United States
Environmental Protection
Agency
Region 3
Sixth and Walnut Streets
Philadelphia, PA 19106
Delaware, District of Columbia,
Maryland, Pennsylvania,
Virginia, West Virginia
legional Administrator May 1983
Environmental
Management
Report
1983
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EPA REGION III
ENVIRONMENTAL
MANAGEMENT
REPORT
FY 1983
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TABLE OF CONTENTS
Page
Part 1 Execut ive Summary 1
Part 2 Discussion of Significant Environmental Problems and
Implications for Agency Management
Air Quality Problem 18
Surface Water Quality Problems 31
Ocean Problems 45
Drinking Water Problems 50
Ground water Problems 53
Hazardous Waste Problems
RCRA Problems 60
Superfund Problems 75
Pesticide Problems 79
Radiation Problems 80
Federal Facilities 88
Appendix A. Supporting Documentation
Air Quality Problems .A- 1
Surface Water Quality Problems A-25
Ocean Problems A-44
Drinking Water Problems A-51
Ground water Problems A-55
Hazardous Waste Problems
RCRA Problems A-61
Superfund Problems A-67
Pesticides Problems A-75
Appendix B. Detailed Analyses of Selected Regional Problems
Violations of Ozone Standards B- 1
Surface Water Pollution by Acid Mine Drainage B-20
Non-Point Source Pollution by Nutrients and
Sediments from agriculture B-25
The Development of a Regional Ground water Data Base B-32
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Executive Summary
Introduction
This Environmental Management Report for the Middle Atlantic Region holds
few surprises. Many of the environmental problems found in Delaware,
Maryland, Pennsylvania, Virginia, West Virginia and the District of Columbia
have been with us for many years. A summary of the environmental problems
within Region III appear on the chart on page 2.
(Region III is among the leading Regions in population density, manufactur-
ing, mining, steel production, and chemical production. Each of these
factors adds its own particular type of pollution problem. Thus, we are
faced with air pollution problems from automobiles and industry; a
significant number of streams degraded by acid mine drainage; and an
undetermined amount of land, groundwater and surface water contaminated by
toxic waste dumps and spills.
These problems tend to be most prevalent in certain areas within the
Region. For example, the major cities of Philadelphia, Pittsburgh,
Baltimore and Washington have most of the air pollution violations. The
Chesapeake Bay is suffering from a variety of water pollution problems from
point and non-point sources throughout its drainage area. Heavy transport
of products, intermediates and raw materials by pipe lines, trucks,
r-.
i *
railroads and waterways results in a potential for major spills. /This
report outlines these problems in detail. Where the problems are well
understood, the report suggests solutions. Where there are still many
unknowns, the report suggests what further study is necessary before a
-7
solution can be developed. !
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SUMMARY OF ENVIRONMENTAL PROBLEMS
REGION III
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45%
17%
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*Doe? not include the Chesapeake Bay which has impaired water uses over some 1,200 square miles of it's
surface area.
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Part 1.
Executive Summary
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This report is organized by media. Problems within each media have normally
been ranked (ranking methodology is presented in Appendix A). No attempt
has been made to rank problems on an inter-media basis.
The basic intent of this report is to provide a significant new prespective
which will give Agency and State planning and management activities, a clear
environmental focus; thereby enhancing our ability to set and achieve
environmental goals.
AIR
The major findings of this report with respect to the air media are as
follows:
1. The overall air quality for most geographical areas of Region III,
has either shown improvement or little change over the past three
years.
2. The number of Standard Metropolitan Statistical Areas in Region III
exceeding standards for particulates and ozone has decreased.
Trends analysis based on the number of days the standards for these
pollutants were violated for the period 1975 - 1981, show a clear
downward trend. Existing State Implementation plans and federal
regulations should allow for attainment of standards for these
pollutants in most areas. The noteworthy exception is ozone in
major urban areas, which will probably require further control to
meet standards.
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3. Monitoring results for carbon monoxide show no clearly defined trend.
We believe this can be largely attributed to monitoring stations being
moved in an effort to obtain more meaningful measurements. Nevertheless,
attainment of the CO standard in all areas is expected under current
regulations.
4. Two counties in Region III still violate the sulfur dioxide standard.
These are Allegheny County, Pennsylvania (Pittsburgh area) and Hancock
County, West Virginia (West of Pittsburgh). It is not immediately clear
which sources are the cause of these violations or exactly what needs to
be done to remedy them.
5. Airborne toxic pollutants have become a major public concern in some
areas. However, data is lacking to determine if there is a problem and
its extent. Although a number of studies have been completed and others
are underway, a number of problems exists relative to data collection
methodology and data interpretation.
6. Long range transport of pollutants, particularly sulfur dioxide and acid
deposition are interrelated problems which are of major concern.
Additional research, data collection and technical/legal manpower will
be needed to address these problems.
7. Indoor air pollution is an issue of increasing concern to many residents
of the Northeast. Although EPA does not have the regulatory authority
to address this issue, our staff receives public requests for
information on a regular basis. A mechanism for obtaining updated
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information on indoor air pollution measurements and controls would be
beneficial.
8. Planning and enforcement efforts have been slowed due to the incertainty
of anticipated changes in the particulate standard. A decision regarding
this new standard would help resolve these uncertainties.
9. About 86 percent of the public schools in the Region have complied with
EPA's inspection requirement for asbestos containing materials. Private
schools however, are not required to report and therefore, we are unsure
of their compliance. We are concerned that schools which lack the funds
for cleanup may not conduct the required inspections. In the absence of
a mandatory federal cleanup requirement, we believe that cooperative
agreements with the states are the best way to insure compliance. This
will however, strain regional resources.
10. The economic recession has resulted in decreased levels of air pollution
as factories and other sources cut their output. There exists a
potential that an economic recovery may not include the appropriate
levels of pollution control. Therefore, the Agency needs to be alert to
any indication that this potential is materializing.
11. We expect that the PSD increment eventually will be consumed in one or
more areas, thus stopping future major industrial construction. We
believe there is a need to establish a tracking system which documents
the use of the PSD increment. We also should develop Agency guidelines
and policy for dealing with this situation.
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12. The current division of responsibility between EPA1s air program under
the Clean Air Act and the Center for Disease Control is causing concern.
The review of independent health-effects studies, resulting from
activities outside our regulatory responsibility, leads to a delay in
the release of information to the public. This has resulted in
increased public worry and pressure on the agency. EPA needs to
increase its internal ability to review health-effects studies and to
release the information to the public.
SURFACE WATER
The major findings of this report with respect to surface water are as
follows:
1. Surface water quality in EPA, Region III has seen significant
improvement in the last decade. Dissolved oxygen (DO) levels have
increased in the Potomac River (near Washington, DC), the Delaware River
(near Philadelphia, PA), the Kanawha River (near Charleston, WVA), and
the Monongahela River (near Pittsburgh, PA). Most of the progress has
been due to the upgrading of municipal and industrial waste treatment
facilities. The Monongahela River has also seen significant progress in
correcting pH problems (through the treatment of coal mining discharges)
and lower cyanide and phenol levels (due to improved waste treatment and
decreased production of the steel industry). Numerous other examples of
localized improvement are documented.
2. Despite these advances, an estimated 6,456 miles of streams in Region
III still cannot meet planned uses because of a variety of pollutants.
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3. The major sources and problems are: acid mine drainage from coal mines;
toxic discharges from industry; nutrients and sediments from
agricultural runoff; nutrients from municipal wastewater treatment
plants; lowering of dissolved oxygen levels due to municipal discharges
and industrial; and high bacteria levels from a combination of municipal
waste, industrial discharges, combined sewer overflows, agricultural and
urban runoff, and on-lot sewage disposal.
4. Acid mine drainage is by far the major cause of use impaired streams in
the Region, accounting for an estimated 49 percent of the use impaired
streams. Attempts to solve the problem, particularly with abandoned
mines, have met with minimal success. Reliable technology for
mitigating the problem has been slow in developing, there is little or
no public funding to develop the technical solutions and to apply them.
Further, it is often impossible to locate private responsible parties to
undertake cleanup. More research on cleanup technologies as well as
better mechanisms to require mine operators to deal with the problem are
needed to meet stream standards. It may also be necessary to further
restrict mining in some areas where streams may be especially sensitive
to acid drainage, unless long term control measures can be effected.
5. There is a general lack of data concerning the prevalence and health
effects of many toxic pollutants from industry. However, the data that
is available raises some concerns. Toxics have been found in an
estimated 16 percent of use impaired streams in Region III and in some
cases could represent the greatest threat to public health of all water
quality problems. An aggressive program of bio-monitoring should be
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undertaken in order to obtain a better data base and make "before" and
"after" determinations of impact on aquatic life. More resources are
needed to accomplish a better program. The completion of BAT guidelines
for toxics related industries will also be a major step in improving
this problem.
6. Non-point source runoff from agricultural activities adds to the
nutrient burden of nitrogen and phosphorous in many streams and lakes
and are responsible for excessive algal growths. Large quantities of
sediments also run off from farming activities. Best Management
Practices (MBP) can control these problems, but to date, farmers have
had little economic incentive to use them. EPA should work with other
federal agencies and the States to encourage the use of BMPs through
educational programs and other means to stimulate controls in priority
areas.
7. Point source discharges from municipal sewage treatment plants have
contributed to nutrient loads in a number of lakes in the Region.
Analysis is needed to determine where point source nutirent controls are
necessary and cost effective. EPA should also develop a program to help
permittees in the operation and maintenance of municipal nutrient
control facilities.
