilities in the above category
sj5j-.it a Mr? by October 1, 1985. The Re-aion and/or States will then
require thie cciTiunity to ccnply with the KIP throujh an enforoonent _
action. The Region or State will work with carrunities to shov ther.
tJ-iey can afford to build a VA-.TP without federal funds.
Region a,t3 States will continue their enforoonent effoit to insure
all constructed wastevater treaO-ent plants ccr.ply with their NTDES
ptmit. Any constructed facility that is not in corplifmce will be
rercjuired through an enforcvax-nt action to set up a plan that aJJrcsses
Uc reasons for nonconpliancc- and places the facility on a exjoSitious
schedule to ta>.e all steps necx-ssary to insure long term cvr^liance.
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Through this extensive effort all major municipalities will be in ccn-
pliance with the OR. This will result in a marked improvement in the
water -quality throjghout New England especially along the coast.
The pretreatnent enforoenent effort is also a ocnbi nation of two efforts.
The first is to insure all comunities develop and implenent programs. EPA
and the States of Massachusetts, Maine, New Hampshire and Rhode Island de-
sigristed 79 ccrr.unities as needing to develop pretreatjnent programs in
order to cor.trol the potential discharge of toxics frcr. indjstrial contri-
butors. The States of Connecticut and Vermont have developed pretreatnent
programs at the State level. The Region has approved approximately 1/2
of the 77 prograTis to date although all programs were to be subr.itted for
approval by July 1, 1983. The other ccrrunities have either not satr.itted
or suhr.itted inapprovable prograns.' The Region has initiated a strong
enforcerer.t effort including administrative orders and press releases
nar.ina the camanities in an effort to have all prograns sutnitted by
Septe-Tiber 30, 1984.
The irylerentation of approved pretreafrient programs will control the dis-
charge of toxic into municipal sewers and the pass through into waterways.
Each comunity will require the industries to properly pretreat their
wastevater and dispose of the sludge in an approved manner. Each comj-
nity must set up a program to inspect, monitor, and enforce both federal
and local pre treatment standards against all indirect discharges.
Trie other part of the enforcement efforts is to insure that the Federal
Categsrical Standards requiring specific industries to meet national
pretreatr»ent standards by a certain date are fully ccnplied with. An
exenple of this is that the electroplaters were required to install
treatment by April 28, 1984 and meet national standards. EPA has initi-
ated a strong enforoenent program to insure that these dates and standards
are met and is taking appropriate enforcement action including civil
penalties. The Region is developing a strong field inspection progra-
to verify compliance throughout the Region. The Region has also begun
editing ccrrvjr.ities with approved progrars to ins-are that they properly
inple.-fcnt those programs.
III. Regional Agenda
Region has discussed with each State the NXT and each State has
developed a State Municipal Strategy. The Rt'gion and/or State have
prioritized those VA7PP that will not received fc\V?ral f orris and are
requiring then to suli^it furling options and schedules to construct the
nc-cessary facilities by July 1, 1588.
The Rogion and State will require all constructed V*%TP that cannot meet
thie p*nTiit conditions to su!mt a canioeite correction Plan (CCF) that
identifies the reasons for nbn«JTl i ance and prcix>scs a plan to insure
the facility is returned to compliance.
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• Continue to require comjnities to suhr.it pretreatr»ent prograns as
quickly as possible.
••Re view'and approve all pretreatonent programs upon acceptability.
• Initiate enforcement action against recalcitrant municipalities
• Initiate field inspections on a systematic basis to insure industries
comply with categorical standards
• See); penalties for all non-conplying industries to help make the regulated
corr.'jnity aware of E?A aggressive enforcenent
efforts.
IV. Headquarters Action
o Office of Water Enforcenent and Permits should issue a National Pre-
treatnent Ccr^-liance Stratec-y to insure a consistent National Prograr.
is adopted.
o EPA Headquarters nust review the National Municipal Policy if Federal
forcing for r.ur.icipal wastewster construction is extended beyond 1955
and modify it appropriately.
o E?A Office of Water ErJorcenent and Permits must increase Regional
resources to fully irplenent an enforcenent effort for pretreatnent
and municipal ccr.plia.nce.
ISEJ? Coordinator Larry Brill (223 - 5330) - Water Management Division
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Region I
Issue 19
PROBLEM S37iTEK2?T
'Two major envirornental issues irpacting the New England Coast
are estuarine water quality problems caused by industrial and denes-
tic waste effluents, ccri-ined sewer overflows and non-point source
runoff and ocean disposal of dredged material.
