REGION I
EMR 1985
-------
United States
Environmental Protection Agency
Region I
ENVIRONMENTAL MANAGEMENT REPORT
1985
Michael R. Deland, Regional Administrator
Paul G. Keough, Deputy Regional Administrator
Compiled by:
Administrative Services Division
Harley F. Laing, Director
Norman L. Willard, Plan./Eval. Brch.
Paul L. Cirello, Reg'1 Admin, Office
Jonathan V. Jacobson, Prog. Intern
September 1985
-------
1985 Environmental Management Report Update
Region I
Table of Contents
Part I RA's Overview/Executive Summary 1-1
Part II Regional Environmental Problems
Ranking Criteria and Problem Ranking II-O-l
Problem Summary Sheets I1-0-2
Issue #1 Coastal and Marine Environment II-1-1
o Boston Harbor
o Ocean Disposal of Dredge Spoil
o Bays and Estuaries
Issue #2 Toxics I1-2-1
o Air Toxics
o Toxics in Drinking Water
o Lead Poisoning
o Case Study: Ten Mile River
Issue #3 Ground Water Protection II-3-1
o Leaking Municipal Landfills
o Underground Storage Tanks
o Pesticides
o Case Study: Cape Cod Aquifer Management Plan
Issue #4 Waste Reduction, Treatment, and Disposal I1-4-1
o Wastewater Treatment
o Hazardous Waste
o Municipal Landfills
o Low-Level Radioactive Waste
o Case Study: General Electric — Pittsfield, MA
Issue #5 Long Range Transport II-5-1
o Acidic Deposition
o Ozone
Issue 16 Water-Related Land Management I1-6-1
o Non-Point Source Pollution
o Wetlands
Part III Regional Recommendations for the Agency Priority
List FY 87-88 III-l
-------
PART I
REGIONAL ADMINISTRATOR'S
OVERVIEW/EXECUTIVE SUMMARY
-------
New Englanders are a special breed. We live in the northeastern
tip of the United States, in part because we place high value upon the
unique quality of life and the clean environment which characterize this
area. We jealously guard our independence and way of life. We take
pride in our mountains, treasure cur accessible open spaces, forests
and farmlands, and appreciate the undeniable contribution that clear
rivers and lakes and healthy oceans and estuaries make to this quality
of life.
The Region I Environmental Management Report (EMR) Update presents
issues which are of greatest interest to New Englanders. These issues are
all number one priority concerns in the Region and pose serious immediate
or potential threats to our public health or environment. In all cases,
public awareness and demand for action is high. Finally, while many of
the issues fit neatly into media categories, most stubbornly disregard
these designations and require creative integrated response strategies.
This EMR Update is notable in that, for the first time, we solicited
state and interest group participation in the development of the initial
problem list, in reviewing problem statement discussions and in ranking
the Region's most significant problems. In all instances, we found these
external contributions to be thoughtful and helpful to us in producing
a document which is both more complete and reflective of a broader set
of perspectives. I hope that this experience can serve as the first
step in greater external participation in the range of Agency planning
processes.
MOST SIGNIFICANT ENVIRONMENTAL PROBLEMS
Coastal and Marine Environment - The most prcminient natural feature
in New England is the coastal and marine environments which define our
eastern profile. For centuries, industrial and domestic effluents,
combined sewer discharges and non-point source runoff have polluted our
estuaries and coastal waters. Boston Harbor, a vital commerical, recre-
ational and historical center is grossly polluted as a consequence of
outdated and poorly maintained urban wastewater treatment plants and
combined sewer overflows.
Because of the importance of shipping to the Region, our harbors,
ports and channels require regular maintenance dredging of sediments,
seme of which are contaminated by conventional and toxic pollutants.
The ocean disposal of these sediments poses a complicated environmental
engineering problem. Estuarine studies, initiated this year for Long
Island Sound, Buzzards Bay and Narragansett Bay, highlight the severe
pollution problems confronting New England's bays and estuaries.
Toxics - Over a span of only a few years, EPA has shifted its regulatory
emphasis from conventional pollutants to toxic pollutants. Substances
ccmmonly referred to as toxic pollutants constitute a broad and varied
group. The substances of greatest concern in New England are pesticides
and herbicides that can infiltrate surface water or leach into ground
water, volatile organic compounds that can be released into the air
-------
from landfills or as by-products of industrial activity, asbestos that
was widely used as building material and lead, which is deposited in
soils fron vehicle emissions and fron leadbased paint that has peeled
or has been scraped from older, painted wood structures.
In this problem summary, a case study of the Ten Mile River (ac-
tually 20 miles long), which receives toxic metals discharges from 18
major industrial and 2 major municipal sources, is presented. During
low flow conditions, approximately 90% of the entire stream consists
of wastewater effluent.
Ground Water Protection - New England is heavily dependent upon ground
water for drinking water. Fully 80% of the region's community water
systems utilize ground or combined,ground and surface water sources and
an estimated 95% of the rural population relies exclusively upon ground
water for drinking water. Over the past ten years there has been
steadily mounting evidence that New England's shallow aquifers are
vulnerable to contamination frcm a variety of sources, including;
hazardous waste sites, municipal landfills, surface impoundments, pes-
ticide applications, underground storage tanks and, in many areas,
pressures from expanding residential and commercial development.
In this problem summary, a case study of the Cape Cod Aquifer
Management Plan is emphasized. This innovative project is designed to
focus and coordinate local, state and federal efforts to protect one of
the region's sole source aquifers.
Vfaste Reduction, Treatment and Disposal - A critical shortage of envi-
ronmentally sound waste treatment and disposal capacity in Region I
and the continually increasing rate of waste production of all types
combine to pose a major waste management problem. The situation is
becoming even more urgent as a result of three principal factors -
1) the impending loss of existing facilities which may close rather than
comply with stricter RCRA requirements, 2) the rapidly increasing cost
of hazardous waste management and transportation and, 3) the increasing
public opposition to siting of waste facilities.
In this problem summary, four aspects of New England's waste
problem are examined: hazardous waste, wastewater, munipical landfills,
and low-level radioactive wastes. A case study on discharge of PCS
wastes into the Housatonic River frcm the General Electric plant in
Pittsfield, Massachusetts, is also included.
long Range Transport - Long range transport of air pollutants is a
major problem in New England simply because we are downwind frcm both
the most heavily industrialized regions of the nation and one of the
most heavily travelled motor vehicle corridors. It is estimated that 65
to 80% of the acidic deposition in New England is caused by long-range
transport. Similarly, on most days when the national standard for
ozone is exceeded in Region I, a significant part of the problem is
transported ozone. Even though long-range transport poses a major
tlireat to public health and the environment, solutions to the problem
have been elusive.
1-2
-------
Water-Related Land Management - In New England, a wide range of land-
use practices degrade our water resources. The region's water resources
continue to be adversely affected by nonpoint sources of pollution
resulting from agricultural, construction, and industrial activities.
Since the pilgrims first landed in New England, expansion growth has
encroached upon our freshwater and saltwater wetlands, which are particu-
larly vital, productive and irreplaceable natural resources. Non-point
source pollution and wetland protection are emerging environmental
issues of unquestioned significance for New Englanders.
REGIONAL ACCOMPLISHMENTS
We are proud of our accomplishments. In the past year, the Region I
team continued to exhibit strong conmitnent to fulfill our public
trust to protect the public health and environment. The following are
a few selected highlights of our principal accomplishments.
Enforcement continues to be our number one priority in Region I.
In the past year, we built upon our 1984 record setting performance and
initiated several new programs aimed at specific sectors of the regulated
community. For example:
0 To put a stop to the long standing violations of the Clean Water
Act by the Metropolitan District Conmission (MDC), the Department
of Justice, on behalf of Region I, filed federal court action against
the MDC, the Commonwealth of Massachusetts, the newly formed Water
Resources Authority and the Boston Water and Sewer Commission.
This action is essential to ensure that the long delayed Boston
Harbor clean up will be implemented, and implemented as fast as
possible.
0 Successfully implemented the National Municipal Policy, which
requires the completion of a schedule for cities and towns to
comply with the July 1988 deadline for secondary treatment.
Fully 90% of our communities have developed such schedules, and
by the end of FY85 we hope to have 100% compliance with this
requirement.
0 Aggressively conducted an audit program to ensure that communities
implementing approved pretreatment programs. The Region has is-
sued several Administrative Orders to communities which are not
implementing this critical program.
0 Intensified a campaign against fuel switching and tampering with
emission control equipment on motor vehicles and installed a toll-
free "hot line" for citizens to report violators. Inspections,
previously conducted by Headquarters, at dealerships, repair shops,
gasoline stations and fleet service operations together with the
establishment of toll-free "hot line" has produced information
on several important violators that resulted in prosecution.
1-3
-------
0 Developed a timely and appropriate enforcement policy for federal
facilities under RCRA. This policy was subsequently adopted across
the nation and incorporated into the 1986 RCRA implementation stra-
tegy.
We are equally proud of the many program accomplishments that we
achieved in the past year.
0 Denied 301(h) waiver applications for Boston Harbor and Salem
Harbor in Massachusetts. These decisions ensure that sludge will
not be discharged directly into the relatively shallow, basin
shaped Massachusetts Bay and will protect many known and unknown
potential adverse environmental impacts.
0 Initiated comprehensive environmental studies in Narragansett Bay,
Buzzards Bay, and Long Island Sound, three of New England's most
valued estuaries. These projects are part of the four estuary,
multi-million dollar effort funded by a special Congressional appro-
priation in FY85.
0 Established a Ground Water Protection Office and distributed
$600,000 in ground water grants to the New England states.
Initiated an innovative comprehensive ground water protection
plan for the sole source Cape Cod aquifer, which emphasizes
contamination prevention not reaction. We are hopeful that this
pilot project (which includes strong cooperation with the Common-
wealth of Massachusetts the Cape Cod regional planning authority
and local officials) will provide many useful lessons, which can
be applied to the management of other aquifers.
0 Coordinated the development of permit and compliance efforts on
the Ten Mile River in Massachusetts and Rhode Island to ensure
that individual water discharge permits incorporate toxic limits
based upon a complex evaluation of the toxic loading capacity of
the stream. This is the first such effort in New England.
0 Signed the first cooperative agreement in the country at the
Nashua, New Hampshire, Superfund site. The ground water at this
site will be cleansed over a two-year period by a mobile treatment
facility at an estimated cost of $5.4 million.
0 Conducted 15 emergency actions under Superfund this year. Twelve
of 13 asbestos emergency response actions in the country were
conducted in Region I, and one emergency water supply was instal-
led.
0 At the Silresim Superfund site, Region I worked with 204 respon-
sible parties, which formed the nation's first of its kind respon-
sible party trust to conduct the Remedial Investigation/Feasibility
Study for this site. At the Ottati and Goss site, completed the
nation's first trial on the merits of Superfund. And, at the
Keefe Environmental Services site, completed the first major
party "cash-out" in the country with 117 responsible parties at
a value of $5.7 million.
1-4
-------
0 Developed a wetlands strategy for Region I. As part of this
strategy, the Region will prepare a list of priority wetlands
in New England. The Region also initiated a §404(c) process
to provide for public review of a proposed Army Corps of
Engineers permit to develop a shopping nail in Sweedens Swamp
in Attleboro, Massachusetts.
0 Testified before the Connecticut Legislature to endorse the defeat
of a bill which would have repealed the states Inspection and
Maintenance program. This is a particularly important achievement
since ozone is a criteria pollutant of greatest concern in southern
New England. We also testified before the New Hampshire Legislature
to encourage it to institute an inspection and maintenance program
for the Nashua area. In both cases, we threatened to withhold
federal highway and sewage treatment construction funds and, in
both cases, the inspection and maintenance programs prevailed.
0 Established one the nation's three Asbestos Information Centers
at Tufts University with a $250,000 grant. The Center will develop
and implement pilot education programs and informational services
geared towards groups that have direct impact on asbestos exposure,
including: school and health officials, contractors and building
owners, and managers.
0 Awarded a joint grant to the New England Interstate Water Pollution
Control Commission and the New England States for Coordinated Air
Use Management to provide technical assistance and coordination for
toxic pollution issues of concern to all New England states. The
first product from this new venture was a three-day risk assessment
seminar.
0 Established a VOC Task Force which has gone through both the state
and EPA inventories and identified 591 sources subject to VOC reg-
ulations in New England, listed these sources by CTG category and
identified the date each source must be in compliance with new
emission limitations. We have also initiated a program to train
state and federal inspectors to insure that they are familiar with
the regulations, methods of control, and inspection techniques.
0 Pursued an active recruitment of capable minority employees. In
1985, with an 81% increase, Region I exceeded the performance of
all other regional offices and ranked sixth among the twenty-seven
offices in the entire Agency.
In concert with our obligation to fulfill EPA's statutory respon-
sibilities, we will continue to work with the New England States and
environmental groups to seek creative ways to protect our public health
and environment. For example, this Spring I implemented a smoking ban in
all Region I offices, and I am working with my colleagues fron other Region I
federal departments to adopt a government-wide ban. This was a compara-
tively easy decision to implement - because of the unquestionable health
benefit.
1-5
-------
As we wrestle with the complexities of cleaning up oar hazardous
waste sites and our (Boston) Harbors — tasks that consume billions of
dollars and decades — we must always seek the simple steps that we as
individuals can daily take to protect our health and environment.
EMERGING ENVIRONMENTAL PROBLEMS
The future holds many new challenges. The nature of these challenges
will be shaped, in large measure, by three factors. First, technological
advancements in measuring minute quantities of pollution, down to parts
per trillion and even parts per quadrillion, moves at considerably faster
pace than our ability to understand the risks associated with exposure
to these quantities over long periods of time. Second, public interest
and reaction to the discovery of an environmental problem or the need
to site an environmental management facility is instant and unyielding.