8. Dissolved oxygen levels in a number of streams have been substantially
reduced by the oxygen demand of waste from inadequate municipal sewage
treatment plants. The States should direct future construction grants
funding to communities whose present discharges cause water quality
problems.
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9. High bacteria levels are the most common water quality problem in
Virginia, Delaware and the District of Columbia. Bacteria is easy to
control if the source is known. Since the source of much bacterial
contamination has not been documented in the Region, studies of this
problem should be undertaken by the States.
OCEANS
The major findings of this report with respect to the oceans are as follows:
1. The overall condition of the coastal waters and the marine environment
within Region III are considered good. However, ocean dumping, ocean
discharges and oil and gas drilling are potential point source threats
to ocean water quality. Lowered dissolved oxygen levels in the oceans
are also caused by the entry of organic materials through non-point
sources of pollution.
2, No ocean dumping is presently taking place in Region III waters,
although an ocean incineration site, a sludge dumping site,and a dredged
site are proposed. Extensive monitoring programs are proposed for these
sites.
3. There is only one large sewage treatment plant presently discharging
into the ocean. This plant, at Ocean City, Maryland, appears to be
causing no harm to ocean quality. Section 301(h) of the Clean Water Act
allows some modification to the secondary treatment requirement for
publicly owned treatment works (POTW) discharging into "marine
waters."
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4. Oil and gas drilling in the oceans present a potential hazard through
accidental spills and the discharge of drilling muds. Spills are
regulated by the Coast Guard. EPA has proposed to control drilling muds
through the use of a general permit for all drilling platforms located
in the Outer Continental Shelf. Although no commercial drilling is
presently taking place, the potential is there and will probably
eventually transpire.
5. A number of fish kills have occurred offshore due to lowered dissolved
oxygen levels. These events are thought to be due to phytoplankton
growth caused by naturally occurring nutrients and nutrient plumes from
major estuaries such as the Chesapeake and Delaware. Of future concern
to ocean water quality is the disposal of dredged spoils, the disposal
of sewage sludge, potential large oil or hazardous waste spills from
tankers or offshore drilling, and the possible effects of ocean
discharges by POTWs. Further studies and close surveillance of these
activities will be required, however, present resources are inadequate
to accomplish this to the desired level.
DRINKING WATER
State and EPA implementation of the Safe Drinking Water Act has revealed
several important problems. These are: compliance violations by small
systems, response to unregulated contaminants, Pennsylvania primacy, and
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water quality issues. The highest priority has been placed on small system
compliance. According to the latest inventory, 5,272 of the 5,854 community
water systems in Region III are small systems serving less than 3,300 people
each. Although small systems supply only 9.1 percent of the total
population served by community systems, approximately 98 percent of the
persistent violations of drinking water standards occur in small systems.
These violations involve failure to meet monitoring and reporting
requirements or failure to meet drinking water quality standards. A
financial study indicates that many of these systems have serious financial
and/or operating problems.
GROUNDWATER
EPA's data on groundwater contamination is based primarily on reported
incidences of contamination plus a review of the groundwater quality near
hazardous waste disposal sites slated for cleanup under Superfund. The data
is far from complete because there is little information on recharge areas,
water quality from private wells, or possible contamination by active
hazardous waste sites. There is also a lack of complete geohydrological
data for all areas in the Region.
The principal sources of groundwater contamination are industrial waste
disposal facilities, agricultural wastes, on-lot waste disposal, oil and gas
exploration, mining, and salt water intrusion. Many of the health-related
concerns are attributable to the presence of volatile organic chemicals such
as trichloroethylene (TCE) and perchloroethylene (PCE). These contaminants
are typically associated with a variety of commercial/industrial
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activities. More information needs to be gathered on the location of
drinking water sources, the aquifers they use and area geology in order to
determine how best to protect these supplies from future contamination.
HAZARDOUS WASTE - RCRA
The major findings of this report with respect to RCRA are as follows:
1. A total of 7,556 hazardous waste activities have been reported in Region
III. Of this total, 952 facilities have been identified which require
RCRA permits for the treatment, storage or disposal of wastes. Although
there is a general lack of data concerning the amount of hazardous waste
being handled and incomplete inspection of waste handlers, several
problem areas have been uncovered. These are groundwater contamination,
siting of hazardous waste facilities, the disposal of hazardous wastes
in sanitary landfills, and the illegal disposal of hazardous wastes.
2. Groundwater contamination occurs most frequently from surface
impoundments, landfills, and land use practices. We must identify and
correct these problems as soon as possible.
3. Siting of hazardous waste facilities will be a continuing problem with a
high level of public opposition. The failure to approve new sites is
widening the gap between the volumes of waste generated and the capacity
of storage, treatment of disposal facilities. EPA must promote close
cooperation among state and local governments, industry, and the public
to resolve this situation.
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4. The present small generator exemption and the allowing of small
quantities of hazardous waste to be disposed of in sanitary landfills
has the potential of creating situations that could endanger public
health. The current regulations should be revised to eliminate this
possibility.
5. RCRA requirements alone cannot prevent "midnight dumping" of hazardous
wastes. The problem can be solved only through a coordinated effort
between federal, state, and local law enforcement and environmental
agencies.
HAZARDOUS WASTE - SUPERFUND
Emergency actions are taken when there exists an eminent danger to public
health. These acctions can range from securing the site to actual removal
of the hazardous material.
Remedial cleanup of hazardous waste sites is based on a priority ranking
using the Hazard Ranking System (HRS). The HRS is a good system for
evaluating sites, but it does have some shortcomings. Not all potential
sites have been investigated, nor has the HRS been applied to all sites that
have. Thus there will be new sites which will be added to the National
Priority List, thereby shifting priorities.
Another major problem concerns the inability of some states to provide the
required 10 percent share of costs for a detailed survey and/or cleanup of a
site. Unless the states develop better mechanisms for securing their share
of the costs, cleanups will be delayed.
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PESTICIDES
Most pesticide problems are related to improper use by pesticide
applicators. Most pesticide applications take place in residential areas
rather than in agricultural areas. Commercial pest control operators
working in homes are responsible for the majority of proven pesticide
mis-use incidents which may cause harm to man or the environment. Although
some form of state enforcement action is taken in all proven mis-use
incidents, more efforts are being made to address the mis-use by commercial
pest control operators.
RADIATION
The radiation program in Region III has as its prime responsibility the
review of State and County emergency plans for nuclear power plants.
There are eight nuclear power plants in Region III and one in Region II for
which the 10-mile planning zone extends into Region III. Five State plans
and twenty-eight County plans are being developed which must be reviewed by
the Region III radiation program. In addition, each plan must be exercised
in a full-scale drill at least annually, leading to nine annual exercises
which are attended by the Regional Radiation Representative.
The Canonsburg inactive uranium mill tailings site is located in Region
III. Remedial actions at this site will be performed by the Department of
Energy over the next couple of years. The Region has reviewed the draft EIS
for site cleanup, will review the final EIS, and will keep abreast of the
remedial actions.
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FEDERAL FACILITIES
Based on GSA inventory records, there are 2,214 Federal Facilities in EPA,
Region III. These facilities encompass some four and a half million acres
of land.
Pollution abatement projects are presently being carried out at 503 of these
facilities.
There are 144 federal facilities which are major air contributing sources
(100 ton per year potential), of which five are known to be out of
compliance. Each of these five sources are operating unaer an acceptable
abatement schedule.
There are presently 256 NPDES applications on file of which some J2 percent
are out-of-compliance. Many of these are operating with expired permits.
Compliance rates have increased in recent years.
Presently 36 federal facilities have submitted Part "A" RCRA applications.
In accordance with Executive Order 12316, EPA will play an advisory role to
the Department of Defense in the investigation, study and clean-up of
Superfund sites for federal facilities.
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REGIONAL SUMMARY
The following table summarizes the Environmental problems in Region III.
The most significant Regional problems include hazardous waste dump and
disposal sites, the siting of new hazardous waste facilities, ozone and
SO- air pollution, surface water contamination by acid mine drainage and
non-point sources, PCB contamination incidents, persistent violations with
small water supplies and significant potential groundwater contamination.
The following four regional problems were chosen for more detailed analyses
of the problem and probable solution(s). These analyses are contained in
Appendix B.
a. Violations of ozone standards
b. Surface water pollution by acid mine drainage
c. Non-point source pollution by nutrients and sediments from
agriculture
d. The Development of a regional ground water data base.
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Part 2.
Discussion of Environmental Problems
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Introductions
Part 2 is a media-by-media discussion of significant environmental problems
and implications for agency management.
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AIR QUALITY PROBLEMS
1. Environmental problem
TSP Standards Violations in Steel-Producing Areas (Priority 1)
a. The problem
The primary NAAQS for Total Suspended Particulate was exceeded in
1980 and/or 1981 in Baltimore City and Baltimore County, MD, in
Allegheny County, Beaver County, Chester County and Westmoreland
County, PA and Brooke County and Ohio County, WV.
b. Cause of the problem
All of these are steel-producing areas with various levels of
non-compliance from steel making as well as many other sources of
particulate matter which tend to cluster around steel-making
operations. SIP Planning to actively remedy these ambient
violations has been on a back burner for several years, since the
announcement that a new particulate standard is imminent, and the
change in emission levels that has resulted from the imposition of
RACT and as a consequence of the slow economy. However, there is
an increasing level of activity to substitute control over fugitive
and roadway dust in lieu of control over process emissions.