II. PRDBLEV.
II.*..
a. Background - Ihe major pollutants effecting New England estuaries
are coliforr, bacteria, heavy metals, nutrients and organic cher.i-
cals. Trie bacteria, nutrients and metals originate frcr, nonpoint
source nroff , wastewater treatment plants and ccr-ined sewer over-
flows.
b. Geographic scope - Under a recent congressional action, four mil-
lion dollars was appropriated for studies of four estuaries: Puget
Sound, Long Island Sound, Narragansett Bay and Buzzards Bay. Of
these ironies, approximately 2.6 ir.illion dollars will be administered
by E?A in assessing the proble-;S, identifying corrective measures
and ir?l orient ing these measures in the New England estuaries.
c. Major irpacts - Estuarine pollution is nost exemplified by the
closjre of shellfishing groands, loss of the use of beaches for
contact recreation, and a general der.ise of aesthetic quality.
d. Level of public concern - There is a very high level of public
concern over~the degredation of estuarine water quality. For in-
stance, Save the Bay, a private envirornental group fomed approxi-
mately ten yc-ars ago to address the problers of Nai-ragansett Bay,
has 10,000 djes paying fa-.ilies listed in their nerbership and has
establis>*d itself as a viable political faction.
e. Kajor _so-jrces - The majority1 of marine pollution to these urban
esUjaries originates fror. malfunctioning wastevater treatnent
plants, otnbined sewer overflows, non-point source runoff, dredging
activities and oil transport an.3 distribution.
f. Con'-ar-inants of concern - Heavy metals, organic chwiicnls, coliforr.
tJctefia","hijtrjents, KfD^, and petroleum hyJrocai-bons.
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MARINE KATE? OUALm
I.
'Two major environmental issues imparting the New England Coast
are estuarine water quality problems caused by industrial and domes-
tic waste effluents, ccr^ined sewer overflows and non-pcint source
runrff and ocean disposal cf dredged material.
II. PROBLEM ASSESSMENT
31A. ESTUAPIES
a. Background - The majcr pollutants effecting New England estuaries
ere cclifcrrr berterie, heavy ratals, nutrients and organic cleri-
cals. The bacteria, nutrients and metals originate frcr. nonpcint
source runrff , wastewater treatment plants and combined sewer over-
flows.
b. Geographic sccpe - Under a recent congressional action, four nil-
"licn dcilars was apprcpriatei fcr studies cf four est-uaries: Puget
Sound, Long Island Sound, Narragansett Bay and Buzzards Bay. Of
these rcnies, apprcx Lately 2.6 ir.illion dollars will be administered
by EPA in assessing the problems, identifying corrective measures
and irpltrt-nting these measures in the New England estuaries.
c< Mejsr ir^iarts - Estuarine pollution is nest exemplified b^' the
clcsjre cf shellfishing grounds, loss of the use of beaches for
contact recreation, and a general demise of aesthetic quality.
d. Level of jpublic concern - There is a very high level of public
concern ever the degredaticn of estuarine water quality. Per in-
stance, Save the Bay, a private environmental group forrned approxi-
mately ten years agr tc address the pr obi ens of Narragansett Bay,
fias 10,000 dues paying ferilies "listed in their n*crr-ivrship and has
estat.•lis^c<3 itself as a viaMe political faction.
e. fejor_ sources - TTie r^jority cf Ferine pollution tc these urban
estuaries originates frar malfunctioning wastewater treatment
plants, ccrijinc-d sewer overflows, non-point source runoff, dredging
activities and oil transport and distribution.
f. Oontcri nanis of con£trn - Heavy nvtals, oi-ysnic chrtnjcflls, coliforw
bacteria,' 'nutrients, BOIX,, and pcLroleom hydrocarbons.
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Q. Expected enviromental results - As the above itentioned problems
ere alleviated, the benefits te be expected are:
- • An increase in both contact and non-contact water use.
r
0 An increase in recreational and comercial shellf ishing.
* AT. increase in property values bordering the polluted areas.
0 Rehabilitation of areas by populations of health and diverse
marine organisms.
0 An increase in the aesthetic quality of the water.
HE. OC.V: DISPOSAL Or DRE2GED MATERIALS
£. BerVcrcund - New England waters have been used for the disposal of
dredge: iraterials. Appr ox irately 75% (or 19 ir.illion cubic yards)
of the tcta! arcunt of material dredged in New England between 1971
anc 195D was disposed in open waters off New England's coast. Of
this tctal, 3,280,843 cubic yards were disposed at two EPA approved
iteriir. sites over the past four years. The derand for disposal
at these and other open water sites is expected to continue and
possibly increase over the next decade because of the need to
meir.tain and enhance regional harbors and ports.
t. Geographic sccpe - Major dredging efforts in New England will be
the harbors in Rhode Island and Southeastern Massachusetts; mainly
Providence, the Mount Hope Bay area, Pall Fiver, and New Bedford.
c. Kc jcr inparts - Impacts due to the disposal of dredged material
are 'not totally predictable as yet. The potential for affecting
recreational artf ccnrercial resources and general water quality
is always present when discharging cent arina ted dredged materials.
d. Level cf_pub]ic concern - TTiere is a high level of p-jblic concern
re-Ja'rdi'ng the e'nviVonnvnta] impacts of dredg«3 material disposal
into the ocean as well as the socio-economic impacts if nc new
di edged disposal sites are identified. As pviMic meetings are held
on specific projects, public test irony helps to select vhich
alterrtative(s) are most acceptable.
e> EXJ ec ted env i rorvrt- nt a 1 resul t s
effect on recreational and conT«?rcial resources
and general water quality d.iannels.