And, third, changing demographic, economic, and social forces will con-
tinually create a new and different set of environmental problems com-
pounding the problems we currently face.
These factors contribute to concern for a number of emerging
environmental problems in Region I.
0 New Englanders are very concerned about accidental and planned
releases of air toxics into our environment. The concern stretches
beyond deep concern for industrial releases to a rapidly emerging
concern about risks associated with exposure to air toxic emissions
in indoor environments.
0 Formidable public opposition to the siting of wastewater treatment
plants, hazardous waste treatment facilities, low-level radioactive
waste sites, and municipal landfills is cause for great concern.
Citizens and communities seem unable to resolve the conflict be-
tween the desire to manage our wastes in an environmentally sound
manner and the need to site a treatment facility. This inability
represents one of the greatest political challenges that we face.
0 The expanding high-technology economy of New England presents
growing concerns about the direct and indirect environmental and
public health risks posed by these industries. How will planned
releases of new genetically engineered organisms affect public
health and how will the exotic array of chemicals used in the
research and production of high-technology components affect our
environment?
For the most part, we have solved the easiest problems by removing
gross amounts of conventional pollutants from our air, water, and land.
We are now confronted with toxic pollutants in minute quantities which
move freely from one media to another, sometimes as a direct result of
clean-up actions that we take.
1-6
-------
The Environmental Management Report contains not only the descriptions
of our roost significant problems and prescriptions for action but it also
reflects the ongoing ccmmitment by Region I staff to aggressively protect
the New England environment.
Michael R. Deland
Regional Administrator
1-7
-------
PART II
REGIONAL
ENVIRONMENTAL PROBLEMS
-------
Ranking Criteria and Problem Ranking
Region I
Ranking Criteria:
1. Nature and size of population potentially affected
2. Seriousness of public health risks posed
3. Nature of environmental resources threatened
4. Immediacy of the problem
5. Level of public concern
6. Magnitude and severity of the problem
Problem Ranking:
1. Air Toxics
2. Hazardous Waste
3. Toxics in Drinking Water
a) Leaking Municipal Landfills
b) Underground Storage Tanks
c) Pesticides
4. Ozone
5. Acidic Deposition
6. Wetlands
7. Boston Harbor
8. Lead Poisoning
9. Bays and Estuaries
10. Municipal Landfills
11. Wastewater Treatment
12. Ocean Disposal of Dredge Spoil
13. Non-Point Source Pollution
14. Lov^-Level Radioactive Waste
II-O-l
-------
Rank/Problem
1985 EMR Update — Region I
Problem Ranking and Summary Chart
Geographic
Scope
Major
Sources
Major
Impacts
Contaminants
of Concern
Level of
Public Concern
1) Air Toxics
Regionwide
building materi-
als; bedrock;
hazardous waste
facilities;
woodstoves; WWTPs
Public health:
cancer, birth
defects, etc.
Asbes tos; forma1-
dehyde; radon;
volatile organics
High and increasing
due to concern about
health effects
2) Hazardous
Waste
Regionwide
Illegal disposal of Public Health:
industrial wastes cancer, birth de-
fects through ex-
posure to conta-
minated air and
drinking water;
damage to water
and air ecosystems
Wide variety of
toxic and hazar-
dous substances
including Dioxin
TCE, and PCBs
High; very high
in communties
adjacent to
hazardous waste
sites
3) Toxics in
Drinking
Water
Regionwide: 77%
of community water
systems rely on
ground water for
all or part of
their supply
Hazardous waste
sites; industrial
discharges; agri-
cultural activi-
ties
Public health:
cancer, birth
defects, acute
toxicity, nervous
system damage;
closed wells
Organics; Pesti-
cides (Temik, EDB,
2,4-D)
High; increasing
with new discoveries
of contamination
3a) Leaking
Municipal
Landfills
Regionwide
Municipal
landfills
Public health
associated with
ground water
contamination;
closed wells
Hydrocarbons,
iron, manganese
High especially
among
environmental
groups
-------
1985 EMR Update — Region I
Problem Ranking and Summary Chart
Rank/Problem
Geographic
Scope
Major
Sources
Major
Impacts
Contaminants
of Concern
Level of
Public Concern
3b) Underground
Storage Tanks
(ground water)
Regionwide;
especially severe
in ME
Underground
storage tanks
Public health
associated with
ground water
contamination:
cancer, nervous
system damage,
anemia & kidney
disease; closed
wells
Benzene & other
gasoline compo-
nents; other
toxic compounds
Moderate and
increasing
3c) Pesticides
Agricultural areas
in N.E.
Pesticide appli-
cation
Public health
associated with
ground water
contamination;
closed wells
EDB, Temik,
2,4-D
Moderate
4) Ozone
CT, RI, MA,
so. NH, and so.
ME
40% vehicles and
60% statonary;
motor vehicle use
in NYC-D.C. cor-
ridor
Respiratory affects
among infants, el-
derly, and people
who suffer from
respiratory ail-
ments; possible
damage to forests
VDCs and NOX
Moderate to high;
media coverage
during ozone season
5) Acidic
Deposition
Regionwide;
particularly
acute in areas
with limited
buffering capacity
Fossil fuel combus-
ion for electric
power generation
and industrial
processes;
automobiles
Widespread, severe,
growing, and per-
haps irreversible
harm to surface
water ecology;
possible damage to
forests and mater-
ials; visibility
and SC>2
Very High
-------
1985 EMR Update — Region I
Problem Ranking and Summary Chart
Rank/Problem
Geographic
Scope
Major
Sources
Major
Impacts
Contaminants
of Concern
Level of
Public Concern
6) Wetlands
Freshwater wet-
lands especially
in so. N.E., so.
NH and central ME
Construction
dredge and fill
practices
Destruction of
valuable habitat;
degradation of wa-
ter quality; loss
of natural flood
and erosion
control
Construction
fill
High in so. N.E.
and central ME
7) Boston Harbor
43 communities
in Boston Metro
area; 2 million
people (40% of
state population)
600/MGD of waste-
water and 2500
tons of sludge; 2
poorly operated
and maintained
WWTPs and 108
CSOs
Public health;
aquatic eco-
systems; closed
beaches, shell-
fish beds, and
fisheries;
aesthetics
Bacteria;
pathogens; heavy
metals; PCBs;
organics;
nutrients;
grease and oils;
floatables
Very high; public
participation and
media coverage
8) Lead
Poisoning
Mainly urban areas;
Boston has acute
lead in soil prob-
lem in certain
neighborhoods
Soil: flaking and
chipping house
paint; water:
solder and pipes
Public health:
brain and nervous
system damage
especially in
children; cardio-
vascular problems
in adults
Lead
Moderate; high in
neighborhoods with
acute problems (e.g.
Dorchester and Rox-
bury in Boston)
9) Bays and
Estuaries
Narragansett Bay
Long Island Sound
Buzzards Bay
Industrial dis-
charges (metal
plating, chemicals,
pe troleum); CSOs;
NPS; malfunctioning
WWTPs
Public health;
closed beaches,
fisheries, and
shellfish beds;
damage to estua-
rine ecosystems
Coliform bacteria;
heavy metals;
organics;
PCBs
High; participation
in Bays Study
management commit-
tees
-------
Rank/Problem
1985 EMR Update — Region I
Problem Ranking and Summary Chart
Geographic
Scope
Major
Sources
Major
Impacts
Contaminants
of Concern
Level of
Public Concern
10) Municipal
Landfills
Regionwide
Homes; businesses;
municipal trash
collection
Shortage of
capacity
Non-hazardous
solid waste
High about siting
11) Wastewater
treatment
Regionwide
WWTPs; CSOs;
sludge
Closed beaches and
shellfishing
areas; degradation
of surface waters;
public health; ad-
verse affect on
recreational and
commercial water
uses
wastewater: coli-
form bacteria,
gross solids,
floatables;
sludge: pathogens,
heavy metals,
toxics
Moderate to high
12) Ocean Disposal
of Dredge Spoil
Coastal areas;
harbors, channels,
and marinas;
especially RI and
southeast MA
Sediment from
harbor, channel,
and marina
dredging
Adverse impacts on
sensitive fish and
whale species from
improper disposal;
delayed dredging
projects due to
lack of disposal
sites
PCBs and other
contaminants
found in bottom
sediments.
High among
environmental groups
and commercial fish-
ing interests
13) Non-Point
Source
Pollution
Regionwide
Agriculture; con-
struction; urban
runoff; CSOs
Damage to surface
water ecosystems;
degradation of
surface and ground
water quality;
associated public
health risks;.
closed fisheries
and shellfish beds
Organics; pesti-
cides; nutrients,
PCBs; heavy
metals; oil;
hazardous mater-
ials
Moderate and
increasing
-------
1985 EMR Update — Region I
Problem Ranking and Summary Chart
Rank/Problem
Geographic
Scope
Major
Sources
Major
Impacts
Contaminants
of Concern
Level of
Public Concern
14) Low-Level
Radioactive
Waste
Regionwide but
especially acute
in MA and CT
Nuclear power
plants; medical
applications;
industry; weapons
research and pro-
duction
No disposal
facilities
Low-level radio-
active substances
and contaminated
material
High about siting
-------
Region I
Issue #1
COASTAL AND MARINE ENVIRONMENT
I. PROBLEM STATEMENT
For centuries, industrial and domestic effluents, combined sewer
discharges and non-point source runoff have polluted the estuaries and
coastal waters of New England, the predominate natural resource in the
Region. Boston Harbor, a vital commercial, recreational, and historical
center, has been rendered grossly polluted as a consequence of outdated,
and poorly operated and maintained urban wastewater treatment plants and
combined sewer overflows. Because of the importance of shipping to the
Region, its harbors, ports and channels require regular maintenance
dredging of sediments, some of which are contaminated by conventional
and toxic pollutants. The ocean disposal of these sediments poses a
complicated environmental engineering problem. In addition, estuarine
studies that were initiated this year for Long Island Sound, Buzzards
Bay and Narragansett Bay have brought attention to the severe pollution
problems of New England's bays and estuaries.
Historical patterns of coastal area settlement and industrialization
indicate where severe pollution has occurred. The resulting degradation
in water quality has seriously impaired recreational and commercial uses
of water bodies. Shellfish resources, for example, have been adversely
affected by bacteria, heavy metals, and organic chemical contamination
from inadequately treated sewage. Public health authorities have also
had to prohibit swimming at a number of beaches. In addition, marine
pollution also endangers sensitive fish species and some whale species.
Where wastewater treatment plants have been built or combined sewer
overflows have been corrected, noticeable improvement in water quality
and water use has resulted. These improvements include: reduced bacteria
counts and lower human health risks; decreased heavy metals and organics
concentrations with a concomitant reduction in toxicity levels in the
marine environment, and smaller loads of such nutrients as nitrogen.
Boston Harbor
As of July 1, 1985, the Massachusetts Water Resources Authority
(MWRA) assumed responsibility for water and sewer operations from the
Metropolitan District Commission (MDC). Serving more than two million
people (43% of the states' population) in 43 communities , the MWRA's
sewer system discharges 600 million gallons per day (MGD) of inadequately
treated wastewater from two primary treatment plants and 108 combined
sewer overflows (CSOs) into the Harbor. Thirty-four of the CSOs discharge
continually. In addition, 2500 wet tons of sludge are discharged into
the Harbor daily. Pollutants, including coliform bacteria, floatables,
oil, grease, solids, BODs, PCBs and heavy metals, pose public health
risks, result in closed beaches and shellfish beds, and in other ways
damage the marine environment and adversely affect Harbor aesthetics.
Despite the formulation of a ten year clean up strategy which includes
the MWRA's tentative decision to construct a secondary treatment plant at
Deer Island, rehabilitation and construction of interceptor sewers, and
II-l-l
-------
CSO correction, and a preliminary treatment plant siting decision, several
issues remain unresolved. Secondary treatment will double the volume of
sludge produced. Although four sludge management options exist (composting,
ocean disposal, landfilling, and incineration), none of them are problem
free and, thus far, a strategy has not been developed. In addition, the
cleanup program is estimated to cost nearly two billion dollars. At
present construction grant levels, local water and sewer rates would
have to double in constant dollars over the next decade.
Public concern is high as evidenced by almost daily coverage in the
Region's major newspapers, public meetings, the creation of 15 advisory
groups, and the attendance of over 4,000 people at public hearings on
siting options for the construction of a state of the art secondary
treatment plantwhich will serve MWRA member communities. The Harbor
problem requires coordination with EPA Region II, numerous other federal
agencies, seven State agencies, three local municipalities, the Massa-
chusetts Water Resources Authority, and the Boston Water and Sewer Commission.
Ocean Disposal of_ Dredge Spoil
Because of natural sedimentation and coastal changes, New England
harbors require periodic maintenance dredging to ensure navigation and
continuation of marine related conmercial activities. Failure to designate
a final dredge material disposal site, however, has delayed many public
and private projects at sites including federally maintained channels
and ports, municipal channels and marinas. Dredging operations are most
affected in the Rhode Island and southeastern Massachusetts region where
there are no disposal sites. Along the rest of the coastline, dredged
materials are currently disposed of at interim sites.
In light of possible impacts on aquatic life including benthic fish
species, shellfish and endangered species of whales, and other concerns,
several studies have been conducted at potential disposal site locations
in Long Island Sound. Other studies are being conducted at interim sites
off the coasts of Maine and eastern Massachusetts. PCBs, which have been
found in dredged sediments have received special attention.