Process emissions tend to be of small size while road dust is
generally somewhat larger because road dust consists of both
particles which have fallen on the road and particles originating
from the road itself. Suspended roadway dust tends to be larger in
size than process emissions. The trades are less than ideal in
terms of small particles and the future attainment status of these
areas will depend on the new standards established. Very little
progress on these problems is expected until the new particulate
standard is promulgated. Should a marked improvement in tne steel
making economy occur, it is likely that particulate levels in these
areas would worsen markedly.
c. Regional significance
This problem is significant but not unique to Region III because of
the number of steel plants in the Region. In addition,
non-attainment of the TSP standard beyond the statutory
non-attainment date could be of great significance to the Region
due to the potential for curtailed growth and the possible impact
on Federally-funded projects.
d. Trends
TSP levels have shown a general downward trend in these areas since
the mid 1970's, coincidental with a general economic downturn in
the steel industry in the Northeast. The TSP standard continues to
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be violated despite the reduced level of steel-making activity.
The downward trend in TSP levels may or may not continue depending
on the individual circumstances of the areas involved. In this
case, trends are not a reliable prediction of future events due to
the potential for economic improvement.
2. Barriers to solution of the problem
One of the principal barriers to solution has been the delay in
promulgating a size-specific particulate standard. During the 1979 SIP
revisions, major strengthening of TSP regulations was not required
because a new particulate standard was thought to be imminent at the
time. Instead, RACT measures are all that EPA required. In addition,
many previously negotiated consent decrees requiring emission reductions
at steel plants are being renegotiated under the bubble policy. Under
the TSP standard, road dust controls may be traded for conventional
source controls despite differences in particle size and potential lor
health significance. Until promulgation of the size-specific standard,
resolution of this problem is unlikely.
3. Management implications
a. Regional Actions
(1) EPA
Region III must continue to enforce the regulations that are
now in effect. This will mean a continuation of past policies
unless new directions are received.
(2) States
Region III states continue to wait for a size-specific
particulte standard. It is also not realistic to expect
states to oppose emission trades in an industry which is as
economically depressed as the steel industry.
b. EPA Headquarters actions
Actions by EPA Headquarters have not yet begun to remedy the
problem. As mentioned above, the long-awaited size-specific
particulate standard has prevented additional SIP measures in
non-attainment areas.
4. Anticipated results
Until EPA promulgates the new standard, the current situation will most
likely continue.
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1. Environmental problem
Ozone Non-Attainment (Priority 1)
a. The problem
The ozone standard is not being attained over large areas of Region
III, principally in the northeast corridor and near Pittsburgh.
b. Cause of the problem
In most cases, attainment of the standard is predicted by 1987
within the error of the available models. This result is primarily
due to the Federal Motor Vehicle Control Program and controls over
stationary sources of hydrocarbons. While modeling may forecast
attainment by 1987, there is sufficient uncertainty that attainment
cannot be said to be assured.
c. Regional significance
It is necessary that a close watch be kept on reductions in ozone
concentrations between now and 1987 to verify that the controls as
implemented achieve the ozone reductions predicted by models. In
addition, certain control measures (I & M in Pennsylvania) were
late in being accepted. In this circumstance, further Federal
sanctions if any must be carefully weighed to prevent loss of
other, perhaps more desirable, programs. An effort should be made
to establish an acceptable program to allow EPA to administer the
Air program in an optimum manner.
d. Trends
The general trend in ozone levels in Region III has been a gradual
reduction in violations over the years. It is difficult to
accurately assess the trend because of changes in monitoring
methods and station locations over the years. The inclusion of new
stations in "rural" areas has tended to increase the observed
number of violation - days in some cases where the trend at a given
monitor would be downward. An attempt has been made to currect
this effect in the graphic presentation later in this report.
2. Barriers to solution of the problem
Since the problem is simply to assure attainment of the ozone standard
by 1987, the only barriers to solution of the problem are events which
may cause the standard not to be attained. These might include failure
of states or municipalities to implement required control measures (such
as I/M for motor vehicles), unplanned increases of emissions which might
result from (for example) shut-down of a major public transit system, or
failure of reductions in emissions to achieve modeled ozone reductions.
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3. Management implications
a. Regional actions
(1) EPA
Required submissions from states include ambient air quality
data and data on reasonable further progress (RFP) toward
attainment. The region will review these submissions and
compare emission reductions achieved with those projected to
be achieved. It will also be possible to utilize the planning
models to predict the resultant ozone levels from reductions
achieved. A comparison with measured ozone levels will
determine whether ozone reductions predicted by the models are
actually occurring.
(2) States
In addition to their major role in implementing control
measures, the states are required to submit RFP reports and
ambient data to EPA which will be the basis for the above
analysis.
b. EPA Headquarters actions
In addition to its regulatory overview role, EPA Headquarters will
need to support the regional analysis of progress toward the ozone
standard. In the event that modeled reductions are not accurately
reflected in measured ozone concentrations, more sophisticated
models will need to be made available to attempt to refine the
analysis. It may also be necessary to apply the Regional Model to
better assess the incoming ozone and precursor concentrations that
might interfere with attainment. If modeled ozone reductions do
not occur, a major re-planning effort might be indicated using far
more sophisticated models than the EKMA which was used for the 1982
SIPs.
4. Anticipated results
If all the models are reasonably accurate, the anticipated emission
reductions should occur and the ozone standard should be attained.
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1. Environmental problem
SC>2 Primary Non-Attainment in Allegheny County, PA (Priority 1)
a. The problem
Allegheny County, PA shows S02 primary non-attainment in
1980-81. A single monitor, Hazelwood, shows annual averages of 139
and 118 ug/m3 during these years respectively. There are also
modeled violations of the standard at other locations in the county.
b. Cause of the problem
The monitored violations appear to be due to an inoperative sulfur
recovery unit at J & L steel, and so should be controllable by
bringing the control device into operation. However, there are
also modeled violations of the SC>2 standards throughout the
county which are not reflected in the monitored data, probably
because monitors can only be located at a finite number of fixed
points. In this case, the violations appear to be due to a large
number of sources both inside and outside the county, most of which
are already tightly controlled.
c. Regional significance
If the primary SC>2 standard is not attained by the statutory
deadline, the Region would be forced to assess the situation.
Potential actions include additional SIP planning for the area-wide
problem and source-specific actions for the monitored violation.
d. Trends
Since the monitored violation at Hazlewood is due to an inoperative
piece of control equipment, attainment at that monitor can be
expected when the equipment is returned to service. The modeled
violations elsewhere are expected to persist and must be verified
using ambient monitors.
2. Barriers to solution of the problem
For the source-specific violation, the only barriers are the engineering
constraints in getting the sulfur recovery unit on line. For the
area-wide problem, there is a lack of further reductions in S02 which
may be readily obtained within Allegeheny County. If the monitoring
proves the problem to be real, emission reductions will need to be
obtained from outside the immediate area, perhaps including sources in
other states.
3. Management implications
a. Regional actions - EPA and State
The remedy to this problem is not immediately apparent and so the
Allegheny County Health Department and EPA are now conducting an
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analysis of the problem. Potential solutions include reductions in
both distant and local sources of SC>2. The study also includes
some validation of the model results.
b. EPA Headquarters action
If interstate emission reductions are required, these may extend
into Ohio which is in another EPA Region. If interstate transport
is involved, there will also be new policy questions to resolve.
4. Anticipated Results
It is possible that the study now being conducted will show attainment.
If the models are proved correct, however, it will probably be necessary
to require interstate emission reductions to achieve the standard.
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1. Environmental problem
Airborne Toxic Substances (Priority 2)
a. The problem
In spite of the lack of standards on these substances (except vinyl
chloride), there is substantial public interest in ambient levels
of toxic substances. As a result of the high level of public
interest, the regional office must deal with these problems despite
limited regulatory authority or program funding.
b. Cause of the problem
It is sometimes the high level of public interest which generates
the workload for the Regional Office in addition to the toxic
substance itself or its health effect, though in some cases the
hazard may be immediate; each case therefore must be dealt with as
a potentially serious health problem.
c. Regional significance
In Morgantown, WV, a study of organics adsorbed on particulate
matter has yielded a positive Ames response. The original work
done by a NIOSH laboratory is now being expanded into a cooperative
EPA/NIOSH study coordinated by the Regional Office.
In response to a request by the City of Philadelphia, funding was
provided for purchase of instrumentation and a study of ambient
toxic organics in the city. Philadelphia is also a leader in
registration of toxic substances under its "Right-to-Know" law.
Funding has also been provided recently to the Commonwealth of
Pennsylvania to plan, develop and implement a comprehensive air
toxics program taking into consideration critical substances,
emissions control techniques, health and inter-media effects. In
addition, several EPA studies are also under way in Philadelphia
including the Integrated Environmental Management Program and an
experimental study of various sampling and analyses techniques by
the Environmental Monitoring Support Lab (EMSL) in North Carolina.
In the past, Region III has conducted a study of toxic organics in
Charleston, WV and routinely receives inquiries from citizens and
elected officials on the study.
As the RCRA permit process moves forward, closer integration of
regional resources is taking place in order to prevent subsequent
harmful emissions of air toxics from transport, destruction or
storage facilities of hazardous waste materials.
d. Trends
Toxic organics may be classified as a perceived environmental
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problem in spite of the lack of standards including long-term
low-level exposure and its effects. In order to properly handle
this problem, it will be necessary for Region III to continue to
devote resources and to receive support from various headquarters
and laboratory groups that have provided help in the past.
2. Barriers to solution of the problem
Barriers include the difficulty in measuring toxir air pollutants, the
absence of ambient or emission standards, the difficulty in achieving
emission reductions for non-regulated pollutants and the tendency of
some persons and organizations to "sensationalize" the problem.
3. Management implications
Regional actions
(1) EPA
The Regional Office must continue to devote resources to toxic air
pollutant programs, expanding them as necessary in order to protect
the public from real health threats and to address perceived
threats. The alternative would be a public perception of an agency
which is not protecting public health.