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III. REEIO^M A3ETCA
IIIA. ESTUARIES
a. Past responses
• Research en estuarine pc Hut ion and the development of cor.p-jter
irodels capable cf pollutant dispersion prediction. For instance,
in 19E2, EPA developed a dispersion rodel for Nerragsnsett Bay.
Irie ncoel has been used by the Rhode Island Department of Er>-
virorrental Management to justify the State's application for
CSO funds during the first round of funding and will be enplcyei
fcr f Jture yearly applications for CSO funds. Ttie nodel has
also been used in an EPA Headcjuarter's study of the benefits cf
cleaner water in Upper Narragansett Bay.
b. Re ^emended regional actions
• Adrinister the Special Bay and Estuary Studies of the three
estuaries recently funded through Congressional action.
c. Barriers tc overcome
e Cleanup cf these estuaries will require a large public ccrrr.it-
mer.t and investment fcr nc-n-pcint source, CSO and pcint source
contrcls.
3 1 IB. CCEA'C DISPOSAL Cf DRIDGED KATERIALS
a. Past Responses
* EPA - Corps of Engineers coordination on dredge and fill projects.
b. Pc-cQ-T-'erKi:! recicnal actions
e Desig'.at.icn cf .a southeastern regional dr«3ge3 material disposal
site fcr projects in Rvcde Island and Southeastern Massachusetts.
C. Barrers tcovercone
is a need tc expand our present kn^-ledge of the in-.pacts
of Fiaterjal disposal in the marine enviroirvnt, and to
appropriately condition our regulatory fr ax-work t«s*?d on the
extend of present knowledge.
IV. HEADQUAK] tl>S ACTION NEEDED
IVA. ESTUARIES
• Establish a federal priority for the control of co^«in«3 sewer
overflows (Assistant Administrator for Water).
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• Increase federal support of riarine research. Fundiny of this
.work will make possible continued refinenent of the dispersion
rodeis.
• Coordination of a mutual assistance program with other federal
agencies involved in oeeanographic or estuarine research (Assis-
tant Administrator for Kater).
* Continued, fund ing for support of estuarine water quality ir^rove-
roent programs (Office of Marine and Estuarine Protection).
IVE. OCEAN DISPOSE or DPJDGED MATERIALS
e Continue national dredge disposal site inpacts characterization
procra- through continjef ronitoring (Office of Marine Discharge
Evaluation).
;_u=: Coordinator: Don Porteous (223-5043), Water Ka-iagerent Division
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Region 3
Issue 610
COMBINED SEWER OVERFLOWS WS> NOltPOINT SOURCES
I. Prohler Statement
Ccntined Sewer Overflows (CSO's) located in nost larger cities and nuner-
cxis rural ccrr.uriities in New England degrade the water quality of najor
rivers, coastal areas and several lakes.
Nonpoint Sources (NPS) of pollution inpair high quality drinking, fishing
arc recreation waters in Nev England.
II. Probler. AssessrSent
a. Background - Most major cities and numerous rural ccmunities in New
England have ccnbined sewers. During periods of wet weather the
sewers beccne surcharged overflowing untreated wastevater into
rivers, lakes arc coastal waters resulting in degraded water quality
arc irpeirment of beneficial uses.
No-point prob!e-iS are generally localized or sporadic in contrast to
gross, wids-spreaf point source pollution loadings. Agricultural
ruroff frcr. nanure handling and cropping practices, erosion and
seSinentatior, associated with large scale connstruction and urban
storr. runoff all inpair lakes, ponds, estuaries, bays and otherwise
high quality waters. A rounting priority issue is groundwater
cor,ta,-.i nation frcri faulty on-site systens, landfill leachate,
urten storr. runoff, leaking storage tanks, pesticides/herbicides,
anc r^terials storage sites.
b« Geographic Scope - Although the probleri is New England-^wide , nost of
t-he carr.ur-ities having CSOs are located astride major rivers or ad-
jacent to coastal waters. Approxirately forty percent of the popula-
tion of New England is served by combined sewer systens.
Urban runoff anc construction problems occur mainly in southern New
England, as well as in areas undergoing rapid urbanization, resort
develojj-.ent a-t3 large-scale construction projects. Agricultural and
forestry NPS are concentrated in northern New England, e.g., Chars-
plain Valley and Maine lakes country. NPS groai3water conta-ination
occjrs through New England.
c. Kejqr lij^cts - Anong the serious adverse econonic and environmental
injects o£ "co-.Sined sc-^c-r o\-erflows ar»d nonpoint sources are the
following:
c-^.-r Overflows
CSOs result in the closure ofshcllfish harvesting aix-as aid svirming
Loaches ar<3 often preclude other recreational u*es. H>ey ca-i aesthet
ically d».-<3ra.'-fc wateitcdies. "Hie ijnpact of preclucV-d uses is often
substantial since urban areas w!>ere use pressures are nost intensive,
are nost ccrnonly affected.