Because New England's coastline is a critically important Regional
resource, public concern is high, especially among fisheries' interests and
environmental groups. Commercial shipping firms often require dredging
to continue business; fishing interests and environmental groups are
concerned with dredged spoils.
Bays and Estuaries
Upper Narragansett Bay in Rhode Island, Buzzards Bay in Massachusetts
and Long Island Sound (LIS) in Connecticut have been polluted by industrial
and domestic wastes since the 1800s. Metal plating, chemical manufacturing
and petroleum transport and distribution comprise the industrial contri-
bution; malfunctioning sewage treatment plants, and numerous combined
sewer overflows account for the domestic portion. Non-point source
runoff also contributes to the problem.
II-1-2
-------
The cumulative effect of pollutants, including microbiological
organisms, man-made organics, and heavy metals, has been the severe
degradation of these coastal waters. In Buzzards Bay, high PCB concentrations
in sediments have also been discovered. The presence of these pollutants
pose a public health risk to consumers of contaminated fish and shellfish,
the loss of fishing areas and shellfish beds (e.g., striped bass fishery
in LIS). In addition, the presence of very low dissolved oxygen levels
(levels near zero have been reported in certain portions of Upper Narra-
gansett Bay) damage estuarine ecosystems.
Public visibility and concern for the Bays is high. Work plans were
developed for the EPA Bays Studies with the aid of numerous public meetings
and public participation in management committees. Management committees also
include representatives from several State agencies and the National
Oceanic and Atmospheric Administration (NOAA). The U.S. Army Corps of
Engineers, the U.S. Fish and Wildlife Service, the U.S. Geological Survey,
and the U.S. Department of Agriculture have also been involved.
II. REGION I AGENDA
Boston Harbor
Since 1980, the Region has issued six Administrative Orders to
correct persistent violations of the CWA at the Deer Island and Nut
Island treatment plants. The Region has also been providing technical
and legal assistance to the Massachusetts Superior Court, as a "friend
of the court" in a civil suit filed by the City of Quincy, MA against
Massachusetts and the MDC. On January 29, 1985, the Regional Administrator
referred the Boston Harbor problem to the U.S. Department of Justice.
The case is being heard in the United States District Court,
District of Massachusetts, and a decision on liability is expected in
September 1985. On March 29, 1985, the Region issued a denial of the
MDC's reapplication for a waiver from secondary treatment requirements
under Section 301(h) of the Clean Water Act.
Current Actions:
o Preparing the Final Environmental Impact Statement (FEIS)
on treatment plant siting options.
o Assisting Massachusetts in evaluating near-term and long-
term solutions to sludge handling and disposal problems.
o Preparation of Draft Supplemental Environmental Impact
Statement (SDEIS) on sludge management.
o Requesting the U.S. District Court to oversee the cleanup
of Boston Harbor through binding compliance schedules for
the construction of necessary treatment facilities and
for development of sludge management programs.
Future Actions Needed:
o Issue a Record of Decision on treatment plant siting
alternatives.
o Press for the near-term elimination of sludge discharges
to the Harbor as an interim solution pending final decisions
on sludge management.
II-1-3
-------
o Initiate treatment facilites planning on the preferred
alternative. Determine sites for barging and staging locations.
o Spur early completion of facilities planning and design for
the primary treatment facilities, and subsequent completion
and operation of secondary treatment and sludge management
facilities.
o Promote the use of mitigation measures to eliminate or offset
impacts of proposed projects.
o Maximize public participation throughout the entire decision
making process (e.g., sludge disposal, treatment plant
siting, mitigation measures).
Barriers to Overcome:
o Limited federal construction grants funds to assist in
financing the construction of needed treatment facilities.
o Complications of interregional decisions with regard to the
use of Mile 106 ocean disposal site as an interim solution
for disposal of sludges now discharged to Boston Harbor.
o Reluctance of the public and many elected officials to accept
impacts associated with potential projects.
o Resolution of responsibility between the MWRA and its 43
member communities for the correction of CSO problems.
Recommended Headquarters Action:
o Inform Region I of developing policy and regulatory require-
ments with regard to sludge disposal practices to assure
that Regional decisions will be based on the best available
information and consistent with future Agency policy.
o Assist the Region in addressing interregional issues in
connection with the use of the Mile 106 ocean dumping
site should that become the selected option.
o Pursue alternative financing mechanisms to address "big-
city" funding problems, such as the use of set-aside or
carryover accounts.
The Region's environmental objectives include the elimination of
sludge discharges to the Harbor, construction of adequate secondary
treatment capacity for all wastewater within the MWRA's area of jurisdic-
tion, and correction of CSO problems which contribute to pollution of
the near shore areas of Boston Harbor. Achievement of the objectives
will result in substantial improvement in the quality of the waters of
Boston Harbor which will be demonstrated by reduced beach closings,
reopening of closed shellfishing areas, and increased recreational and
tourist activity in and around the Harbor.
Ocean Disposal of Ore
The Region's general strategy is to promote continuation and finali-
zation of site designation studies and enter into extended cooperative
arrangements with Army Corps of Engineers for funding and field work
where possible. The scope of these studies should include land-based
disposal alternatives as well as ocean disposal. Currently there is no
substantial action being taken due to a lack of funds.
II-1-4
-------
Current Actions:
o Working with the Corps to arrange cooperative agreement.
o Assisting the Corps in review of tasks that are being
undertaken at the interim ocean disposal sites, until
final designations can be made.
Future Actions Needed:
o Designate three final disposal sites. Include public participation
in the decision-making process.
Barriers to Overcome:
o Insufficient funding for the disposal site designation
process.
o Concerns of environmental organizations and fishing interests
about the environmental impacts of ocean disposal of
dredged materials.
Recommended Headquarters Action:
o Provide the funding support to conduct and finalize dredge
spoil disposal site designations.
Final disposal sites must be designated in order to facilitate
needed dredging operations. At the same time, we must ensure strict
adherence to ocean disposal criteria to minimize environmental impacts.
Bays and Estuaries
Narragansett Bay, Long Island Sound and Buzzards Bay are among four
estuaries funded by a $4 million congressional appropriation in FY-85.
The appropriation is for water quality research, monitoring, and assessment
to be used to subsequently develop strategies to protect water quality,
marine resources and associated public and commercial uses.
Current Actions:
o Assist in development of workplans and long-term strategies.
o Allocate funding for proposals fulfilling workplans.
o Undertake portions of sampling specified in workplan.
o Coordinate activities of other Region I programs which
address the Bays' issue.
Future Actions Needed:
o Develop FY86 workplan by September, 1985.
o Develop wasteload allocation for toxics and conventional
pollutants discharged to Upper Narragansett Bay.
o Determine the extent of toxic contamination of fish and
shellfish in Long Island Sound.
o Determine the potential for low dissolved oxygen concentrations
in the western portion of Long Island Sound.
o Determine sources of microbiological pathogens which lead to
shellfish bed closures in Buzzards Bay.
Barriers to Overcome:
o Lack of coordination among the numerous state and federal
programs which affect the individual Bays.
II-1-5
-------
o In Massachusetts, the delegation of regulatory and enforcement
powers among a number of local community authorities (e.g.,
zoning boards, public health agencies) has resulted in a
lack of consistency in regulations and lack of regionwide
planning.
Recommended Headquarters Action:
o Development of national data management system for estuaries.
o Development of Bays Program QA plan.
o Development of accountability measures for problems having a
geographic focus which cuts across program lines.
o Provide funds for implementation.
o Delegate grant making authority to the Regional Administrator.
The result of the Bays studies will be used to develop permit limits
for industrial and municipal dischargers and projects to abate non-point
source pollution (e.g., urban and agricultural runoff, CSOs), and to
establish priorities for inspections of discharger compliance. Analyses
of coastal water contamination may also be used to justify the need for
additional wastewater treatment capacity. Such measures will serve to
protect human health and aquatic resources by reducing the level of
conventional and toxic contamination in these waters. The environmental
indicators which may be used to measure progress are acres of shellfish
beds reopened for harvesting, the number of days the beaches are closed,
and background levels of toxicants in finfish and shellfish.
II-1-6
-------
Region I
Issue #2
TOXICS
I. PROBLEM STATEMENT
Over the span of only a few years, EPA has shifted its regulatory
emphasis from conventional pollutants to toxic pollutants. Substances
commonly referred to as "environmental toxics" or "toxic pollutants"
constitute a broad and varied group. They include, for example, pestcides
and herbicides that can infiltrate water supplies from runoff into surface
waters or leach (migrate) into groundwater, volatile organic chemicals
that can be released into the air from dump sites or as by-products of
industrial activity, asbestos that was widely used as a building material,
and the toxic metal lead, which is deposited in soils from automobile
emissions and from lead-based paint that has peeled or has been scraped
from older, painted wood structures.
Although these and other toxics will vary in terms of their physical
and chemical properties, as environmental management problems and as
important public health issues, they often share sane common attributes.
- Concern focuses on low-level chronic exposure to toxics
Toxics are usually found in the environment at low concentration.
Human health concerns tend to focus on chronic exposure. In the
past, toxics were not seen as a significant environmental issue;
only recently have we developed the technical capability to detect
minute concentrations of environmental toxicants and to estimate
exposure rates. There remain major information gaps in our knowledge
of toxics substances and their effects — we lack adequate data, for
example, about the persistence and effects of toxics in the human body
(and in the environment), and we are only beginning learn about the
risks that may be posed to human health by prolonged exposure to
different toxic agents at low levels.
- Exposures to toxics can be multi-media
People can be exposed to toxics in a number of ways. Breathing air,
drinking water, eating food, contact with the skin are among possible
exposure pathways, depending on the characteristics of the particular
toxicant under study and where and in what form it is found in the
environment. From an environmental management standpoint, some treat-
ment and disposal methods can transfer toxics from one environmental
"medium" to another, altering concentrations, characteristics, and
exposure pathways, and ultimately, impacts on human health.
- Exposure is to a complex mixture of toxics
People can be exposed to a wide mix of individual toxic substances.
Little is known about the interactions among them in the environment
or about the risks or possible effects of simultaneous exposure to
more than one chemical.
II-2-1
-------
- Health effects of toxics at these low levels are uncertain
There is widespread public concern that exposure to environmental
toxicants can cause cancer, genetic defects, birth defects or other
health effects. Research into these impacts continues to be carried
out. But given the current limited state of knowledge about toxics
and potential human health effects, it is very difficult to establish
a "risk-free" level for suspected carcinogens.
For these reasons, risk assessment has become an important technique
to decision makers on how to manage toxics in the environment. Risk
assessment components play a key role in establishing program priorities,
setting national and state standards and determining appropriate regulatory
responses to toxic pollution problems.
Air Toxics
The air route of exposure to toxics is coming to be viewed as a major
public health concern. While most of EPA's regulatory emphasis has focused
on the ingestion of toxics, eg. drinking water and eating food, inhaling
toxics may be a problem of equal or perhaps greater importance. Defining
the nature of the air toxics situation presents EPA and states with a highly
complex problem because of the diverse nature of both the pollutants of
concern and the sources of those materials. Seme of the major air toxics
issues for New England are discussed below.
o Indoor Air Pollution. Human health risks from indoor air pollution
may be much greater than from ambient outside air because there can
be higher concentrations of pollutants and because continuing, longer
term exposure is possible (see Table 1). In particular, indoor radon
frcm either building materials, ground water, or underlying soils and
bedrock may pose very serious risks in worst-case areas.
Sources
Table I. Indoor Air Pollutants In Buildings
Pollutant Types
Building contents
Heating and cooking
combustion appliances
Furnishings
Hill uater
Natural gas
Copying machines
Deodorants
Liquid marker blackboards
Carbonless carbon paper
Air conditioning system
Bathrooms, shakers
Flush toilets
•Air fresheners'
Human occupants
Metabolic activity
Coughing and sneezing
Human activities
Tobacco suuke
removal
Cooking
Aerosol sprays
Cleaning products
Hobbies and crafts
GO, to, NOj, formaldehyde, [articulates
Formaldehyde, other organics, mold and
fungi
Radon
Radon
Ozone
Organics
Organics
Microbes, molds, fungi
Bccess humidity
Microbes, odors, disinfectants
Ftamaldehyde. other organics
CO, («3, odors, excess humidity
Microbes
CO, NOj, POM, nitrosamines, partlculates,
odors, irritants
Pesticides
Organics, particulatea, excess humidity
Pluorocarbons, vinyl chloride
t«3, pine oil, chlorophenols
Organic solvents
11-2-2
-------
o Asbestos. Asbestos is a human carcinogen that until recently was
commonly used as a fireprcofing and insulating material. Asbestos
can be a source of indoor air pollution. It can also be emitted
when buildings are demolished or renovated, and can be released
from asbestos-contaminated dump sites if not properly contained.
o Intermedia Transfer. There are a variety of ways toxics can be
transferred from other environmental media to the air medium.
Hazardous waste sites, for example, may contain volatile solvents
that can evaporate into the air or be released air when contaminated
soils are moved during site cleanup activities. Volatilization can
occur when air stripping is used a treatment method in a water
cleanup operation or when industrial wastes with certain toxic
constituents are discharged into a wastewater treatment facility.
It is possible for toxic air emissions to be released when toxic-
contaminated sludges are incinerated.
o Woodstoves. In many parts of rural New England, woodstoves are
a primary source of residential space heating. Stoves can leak
potentially toxic particulates and possibly harmful incomplete
wood combustion by-products indoors. Toxicological research
is underway in this area.
o Waste Treatment and Disposal. Increased pressure to switch from
landfills to waste incineration as a solid waste disposal option
1 may result in increased -toxic air emissions.