(2) States
Most State air agencies must respond to toxic air pollutants
because of public demands. Typically, problems are passed on to
EPA, but a strong public outcry will result in individual State
regulations. The resultant non-uniformity could become a problem
to industry.
b. EPA Headquarters actions
In the past, the Region has received support from various
Headquarters components to deal with toxic air pollutant problems.
This support should continue. However, the absence of an agency
air toxics policy has hampered initiatives of some states,
particularly those with underdeveloped or non-existent programs.
4. Anticipated results
A reduction in real or perceived threats to public health is the
ultimate goal of our actions in toxic air pollutants. Individual
problems must be dealt with on an individual basis. If a specific
problem occurs frequently, it may be desirable to deal with it on a
generic basis.
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5. ADDITIONAL ISSUES WORTHY OF DISCUSSION
The following issues are not prioritized, but are felt to be important to
discuss:
Indoor Air Pollution
During a large part of the year in the Northeastern United States, people
spend most of their time indoors with the windows closed. Under these
conditions, their exposure to air pollutants is very different from outdoor
levels. Measurements show that indoor sulfur dioxide levels are generally
lower than outdoors (except where kerosene heaters are used) while carbon
monoxide and nitrogen dioxide levels tend to be higher where gas is used for
cooking. When a smoker is in the room, particulate levels often exceed the
criteria for various alert stages. In addition, indoor air often contains
substances which are not encountered in significant quantities outdoors.
Examples of these substances are formaldehyde from insulation and
construction materials, radon gas from uranium-bearing soils, solvents from
various paints, paint removers, fabric sizing and adhesives from carpeting,
etc. Many of these substances are potentially as hazardous as normal
outdoor pollutants - for example formaldehyde and methylene chloride (used
in household paint removers) are suspect carcinogens. Kerosene heaters are
a difficult problem to deal with because of the role played by the choice of
fuel in determining the health problem, and because their use is voluntary.
In the regional office, we routinely receive inquiries on the hazards of
indoor air pollution. If we know of a specific hazard, we will direct the
caller to a reliable source of information. While EPA does not regulate
indoor air and does not envision any regulatory activity in the future, an
understanding of population exposures and health effects is needed. First,
to properly evaluate the epidemiological data used to set air quality
standards, population exposure to indoor air pollutants needs to be
accounted for. In addition, since EPA has a public health responsibility it
seems proper that we should be able to inform the public of indoor hazards
even if we do not intend to regulate them.
In order to provide this service, the regional office will need data on
indoor air pollution and its hazards. Such data could be compiled at
Headquarters and sent to all regions, saving much duplication of effort.
Research on indoor air pollution should also be re-established.
Transition to Size-Specific Particulate Standard and Other
Standard Changes
For several years it has been known that EPA would probably adopt a
size-specific standard for particulate matter. The general impact of this
knowledge has been a virtual halt in the planning process to achieve the TSP
standard. Enforcement efforts have also been slowed by the uncertainty in
the standard. The long delay in proposing the standard revision has caused
this state of limbo to continue beyond the statutory attainment date. Even
after the standard is promulgated, it will be several years before
sufficient ambient data is available to re-enter an orderly planning
process. The impact of this problem is especially severe in steel-producing
areas.
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Proposal and final promulgation of the revised particulate matter standard
should be accomplished by headquarters on a priority basis. We have seen
adequate guidance from headquarters on the transition, so additional
guidance is not required. The guidance which we have seen is quite general
and is based on the minimum of information that would be expected to be
available to judge future attainment status of areas needing particulate
control. The guidance should be kept flexible enough that we can use
whatever data is available in the transition process. For example, if a
study has been done that includes size-specific measurements, we should
utilize these rather than assuming PM-10 will be some set fraction of TSP.
Acid Precipitation and Deposition
Acid precipitation appears to be affecting many lakes and streams in the
Northeast United States, however it is not apparently an immediate threat to
health. However, it certainly is a perceived problem on the part of the
States and is definitely a political and international relations problem.
We frequently receive requests for information on "acid rain" and generally
refer the requstor to our library where we have a small reference collection
on the subject.
Headquarters assistance is needed in the form of more and better literature
for distribution on the subject which will present the evidence in a factual
manner and that would not be misunderstood by the public. Recently,
standard methods for measuring wet deposition have been established, however
it is also apparent that there is no authoritative consensus on the trend in
pH since the historical data has been gathered by many different methods.
Each of these previously used methods should be compared with the reference
method so that the data can be compared to yield trends, though these would
only be best estimates due to poor quality assurance on some past
measurements. In addition, even if there is no trend in precipitation pH,
buffering agents underlying many watersheds may be depleting due to the
constant acid loading from rainfall and dry deposition. Thus trends in
surface and lake acidity may be as important as trends in precipitation
acidity.
More research is needed to develop testing methodologies for dry
deposition. Headquarter's assistance is needed to develop an overall
strategy for acid precipitation and deposition which defines the data base
that is needed to determine the significance of this potential problem.
Given that piece of information, our states could better define their role
in contributing to the data base. The overall strategy should also provide
specific time frames in which critical regulatory decisions would be made.
Our state of knowledge today and the time required to achieve an
understanding of the problem sufficient to establish the need for regulation
should be clearly laid out in a form understandable to the general public.
Asbestos-in-Schools Program
Starting in 1979, EPA conducted a voluntary program to assist schools in
inspecting their buildings for asbestos containing materials. Region III
took an active role in implementing the voluntary program by conducting
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training seminars for school personnel and by visiting schools with special
problems. Approximately 20 percent of the public schools and 75 percent of
the private schools were not inspected under the voluntary program. For
this reason, EPA issued a regulation in May 1982 requiring all schools to be
inspected by June 28, 1983.
Region III public school districts have inspected 86 percent of their scools
and are well on the way to 100 percent compliance with the inspection
regulation. Since there is no regulation mandating abatement action, it is
left to school administrators, employees, and parents of students to see
that asbestos materials are encapsulated, enclosed or removed. Of the
schools inspected, 12 percent need corrective action. Many schools have
little or no funds for correcting asbestos problems. The lack of an
abatement regulation provides another obstacle in resolving the
asbestos-in-school problem. Inspection and abatement in private schools is
the biggest problem in Region III. Since schools are not required to report
to EPA under the inspection regulation, it will be difficult for Region III
to target those private schools that are not in compliance. Those that do
inspect usually have no funds for correction of the problem.
Fourteen of the 100 largest Local Education Agencies (LEA) in the country
are in Region III. According to the compliance strategy issued by
Headquarters, the records of these 14 LEA's must be inspected. Since Region
III resources for the asbestos program are limited, it is recommended that
the Region enter into non-funded cooperative agreements with the States.
The degree of State participation could range from establishing a tracking
and reporting system of the asbestos-in-schools program to taking over the
entire program. Even with State cooperative agreements, the Region's
resources will probably be strained in providing assistance to those States
with little resources of their own such as Pennsylvania and West Virginia.
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Effect of Economic Recovery on Air Pollution
The present economic recession has hit especially hard at the older steel
production facilities in the northeast, especially in the areas in the
western part of Region III. Particulate levels have dropped recently and
have generally tended to track the steel production levels in the vicinity
of some steel mills. Our best guess is that an economic recovery would
cause particulate levels to increase. This material is also generally in
the small size range and so would probably also be a problem with a
size-specific standard. Depending on the level selected for the new
standard, some additional controls may be needed if an economic recovery
takes place.
At the present time, useful input from headquarters on this problem would be
some plant-specific economic forecasting which would assist us in
forecasting future steel-producing activity. However, in view of the
economic problems and high unemployment in these areas, a return to the
concept of technology transfer (formerly part of R & D) may be appropriate
both in helping with economic recovery and in controlling the pollution
associated with that recovery.
Economic Growth and Energy Development
In spite of a marked slowdown in energy growth since the 1973 oil crisis,
there is a continued trend toward increased energy production and economic
growth. Much of this growth also replaces older facilities and is covered
under New Source Performance Standards or the PSD requirement for BACT.
Thus where growth causes replacement of existing facilities, pollution
reductions may occur. On the other hand, except for certain industries like
electric power where production facilities must be located somewhere near
the demand, much of the growth is occurring in the sun belt while the
existing facilities being replaced are in the northeast. Thus this current
round of economic growth is actually one source of unemployment in older
areas. Unfortunately, in some cases environmental laws are being blamed for
loss of jobs.
While the trend to move south is not subject to regulation by EPA, the
impact of environmental regulations should be of concern. Since we are
required to perform economic impact analyses for many of our regulatory
actions, this analysis could be extended to evaluate the overall effect of
environmental regulations on the economy. EPA should publish this
information in an easily-read format for consumption by the general public.
Consumption of the PSD Increment
Growth in itself is not a serious environmental problem due to the stringent
requirements imposed on new facilities, however PSD policy currently allows
the possibility of the entire available increment to be consumed by the
first applicant(s) in any area. While this has not been a problem to date,
we will arrive at a point where a new facility cannot be built because the
increment has been fully consumed. When this happens, there will
undoubtedly be some action taken against EPA. This will possibly prove
embarrasing to the Agency in view of our almost complete lack of any
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increment tracking system. We therefore suggest that a computerized
increment tracking system be established, possibly as a part of AEROS.
Since the increment is a measure of air quality, it would make the most
sense to associate it with the SAROAD system, though it also has many
attributes closely associated with the NEDS data base. A third data base
associated with these two seems appropriate.