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CSOs prevent final clean-up of iriajor rivers and river segnents.
Oft-times river clean-up has proceeded to an advanced stage - major
wastewater treatnent facilities have been ccrpleted, but CSOs produce
water quality problens;
e The total cost of ccntined sewer control in Nev England est rated
by the 19 S3 Needs Survey to Congress is $4.5 billion.
Urban runoff - Runoff fror. paved areas, rooftops and lawns carries
sedlner.ts, nutrients, pathogens, toxics and debris into strears, ponds,
water supply reservoirs and estuaries.
Constrjctior. activities - Improper construction practices at particular
sites cause erosion and sedimentation and associated runoff of nutrients
and toxic substances into strears, la>.es, water supplies and estuaries.
Silt, nutrients, and toxics runoff frcn construction practices directly
ir.pair critical waters, sensitive aquatic ecosystems, spawning areas and
prime recreation/aesthetic values. Further, these silt/toxic loads
successively settle and shift with the currents for years to ccne,
accelerating bank erosion and flooding.
On-site vsste disposal systens - Suburban and rural ccmunities continue
to rely on individual 'subsurface disposal systens. Approximately 35% of
the region's popjlation utilize subsurface systens to dispose of their
donestic wastes. Although such systens are often the most effective and
econcr.ical waste treatment alternatives, they can create water quality
prccleris in both ground and surface waters if they are improperly sited,
designed, or rvaintained.
Agricultural activities - Agriculture-related pollution poses significant
water "quil'ity probler-s where anir.al waste handling, cropping practices,
and pesticide. 'herbicide applications de-grade high quality waters prized
for t^ieir recreation, fish and wildlife, water supply and aesthetic values.
Forest nar,ao«z-*nt a-tivities - On a scattered basis, improperly designed
'ing "roads "and "skiddi'ng practices impair high quality- uses.
d. I>?vel of PtibJic Concern - T^ere is a high degree of public concern for
"tile "c lea n^up "arid Vfccl«--4t icon of public water uses in urban areas such
as Boston Harbor, Narragansett Bay and New Haven Harbor which are ini>acted
by CSOs and urban storm runoff. Concern runs high to ruintain New
England's assets of high quality lakes and streams, and water Baylies.
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e. Major sources - Ttie major source of CSOe are older combined urban
sewer systems which were designed to convey both stonrwater and
wBStewater. However, during wt weather these system are hydra'jli-
.cally overloaded and they overflow into adjacent waterways. Major
• NPS sources are urban storm runoff, agriculture, forestry, and
construction, and on-si'te waste disposal.
*• Contarinants of concern - CSO discharges include a mixture of all
the cor-tar.ina.-its in wsstewster and stocnwater. NPS contar.inants
include sedijrents, nutrients, heavy metals, toxic substances and
6ebris.
g. Expected eviroamental results
Cor±ined Sewer Overflows
e Control of CSOs, when ir-lenented in combinatin with other
basic water pollution control treasures, will result in reclama-
tion of the desired uses along the major rivers and reny miles
of the coastline in New England.
• Shellfish beds may be opened; swinr.ing and recreational areas
can be fully utilized; fishing, canoeing and general use and
rnt of the rivers and coastal areas will be substantially
d; the aesthetic qualities of the water will be restored.
0 Since the New England eccnrry is so closely linked to the environ-
mental quality of the region, significant economic benefits
will accrue as a result of the completed clean-up.
Nonpoint Sources
• Pollutant loads frcir, norfoint sources can be expected to be re-
duced by ij^lenentation of Best Kanagcnent Practices (B^'s)
thus nr.iriirizing the water uses irf&ired and providing insura-ice
a-gainst coetly, disruptive incidents and need for expensive
rcnedial measures.
* Construct ion - reduced eroeion and sed indentation of streans,
ponds and estuaries during residential, cormfrcial, and highway
Cfjnstruction.
• Urban stoiir. runof_f_ - Significant reduction in axJijivnt, nutrient,
and" metals i~unoff, restoring ar«3 maintaining water uses.
On-.site wastcwater disp'^l - Prevention eg pollution to wells,
aqu'i fe'rsi "si Warns ^ and pjnds cuiTently conlflpr.inat«3 or threatened
by in^..rcjfic-r on-site d
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0 Agriculture - Reduced sedimentation, pesticide/herbicide
cor.tarr.inat.ion, phosphorous loadings and lake cutrcphication.
* Forestry' - Decreased erosion and sedimentation into quality lakes
anc--strea,-.s fror. iirpr-oper forestry activities.