For these air toxics sources (and others not discussed here), actual
exposure and risk data is incomplete or not available. Although some data
is available for particular problem sites, air monitoring for toxics is not
routinely done because it is technically difficult and expensive.
In addition to these chronic releases of air toxics, the industrial
accidents in Bhopal, India, and Institute, West Virginia, have focused
attention on the importance of reducing risk from accidental release as
well. Current EPA strategy involves establishing an acute hazards list
for the chemicals of greatest concern, developing guidance for contingency
plans in case of emergencies, and enhancing state and local capabilities
to respond to such releases.
Toxics Iji Drinking Water
Contaminated drinking water is among the more widely known and
troubling of environmental and public health problems. In New England,
77% of comnunity water systems serving 20% of the population rely on
ground or combined ground and surface waters sources for their drinking
water; over 95% of the Region's rural population relies on it exclusively.
This reliance, together with a comparatively high water table, make New
England especially vulnerable to contamination from hazardous waste
sites and leaking underground storage tanks (see Issue #3).
Drinking water contamination can also occur in water distribution
system. For example, lead has historically been a concern in the Boston
water system, and the use of lead/tin solders is a matter of potential
I1-2-3
-------
concern that is currently being investigated problem (lead is discussed
in more detail below). Two other significant categories of potential
drinking water contaminants are discussed below.
o Organic Chemicals. The contamination of ground water by organic
chemicals is generally associated with a hazardous waste site,
an industrial discharge to surface waters or the ground, or a
leaking underground storage tank. The impact is most often seen
in private wells. The contaminants of concern are generally
volatile organic compounds. While there are no final federal
standards for these chemicals, EPA has established recommended
maximum contaminant levels (RMCL's) for nine compounds for
drinking water. As is the case with many chemicals, the health
effects fron exposure to multiple chemicals at the low levels
found in most drinking water supplies are unclear at this time.
o Pesticides. In New England, there is growing concern about pesti-
cide contamination of ground water, particularly in agricultural
areas and along utility and transportation rights-of-way. In one
unfortunate incident in Whatley, Massachusetts, 90 percent of the
town's private wells were found to be contaminated with EDB and
rendered ususable. Residents had to find the financial means to
develop a new public system to meet the drinking water needs of
the community.
Lead Poisoning
Unlike many toxicants, there is considerable information available
relating to the human health effects of lead, and in particular, neurological
damage to infants and young children. There is also evidence that lead
is linked to cardiovascular problems in adults. EPA has regulated levels
of lead in drinking water for several years, and has also set standards
for concentrations of lead in gasoline to reduce exposure to lead from
? no-
fi
or
o
£ «.
i
£ |0-
'c
O
M ID.
k ™
2.
•o
5 ia
*
•
Baoiai 0»u t knUu on BBkctag Lad ia CuoUa*. B* UO-W-M-aoi. Mi.. 1
Lead Used in Gasoline Production and
Average Blood Lead Levels
(February, 1976 to February, 1980)
Nc^
* \ \
X
V-^ A
\ A /\
'•• YA
' \\
\\
A
fc
n m mn mn •» MO •
•3
•a
,J
•u<§
1
•a -o
5
«
•n i
S
•• i
4
.« Ugcnd
O Uod te t«»«t>»«
A k!H>«*t*-
«
II-2-4
-------
motor vehicle emissions. However, historic emissions of lead into the
air, combined with lead from other sources such as paint, have left a
legacy of lead accumulation in urban soils that continues to pose a
public health problem in spite of our current regulatory efforts.
o Lead In Gasoline. As shown in the graph, there is a direct
relationship between lead content in gasoline and in human
blood lead levels. EPA has recently reduced allowable lead
levels from 1.1 grams/gallon to 0.5 grams/gallon, and in
January 1986 the standard will be lowered to 0.1 grams/gallon.
o Lead In Soil. Significant numbers of lead poisoning cases
continue to be reported as a result of contaminated soil. Lead
concentrations in many northeastern soils exceed the 500-1000
ppm threshold of concern established by the Centers for Disease
Control, and frequently reach 5,000 to 10,000 ppm. Analysis of
thousands of soil samples in Boston over the past five years
indicate an average lead content of 600-700 ppm. In the 16
worst-case census tract areas in Boston shown below, the average
soil concentration is 2,000 ppm.
IS
'S$sǤ
B
f?3?$
£$<$£
*$£*§
-$&'
?£&
V|ii:$8
tfSfS
ij^i
Hi';f^
;V';3vji:
Si;'i-:''
i&JMe
•&"•?£
!£•§£>
?!$£;
S&&
^Sjfc*
Plfe
353£;;
ffevS
i£M?
pi
US
•i|$i
1
Concentrations
Census Tract
802
903
906/913
913(east)
913(west)
914 (east)
914(west)
915 (north)
915(south)
917/918
917/920
923
924(s-w)
924(n.)
924(s-e)
1001
1(102
1004
1005(e. )
1005(w. )
1011.02(north)
1011.02(south)
ft Poisoned
Children ft
29
26
31
17
36
18
23
35
39
46
82
43
49
11
26
19
30
22
9
28
48
27
Blocks
1-2
6
5
3
4
2
3.5
4
5
6
9
5
6
1
3.5
4
1-2
3
1
3
11
4
Source: Boston Childhood Lead
*
Boston office
>25ug Pb/dl in blood
of Pb-Poisoned* Children
ft Poisoned
Children/Block
14.5-29
4.3
6.2
5.7
9
9
6.6
8.8
7.8
7.6
9.1
8.6
8.2
11
7.4
4.8
15-30
7.3
9
9.3
4.4
6.8
Poisoning Report, Draft,
ft streets
4
8
7
6
8
4
7
8
6
12
15
10
11
3
7
6
5
5
3
7
11
7
June 17,
ft Poisoned
Children/street
7.3
3.3
4.4
2.8
4.5
4.5
3.3
4.4
6.3
3.8
5.5
4.3
4.5
3.7
3.7
3.2
6
4.4
3
4
4.4
3.8
1985
of Environmental Affairs
II-2-5
-------
Children are exposed to lead in soil in normal hand-to-mouth
activities that result in inadvertant soil consumption. Frequency
of lead poisoned children in the 16 worst-case Boston lead census
tract areas are shown below. In one tract, an average of 7
children per street segment were poisoned with lead.
Lead In Drinking Water. The current drinking water standard for
lead is 0.05 mg/1. This level may be lowered based on data
showing possible health effects at lower levels. EPA has worked
with Massachusetts to lower lead in the greater Boston by con-
trolling corrosive water before it enters the distribution system.
Problems may persist because of contamination from the materials
found in lead/tin solders which are used for piping connections.
Preliminary results from a screening done of 285 samples from
Region I employees' home drinking water show that 11% of the
samples exceeded the current maximum EPA standards for lead. In
1985, Massachusetts became the fifth state in the country and
the first in New England, to ban the use of lead solder in potable
water systems.
II. REGION I AGENDA
Air Toxics
The Region has focused primarily on providing technical and program
assistance to states to develop air toxics control programs. It has also
been involved with states investigating problems at particular sites.
Current Actions:
o Conduct air monitoring and assist in the interpretation of
health effects data and lab analysis.
o Help the states to develop implementation plans and conduct
training program for them. The Region has recently hired
an expert Air Toxicologist to assist in health effects
evaluation.
o Give greater emphasis in the Regional operation to the inter-
media transfer of toxics into the air, particularly from
hazardous waste sites being cleaned-up under the Superfund
program (See Issue #4)
o Awarded a grant to NEIWPCC and NESCAUM to hire an air toxics
coordinator.
Future Actions Needed:
o Assist states in developing air toxics problems, monitoring
for air toxics, and interpreting the resluts of monitored
or modeled levels of air toxics.
o Improve the understanding of the health effects of air toxics.
o Implement relevant aspects of the national air toxics plan.
o Develop better data concerning intermedia transfer.
o Develop better emissions data for sources of air toxics.
Barriers to Overcome:
o Lack of sufficient technical information describing
II-2-6
-------
the nature of the problem (eg., ambient air monitoring data).
o Absence of clear statutory authority to deal with many of
the most significant problems of toxics, particularly indoor
air pollution.
o Insufficient resources allocated.
Recommended Headquarters Action:
o Give greater recognition of air toxic activities in national
resource distribution.
o Increase levels of technical assistance so that regions and
states can better understand the nature of the problem and
develop appropriate control strategies.
o Recognize the importance of problems that may be posing
significant risks, but which are not currently being
addressed, like indoor air pollution.
Toxics In Drinking Water
The Region is currently involved in a wide variety of activities
related to drinking water contamination. The Superfund and RCRA programs
in particular are devoted in large part to cleaning up and preventing
groundwater contamination (See Issue #4).
Current Actions:
o The Region provides technical assistance to states in risk
assessment and the evaluation of public health effects
due to drinking water contamination as well as laboratory
support for the analysis of drinking water samples.
o Under FIFRA, the Region provides states with grants to
certify pesticide applicators and to enforce applica-
tion requirements.
o Implementing the Health Advisory Program for new VDCs
o Assisting states in their pesticide surveys.
Future Actions Needed:
o Implement new federal guidelines for VDCs and pesticides
as scon as they are promulgated.
Barriers to Overcame:
o Time delays in setting national standards.
o Knowledge of health effects from multiple chemical exposures.
o Inconsistent drinking water guidance levels across states.
o Inconsistent EPA policies for allowable levels of pesticides
levels in drinking water.
Recommended Headquarters Action:
o Provide regions with rapid turnaround on Health Advisories
and other guidance levels.
o Provide regions with additional support documentation on
established criteria.
o Move faster to establish national standards for organics and
pesticides.
o Assure consistency among EPA's recommended and enforced
levels.
II-2-7
-------
Lead Poisoning
Over the past five years, Region I has analyzed soil samples, provided
technical assistance to other levels of government on exposure mitigation
and exterior deleading techniques, served on many community lead advisory
committee and met with many numbers of interested citizens concerned about
lead exposure risks.
Current Actions:
o Working with the Boston Preventive Deleading Committee to
identifying the extent of environmental contamination
and human exposure to lead in soil.
o Increase enforcement efforts to prevent the introduction
of leaded gasoline in cars designed for unleaded gas.
o Sampling drinking water for lead to test for a correlation
between lead levels in water and the use of lead in solder.
Massachusetts has banned this use of lead in solder.
o Testified before the Massachusetts legislature on behalf
of a bill to prohibit the use of lead solder. The bill
was recently signed into law.
Future Actions Needed:
o Evaluate EPA statutory ability to respond to all dimensions
of the accumulated lead problem, including lead in soil.
o Evaluate the Boston Preventive Deleading Committeee
proposal, which requests that EPA use Superfund in reponse
to lead contamination in targeted areas of the city.
o Develop and implement strategies to ensure that all current
and future EPA participation in this problem is complemented
by corresponding state, local, and citizen action to
eliminate and/or prevent exposure.
o Evaluate results of the regional Lead in Drinking Water survey
to document the need for either additional studies covering
a larger area or to restrict the use of lead/tin solder.
Barriers to Overcome:
o Lack of clear EPA authority to address the lead issue.
o Lack of adequate resources.
Recommended Headquarters Action:
o Evaluate the Boston Preventitive Deleading Committee's
statement on the use of Superfund and/or other Agency
authority to address problems like lead in soil and
resultant human health impacts.
o Conduct a nationwide sampling program for lead in drinking
water to determine if lead/tin solder for piping connections
should be banned.
II-2-8
-------
CASE S*UD2: TEfcl MILE
I* KXBLEH
' The Ten JHile Riye-r .flows for-- 2$ mile& tlir^ugtv -industrialised
areas of southeastern Massachusetts -and eastern Rhode Island.
Almost half of '. the- river /. .is i£ed by • j3ams,: ;,and a good portion
of the remaining length is encased in aaiMaade'vaLts* The
Massachusetts portion of the Ten Mile receives, waste from 18 major
ixidustrial ai*3v 2 major rstocipal dlscfearl^^jllpnyoOf -whi<^i ara
associated with the jewelry and metal 'fiMshin0 industry*
of ^eoxic^&taia-ic ^^stss^'frotf'lihese sources are
causing major water quality problems for the Ifen Mile. Surveys
cm#ueted in 1984 fotttid a:,widelrar^ of jptals? in the vater ODlurnn
and in the sediment inching calete technicial work on the River study and issue
NPDES permits^ associated administrative orders and
coraplianos schedules, by the end of FY 85.
o Bold a public hearing on the draft NPDES permits.
••- future Actions- Needed * ; ; ... .=
o Finalize draft NPIBS perndts, and oversee the conditions
of those permits and the associated order.
i ' '"•:'-'- •' •• v - -•.-•>•-; .. - ;........
Barriers to Overcome:
o lack of realistic water quality goals and stream uses for
severely polluted streams such as the Ten Mile River.
o Unresolved treatment requirement issues:
; * Are the; treatment requirements technically feasible?
- How should eoonoftic factors be considered?
Recommended Headquarters' Action: ;v
o Ensure that all Regions and states implement consistently
stringent water quality based: effluent limits so that
there are not inequities among different geographic
. areas. ... ...• . •
I1-2-9
-------
Region I
Issue #3
GROUND WATER PROTECTION
I. PROBLEM STATEMENT
Approximately 20% of New England's population (nearly 3 million people)
depend on ground water as their sole source of water supply. Moreover,
2,087 community water systems (80%) utilize ground or combined ground and
surface water sources and an estimated 95% of the region's rural population
rely upon ground water for drinking water, over the past 10 years there
has been steadily mounting evidence that New England's shallow aquifers
are vulnerable to contamination from a variety of sources, including:
hazardous waste sites, landfills, surface impoundments, pesticides, and
underground storage tanks.