Health Impact Studies
In several instances over the past few years, independent reseachers have
conducted health-effect studies in our region which alleged excess cancer
deaths, identified hazardous industries with direct health effects, and in
some cases produced reports which caused unnecessary alarm on the part of
people in the "affected area". Our current policy is to forward such
studies to the Center for Disease Control in Atlanta since EPA's in-house
source of expertise, the Epidemiology Branch in HERL, has been abolished.
CDC generally takes several months to provide assistance, hence many people
go through unnecessary worry. Often elected officials get involved because
of the long response time which causes more work for the regional office.
This is especially vexing since some of these "studies" are based on unsound
scientific principals, hence the public is needlessly alarmed.
Since EPA still has many experts on staff who could help resolve these
problems, it would be helpful if a first-cut responsibility for review of
outside studies could be established within EPA. This would allow both a
rapid response to citizen inquiries and would avoid sending obviously flawed
work to CDC. At the minimum, where an expert is available to the Region, we
should have authority to use him before going to the Center of Disease
Control (CDC has assigned a liaison to the Region 111 office which has
helped greatly).
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SURFACE WATER QUALITY PROBLEMS
Introduction
The purpose of this report is to identify: 1) priority surface water quality
problems of EPA Region III, 2) barriers to solutions of these problems *nd 3)
their management implications. Water quality problems in EPA Region III are
summarized in Figures 1 and 2. (For a detailed assessment of waterbody use
impairment, see Appendix A). The methodology used to identify the priority
water quality problems in Region III follows this introduction. Utilizing
this methodology, these priority Source/Pollutant categories were identified:
Priority A: Coal Mining/pH, Iron, Sediment *
Industry/Toxics (inorganic and Organic) *
Domestic Wasted/Nutrients
Agriculture/Nutrients, Sediments
Domestic Wasted/Dissolved Oxygen
Point and Non-Point Sources/Bacteria
Priority B: Urban Runoff/Nutrients
Spills/Oil, Hazardous Substances
Oil and Gas Operations/Dissolved Solids, Sediment, Toxics
Freeipitation/pH
Wetlands
In this section, solution barriers and management implications are proposed
for Priority A problems. Due to their regional significance, Coal Mining/pH,
Iron, Sediment and Agriculture/Nutrients, Sediments are analyzed in depth in
Appendix B.
Oil and Gas Operations, Wetlands and Acid Precipitation have been identified
as emerging problems which may, should current trends continue, become higher
priority problems. These emerging problems should be monitored closely by EPA
Region III.
Of particular regional significance are problems associated with the
Chesapeake Bay, an estuary which supports a variety of important uses. Recent
trends have shown a deterioration in water quality and decline in certain
aquatic fin fish and shellfish species. It has been theorized that high levels
of nitrogen and phosphorus may indirectly be responsible for the significant
impacts on water use. The Chesapeake Bay is considered a high priority
waterbody that fits into several of the generic priority categories identified
above.
Few priority waterbodies fall under this category. However, it has been
included because of the Regional extent of the problem.
This category does not include coal mining and oil and gas operations
related toxics.
Includes combined sewer overflows.
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FIGURE 1
REGION III
USE IMPAIRED STREAMS
Estimated Total Miles: 6,456
pH, Sediment, iron
49%
Nutrien
Sediment
Dissolved
Oxygen
9%
Agriculture
and
rban Runoff /
Domestic
Waste
15%
-
BY PROBLEM PARAMETER
BY SOURCE
Note: Best professional judgment was used to estimate source contributions. Generalizations were made as
to the source of some problems.
1 Potential toxics problems have also been included in the category (potential problems have not been in-
cluded in other categories).
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ICMJV
1000-
/)
d 500H
PH
M
N
M
D
PA
M
B
1000-
500-
PH
M
M
s pqs
N
D
MD
M
B
1000 1
500-
M
pH
M
N
M
D
wv
M
B
1000-
§ 500-
M
M
N
VA
1000-
M
500-
B
pH
M
N
M
D
DE
1000-
500i
M
M
pH
M
M
F=1S
N
D
DC
B
KEY: (S) Severe
(M) Moderate
(P) Potential
(pH) pH, Iron, Sediment
(N) Nutrients, Sediments
(D) Dissolved Oxygen
(T) Toxics, Organic and Inorganic
(B) Bacteria
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Methodology for Determining Priority Problems
Priority water quality problems were determined by Region III staff in the
following manner. All water bodies of impaired use were rated to determine
their relative significance. The criteria for rating significance ot a
particular geographic water quality problem are contained in the ranking
system (see Table 3 in Appendix A).
Utilizing this system, a group of waterbodies of highest rating were se-
lected as being "representative" of the priority water quality problems in the
region. (Note: These waterbodies are identified in the analyses to follow as
"Regional Priority Waterbodies".)
The "Regional Priority Waterbodies" were then assessed to identify the
categories of sources and pollutants which contributed to the use impairment.
The resulting Source/Pollutant categories were segregated into Priority A and
B, according to relative impact on the priority waterbodies.
As indicated, "Regional Priority Waterbodies" in this context are identified
to facilitate determination of priority water quality problems in the region.
These waterbodies represent examples of generic problems which occur
throughout the region and do not represent a list of targets for EPA funding
at this time. Such a list could only be developed subsequent to completion of
State Section 305(b) Water Quality Inventories which address priority
waterbodies.
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DOMESTIC WASTE/NUTRIENTS
1. Description of Problem
. Sources: Point source discharge from municipal wastewater treatment
plant. Nutrients of primary concern are nitrogen and phosphorus.
. Impaired Uses: Aquatic life, domestic water supply, recreation, aesthet-
ics.
. Method of Impairment: Nitrogen and phosphorus promote excessive growths
of algae, particularly in lakes and estuarine systems. Algae can
cause large drops in dissolved oxygen (through respiration) which can
be lethal to fish, imparts an offensive taste and odor to domestic
water supplies, impairs boating and fishing, and is aesthetically
offensive. Algae have also been linked to infections in humans
through water contact recreation, causing gastrointestinal,
respiratory and dermatalogical problems.
. Regional Significance: Often both municipal plants and agricultural run-
off contribute to excessive nutrient levels. Domestic Waste/Nutrient
dis-charges contribute to nutrient loads ot 14% of the impaired
stream miles and 25% of the impaired lakes in the Region.
. Trends: Generally, municipal discharges of nutrients have been or will
be corrected where adequate local cost-sharing is available.
. Regional Priority Water Bodies: Loch Raven Reservoir (MD), Back River
(MD), Patuxent River (MD), Green Lane Reservoir (PA), Neshaminy Creek
(PA), Pymatuning Reservoir (PA).
. Documentation: For priority water bodies, sources and effects have been
well documented. However, documentation for other advanced treatment
funding is lacking in many cases due to inadequate definition of the
relative contribution of point and non-point sources to total
nutrient loads.
. Treatability: Phosphorus control is a relatively common practice in mu-
nicipal wastewater treatment systems. Nitrogen control is
technologically feasible, but use is less frequent due to cost
considerations.
2. Barriers to Solutions
. Source Definition: Adequate documentation of point/non-point source
loads will be necessary in many cases, especially where Advanced
Treatment funding is desired.
. Operation & Maintenance: Where nutrient controls are constructed, opera-
tion and maintenance is often inadequate.
. Municipal Cost-Sharing: Some municipalities may have trouble absorbing
their share of advanced treatment costs because of changes in federal
funding policy.
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3. Management Implications
. States: Review existing construction grants priority system for modifi-
cations which would attach higher priority to significant water
quality problem areas. Assess current operation and maintenance
programs and institute changes where necessary. Assure that NFS
considerations are incorporated into AT development process.
. EPA Region III: Provide guidance to the States regarding 1) modification
of their priority systems to emphasize mitigation of water quality
impacts on streams, 2) operation and maintenance programs and 3)
Incorporation of NFS considerations into AT review process.
. EPA - HQ: Develop a national program addressing operation and mainte-
nance of municipal nutrient control facilities.
4. Anticipated Results
Implementation of recommendations would result in: 1) construction of
advanced treatment facilities where they are most needed and 2) proper
operation and maintenance of the facilities. Considering the high costs
associated with advanced treatment, the benefits to be gained are self-
evident.
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INDUSTRY/TOXICS
1. Description of Problem
. Major Sources: Contamination is primarily industrial in nature and takes
several forms: point source discharge, spills, stormwater runoff,
impoundments, landfills and improper disposal, etc. (Note: This
section does not address mine drainage or oil and gas drilling
related substances.)
. Impaired Uses: Aquatic life, domestic water supply.
. Method of Impairment: Human consumption of water or fish contaminated
with certain toxic substances represents a significant public health
risk. Contamination of water by some substances can lead to taste
and odor problems in public water supplies. Many toxic substances
are harmful to fish and other aquatic organisms.
. Regional Significance: Toxics are responsible for an estimated 16% of
the use impaired stream miles in Region III. Toxics are the greatest
potential threat to public health of all water quality problems.
. Trends: Levels of certain toxic substances have decreased in recent
years. For instance, PCB levels appear to have peaked in many areas
and now show a downward trend. This is probably in part due to the
comprehensive PCB control program currently in effect and is an indi-
cation of the benefits of toxics control. However, data is generally
inadequate to identify trends regarding EPA's 129 Priority
Pollutants. As more data becomes available, current problems should
be better defined and additional problems are expected to emerge.
. Regional Priority Waterbodies: James River (VA), Allegheny River (PA),
Schuylkill River (PA), Delaware River (PA), Ohio River (PA, WV).