•
III. REGIONAL AGENTft
a. Past Responses
Ccr.bined Sewer-Overflows
• New England - New Haven, Hartford, BridgeportfCT), Providence
(RI), Breton, Springfield, Worcester (MA), Concord, Manchester
(NH), Portland, Bangor(KE), and Burlington(VT) are among the
major cities in New England that have combined sewer syster.s
discharging overflows into adjoining waterbcdies-rivers, lakes
and coastal waters. In northern New England a snail number of
s-aller conrrjnities are also served by CSQs. Many municipali-
ties have taken limited rerwdial action to reduce the frequency
of the CSOe, and several conrunities have eliminated the over-
flows try means of sewer separation. Eight CSO projects located
in KA, CT, KE, NH, totaling SIB.5 million in construction cost,
are currently being considered for funding under Section
201(n)(2) of the CXA (Marine CSOs). Construction on these pro-
jects can be initiated ixT7»?diately upon issuance of the grants.
This provision of the CKA can provide a powerful tool for deal-
ing with CSOs in New England.
N^r.point Sources
• Prevention is a prime objective in K?S prcgrans. Tt>e focus is on
b-jli'ding BKP's into the daily activities that potentially contri-
bute to npnpoint pollution.
0 Pestoretion nc-asures and intensified BtfT's are directed at prob-
ler. areas ir;«cting priority water. Tt»e St. Albans, Rural Clean
Kcter Project (PCW?) on Lake Char^lain and the Wostport River
Estuary (Kas.Racchusetts) RO3" project have enrolled problem
fanr.s in manure handling and crapping BMP's.
* All New England states have nonpoint source assessments and im-
plfcntntation in Kater Quality Kin^c-ncnt Plans and State work
plans.
• Tlie Region has boon working with the states; soil and water con-
servation interests; the agricultural construction and forestry
ccjijnunity; and the host of sister agencies, organizations,
and interests in wh.ee hands lie the iivluwntation of RIP'S.
Several Now England Soil Conservation Service State
Conservaticjnists have refocused the 9^11 KMej-shed Program
under P.L. 566 to fund HKT's in critical lake vMeistvds, in com-
bination with Agricultural Coa«^ei-vation Pr^iiW cost-spring and
EPA Clean Lakes Restoration Grants.
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b. Fecjrervdec Pec ions! Actions
Oar±ined Sewer Overflows
• • In cor, junct ion with the State water pollution control agencies,
modify NFDES penrits to require definitive in^lerentaticn of
ccnbined sewer overflow control prcgrarrvs.
0 Vterk with the State anc" c:n-,j.-iities to develop sound applications
for securing maximum funding under Section 201 (n) (2) of the CV5>.
e &>cojrage States and local corrvjnities to develop lov cost-high
benefit CSO control operational and maintenance programs.
e Encourage States and local ccnr»uriities to iriplenent CSO control
prcgrars utilizing Federal, State and local funds.
hioripoir.t Sources
0 Work with the states to beef up state N?S ivf lerentation plans,
outlining specific activities, geograpMc areas, programs, respon-
sibilities, funding and scheduling.
0 Assist state water quality agencies in refining water quality
stajxSards to reflect use iFfeirtnent fron N?S and to incorporate
criteria for N?£ pollution.
e Encourage state water quality agencies to involve sister
agencies and to furnish their, water quality information
• Involve environmental , corrercial and industry grcups, e.g., con-
struction.
• Support the states in assisting local officials responsible for
local plar.r.ing, zor.ing, subdivision controls, site
code enforcement, and road and street irainte nance.
* Foster state and local action to monitor and enforce
• Prcrote state and local cost-sharing and tax incentives for PMT's.
c . Ba i IT i ers to overcome
O-nb i ned Sc^c r Overflows
0 Federal, state and local g^venvtnts have fcx\js«.->d thpir atten-
tion on the task of providing basic collection and t re a brent
of wastewater. "Hie control of ccirtoined sewers Kis boen given
secondary priority prinarily due to the 3ijt>iled-c<:Titcx'r-n- placed
on Uem by federal statutes, regulations, guirtolinos aixl programs.
Ttiis reduced priority has resulted in limited L
of prcgramr. to reduce CSO&.
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e The technology for control of overflows, within reasonable
financial frarework, is available. The application and Imple-
mentation of the technology is a critical factor.
• • The prirary barriers to solution of the probler are federal,
state and local governmental priority for control of the over-
flows and governnental financial resources to construct the
required CSO control systems.
N3~ipoint Sources
* The diffuse, intermittent nature of N?£ sources makes it diffi-
cult to recognize their water quality impacts and mount effectiw
abatement strategies.
e The diversity of managernent agencies requires coordinated efforts
to develop and iir.plenent pollution abatement measures.
c Since BX?'s usually involve chancing ingrained habits and opera-
tions, long lead tires are often required in the adoption process.
Local ffjtoncny may iir,pede adaption.
e DirdnisMng support funds make abatenent efforts more difficult
to ir.plenent.