One indication of the extent of ground water contamination is that over
280 private wells and 50 public wells in 5 states (no data was available for
Maine) were closed between 1980 and 1982. The New England states reported
that in 1983 the ground water in 108 towns was seriously contaminated in
at least one location by toxic organic pollutants. These reported incidences
are almost certainly an underestimation of the size of the problem.
New England's soil types are highly permeable and susceptible to
the leaching of contaminants through the surficial geology to the bedrock
layer. This, coupled with the generally high ground water table, allows
foreign materials such as spent solvents, pesticide residues and petroleum
products to quickly penetrate the soil layer and reach the ground water.
State agencies have historically been more involved in subsurface
regulatory programs than EPA. Their experience combined with a fragmented
and limited Federal ground water response, leaves a principal role for
the states. In addition, the states have traditionally cooperated with
local governmental units, which are the first line of defense for ground
water protection activities.
Local governments must be provided the tools for making proper ground
water management decisions, specifically in the area of land use control.
Along with state and local governments, EPA works closely with the U.S.
Geological Survey with its ground water expertise, and U.S. Department
of Agriculture (USDA) and Soil Conservation Service (SCS) both of which
have involvement in and knowledge of agricultural activities.
Early state and federal response has been required to respond to the
variety of potential sources of contamination which threaten New England's
ground water resources. Recently, as a result of the Hazardous and Solid
Waste Amendments of 1985, our regulatory capacity to respond to hazardous
waste sources of contamination has been significantly expanded. The Waste
Amendments, for example, provide EPA with the new and broader authority
to pursue ground water protection at land disposal facilities. These
facilities are of great concern because they are principal sources of
ground water contamination in Connecticut and Massachusetts.
The following are brief discussions of the other sources of ground
water contamination which are of greatest concern in New England.
II-3-1
-------
Lsaking Municipal landfills
Leachate from poorly designed and overloaded landfills contaminates
ground water. Among the major contaminants in the leachate are hydrocarbons,
iron, and manganese. This emerging problem has primarily resulted from
inadequate attention to ground water in siting decisions. In addition, no
distinction was made between hazardous and non-hazardous waste prior to
the RCKA act, and all landfills could accept hazardous waste until November
1980. Although the problem is region-wide, no systematic effort has been
made to investigate and locate these older landfill sites and to monitor
the affected ground water. About twenty percent of the NPL sites nationally
were, at one time, municipal landfills.
Underground Storage Tanks (UST)
Gasoline and other toxic chemicals leaking from underground storage
tanks are among the most common causes of ground water pollution. National
estimates for numbers of existing underground gasoline storage tanks range
from 1.5 to as high as 10 million (based on a recent analysis by the Steel
Tank Institute). An estimated 75,000 to 100,000 of these may be leaking
into the ground water and perhaps toward an unsuspecting family's basement
or a drinking water supply. It is estimated that there are up to 200,000
tanks in Region I. While all New England states are affected, the problem
appears to be most severe in Maine.
Chemical constituents of gasoline are among the most toxic of substances
common to our everyday lives. Gasoline may contain up to 1,200 components,
of which, about 300 have been identified. A few of these constituents have
been shown to induce cancer on laboratory animals and one, benzene, is a
known human carcinogen. Toxicological and limited human studies have found
gasoline components to cause such health problems as anemia, nervous system
disorders, kidney disease, cancer and lead poisoning.
Although fuel tanks are by far the most numerous type of underground
storage tank, other hazardous chemicals are stored underground. While
there have not been reported cases of leaking solvents from underground
storage in New England, there have been several serious incidents reported
in the California's high technology Santa Clara Valley. Because of a
concentration of similar industries in New England there is also a potential
hazard in this region.
A new federal initiative to control UST has been mandated by Congress
in legislation passed in November, 1984. The New England states are viewed
as national leaders in their attempts to initiate state regulatory programs
in advance of future federal efforts.
Pesticides
Although most agricultural pesticides have been properly applied, their
residues represent a serious threat to the purity of the ground water sup-
plies in New England. Approximately 16 active ingredients/metabolites of
registered pesticides have been found in samples of ground water, seven of
which have been identified in one or more New England States resulting pri-
marily from the agricultural application of soil fumigants, insecticides or
I1-3-2
-------
herbicides. Several states have utilized existing authorities to reduce the
likelihood of future contamination. They are often inhibited, however, by
a lack of critical information necessary to more effectively evaluate poten-
tial health risks from use of contaminated water having very low residue
levels.
Extensive ground water contamination by ethylene dibromide (EDB) and
aldicarb throughout New England has posed serious drinking water problems
for owners of private water supplies. For example, citizens in the Connecticut
River Valley communities of Connecticut and Massachusetts who have levels
of EDB in drinking water which exceed the strigent standard often cannot
sell their homes because state banks will not write mortgages for these
properties.
CASE STUDY; THE CAPE COD AQUIFER MANAGEMENT PLAN
Because of the historic fragmentation of ground water protec-
tion efforts, there is a need for better management and improved
coordination in the ground water protection area. In addition to
the wide range of contamination sources, there has been a prolifer-
ation of programs at the federal, state and local levels. Region
I's Cape Cod Aquifer Management Plan represents an attempt to
consider all sources of pollution, coordinate various government
programs and, most importantly, devote full attention to the ulti-
mate goal of long-term ground water protection.
A regional approach to solving the institutional problems and
enhancing ground water protection is taking shape through a pilot
resource management project on Cape Cod. In this project, we will
develop a management structure through which to catalog all possi-
ble sources of contamination for the sole source Cape Cod dquifer.
The project will also provide a focal point for integrating various
programs with current or potential responsibility for ground
water protection on the Cape.
In addition to the Region I Office of Ground Water Protection,
this project will include participation by the Massachusetts Depart-
ment of Environmental Quality Engineering and the Cape Cod Regional
Planning and Economic Development Commission. Region I also plans
to work closely with the U.S. Geological Survey which has extensive
data and experience working with ground water. Eastham and Barn-
stable will be the focal points for this pilot, and will play the
key roles because these communities will have to use the informa-
tion gathered in this project to make tough ground water related
land use decisions. TJie Region is hopeful that this project can
serve as a prototype for the management of other aquifers within
New England and the rest of the country. In order to broaden the
scope of the project and expedite its completion, however, the
Region will require additional financial support.
I1-3-3
-------
II. REGION I AGENDA
Leaking Municipal Landfills
Monitoring and regulation of current landfill sites are state respon-
sibilities. In most cases, however, the states' monitoring programs are
inadequate. Sane municipal landfills obtained interim status and have
continued to accept limited types of hazardous waste in small designated
areas after November, 1980. Under the old statute, EPA was concerned
with only that part of the landfill that received hazardous waste. Whereas,
under HSWA, all landfills are covered and will be subject to RCRA Subtitle C
ground water monitoring requirements. The results of this type of monitoring
should help define the scope of the problem caused by municipal landfills.
Barriers to Overcome:
o Costs associated with the ground water monitoring are very
high, including costs for characterizing site hydrology,
characterizing the plumes, continued monitoring of sites
and developing and implementing remedial plans.
o Capping or closing a facility requires finding alternative
capacity, which is an increasingly difficult problem.
Recommended Headquarters Action:
o Coordinate national ground water monitoring data from municipal
landfills that have obtained interim status in order to
assess the environmental threat posed by these facilities.
o Establish a program to identify old abandoned landfills and to
monitor what affect landfill leachate is having on ground
water.
Underground Storage Tanks
The key to successful implementation of the new UST program will be
strong state programs. The Region will continue to nurture strong partner-
ships with the New England States individually and through regional organ-
izations like the New England Interstate Water Pollution Control Commission
and the New England Council.
Barriers to Overcome:
o Need to regulate fuel oil which is currently exempt from
regulation.
o The tremendous costs to the oil companies to manage and replace
tanks and the likelihood that these costs will be passed on
to the consumers.
o Problems associated with disposal of old tanks.
Recommended Headquarters Actions:
o Ensure that adequate state grant funds be available in FY 87
and FY 88 to allow the states to staff and implement program.
o Aggressively complete the regulatory development program by
May, 1987, as envisioned in the Agency UST Development Plan.
II-3-4
-------
Pesticides
The states have taken the lead role in regulating the use of pesticides.
The Regional Office is conmitted to helping them wherever possible with
additional sampling and analytical support. For example, the Water Supply
Branch initiated a sampling/monitoring and analysis study of selected pub-
lic and private water supplies in western Massachusetts which will supplement
the work done by the State's Department of Agriculture and Department of
Environmental Quality Engineering. The Region will continue to provide tech-
nical assistance in support of state actions involving pesticide contamination
and encourage the ongoing use of existing authorities to avoid future problems.
Past state actions:
Connecticut
o Extensive sampling for EDB - first round of analyses were
completed in 1984 and a second sampling will concentrate on
discernable increases.
o State has taken about 3000 samples showing approximately 248
private wells and 50 public supplies contaminated.
o Performed analysis for 32 pesticides/by products and PCB in
12 towns.
o Refused registration of the soil fumigant Vorlex with for-
mulations containing chlorinated €3 hydrocarbons.
Maine
o Registered Temik for use in Maine only with an additional label
restriction prohibiting use within 500 feet of a well.
Massachusetts
oExtensive EDB study sampled 273 sources with two public supplies
and 33 private wells exceeding the state limit of 0.1 ppb.
o Monitored 164 wells for aldicarb; 5 private wells had levels
greater than 10 ppb., the state action level.
o A monitoring survey of 24 towns in the Connecticut River
Valley (with prevalent EDB contamination) has been initiated.
The project will encompass mapping agricultural activities,
approximating pesticide usage, overlaying all public and
private supplies, and then testing the wells with the highest
probability of contamination for seven agricultural pesticides.
o Pesticide Control Board issued an emergency order (90 days)
banning the use of Temik in potato fields within 1000 feet
of supply wells.
New Hampshire
o A monitoring system to sample ground water in high pesticide
use areas has begun. The first phase of the project will focus
on areas abutting apple orchards. During FY 86 the study
will expand to examine impacts from 10 sites abutting extensive
vegetable growing areas and 10 sites near golf courses.
Rhode Island
o Extensive study of nearly all public water supplies for Temik
contamination. All private wells within 1/2 mile radius of
about 130 potato fields were sampled. Two public and 15
I1-3-5
-------
private wells were found to be contaminated.
o State refused to register Temik for the 1985 growing season
due to the lack of proper labeling retrictions. The ban
may continue into 1986.
Vermont
o The Health Department conducted a study of herbicides used at three
sites, highway guard rail, railroad sites, and utility rights
of ways. Ground water monitoring was conducted to determine
impacts. Results to date have not detected any herbicides
in the ground water.
Barriers to Overcome:
o Potential resistance from cotmodity and grower groups fostered
by an incomplete understanding of the problems involved.
o Lack of resources to support increased technical assistance
and outreach programs.
o Lack of resources to support increased training of applicators
focusing on ground water and safe use.
Recommended Headquarters Action:
o Issue health advisories or drinking water standards for pesticides
found in ground water.
o Initiate The National Survey of Pesticides in Ground Water as
soon as possible. State monitoring of residues in ground
water is at best a small scale effort that has focused on
only a few chemicals of high volume use. A more intensive
monitoring program is needed to better identify the scope
of the pesticide in ground water problem.
o Support residue monitoring of pesticides likely to migrate
to ground water supplies. Soil and climatic conditions
favorable to pesticide residue accumulation and migration,
especially for degradation-resistant pesticides, should be
considered.
o Amend labels, classify restricted use or cancel use when
monitoring data and/or experimentation indicate ground
water contamination from pesticides.
o Develop policy regarding the types of control measures necessary
to mitigate the risks from pesticide leaching. Also, develop
a plan on how to implement various control measures.
o Publish chemical fact sheets for pesticides having potential
for movement into ground water. These fact sheets should
be updated to provide additional information on environmental
characteristics and fate depending on climate and soil
conditions.
II-3-6
-------
Region I
Issue #4
WASTE REDUCTION, TREATMENT AND DISPOSAL
I. PROBLEM STATEMENT
The critical shortage of environmentally sound waste treatment and
disposal capacity in Region I and the continuing production of significant
quantities of wastes of all types, together pose a waste management
problem of major proportion for New England.
The situation has begun to take on a more urgent aspect because an
increasing number of presently operating waste treatment and disposal
facilities in the Region are shutting down because they cannot conform
to stringent state and federal waste management requirements and
restrictions.
The New England waste problem cuts across waste and facility
types. More and more cities and towns in the Region are struggling with
growing volumes of solid/municipal and water treatment sludge wastes and
with a shrinking availability of on-line, environmentally sound landfill
disposal capacity. Per capita, New England produces a disproportionately
large amount of low-level radioactive wastes; a solution to the question
of long-term disposal of these materials remains elusive. On the hazardous
waste side, too, there is cause for alarm: the Congressional Budget
Office recently projected a doubling by 1988 in national demand for
hazardous waste treatment and disposal service capacity resulting from
the combined impacts of full implementation of the RCRA amendments
and the expected heightened Superfund construction activity around the
country.
Waste management is to be counted among the environmental and public
health issues of greatest concern to members of the public. This concern
has placed increased pressure on government at all levels to deal effectively
with the range of waste issues now confronting us. A recent EPA-funded
study at Dartmouth College concluded that "the ability of the EPA and
state agencies to deal effectively with [this problem] is critical to
government credibility as protector of public welfare."