. Documentation: Data is scarce for toxics concentrations in water column,
sediments, fish flesh and finished drinking water (non-MCL para-
meters). EPA water quality criteria are available for 64 toxics for
aquatic life and human consumption. However, data on health and
ecological effects are incomplete and controversial because of lack
of research. In summary, few conclusions can be drawn as to the
extent and effects of contamination, except for site specific
documentation on priority pollutants.
. Treatability: Technology is available (but costly) and includes aera-
tion, chemical addition/settling, and carbon adsorption.
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2. Barriers to Solutions
. Lack of Data: There is a serious lack of data and information on virtu-
ally all aspects of toxics including: 1) ambient water quality, 2)
raw and finished drinking water, 3) fate of toxics, 4) effects o£
toxics on aquatic life and man, 5) contribution of non-point sources
such as landfills and impoundments and 6) total number of toxic sites.
. Technology: Treatment methods are available to remove both organic and
inorganic toxics. (Significant advancements in water quality have
been experienced with the implementation of the technology based BPT
controls.) However, the BAT Guidelines have not been fully utilized
as toxics control method. In addition, monitoring detection limits
are often not low enough to properly assess organic toxic levels.
There are no approved disposal sites for PCBs in Region III.
3. Management Implications
. States:
1. Agree to implement EPA biomonitoring policy (including tissue and
toxicity studies) in State/EPA agreements
2. Accelerate toxics monitoring of suspect public water supplies.
. EPA Region III:
1. Commit to maintaining expertise in biomonitoring as it presently
exists in the Environmental Services Division.
2. Establish a biomonitoring coordinator in the Permits Branch/Water
Division to provide assistance and guidance to States.
Coordinators responsibilities would include:
Equitable and aggressive implementation of EPA's biomonitoring
policy (when finalized).
- When necessary, determine priorities in providing available
Regional expertise.
- Assure that results of biomonitoring are properly considered
when the permit conditions are established.
- Assure that State implementation of EPA's Biomonitoring Policy
is included in the State/EPA agreements.
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3. Select a priority waterbody and conduct several intensive surveys
that are designed to provide data for development of an annual
pollutant budget for appropriate toxics.
4. Establish local bio-data base linkage to the REACH file.
5. Operate an active PCB compliance monitoring program under the
Toxics Substances Control Act and PCB regulations.
6. Work toward the establishment of a PCB approved disposal site in
Region III.
7. Provide assistance to States in their development of a toxics
monitoring program.
EPA - HQ:
1. Finalize an aggressive policy for biomonitoring of effluents.
The policy should consider assessment of acute, chronic, and
bioaccumulation effects of toxics for resident fish species. The
policy and supplemental guidance should also address important
benthic species and primary producers.
2. Establish a national clearinghouse for collection and
distribution of all biomonitoring data collected. This transfer
of such data to other Regions could be very valuable in
minimizing future data requirements.
3. Finalize BAT guidelines for toxics related industries. These
guidelines should provide recommended permit limits or discuss
the value of biomonitoring in determining effluent limits for
that industry.
4. Establish criteria for safe fish tissue concentration for
significant toxic pollutants.
5. Pursue additional resources for State monitoring through Section
106 grants.
6. Revise PCB enforcement strategy to increase the Agency's
visibility in this program. One possible solution could be
nation-wide industry seminars designed to educate those that
handle PCB.
7. Provide additional resources for PCB monitoring in EPA.
8. Update and significantly expand the list of parameters with
recommended maximum concentrations levels (MCL's) for drinking
water.
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9. Support research to lower the existing detection limits for
significant toxic organics.
10. Support research to obtain conclusive data on epidemiological and
toxicological effects, fate and distribution of toxic substances.
4. Anticipated Results
Implementing these recommendations should provide a better data base,
evaluation methodologies and tools needed to adequately address priority
pollutants. This type of program expansion is responsive to the growing
media and public concerns over toxic pollutants.
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DOMESTIC WASTE/DISSOLVED OXYGEN
1. Description of Problem
. Source: Municipal treatment plant discharges.
. Impaired Uses: Aquatic Life
. Method of Impairment: Decay of organic matter and ammonia from domestic
wastewater causes substantial reductions in dissolved oxygen which
may reduce fish reproduction or be lethal.
. Regional Significance: Low dissolved oxygen levels, primarily due to
domestic waste, are responsible for an estimated 9% of the impaired
stream miles in Region III. Although this problem may not be
significant in terms of overall regional impact, it plays a vital
role in the impact of the priority water bodies of Region III.
. Trends: Through implementation of the 201 construction grants program,
dissolved oxygen levels have increased in many streams due to upgrade
of municipal treatment levels. Significant improvements of DO levels
due to upgrades have been documented for the Potomac Estuary, MD,
Hurricane Creek, WV, South River, VA, Patuxent River, MD and the
Delaware River, PA. However, many problems still remain,
particularly inadequate treatment levels in small communities.
. Regional Priority Water Bodies: Back River (MD), Patuxent River (MD),
Delaware River (PA), Neshaminy Creek (PA).
. Documentation: A cause-effect relationship for this problem is generally
well established.
. Treatability: Technology exists for treatment of municipal waste to cor-
rect any dissolved oxygen problems in the receiving stream.
2. Barriers to Solutions
. Operation and Maintenance: Municipal treatment facilities have often
been subject to inadequate operation and maintenance.
3. Management Implications
As with any resource limited program, a well founded priority system
must be established.
. States: Review existing construction grants priority system for modifi-
cations which would attach higher priority to significant water
quality problem areas. Assess current operation ana maintenance
programs and institute changes where necessary.
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. EPA Region III: Provide guidance to the States regarding 1) modification
of their priority systems to emphasize mitigation of water quality
impacts on streams and 2) operation and maintenance programs.
. EPA-HQ: Develop appropriate operation and maintenance guidance.
4. Anticipated Results
The purpose of the priority system is to channel water pollution control
monies to where the benefit gained will compare most favorably with
costs. Improvement in the system will increase the efficiency with which
funds are spent. Proper operation and maintenance will assure that these
benefits do not decrease with time.
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POINT AND NON-POINT SOURCES/BACTERIA
1. Description of Problem
. Sources: Municipal Waste/Industrial/Agricultural/Urban Runoff/On-Lot
Disposal/Combined Sewer Overflows/Marine Vessels
. Impaired Uses: Shellfishing, domestic water supply, bathing
. Method of Impairment: High bacteria levels may require closure of shell-
fishing and bathing areas to prevent disease outbreaks, while appear-
ance in surface water supply intakes may require excessive use of
chlorine for disinfection, resulting in harmful chlorinated hydrocar-
bons in finished water.
. Regional Significance: In the States of Virginia, Delaware and the Dis-
trict of Columbia, it has been estimated that more stream miles are
impaired by bacteria levels than any other parameter, while in Mary-
land, it is the second most widespread problem. In Pennsylvania and
West Virginia, state agencies have found that criteria are exceeded
in most waterbodies during some portions of year. Some violations
are serious enough to constitute use impairment, though documentation
of their extent is incomplete.
. Regional Priority Waterbodies: Delaware River (PA), Upper Chesapeake
Bay (MD), Shenango River (PA), Back River (MD), Pymatuning Reservoir
(PA).
. Documentation: Documentation of use impairment and sources varies widely
from State to State. Data is relatively comprehensive where
potential or actual use impairments are significant, e.g., shell-
fishing areas.
. Treatability: Bacterial quality of point source discharger is control-
lable, as are combined sewer overflow and on-lot disposal system im-
pacts. Agricultural and urban runoff contributions, however, have
been difficult to control to date.
2. Barriers to Solutions
. Lack of Documentation: Data on 1) disease outbreaks due to bacterial ex-
posure in the Region, 2) bacterial levels in Pennsylvania and West
Virginia waters, and 3) source contributions of bacteria is lacking.
3. Management Implications
. State: Assess use impairment caused by current bacterial levels, identi-
fying sources wherever possible.
. EPA Region III & HQ: None
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Anticipated Results
Use impairments due to bacterial levels generally have not been assessed,
with the exception of shellfish closures. Once use impairments are
identified by states, cost-effective control programs can be developed.
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OCEAN PROBLEMS
1. Environmental Problem
a. The Problem and Cause: The current and potential problems in Region
III which involve impairment of ocean waters involve the following
parameters and sources:
Source Parameter
Ocean Dumping Toxics (organic & inorganic), Pathogens
Ocean Discharges Nutrients
OCS Oil & Gas Drilling Muds, oil
Non-Point Source Dissolved Oxygen
b. Regional Significance and Trends: The following summarizes the
status and trends of environmental quality in the marine environment
and identifies significant or potential problems of the ocean and
coastal waters within the Region.
Status and trends 1970-1982
The overall health of coastal waters and the marine environment within
Region III based on present knowledge can be considered good, although some
indications of man's impact on this ecosystem are evident. In review of the
sources of possible impacts to marine waters, only three point source
problems were identified. All three are categorized as potential although
none presently impairs the ocean resources. Non-Point Source impacts
associated with massive agael blooms have been associated with fish and
shellfish kills along the Delaware coast.
Ocean Dumping
At the present time there are no ocean dumpers within the Region. Between
1961 and 1980 there were 16 dumpers located at four different sites, all of
which have been phased out. Appendix A shows total disposal at each site.
Appendix A shows the location of all the disposal sites.
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The only sites having significant impacts were the Interim Sewage Sludge
site and the Acid-Iron Waste site. Both disposal sites were found to impact
shellfish and micro-infauna due to high concentrations of heavy metals. In
addition, pathogens caused the closure of significant shellfish beds near
the sludge site. As noted, both sites have been closed to all dumping.