TV. HEA20UAPTERS ACTIONS NEEDED
Corbined Sewer Overflows
• Establish as a federal priority the control of combined sewer
overflows; (Assistant Administrator for Kater).
e Provide policy and operational guidance to the regions which
recci-t-ends definitive ir.pleme-ntation of CSO progrars through
NrDLS pecr.its; (Office of Vaster Er.forca>?nt and Perr.its).
0 Aggressively ir.plenent Section 201(n).(2) of the CK^; (Office of
Kster Prcgrars Operations).
Nonjx>int Sources
• Enunciate a clearcut NTS Policy and Implementation Program.
• VforK with federal agencies and national organizations to reach
the- diversity of interests involved in controlling the scwrces of
nonjoint pollution; (agriculture, forestry, construction, and
tr ansport at ion).
0 Assure federal projects, grants, and loans incorporate
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0 Prcvide national leadership, guidance and technical assistance,
with "last resort" back-up enforcement (e.g.; coostruction).
• Furbish rodel legislation, guidance and technical assistance to
build up state-local-private sector capability.
0 Befocus existing agricultural cost-sharing programs to support
v=t£r quality objectives.
e Provide funding, tax incentives, and other incentives for deron-
strative programs.
° Arrange details of seasoned experts to facilitate National and
Regional progrars.
Issue cccr fins tors; Walter Newr,an (223-3917) and Bart Ha=je (223-3917)
" Division
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Fart III. Reoior.al Reccrre nest, ions for the Agerxry Priority
List FY 66-87 •
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Part III
Region I Recomnedations for the Agency Priority List FYB6-B7
The Priority List Process and Purpose;
1. A large number of environmental laws are up for reauthoriz-
ation. Amendments nay bring significant new or shifted
requirements. It is therefore difficult (and rather risky)
at this tire to make s-jjcestions for what our priorities
should be for Agency action.
2. No one has indicated what the criteria are for selection
of items for inclusion on the List. Khat assumptions
underlie the List and its preparation How are the regions'
views incorporated in the Priority List?
3. How is the Priority List used? How should it be used in
the regions and at HQ. The answers could shed light on the
preceding question. In soir.e cases, items high on the List
are not budgeted for by the Agency while some lower on the
List are.
The Priority List is too long; it should be shortened
about 16-20 Issues.
to
5. Ve should consider a ranking by medium; it would be easier
to prepare the List and make it more meaningful.
6. In some cases, one item higher on the List cannot be attacke:
until a one lover has been satisfactorily addressed (eg. 923
must be completed before the Region can address 14)
7. Should the List be used to drive planning in the Agency?
Should the process be further refined to factor List entries
into our workplans? Should we incorporate some specific
activities and milestones?
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Fezion I Part III cont'd
Suggested Changes;
1. The List should give more emphasis to enforcement and
compliance. These are important and necessary compon-
ents to many of the current entries and should be
expressly addressed in the List (eg. Is 7, 9, 12, 13,
- 16, IB, 21, 22, and 25).
2. Long-range transport (broader than "acid rain" or.
•acid precipitation") needs to appear near the top.
It should .encompass acid deposition, ozone, and other
transportable materials that threaten public health,
buildings and structures, waters, and crops, trees
and vegetation. New reports and studies point to the
need for controls and for research. Ke should be in
an implementation stage by 1986-87. This issue is of
critical importance to the people of New England.
3. Entry for Air Toxics monitoring ans strategy should
appear earlier on the List. See previous suggestion.
4, The List should include marine water quality-related
issues. A goodly number of regions possess major
coastal and ocean resources and depend on the sea,
bays and estuarine areas for fishing, aquatic nurseries,
ecological cycles and recreation. Action on the CWA
appropriations suggests this will be a major focus of
attention.
5. Dioxin might drop down. The Agencuy could well be at
the end of its Dioxin Strategy project in a couple of
years.
6. An iterr. should be included which links pesticides and
drinking water protection. Leaking underground storage
tanks, landfills, and surface impoundments also affect
drinking water supplies. Monitoring for arr.bient pesti-
cides will be important. These matters are of rapidly
increasing public concern in this Region. Ke therefore
need to amend item 6.
7. Ar.end item 7. Much of item 7 should be completed in
1985. However, monitoring for toxics impacts and the
enforceinent/coiT.pl iance components will still be import-
ant priorities.
8. We need to include indoor air pollution fairly high up
on the List. This if a particularly important public
health issue in New Lngland because of the high fuel/
energy costs in this part of the count-ry, and because
of the heavy and growing reliance on wood and coal
burning stoves for winter heating of residences.