Four aspects of New England waste problem are treated here:
wastewater, hazardous wastes, municipal landfills, and low-level radioactive
wastes.
Wastewater
The massive water pollution control effort that the nation embarked on
following the enactment of clean water legislation more than 10 years ago
has resulted in significant environmental improvements. Indicators of net
gains for the environment include: increases in the percentage of the
population served by wastewater treatment technology, better ratios of
treated to untreated wastewater volumes, measurable improvements in water
quality over more river and stream miles, and the ability of more of our
waterways to support fish species, including anadromous, dependent on highly
oxygenated waters.
II-4-1
-------
Nevertheless, major problems in the area of waste water treatment and
management persist, and much more work lies ahead.
o Combined Sewer Overflows (CSOs). CSOs result in the discharge of
large amounts of untreated sewage into waterways. About 40% of the
Region's total population lives in communities that are affected by
untreated CSOs.
o Mandated Treatment Plants. There are insufficient funds, federal,
state and local for the construction and operation of wastewater
treatment plants needed to meet the water quality standards developed
under the provisions of the Clean Water Act.
o Sludge Management and Disposal. The quantity of sludge produced has
grown dramatically in this Region because older treatment plants
have been expanded and new plants have been constructed. Secondary
treatment requirements and more stringent water quality standards
will result in further increases in sludge production. The presence
of toxic materials in some sludges can bear on treatment and disposal
options, and in certain cases, both land application and incineration
of municipal and industrial sludges can result in "pollution transfer".
Further, managing sludge has been difficult because legal requirements
are fragmented among several federal authorities, and some practices,
eg. distribution and marketing, are not regulated.
• o Industrial Pretreatment Program. Industrial discharges to .publicly
owned wastewater treatment works have the potential to release
significant quantities of toxic pollutants into waterways and bottom
sediments, and "shock loadings" of some industrial discharges can
damage secondary waste water treatment systems. Discharge constit-
uents can bear on choices among sludge treatment and disposal methods.
The industrial pretreatment program is the only federal regulatory
program available for the control of industrial waste waters being
discharged to POTW's.
Improper and inadequate treatment of wastewater contaminates the
waterways and coastal areas of New England. Pollutants from CSOs can
include fecal coliform, gross solids and floatables. Pathogens, heavy
metals, and toxics can be found in wastewater discharges and in industrial
and municipal wastewater treatment and pretreatment sludges.
These and other pollutants have negative effects on uses of these
resources: recreational (e.g., boating, fishing, swimming), commercial (e.g.,
commercial fishing, process water, shellfish harvesting), ancillary economic
activity (e.g., tourist/recreational trade), and general public uses (e.g.,
surface and underground drinking water supply).
Hazardous Waste
A number of factors contribute to the shape and nature of New England's
hazardous waste situation.
There is a serious shortage of treatment and disposal facility capacity
to handle the volumes of wastes generated as a by-product of industrial
II-4-2
-------
activity in the Region (500,000 tons annually) and that which is produced in
connection with cleanup activities at Superfund sites. In point of fact,
there are currently no commercial land disposal facilities in all of the
Region.
Second, a number of existing waste management facilities will lose
their interim status for failure to meet strict requirements imposed by
RCRA and its 1984 amendments, including, in particular, insurance, groundwater
monitoring, double liners for surface impoundments, and restrictions on
the kinds of substances which may be disposed of in landfills. Other
facilities may choose to close rather rather than incur the increased costs
of meeting the new RCRA standards.
A related third factor bearing on the hazardous waste situation in
Region I is the rapidly increasing costs associated with proper hazardous
waste transportation and disposal. The higher costs for generators could
induce more illegal disposal activity in New England.
Finally, while there is a clear need for increased hazardous waste
treatment and disposal capacity in the Region, public concern remains
high, and continued strong local opposition to siting new, or expanding
existing waste management facilities is a virtually certainty. These
problems, though regionwide, are most serious in Massachusetts and
Connecticut where the greatest number of Superfund sites are found and
where most of the hazardous waste in New England is generated.
Municipal Landfills
The New England states face major difficulties in meeting their
solid waste landfill disposal capacity needs. Landfill contamination and
leachate problems are common and represent serious environmental management
issues for many communities across the Region. The capacity shortfall is
particularly acute in Massachusetts and Connecticut, where current landfill
capacity will be exhausted in three to five years. Lead times to develop
new waste disposal capacity are expected to exceed five years due to public
opposition and budgetary constraints.
Low-Level Radioactive Waste
New England must find a way to dispose of its low-level radioactive
wastes. The problem is especially acute in this Region; we produce 13%
of the nation's low-level waste yet we comprise only 5.4% of the nation's
population. In the past, all.of this waste, produced as a by-product of
medical and industrial applications, weapons research and production,
and nuclear power generation (200,000 cubic feet per year), was shipped
out of the Region.
The Low-level Radioactive Waste Policy Act of 1980, stipulates that
by January 1, 1986 each state, by itself or in compact with other states,
provide suitable facilities for disposal of low-level radioactive waste.
After this date, compact states will have the right to exclude or limit
the disposal of low-level radioactive waste generated outside the compact
borders. Because of state legislative inaction elsewhere in New England,
it appears at this time that only one New England state will meet the
II-4-3
-------
January 1986 deadline. Connecticut has entered into a compact with New
Jersey, Delaware and Maryland. At the present time, legislation is
pending in Congress to extend the 1986 deadline to 1992.
107,800
LOW-LEVEL RADIOACTIVE WASTE PRODUCTION
( in cubic feet )
66,500
11,100
Massachusetts
Connecticut
900
Vermont Main* R.I. N.H.
an 1985 MtlMtw provided by
NEW ENGLAND
RADIOACTIVE HASTE
DISPOSAL SITES
Lew- level:
0
High-level:
Halicy
Inc. I
II. REGION I AGENDA
Wastewater
Addressing the wastewater problem has required significant cooperation
between the EPA and the state's public health and pollution control agencies.
Recently/ the Region has delegated the management of construction grants to
each of the states, while retaining an oversight role. In 1984, the
construction grants program enabled the New England states to upgrade or
complete 60 treatment and interceptor facilities. In addition, Congress
enacted a new CSO grant program. In FY 84, Region I awarded seven marine
CSO grants totaling over 12.2 million dollars (40% of the national total)
In FY85 another 4 grants, in a total amount of $4.7 million, will be awarded.
Current Actions:
o Assisting the states to develop their sludge management
programs under proposed 40 CFR Part 501 regulations.
o Requiring, in conjunction with the states, major municipalities
to develop Municipal Compliance Plans. The Region hopes to
have received all the MCPs by October 1, 1985.
o Assisting applicants in obtaining funds for marine CSO projects.
o Requiring POTW's to complete and implement the industrial
pretreatment programs.
II-4-4
-------
Future Actions Needed:
o Work with state and local governments to implement innovative
funding mechanisms (state revolving funds, etc.) to assure
continuing construction of municipal wastewater treatment
facilities when federal funding is no longer available.
o Provide specialized training assistance, based on national
experience, in various elements of wastewater treatment
(operations and maintenance, administration, etc.) to assure
that provisions of the CWA are fully implemented.
o Work with states to finalize planning for CSO projects (including
water quality demonstrations if required)
o Work with states to establish discharge limitations and issuance
of NPDES Permits in coordination with above planning actions.
o Develop strategies to assure that states submit approvable sludge
management programs.
o Develop strategies for situations where states are reluctant to
take enforcement actions against local POTWs that are in
violation of technical sludge regulations.
Barriers to Overcome:
o The CWA does not specifically mandate the level of CSO abatement.
o Lack of funding - The EPA 1984 Needs Survey estimated that
approximately $4 billion will be required for wastewater
treatment facilities in Region I and 2.9 billion will be
needed for CSO control. The Region currently receives $185
million/year based on a $2.4 billion yearly national
allotment and the current state allocation formula.
o States are reluctant to implement Part 501 sludge requirements
because of budget constraints.
o States' hesitancy to take action against violators of state
sludge restrictions; there is a low priority on sludge
management at the state level.
o Many POTW's give development and implementation of the industrial
pretreatment program low priority and are hesitant to take
enforcement action against non-complying industrial sources.
Recommended Headquarters Action:
o Establish policy, procedures and discharge limitations for
permitting CSOs.
o Work with Congress for more specific CSO abatement language in
the Clean Water Act amendments and to amplify the need for
additional special CSO funds.
o Sponsor technical seminars on state of-the-art controls for CSOs.
o Provide guidelines to the Regions on how to review and approve
state sludge management programs.
o Provide assistance in conducting seminars/workshops on sludge
management.
o Sponsor technical seminars for POTW's implementing the
pretreatment program.
o Implement the recommendation of the Pretreatment Implementation
Review Task Force.
In the area of wastewater management, our efforts will be directed
at improving surface and ground water quality. We will measure our
II-4-5
-------
progress based on any number of indicators, eg. opening presently contaminated
beach areas to swimming and other recreational uses, cleansing acres of
currently contaminated shellfish beds to the point that they can be
opened for commercial harvesting, improving the aesthetics of currently
degraded areas to the point that wider use is possible. We need to
ensure that sludge treatment and disposal practices are consistent with -
federal regulations and sound management practices, and will direct
efforts at dealing with the CSO problem in the Region. Over the long
term we will base progress on increases in the variety and vitality of
aquatic life forms, decreases in benthic deposits and alleviation of the
health risks posed by various contaminants in sludges and wastewaters.
We will look for improvements in the quality of surface and groundwater
used for drinking. We will work for further improvements in the ratio
of treated to untreated wastewater, and for increases in the number of
POTW's and industries that are in compliance with NPDES permits and
pretreatment requirements.
Hazardous Waste
This past year Region I has devoted significant effort to advising
the regulated community through letters and seminars of their specific
responsibilities under the new RCRA requirments.
Current Actions:
o Supporting efforts by the academic institutions and communities
to exchange information on and/or develop waste reduction
options.
o Carefully evaluating alternative remedial options for Superfund
sites because of the new RCRA limitations on off-site
disposal.
REGION I Waste Handling Methods
(as reported by RCRA manifest generators)
Physical treatment 44%
Chemical treatment 12%
Surface impoundments 7%
Incineration 7%
Storage 6%
Landfill & Other Land Disposal 5%
Solvent recovery 3%
Biological treatment 1%
Other treatment 8%
Unknown 7%
Source: HQ lEMD/Region I Hazardous Waste
Pilot Project (data is from 1983)
m
..»•;;«
v*&!
w
II-4-6
-------
Future Actions Needed:
o Promote waste minimization and source reduction programs.
o Increase civil and criminal enforcement efforts in order to
reduce the incentives to illegally dispose of waste.
o Sponsor public education/outreach programs to foster acceptance
of environmentally sound methods for on-site treatment such
as incineration and the siting of new facilities.
Barriers to Overcome:
o Lack of alternatives to current disposal practices, especially
the lack of alternative technologies for on-site disposal or
neutralization of waste.
o Public concern about on-site treatment and new facility siting.
o Inadequate incentives for waste reduction and resource recovery.
Recommended Headquarters Action:
o Research and development of alternative technology for on-site
treatment of hazardous waste.
o Better communication to the regions about techniques used and
developed in other regions or in private industry especially
with regard to on-site treatment technologies.
o Actively promote source reduction/waste minimization programs
that have been implemented in private industry. This should
include cataloguing successful programs and making this
information easily available to others.
The short term and long term environmental objectives this area are
to reduce production of wastes, to move away from land disposal, and where
possible make safe and effective use of alternative treatment technologies
such as incineration, nuetralization, air-stripping, and carbon absorption.
We will be making progress when the amount of hazardous waste produced
declines, the number of land disposal sites decreases and if new, effective,
alternative technologies can be developed and placed on-line.
A CASE STUDY: GENERAL ELECTRIC — PITTSFIELD, MA
The General Electric transformer plant in Pittsfield, Massachusetts
discharged PCB wastes into the Housatonic River for many years. EPA,
by means of a RCRA 7003 Order, required GE to ascertain the scope of
the problem including the level and extent of contamination in fish and
sediments/ and the extent PCB transport downstream into Connecticut.
The investigation revealed considerable contamination. For more
than 12 miles of the River, PCBs were found at levels exceeding 50
parts per million. PCBs were in evidence over a considerably longer
stretch, but at lower levels of concentration.
GE, with Region I support, is holding a number of public meetings
and presented the remedial action options to the public. Dredging,
II-4-7
-------
rechanneling or covering in place are being discussed but potential
problems have been identified for each of these alternatives. An
innovative alternative, the use of aerobic and anerobic bacteria that
biodegrade PCBs, is being included in GE's study of, remedies. Pilot
studies are now being planned to determine the feasibility of this
approach to contamination cleanup.
Headquarters should more aggressively promote the development of
new waste management technologies, such as here, encouraging private
industry to explore the possibilities of biological and other alter-
native waste treatment technologies. In addition, the Agency needs
to systematically disseminate information about promising new
treatment and cleanup technologies.
The GE Pittsfield case illustrates how Agency/industry cooperation
can lead to the development of new and innovative ways to manage
toxic waste contamination.
Municipal Landfills
States are chiefly responsible for managing non-hazardous municipal
waste disposal. These efforts include expanding existing landfills and
promoting recycling and other waste minimization programs. Because of
strong negative public opinion and a climate of fiscal austerity,
development of long-term solutions to the problem has been difficult.
EPA aided states in developing new facilites under Subtitle D Urban Grants
until 1981 when the Agency stopped funding this program.
Current Actions:
o Helping revise the criteria for facilities that can receive
hazardous household wastes.