Ocean Discharges
Currently only one sewage treatment plant of any consequence discharges into
ocean waters. The plant at Ocean City, Maryland, has a 20 mgd capacity and
secondary effluent is discharged via diffuser pipe 3850 feet seaward of mean
low water. A buffer zone in which the harvesting of shellfish is prohibited
extends from 55th to 73rd Street and 1.5 miles out to sea. The State of
Maryland shellfish monitoring program shows little or no bacterial counts in
immediate surface waters but sediments are not surveyed for bacteria and
little is known of adjacent benthic conditions.
Under the Clean Water Act, all dischargers must comply with seconoary
treatment requirements. Section 301(h) of the Clean Water Act provides for
modifications of secondary treatment requirements for discharges into marine
waters by publicly owned treatment works (POTWs) which demonstrate their
compliance with 301(h) criteria. These criteria are promulgated in 40 CFR
Part 125 Subpart G. These regulations were published on November 26, 1982.
To date no facility in Region III has been denied a variance request under
Section 301(h), however, two facilities have been tentatively denied. These
facilities are:
HRSD Chesapeake Elizabeth VA0025275
HRSD Lamberts Point VA0025259
Both facilities are located in the Norfolk Virginia area. Chesapeake
Elizabeth discharges into the Chesapeake Bay in an area referred to as
Crumps Bank and Lamberts Point discharges to the Elizabeth River.
By memo to EPA-OMDE (dated May 12, 1983) we identified eight municipalities
and one federal facility as potential applicants. Since that time three
additional facilities have expressed interest in 301(h) variances
(Chesapeake, Portsmouth and Philadelphia). The updated list is presented in
Appendix A.
PCS Oil and Gas
Oil and gas drilling has been identified as a potential source of
pollution. The accidental spill of oil from drilling platforms is regulated
by the Coast Guard. To date there has been no oil and gas development
although 28 test wells were drilled. The EPA issues NPDES permits for all
drilling platforms which are primarily concerned with the discharge of
drilling muds.
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Non-Point Source
There is evidence of coastal eutrophication in waters of the Middle Atlantic
Bight. Water masses along the New Jersey coastline and adjacent to the New
York Bight have been shown to have high levels of primary production and
phytoplankton biomass (Northeast Monitoring Program 1981). Tn 1976 a severe
anoxic event took place in New Jersey coastal waters resulting in
wide-spread fish and shellfish mortalities due to a massive phytoplankton
bloom. It is possible in the future for the coastal waters of Region III to
experience intermittent smaller scale problems resulting from
over-enrichment of coastal waters. Estuarine plumes from large systems, the
Delaware and Chesapeake, may carry high concentrations of inorganic and
organic nutrients that add to the potential for eutrophication and increased
oxygen demand. Other sources are enriched water masses originating in the
northeast New York-New Jersey area with inputs from waste disposal and
riverine discharge. Anecdotal information and observations in summer 1982
along the coast from northern New Jersey to Chincoteague, Virginia, of
patches of discolored water and "slime" in the surf may be indicative of
stresses resulting from increased nutrient input into coastal waters.
2. Barriers to Solution of the Problem:
N/A
3. Management Implications
a. Regional Actions:
Ocean Dumping
Two new disposal sites are presently being designated. The first is an
incineration site located 140 nautical miles due east of the Delaware
Bay. The second is a dredge spoils site located 12 nautical miles east
of the Chesapeake Bay. Extensive monitoring programs are proposed for
each.
Ocean Discharges
To date no facility in Region III has been denied a variance request
under § 301(h), however, two facilities have been tentatively denied.
These facilities are:
HRSD Chesapeake Elizabeth VA0025275
HRSD Lamberts Point VA0025259
Both facilities are located in the Norfolk Virginia area, Chesapeake
Elizabeth discharges into the Chesapeake Bay in an area referred to as
Crumps Bank, Lamberts Point discharges to the Elizabeth River.
The list of potential 301(h) variance requests is limitless since there
are no restrictions as to who may apply. By memo to EPA-OMDE (dated May
12, 1982) we identified 8 municipalities and 1 federal facility as
potential applicants. Since that time three additional facilities have
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expressed interest in 301(h) variances (Chesapeake, Portsmouth and
Philadelphia). The updated list is identified in Appendix A,
PCS Oil and Gas
As indicated in 40 CFR 122.59, a general NPDES permit (as opposed to an
individual permit) may be issued when a category of point sources within
the same geographic area have discharges which warrant similar pollution
control measures. In the case of dischargers within the Offshore
Subcategory of the Oil & Gas Extraction Point Source Category, EPA has
concluded that these type of facilities would best be regulated and
controlled via a general permit.
The DCS General Permit issued by Region III will authorize discharges
from all offshore oil and gas exploration facilities operating in the
waters of the Mid-Atlantic Ocean seaward of the territorial seas of the
States of Delaware, Maryland, New Jersey, New York, Virginia and North
Carolina. These waters are described by the Department of the
Interior's Bureau of Land Management (BLM) in the environmental impact
statements for OCS Lease Sales, 40, 49, 59, and 76.
As noted above, the primary concern is with the drilling muds from the
operation. Appendix A lists those muds which EPA has approved for
discharge. Appendix A also identifies the proposed General Permit area.
The Region is also in the process in issuing its first individual permit
to Shell Oil.
4. Emerging Problems/Issues
a. Dredge Spoil Disposal; Ocean disposal of dredge spoil will be
taking place off the mouth of the Chesapeake Bay at the Norfolk
spoil site. Environmental consequences that may result from this
practice are localized and transitory depressions in water quality,
alteration of benthic communities, bioaccumulation of metals and
organics by benthic organisms, and localized shoaling resulting
from spoil deposition.
b. The surficial sediments in the vicinity of the Philadelphia sludge
dumpsite continue to show persistence of sanitary bacteria, viruses
and potentially pathogenic amoebae. The site and the immediate
vicinity is, therefore, still closed to shellfishing by the Food
and Drug Administration.
c. Little is known of the effects, if any, on the nearshore benthic
environment by the treatment plant outfall at Ocean City,
Maryland. Possible parameters to be surveyed would be microbiology
of sediments, benthic communities, and organic and inorganic
chemical parameters. Effects would be expected to be seasonal.
d. The inputs of two major estuarine discharges, the Chesapeake and
Delaware systems, has not been fully assessed. These estuarine
plumes may be responsible for the transport of adsorbed
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contaminants and particulates to coastal waters. They may also
carry high concentrations of inorganic and organic nutrients that
may add to the potential for eutrophication and increased oxygen
demand of coastal waters when combined with both enriched water
masses and other non-point sources. The potential for intermittent
wide-spread phytoplankton blooms exists and if such a situation
does occur under the right meterologic and hydrologic conditions,
finfish and shellfish mortalities may result due to lowered
dissolved oxygen concentrations.
e. The potential exists for a catastrophic oil or hazardous materials
spill primarily because of the large volume of tanker traffic using
the major shipping lanes that traverse the coastal ocean.
f. Exploratory oil and gas operations are now taking place just off
the edge of the continental shelf. If production begins, there is
the potential for transportational oil spills as well as chronic
low level pollution from operational discharges.
g. If ocean disposal of sewage sludge is resumed in Region III, it
will be necessary to monitor the fate and effects of such activity
to ensure that "unreasonable degradation" of the ocean environment
does not take place or that the assimilative capacity of the
receiving area is not exceeded before corrective action is taken.
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DRINKING WATER PROBLEMS
1. Environmental Problem
a. The Problem
A problem of major environmental management importance is the
provision of safe drinking water to the consumers in Region III.
b. Cause of the problem
The four most significant factors affecting drinking water, ranked
in the order of highest priority first, are:
1. Small systems compliance
2. Response to unregulated contaminants
3. Pennsylvania primacy
4. Water quantity issues
c. Regional Significance
1. The elimination of small water system violations represents
the highest priority problem of the drinking water program.
Of the 5,854 community water systems in the region, 5,272 are
small systems serving less than 3,300 people. These small
systems supply 9.1 percent of the total population served by
community systems. Small systems acccount for the great
majority of non-compliance with the National Drinking Water
Standards (approximately 98 percent of the persistent
violations).
2. Only a hand full of the thousands of organic chemicals are
regulated by the National Drinking Water Standards, yet many
of these are being found in water supplies.
3. Since Pennsylvania has not assumed primacy, EPA is responsible
for implementing the Public Water System Supervision program
in that state.
4. The absence of adequate water supplies due to over pumpage,
salt intrusion, ground water contamination, and drought
situations continue to plague many public water systems.
d. Trends
1. The small water system problem is further magnified with
respect to time because the Safe Drinking Water Act (SDWA) re-
quires that all public water supply systems receiving
exemptions be in compliance with the Standards by 1984 or 1986
(if the system intends to regionalize).
2. Although the scarcity of occurrence data on unregulated con-
taminants is recognized, there is no doubt that this problem
will increase each day as more new organic substance are
created.
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3. Federal responsibility for implementation of the Drinking
Water Program in Pennsylvania will not change unless Federal
funding levels are increased.
4. Water quantity problems will continue to follow economic
growth.
2. Barriers to Solution of the Problem
A financial study conducted by the EPA Office of Drinking Water in
1979-1980 indicated that many of the small systems cannot comply with
the standards because of serious financing and/or operating problems.
As stated previously, the scarcity of occurrence data on unregulated
contaminants is a serious problem. Also, the voluminous number of
organic compounds prevents the formulation of health advisories and
treatment data for every compound. This in turn makes Agency response
to each incident very difficult.