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Fart. IV. Most Significant Enviromental Problem - Region I Chart
-------
Most Significant EnvIronnri.t.a 1 'Problems
OfflCEi Region I
Hank/Problem
1^ Groundwater;
~ Contamin-
ation
Geographic
Scop*
Peglonwlde
due to anils.
geoloqy .and
hydrology of
New England
3 Pillion
New Englaiiders
Major
Impacts
Pi iiks to current and future
(potential 1 drinking water
supplies; could be rendered
unsafe/unfit to drink
Rinks to public health
Need clean water sources
Level of
Public Concern
Very High and
Rapidly Bin ing
1 Major
| Sources
Uncontrolled h.w. alien
Leaking tank*!, pipes t
drums
Landfills t leachflelds
Surface impoundments,
(• Contaminants of
Concern
Spent solvents
Pesticide
residues
Gasoline and
petroleum
products
depend on
qroundwater
aa nole aourcc
of drinking
water (20* of
population)
and >2.000
177%) of our
community water
systems rely on
ground or com-
bined ground t.
aurface waters
for drinking
for industrial/commercial
growth
Closing of wells In many
communities in New England
Potential threats to aqui-
fers and recharge areas
piles, sludgea. lagoons
Chemical spills
Improper handling and
rilnposal of household
t commercial products
containing hazardous
and tonic materials
Other
2 Boston
Harbor
2 million
people in
netro- Boston
(40% of the
population of
Massachusetts
and 4 ) commu-
nltleal
Harbor ar«a
and nearhy
ocean areaa
Dlqcharn* of
*00 mi it »on
of waat"«*at»r
and 2,">00 wot
Risks to public health
Adverse effects on commer-
cial t recreational uses
Aquatic eco-systems
Shellfish beds
Plahvrles
Cloned beaches
Aesthetically offensive
Inparta and conditions
are |>flrt Irular ly severe
durln-i and after storms
High—viewed by
the Involved
public as the
number one nlte-
npeclflc envi-
ronmental prob-
lem in New Eng-
land, and until
recently seen
n» H nn)nr rnvl
rnnmental failure
of all levels of
government
Inadequately treated
wantewater from Roston
t surrounding cities
It towns
Sludge ft effluent
Discharges
CSO's
Lack of adequate
wantewater treatment
capalty t malfunction-
ing equipment
Bacteria and
pathogens
Heavy metal•
PCB'e
Organic*
Nutrients
Creases and
oils
Floating and
act I It-able
•III
' I
-------
REGIONAL OFFICE! *eqion_J
Rsnk/Problem
Geographic
Scop*
Major
Impacts
Mont Signif leant EnvironmentsIproh1rms
Level of
Public Concern
Major
Sources
Contain I nants ot
Concern
Totlcs Reglonwlde Air, surface water, ground-
water, drinking water, land
contamination
Can occur In all media ft
ahlft from one to another
Can affect virtually all
life forms and Interrupt
ecological systems!
human beings
animals
fish t, aquatic life
lnn«*cts
vegetation
forests
croplands
micro-organisms
other living things
Effect" of toilcn on health
of humans and other organisms
can ramie from death, cancer,
birth defects, reproductive
problems, nervous system
dlnorders to auch more mild
aymptomti an naunea or skin
or eye Irritation
At thia point we have only
a limited knowledge of the
effect* of toilcn on lite
forrnn, individually, ayner-
glntlcally, and in small
concentration*. Me will
certainly discover new one*.
Aqt{cultural production,
|jrnr1ur:ta. foodatutfa A
additives
.Stream, river* lake, harbor,
eituarln*, bay, ocean
HedimentH
Very High and
Growlni) concern
Many known, suspected,
k unknown i
large indiintrial
Many t varied
V.K.C. 'a
metals
utilities
dry cleaners
municipal t Indus-
trial effluonta
waste materials In
lamlf illn
hazardous waste sites
consumer/household
cleaning products,
paints, solvi-nts
chemical manufactur-
ing t processing
commercial t home
use of pesticides
food addUlvrs
coal i petroleum
processing b
combustion
leaking tanks, drums,
ft pipes
laboratories
hospitals
mining wastes
batteries
finishing materials
fc wastes
gasol ln« t dlescl
product processing
t combustion
dl-.trl- ft
tntrachlor-
ethylene
PCH'S
dioxin
al icarb
atsbeBtoB
F.DII
b».u
hazardous
wastes
new i eilstlng
chemicals
development,
manufacturing
processing,
handling, use
product
ponents
tad ipnucl ides
Combinations of
the above
Other
-------
REGIONAL OrriCEi. Beg ion I
Rank/Tobies
Moat Significant' Environmental
Geoqraphic
Scope [Impacts
I Level of I Major
[public Concern |smirces
(Contaminants ol
Icunci't n
Setter
Overflows/
Nonpolnt
Sourceg
ATT major
citvps of New
Fnqland am)
numerous
con-
(400
of population
in reqlon)
NFS
poqlon wide
with urban 6
rural runoff
differing in
oource.