Future Actions Needed:
o Spur the exploration of recycling, resource recovery, and source
reduction as management options by public officials and
private sector managers in New England.
o Improve training programs for state personnel to 1) review
design characteristics of resource recovery facilities and
2) review proper landfill design.
Barriers to Overcome:
o No funding of Subtitle D
o Public opposition to new landfills and the expansion of older ones.
o Lack of information, trained staff and funds at the state level.
Recommended Headquarters Action:
o The states have specifically asked for EPA to 1) develop a
checklist of criteria that could be used to evaluate proposed
landfill designs 2) evaluate resource recovery hardware on
the market and 3) provide funding and technical assistance.
o Provide guidance and incentives to the states on developing
comprehensive recycling programs.
o Help increase public awareness for the need to build resource
II-4-8
-------
recovery and other facilities for managing solid waste.
Our aim in this area is to encourage waste stream reduction and to
promote waste materials recovery and recycling, in the hope of dramatically
reducing the volume of waste that needs to be landfilled. An effective
resource recovery program could have the potential to reduce the volume of
new waste by 95%. The environmental impacts of particular waste recovery
proposals must be investigated fully.
Low-Level Radioactive Waste
Current Actions:
o Establish criteria for low-level waste disposal sites.
Future Actions Needed:
o The major role of Region I and the EPA in the future will be
to 1) provide technical assistance to the states and 2)
help inform the public that sites which are selected wisely
and run competently will not present a health hazard to
surrounding populations.
Barriers to Overcome:
o Political and emotional opposition to the siting of radioactive
disposal facilities, even when proposed facilities would be
environmentally sound.
Recommended Headquarters Action:
o Issue criteria for low-level radioactive waste disposal sites
with ample opportunity for public comment.
o Investigate whether EPA should have a role in encouraging
industrial and institutional generators to implement source
and volume reduction programs.
Our goal is to obtain sufficient environmentally sound low-level
radioactive waste disposal capacity that will not pose unacceptable health
or environmental risks.
II-4-9
-------
Region I
Issue #5
LONG RANGE TRANSPORT
I. PROBLEM STATEMENT
Long range transport of air pollutants is a major problem in New
England because we are downwind from both the most heavily industrialized
portions of the nation and one of the most heavily travelled motor vehicle
corridors. It is estimated that 65 to 80% of acidic deposition in New
England is caused by long range transport. Similarly, on most days when
the National Ambient Air Quality Standard (NAAQS) for ozone is exceeded
in Region I, a significant part of the problem is transported ozone.
Yet, while long range transport poses a major threat to public health and
our natural environment, solutions to the problem have been elusive. The
Clean Air Act, with its focus on individual state plans for air pollution
control, is not well suited to dealing with pollutants that cross state
and regional boundaries. This section discusses in detail the long range
transport issues relating to acidic deposition and ozone. While separate
phenomena, they are linked by complex atmospheric chemistry and potentially
synergistic effects on our environment.
Acidic Deposition
The phenomenon popularly called "acid rain" is more correctly termed
"acidic deposition." The acidic material is deposited not only in rain
or snow, but also in dry form as an aerosol (particle) or gas. The major
contaminants in the deposition are gaseous sulfur dioxide (SO2) and nitrogen
dioxide (N02), sulfate and nitrate aerosol, precipitation droplets containing
sulfuric and nitric acids, and assorted trace metals. Volatile organic
compounds (VDC) and oxidants (e.g. ozone) are also involved in the
conversion of S02 and NC>2 to aerosols and acids. Acidic deposition affects
all of New England and Eastern Canada and is now affecting many other
parts of the U.S.
Acidic deposition has major aquatic, terrestrial and atmospheric
impacts. Acidification of freshwater ecosystems has reduced the abundance,
production and growth of bacteria, algae, fish and amphibians. In addition
some acid sensitive lakes can no longer support fish populations. Valuable
commercial and recreational fisheries have been lost in certain areas.
Acidity also increases the ability of groundwater to leach metals and
other chemicals fron soils, affecting both aquatic and terrestrial ecosystems
and potentially degrading drinking water supplies. Acid deposition is
also known to cause material deterioration such as the weathering of
building surfaces and monuments. A potential major terrestrial impact is
the uncertain role of acidic deposition in significant forest decline in
the Northeast, exemplified locally by the red spruce decline on Camel's
Hump in Vermont. Finally, sulfates in the atmosphere can directly impair
visibility, affecting some of the most pristine areas in northern New
England.
Large fossil fuel burning sources contribute almost all of the S02
emissions in the eastern U.S. and in New England. However, the actual
S02 emitted by the New England states together represented only 3% of
24 million tons annually emitted in the U.S. In contrast, certain states
II-5-1
-------
along the Ohio River each contribute more than 5% of the national SC>2
inventory. While mobile sources are significant contributors of NC>2
and VDC, stationary sources still contribute more than half the national
emissions for both pollutants.
Because major uncertainties remain regarding the scope and cause of
the acid deposition problem, the Agency's role remains one of research
through the National Acid Precipitation Assessment Program (NAPAP).
NAPAP, which began in 1980, is a ten year interagency program whose
funding has grown from $11 million in FY 1980 to a proposed $85.5 million
for FY 1986. Some of the major technical issues being researched under
NAPAP include: sources of acidic precipitation, atmospheric processes, and
evidence of the effects of acidic deposition. A major project funded by
the NAPAP is the national lake survey. This study, which includes about
600 lakes in New England, is designed to document baseline conditions
using uniform sampling procedures. As a result, NAPAP will be able to
characterize aquatic conditions and to improve the validity of, and
confidence in, acidification trends research. The first sampling results
will be available in the fall of 1985.
Public concern over acidic deposition in New England was most visible
in Manchester, NH during a three day conference in January 1984 entitled
"Acid Rain 84". Although planned for 200, more than 500 individuals
attended. Concern over acidic deposition remains at a high level today
as reflected by resolutions adopted at city and town meetings, at the
state legislative level, at meetings of the New England Governors, and
at their meetings with the Eastern Canadian Premiers. The Governors and
Premiers have adopted a regional sulfur dioxide reduction plan which
will be the basis of reduction plans for states and provinces in the
area.
Ozone
Ozone is formed when volatile organic compounds (VOC) mix with
oxides of nitrogen in the presence of sunlight during the warm months,
generally May through September. Mobile sources contribute about 40% of
the region's VOC emissions while stationary sources account for the
remainder. The stationary sources can be further broken down into large
point sources (10% of total VOCs) such as chemical plants and bulk gasoline
terminals, and small sources (50% of total VOCs) such as dry cleaners
and gas stations.
Except for Vermont, all New England states have sites which exceeded
NAAQS standards for ozone (0.12 ppm) on at least 15 days in 1984. One
site in Connecticut had 28 violations. On most of the days when violations
occur, a substantial amount of the ozone is transported into the region
from upwind sources. Although the number of violation days was less
than in 1983, the magnitude of the highest violations did not decrease
significantly. In fact, both the number of violation days and the
second highest ozone levels recorded during the summer of 1984 exceeded
the 1981-1983 three year average for these indicators.
II-5-2
-------
Ozone Non-attainment
When the ozone standard is exceeded, a high proportion of the "at
risk" population experiences difficulty in breathing. On days with
concentrations well above the standard, the "at risk" population is
advised to stay indoors and to restrict activity. In New England, the
"at risk" population includes about two million people, or about 15%
of the entire population. Scientists also believe that ozone may be a
primary cause of recent forest decline in the Northeast.
Public concern is evidenced by local Lung Associations' activities
and heightened publicity during the ozone season. All states with ozone
violations and their regional organization, the Northeast States for
Coordinated Air Use Management (NESCAUM), have been involved in a major
ozone study (Northeast Corridor Regional Modeling Project or NECRMP)
and have been strong advocates for its completion.
II. REGION I AGENDA
Acidic Deposition
Because EPA does not believe that enough is known about acidic
deposition to propose controls at this time, Region I's actions are
primarily focused on research activities and information exchange. This
II-5-3
>
-------
includes encouraging the funding of local research, disseminating
research information, and reporting regional research developments and
public concerns to EPA Headquarters. The states' involvement includes
research, legislative action, and participation in the national State
Acid Rain (STAR) program. Funded by a $3 million grant from EPA, this
program is examining issues which might arise if a national plan is
implemented.
Current Actions:
o Provide Regional oversight of the STAR program which
provides $560,000 for projects conducted by the states
including:
1) a Vermont study of emission inventories and maintenance
of emission levels for low emission states
2) a Connecticut study of how the public and industry can
contribute to strategy development
3) NESCAUM studies of SC>2 control techniques and the
form a maintenance plan could take
4) a New Hampshire study of strategy development and the
assessment of economic and environmental impacts
5) Massachusetts studies of strategy development and
emission trading options.
o Participation in NAPAP activities including national
meetings, emission inventory workgroups and the lake
survey.
Future Actions Needed:
o Compile an accurate 1985 SC>2 emission inventory for NAPAP.
Region I and the states will be working together to collect
and submit the data.
o Participate in national workshops addressing inventory and
control plan implementation issues.
Barriers to Overcome:
o Uncertainty over whether the benefits of controlling emissions,
as indicated by scientific documentation of the current
severity and causes of the problem, outweigh the cost of
controls including increased utility rates and reduced
coal miner employment.
o Uncertainty about the causes and mechanisms of acid rain damage.
o Debate over the distributional effects (both geographic and
sectoral) of any emissions reduction policy.
o The inadequacy of the existing Clean Air Act in addressing
non-criteria pollutants.
o Limited funding. Authority, funding and grants are
available mainly for research, not operating programs.
Recommended Headquarters Action:
o Ensure that adequate resources are committed to long-term
research projects and environmental monitoring. The ORD
acid rain budget must be fully funded and monitored.
Findings must be reported in a timely manner with widespread
circulation.
o Use regulatory review and approval experience to guide
I1-5-4
-------
program planning and assure efficient coordination of
acid rain issues. The Office of Air and Radiation must
continue to analyze potential issues and control options.
o Consider local input in establishing regional research
projects.
o Keep regions and states abreast of important developments
and provide a forum for discussion of research findings
and strategy developed by government, industry and the
public.
o Encourage state and regional strategies that would lead
to control plan implementation.
Continued research of the acidic deposition problem should reduce
the existing uncertainties and help EPA to formulate and implement a
national acid rain control program. When such a program is implemented,
the resulting decrease in sulfate and nitrate deposition should retard
acidification of ecosystems and help alleviate other environmental problems
such as materials damage, visibility impairment, and high ambient levels
of fine particulates. While emissions data may be used as surrogate
indicators of our progress, trend data from the lakes survey will be
invaluable.
Ozone
Region I has developed a comprehensive strategy to combat the ozone
problem. It includes analysis of existing data, development of complete
and accurate inventories, aggressive enforcement of stationary and
mobile source controls, and evaluation of long range transport impacts.
Stationary source emissions are being reduced by requiring industrial
sources to either install add-on controls or to switch from VOC-based
coatings to water-based coatings. Mobile source emissions are being
controlled through new car emission standards, inspection and maintenance
(I/M) programs in Connecticut and Massachusetts, and an aggressive inspection
program to combat tampering with auto emission control systems
and the use of leaded gasoline in vehicles designed for unleaded fuel.
Current Actions:
o Working with the states to ensure that affected sources are
aware of regulatory requirements and are in compliance.
o Formation of a VOC Task Force which has 1) identified 591
sources subject to VOC regulations and compliance dates
for each source and 2) developed a regional compliance
enforcement strategy.
o Initiation of a program to train state and federal inspectors
to ensure their familiarity with VOC regulations, methods
of control and inspection techniques.
o Initiation of inspections at auto dealerships, repair shops,
gas stations and fleet operators to:
1) check unleaded gas for lead contamination
2) check for proper nozzles on gas pumps
3) check for tampering with emission control equipment.
o Institution of a toll-free "hot line" available for the public
to report cases of suspected tampering and misfueling.
Tips received assist in establishing inspection priorities.
II-5-5
-------
o Participation in a major photochemical dispersion modeling
study of the Connecticut-New York-New Jersey area. The
study will evaluate the effectiveness of various control
strategies in bringing the area into attainment.
Future Actions Needed:
o Focus EPA inspection activity on the 315 stationary
sources that should now be in compliance while providing
technical assistance to the states to bring the remaining
sources into compliance on schedule.
o Work with the states to definitively determine the compliance
status of approximately 25 potentially significant violators
already identified.
o Refer mobile source violators to EPA Headquarters for
subsequent enforcement action.
o Work with New Hampshire in implementing an I/M program
in the Nashua area and with Connecticut and Massachusetts
to enhance their I/M programs. Work with states to
initiate or expand anti-tampering and anti-fuel switching
programs.
o Participate in a national Ozone Task Force addressing all
aspects of the ozone nonattainment problem. Assuming
lead role for long range transport and SIP development
issues.
Barriers to Overcome:
o Lack of regional control strategies to address long range
transport.
o Inadequate resources to fund mobile source inspection activ-
ity and the application of sophisticated photochemical models
to evaluate control strategies.
o Problems with state data concerning significant violators.
o Inexperience at state and federal level in inspecting VOC
sources.
o Lack of public awareness concerning 1) serious health threats
associated with ozone and 2) the relationship between
automobile use and ozone levels.
Recommended Headquarters Action:
o Provide resources at the regional and national level for large
scale modeling studies to evaluate control strategy effectiveness.
o Continue the work of the Ozone Task Force and encourage the devel-
opment of a firm new policy, consistently applied throughout
the country.
o Facilitate an aggressive enforcement posture by funding additional
training for inspectors and mobile source inspection activity.
o Provide a regulatory framework for implementation of regional
scale control strategies to combat long range transport of
ozone.
Achieving and maintaining ambient ozone standards will require working
with the states in order to develop air quality implementation plans by 1987.
Because of the long range transport dimension of the problem, however,
achieving meaningful progress will be difficult unless the issue is addressed
on a national basis.
II-5-6
-------
Region I
Issue #6
WATER-RELATED LAND MANAGEMENT
I. PROBLEM STATEMENT
In New England, a wide variety of land-use activities contribute
to the degradation of our water resources. The Region's surface and
ground waters continue to be adversely affected by non-point sources
(NPSs) of pollution resulting from agricultural, construction, and indus-
trial activities. Dredge and fill practices associated with construction
and development have destroyed much of the Regions's valuable wetlands.
In order to restore and/or preserve our high quality surface and ground
water systems, we need to aggressively advocate the implementation of best
management practices (BMPs) for NFS control. The broad array of water
resource damaging, land-related practices combined with development
pressures, ingrained habits, and lack of public awareness, however, make
the design and implementation of BMPs difficult.
A threat to both water quality and recreational and commercial
water uses, NPSs include agricultural runoff and pesticide use, utility
and transportation rights of way, urban runoff, construction sites, waste
management facilities, landfills, and petroleum transportation and storage
facilities. A priority problem associated with NPS pollution, which has
emerged in recent years, is ground water contamination (See Issue #3).
Since the colonial era, human settlement has encroached upon the
Region's fresh-water and saltwater wetlands, a particularly vital, pro-
ductive and irreplaceable natural resource. Although wetlands comprise
a small percentage of New England's surface area, they are essential to
the health, nurturing, and survival of fish and wildlife populations
including several endangered species and two thirds of the commercial
fish species harvested off the Atlantic coast. When left undisturbed,
wetlands also perform a number of important hydrological functions.
First, they protect surface and ground waters from NPS pollution. It is
increasingly recognized that wetlands maintain water quality through
filtration of sediment and uptake of nutrients and pollutants. Secondly,
they serve as critical ground water discharge and recharge areas. Finally,
wetlands act as flood storage areas, and they provide a buffer against
storm damage and erosion in coastal areas.
Non-Point Source Pollution
While pollution from non-point sources occurs throughout New Eng-
land, it is most severe in lake watersheds, headwater streams, estuaries,
and critical aquifers. Agricultural runoff from manure handling, crop-
ping practices, and pesticide use can contaminate water resources with
toxic organics, concentrated nutrient loads, and high levels of biological
oxygen demand. Particularly severe in areas undergoing rapid urban,
conmercial, industrial, and resource development, improperly controlled
construction activity can foul local waterways with debris and sediments.
Effluent from urban runoff and combined sewer overflows (See Issue #4)
pollute urban rivers, bays, estuaries, and other coastal waters. Old
landfills, abandoned waste disposal sites, and in-place sediments
(sludge deposits generated by past industrial activity, usually found
II-6-1
-------
behind old mill ponds) also contaminate surface and ground waters. In
addition to agricultural wastes, sediments and debris, NFS pollutants
include heavy metals and oil and hazardous materials.
Although the EPA has successfully implemented programs designed to
address point source pollution, abatement of NFS pollution has proven to
be elusive. Because non-point sources result from such a wide variety
of practices and processes, mitigation of NFS pollution would, in many
cases, require adoption of methods and implementation of controls for a
broad array of activities, affecting the everyday routine of individuals,
groups and businesses. In addition, NFS pollution often occurs as the
result of unpredictable and sporadic events such as heavy rain storms.
Its diffuse and intermittent nature also makes it difficult to recognize
NFS water quality impacts and design effective abatement strategies. In
New England, the diverse topography poses additional challenges because
it requires the development of control methods for specific types of
landscapes. Finally, NPSs are not covered under the NPDES permit system.
New Englanders, in general, care deeply about the quality and future
of their water resources. In light of the visible effects of NFS pollution
including closed beaches, prohibitions on shellfish harvesting, and
closed drinking water wells, public concern for this issue is increa-
sing. In addition, a number of federal agencies (e.g., the Department
of Agriculture and the Department of Tranportation), state and local
governments, zoning boards, and private construction companies have
addressed NFS pollution.
Wetlands
Despite their value and relative scarcity, our wetlands continue to
be lost at an alarming rate. Although encroachment upon tidal wetlands
has been largely arrested, destruction of valuable freshwater wetlands
has eluded control. Areas of special concern include the Route 128 and
1-495 belts in Massachusetts, southern New Hamphire, the Burlington,
Vermont vicinity, Hartford and Middlesex counties in Connecticut, and
peatland resources in central Maine.
The loss of wetlands has had a number of adverse impacts. With the
destruction of valuable wildlife habitat, there has been a concomitant
decrease in wetland animal and plant species' populations. The loss of
wetlands has also been accompanied by long-term degradation of downstream
water quality and increases in the severity and frequency of downstream
flooding. There is also a reduction and, in some cases, an irreversible
loss of educational uses and aesthetic value.
Although the Clean Water Act provides for wetlands protection
through Section 404 permits, fundamental and longstanding disputes
between EPA and the Army Corps of Engineers at the national level have
hampered the operation of the program. For instance, as a result of a
five year disagreement over the definition of fill material, many discharges
into wetlands are not regulated. In addition, the Memorandum of Agreement
(MOA) between the two agencies has expired. EPA doesn't want to renew
it unless improved conflict resolution procedures for environmentally
damaging projects are incorporated. In Region I, the most recent 404
II-6-2
-------
controversy involves the construction of a shopping mall on a wetlands
site in South Attleboro, MA. EPA has initiated 404(c) "veto" proceedings
because another, upland site for mall construction exists nearby.
The 404 program suffers from other weaknesses. Most importantly,
there are several ways to avoid federal jurisdiction. For example, while
the 404 program regulates many kinds of fill operations, draining a
wetland, a common agricultural practice, is not covered. There are sane
estimates which state that 50% of all wetland loss, nationwide, has
resulted fron such unregulated activities.
Public concern for the wetlands issue varies across the Region with
residents of Massachusetts, Connecticut, and Rhode Island having the
strongest sentiments. These areas have been most affected by the loss
of wetlands resulting fron development pressures. In rural northern
New England, encroachment upon wetlands has been a less severe and widespread
problem and thus there is a lower level of public concern. A notable
exception to this pattern has occurred in central Maine, where the prospect
of harvesting peat from the peat bogs for energy purposes has stimulated
considerable interest and concern among conservationists and developers.
II. REGION I AGENDA
Non-point Source Pollution
The Region's emphasis is on integrating preventive measures such as
Best Management Practices (BMPs) into the diverse activities affecting
nonpoint source runoff and seepage. These efforts entail providing
leadership to other federal agencies, working with the states, and work-
ing with regional and local agencies and interests. The Region has also
undertaken programs to clean up water bodies contaminated by NPS pollu-
tion.
Current Actions:
o Preparing a Regional analysis and summary of the NPS problem,
based on the Association of State and Interstate Water
Pollution Control Administrators (ASIWPCA) Assessments,
Mid-year reviews, and other information.
o Working with the states to develop, refine, and updating
state NPS Management Programs called for in the EPA
National NPS Strategy and in the NPS provisions in pending
CWA Amendments.
o Arranging federal agency assistance and insuring consistency
of federal actions to meet state concerns and needs to
carry out NPS strategies.
Future Actions Needed:
o Develop prototype NPS programs for Estuarine and Cape Cod
Aquifer programs.
o Integrate NPS programs into Regional Wetlands Strategy
and apply to priority wetlands.
o Develop general permits for urban runoff.
o Assess measures to control pollutants released from in-place
I1-6-3
-------
sediments and implement them at priority sites.
o Conduct workshops on critical technical and policy issues
such as agricultural chemical contamination of ground
water, urban runoff, road salt, in-place sediments, and
emerging issues as identified.
Barriers to Overcome:
o The diffuse, intermittent nature of NPSs makes it difficult
to recognize their water quality impacts and mount effective
abatement strategies.
o The diversity of management agencies requires coordinated
efforts to implement control measures, touching many
activities and interests.
o BMPs involve changing ingrained habits and operations,
entailing a prolonged transition process.
o Diminishing support funds discourage abatement efforts.
o Negative attitude of private sector interests towards in-
creased government regulation.
Recommended Headquarters Action:
Headquarters can line up support for NFS implementation through
interagency coordination at the National level, as follows:
o Work with other federal agencies and national organizations
to reach the diverse interests involved in NFS control.
o Assure federal installations, projects, grants, and loans
incorporate BMPs.
o Ensure that agricultural cost-sharing programs incorporate
the Agency's water quality objectives.
o Provide funding, tax incentives and other incentives for
demonstration projects.
o Develop state-local-private sector capability by furnishing
model legislation, guidance, and technical assistance.
o Support Regional positions and budget for NPS activities.
o Enlist the services of seasoned experts to provide assis-
tance to national and regional programs.
Protecting our water resources will necessitate more careful
management and effective control of activities which may result in runoff,
aquifer contamination, or other types of non-point source pollution.
Through clean up programs in the short-term and promotion of BMPs in the
longterm, we hope to maintain high levels of water quality and reduce
violations of water quality standards criteria (e.g., turbidity, nutrient
loads, toxics, and microbiological contaminants).
Wetlands
Current Actions:
o Develop comprehensive regional wetland protection strategy
which will increase the effectiveness of 404 and regional
programs.
o Continue to closely review proposed 404 permits to insure
that no significant, avoidable or unmitigated losses of
wetlands occur.
I1-6-4
-------
Future Actions Needed:
o Increase Region I enforcement activity in coordination
with the Corps, Fish and Wildlife Service, and National
Marine Fisheries Service during FY-86.
o By FY-86, use Section 404(c) authority and Advanced Identi-
fication of Sites system to protect candidate wetlands
identified on May 1985 Priority Wetlands List.
Barriers to Overcome:
o Resource constraints, in particular, availability of staff
time to undertake new initiatives.
o Continued EPA/Corps disputes and divergent policies vis £
vis federal wetland protection.
Reconmended Headquarters Action:
o Renegotiate EPA-Corps national MOA in a manner which promotes
wetlands protection.
o Reach accord with Corps on definition of "Fill Material".
o Delegate 404(c) decision making authority (permit veto
power) to EPA Regions.
The protection of wetlands from non-water dependent fill projects
and full mitigation for all necessary and unavoidable wetlands impacts
necessitates that EPA work towards increasing the effectiveness of the
404 program and improving cooperation with the Corps. In order to moni-
tor our progress, we should track changes in wetlands acreage, the popu-
lation of selected indicator species dependent on a wetlands habitat,
and hydrologically related measures such as downstream water quality
and severity and frequency of flooding.
II-6-5
-------
PART III
REGIONAL RECOMMENDATIONS
FOR THE
AGENCY PRIORITY LIST FY 87-88
-------
Region I Recommendations for the Agency Priority List FY87-88
The Priority List; Process and Purpose
1. The priority list seems to mix headquarters programs, regional programs,
and agency principles together. We suggest categorizing priorities
according to agency objectives with a further breakdown between regional
and headquarters activities.
2. The list must reflect a sequential order of actions. In seme cases,
certain HQ functions were listed lower on the list than regional
activities which are dependent on the HQ action.
3. We have difficulty in comparing priorities for protecting public
health from exposure to contaminants from air emissions, drinking
water, and the improper waste disposal.
4. Program offices in the regions would like more specific information as
to how Headquarters uses the Agency Priority List.
Suggested Changes
1. The Ground Water Protection Strategy (#12) should be raised. This
vital drinking water source is threatened by hazardous waste facilities,
USTs, pesticide applications, and landfills.
2. Because of immediate public health considerations, raise Drinking
water Contaminants (#23).
3. Protections of Wetlands (#14) should receive higher priority.
Development pressures in the Region threaten these valuable water
resources.
4. Because toxic industrial discharges to wastewater treatment systems
are outstripping our ability to control them, we should give greater
emphasis to the Pretreatment Program (#16).
5. Raising Multimedia Pollution (#22) will enable the Region to place a
high priority on geographic specific areas such as Boston Harbor and
Buzzards Bay.
6. Lower the priority of RCRA Regulation Promulgation (#6). Although
this is a priority activity at HQ it does not affect top regional
priorities.
7. Lower the Reissuance of NPDES Permits (#11). This is an ongoing program
which requires no special emphasis. The current backlog should be eliminated
by the end of FY 86.
III-l
-------
8. Long-Range Transport (broader than acidic deposition) needs to appear
near the top. It should encompass acidic deposition , ozone, and
other tranportable 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 reasearch. We
should be in an implementation stage by 1986-87.
9. We need to include Indoor Air Pollution. This is a particularly
important public health issue where energy conservation measures
have reduced the ventilation of air. High energy costs have also
led to an increased reliance on wood and coal burning stoves, further
exacerbating the situation. High radon concentrations inside New
England's residences is also very important from a public health
perspective.
10. Achieve and Maintain Compliance with Air Quality Standards (#9)
should be raised to #4 dropping 4-8 down one. This change is justified
by the following reasons: (1) ozone is a criteria pollutant for
which there is a health based standard; (2) ozone non-attainment
affects over 20 major urban areas in the U.S.; (3) the 1987 attainment
deadline is not expected to be met in these 20 areas and (4) ozone
nonattainment is due in part to excessive VOC emissions, many of
which are toxic.
11. Add a phrase to #26 so the first sentence reads "Complete the regulatory
control program for control of exposure to radioactive wastes and
finalize guidance on exposure to non-ionizing radiation."
111-2
------- |