beaches and shell flnh
Hl«jh
areas
Health hazard
Prevent reclamation for desired
uses
Impairment of water uses In
populated urban areas and
quality waters and ecosystems
in rural areas
Hlqh
Comliined sewer
systems
Same as those
contained in
waste water
Urban runoff
Aqrtculture
Construction
On-site waste systems
Sediment
Nutr
Metals
-------
1 «>n< EHR
Most Sign if leant Environments l_Probl ems
REGIONAL OFFICEi Beg ion I
Rank/Problem
Geographic
Scop*
JMnjor
1 impacts
Level Of
PuhIic Concern
J Major
Source
Contaminants of
Concern
National
Municipal
Policy/
Pretreatwent
Mrlne
water
Quality
KlT municipal-
ities must
comply with
WA by 7/1/BB
pretreatment
79 comnunTTTeS
in Me., Mass.,
N.H. . and R.I.
require pre-
treatment pro-
9 r eras
which
pretrent waat«
water fc
dispone
of sludqe
Cntuarivn -
Boston Harbor
Loni Island
Sound
N*rraqann«tt
Bay
Buzzard's Bay
Oredqlnq In
harbors in R.I.
and SF. M4 Bay,
Fall Plver,
New Bedford
Significant financial import-
ance to communities If CWA
funding not reauthorized.
If pretreatment pronrama are
not in place, communities may
not control tonic discharges.
Significant cost to some
induntrlea to control tonic
waste
Clonure of shell fishing
ground*, loss of use of
beaches, demise of aesthetic
quality.
Major dredging always has
potential for affecting
recreational and commercial
rennurce* and general water
degradation.
Moderate
High
Waste water treatment
plants
Any waste water
discharge
79 affected communities Toilcs
All Industries requiring
pretreatment
Toiics
Majority of marine poll-
ution originates from
malfunctioning aewaije
treatment plants,
combined sewer overflows,
non-|>olnt source runoff,
drf*d<|ing activities and
ol 1 transport and
distribution
Heavy
me tii Is
Organic
chrmicala
C<>|i form
bacteria
Nutrients
Petroleum
hydrocarbons
-------
J_9M_FMP_Uptl.n *•
Most_Slgnl Meant F.nv Ironm-otal 'i
REGIONAL OFFICEi Region I
1 Geographic
Rank/Problem I Scope | Impacts
Level of iN.ijor
Putil lc Conco rn | S<>y_rce_s_
|( ontaml nantft ot
It'once 111
Implementation
o( Super fund
Proqraw/New
Bedford Harbor
New Bedford Hlqh concent ratlona of PCR'a High
area in
Flfihlnq h^n Imposed over
Ifl ,000 acr^n of Harbor -
closinq lar
metal aludges
Solventa -
halogenated fc
non-halogenstea
Haste pesticide
reslduen
Asbesto* and
Public Health
Peqion- Known human carclnoqen with no Relatively
wle)« known safe level of exposure high
Renovation/demolition of
public and private
bul Idings.
Private dwellings to a
lenser degree
Asbestos
-------
REGIONAL OFFICEI "eg ton I
HanVProbl
Geographic
Scop*
flavor
Impacts
19B4 EMU Update
Most Significant Environmental Problems
Level of
Public Concern
Major
Source*
Contaminants ot
Cone*r n
Toiics
Icont'd)
Institutlonal impacts toot
Difficult for federal
ann state lawmMKtriH anu
regulators tn establish
standariln and criteria
and to device Implemen-
tation programs
Difficult for public to
understand these natter*
Long Rang*
Transport
of Pollut-
anlsi oions
t other air
pollutants,
» acid
deposition
Otone is a
particularly
serious prob-
lem in Conn,
Haas, Rl,
So. NH t Bo.
Main*
Region I Is
the victim of
the nation's
2nd most
severe otone/
air pollution
levels
Acid deposition
In an enpeclal ly
••vere problem
In New
«1'l» to
Ing capacity
of our no! Is
• nd
V» are
downvlnd of »h»
Ion*' • pia ]or
1.95 million people In New
Rnqland are at rink of
renplratnry prohlemn dus
to oznn»-/alr pollution
epiBoT»>B, especiallyi
— th<» ««ld«»rly
- people who have nnthsia,
enphpHfma, bronchitis
- Infants under 2 yrs. Old
Public health Impacts,
Including respiratory
aynptnmn fc reduced resistance
to Infection. More hosplt-
sliiatlons during episodes.
Lost work tine
Stunted growth of vegetation
*.cM_d«»j>o8it_loii - serious,
wT'l^ni-r.-a'!. <|rnwinq b porhaps
lrrovf>rnlhle adverne Impact a i
streamn, rlvern, laKen, r«?s-
evolrat flnherlrs 4 aquatic
life t llfo nyst.emni r.errea-
trtal nyntrmn, tncludlnq •
fnrontn. vni|««tat Ion, nolla,
P i rro-nrrjan I nmni buildings,
Rtructurfn fc materials!
*nh«nc"1 ability of «|round-
wAt<>r IM l«»arh m»tals fc chem-
lc«l«» |>art Iciil^te resplra-
Oip^ne - Moderate
1 "o~TlTq h for the
<|rn«*ral public
I. Hl
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