Current fiscal problems with the Commonwealth's budget have been cited
as the main reason the Commonwealth of Pennsylvania has not sought
primary enforcement responsibility for the Public Water System
Supervision (PWSS) Program. Another barrier is the uncertainty in DER's
minds over continued Federal funding. Funding for State Administration
of the PWSS Program has not increased since 1979. In fact, State grants
were reduced in fiscal year 1983 and further reductions are projected
for fiscal year 1984. The Commonwealth has perceived these reductions
as deterrents to assuming the responsibility for the program.
The major barrier to the water quantity issue is the increase in water
demand due to economic growth. A portion of these problems could be
alleviated through the implementation of the proposed Ground Water
Protection Policy. However, the Policy has not been released by Head-
quarters.
3. Management Implications
a. Regional Actions
1. EPA
The Region will continue to support the States both financially
and technically in an effort to protect the public drinking
water supplies. The Agency will continue to implement the
Public Water System Supervision program in Pennsylvania as
long as the State does not assume primacy.
2. States
The States will continue the front line struggle against
economic, industrial, agricultural, and environmental
practices which have caused increasing concentrations of
harmful chemicals in drinking water sources. States will give
priority to those problems which have the greatest public
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health significance affecting the greatest number of
consumers. Decreases in funding at a time when there is a
need to meet increasing responsibilities in areas more
difficult to address will continue to be a major management
problem.
b. EPA Headquarters Actions
Headquarters will continue to receive pressure from both the States
and the local citizens to be more responsive to the need to provide
safe drinking water.
4. Anticipated Results
Resource decisions made by Headquarters will undoubtly have a barometric
affect on the future of the nation's drinking water quality.
5. Emerging Problem/Issues
a. Implementation of proposed National Revised Primary Drinking Water
Regulations addressing the Volatile Synthetic Organic Chemicals in
Drinking Water. New regulations are a drain on reduced grant
resources to the States.
b. Compliance with the Trihalomethane Regulations in Virginia for
those systems serving between 10,000 and 75,000 people.
c. Increased water supply problems facing decreased Federal funding to
States for administration of programs.
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GROUND WATER PROBLEMS
1. Environmental Problem
a. The Problem
Generally, existing and potential ground water pollution problems
have been identified in the Region as eminating from a variety of
sources such as agricultural practices/animal wastes, on-lot waste
disposal, salt water intrusion and industrial/municipal residuals.
In West Virginia and Pennsylvania additional threats to ground water
quality have been identified, such as coal mining activities, acid
mine drainage, gas and oil storage, transmission and exploration.
Additionally, there have been reported 87 isolated incidents of
ground water contamination during the last eight years throughout the
Region; some incidents also include Superfund sites. The incidents
reflect either a non-compliance incident or an incident report that
reflects only on the ground water problem in the immediate area.
Given the data gaps listed in Section 2, we can only estimate what
additional incidents are occurring and going unreported. The most
outstanding issue identified during the compilation of the GWEMR was
the lack of a detailed regional ground water data base. Presently,
the various States in the Region appear to have a more developed
ground water program than the Agency, as well as a better knowledge
of the aquifers used for water supply. However, the majority of the
reliable data obtained to date is from EPA's public water supply
records and not the State's ground water data base. In order to
better understand and define existing and future problem areas, a
detailed data base must be formulated. Also, the Region is planning
to meet with the States in an effort to define problem areas. The
strategy to accomplish this is outlined in Appendix B.
b. Cause of the Problem
The previoulsy discussed problems have been caused in the pastby a
lack of concern for ground water protection, an inadequate knowledge
of the local geology, and the false assumption that the soil/rock
overburden adequately protects ground water from pollution sources.
The problem of not having an adequate ground water data base stems
from the fact that the relative need for such a base has not been
previously realized. Better analytical methods enabled us to improve
our detection analysis enabling us to uncover more ground water
problems. Further, the increased use of toxic materials and better
information on the inadequacy of local geologic formations to
assimilate the waste has increased the susceptibility for
contamination. Our increased knowledge of health effects has also
shown that previously neglected ground water contaminents are
signficant adversaries to our health. All of this has caused us to
realize that we do not have an adequate ground water data base to
assess the current problems.
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c. Regional Significance
With about 80% of the Region's water supplies depending on
groundwater, that once contaminated, ground water holding formations
are relatively hard to clean-up, and with the knowledge that
contamination sites will grow in number with population and
industrial activity, ground water protection problems are ever
increasing. Given the fact that it is the most significant
"discovered" media, it has the most potential for protection with the
greatest benefit for the cost incurred.
d. Trends
The Region's ground water trends were based upon two information
sources, the Ground Water Compendium and RCRA/Superfund sites. The
Ground Water Compendium contains isolated incidents of ground water
contamination that have been brought to the Water Supply Branch's
attention through a variety of means. The compendium presents the
date of occurrence of the incident, the type of contaminant(s), the
type of water supply system (private, public), a narrative statement,
and the investigative agencies.
The RCRA/Superfund sites were screened toward reported sites having
known/or potential impacts on subsurface drinking water supplies. To
better understand the Region's ground water problem areas, these
sites are included in the Ground Water Compendium.
The following data sources were used in compiling the trends in
ground water contamination:
- Geologic maps and cross sectional maps
- Topographic maps
- USGS and State reports on geology and ground-water resources
- Descriptions of underground sources of drinking water in West
Virginia and Maryland
- RCRA/Superfund site evaluations
- Water Quality Management Reports
- Areawide environmental assessments for coal mining in West
Virginia
- Water Supply Branch files
Delaware has identified agricultural practices/animal wastes, on-lot waste
disposal, salt water intrusion, and industrial/municipal residuals as
ground water pollution problems. The Region's Ground Water Compendium
cites 17 incidents of contamination over 1976-1982. Of these, 10 consist
of contamination by TCE, PCE, and other organics. The occurrences are
principally in New Castle County, the most urbanized of Delaware's three
counties. Nitrate contamination has been identified as a statewide
problem and a localized problem in Southern Delaware due to agricultural
activities and especially the large number of broiler farms.
Coliform/nitrate contamination of numerous wells in the community of North
St. Georges has been attributed to on-lot waste disposal systems.
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Saltwater intrusion has been identified as a problem in coastal areas; the
Ground Water Compendium cites an incident in Rehobeth. The State contains
four Superfund sites: Army Creek, Tybouts Corner, Witco, and Stauffer.
Currently, there are no public water supplies in the District of Columbia
using ground water as a source. No ground water contamination incidents
have been reported. The Region does have a geologic map, well location
map, and a USGS paper on ground water resources of Washington, D. C. and
vicinity. Generally, the Region does not perceive the District as having
any ground water problem areas.
Maryland has identified agricultural practices/animal wastes, onlot
disposal, salt water intrusion, and industrial/municipal residuals
(particularly in the Baltimore area) as potential ground water problems.
The Region's Ground Water Compendium identifies 10 incidents through
1979-1982. Of these incidents, 9 involved organic contaminants (TCE, PCE,
benzene, paraquat, and others). One incident involved mercury and a
second hexavalent chromium. Underground sources of drinking water in
Maryland have been described as part of the State's draft UIC application.
The bulk of information on ground water contamination in the Region covers
Pennsylvania. This is principally due to the Region's direct involvement
in implementation of the Safe Drinking Water Act. The number of incidents
reported does not necessarily reflect the seriousness of problems, but
merely the Region's access to information. Nevertheless, 54 of 89
incidents contained in the Ground Water Compendium occurred in
Pennsylvania. Of the 54 incidents, all but 12 involved TCE and/or PCE
contamination. Twenty-five incidents of TCE contamination were reported
in Bucks and Montgomery Counties, the Greater Philadelphia area; 16
involved community water supplies. The Water Supply Branch has sampled
240 public water supplies throughout the State for organic contaminants.
The sampling sites represented about 1% of supplies in the State; at least
2 samples were collected in each county. Additional organic data is
supplied by the National Ground Water Supply Survey. This survey has data
to statistically determine the presence and levels of volatile organic
chemicals in the ground water. Many of these types of compounds have been
involved in a number of previous ground water contamination incidents.
The State has identified coal mining activities, gas and oil storage,
transmission and exploration, and extensive agricultural activities as
some of the major threats to ground water quality some of which are used
as a drinking water source. Additionally, nitrates have been identified
as a ground water problem; and salt water intrusion has been
identified as a problem in the Bradford/Erie area. Superfund sites that
surfaced high in our rating system are: Fisher and Porter, Stanley
Kessler Company, Metal Bank of America, McAdoo Associates, WADE,
Enterprise Avenue, Bruin Lagoon, Centre Company, and Lehigh Electric.
The Region's Ground Water Compendium contains only 1 incident of ground
water contamination in Virginia: hexavalent chromium in Roanoke County.
Fluoride contamination has been reported also in the Roanoke area.
Agricultural practices/animal wastes, on-lot disposal, urban runoff and
industrial/municipal residuals (particularly in the Hampton Roads area)
have been identified as potentially impacting ground water resources. The
most significant Superfund site was Matthews Electroplating.
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The Region prepared Areawide Environmental Assessments for 7 river
basin areas in West Virginia containing coal resources. The assessments
focused on mining-related impacts on ground water, and not on
contamination by municipal/industrial sources. Areas examined included
the Coal/Kanawha, Elk, Gauley, Guyandotte, Monongahela, North Branch
Potomac, and the Ohio/Little Kanawha river basins. The State has
identified acid mine drainage as a ground water pollution source.
Localized ground water problems are discussed in the assessments and
include high sodium chloride, sulfate, and iron levels. Fluoride is a
common constituent of West Virginia oilfield brines and is present in
measurable amounts in most ground water. In the Little Kanawha area,
fluoride in well water ranged from trace amounts to greater than 2.0
mg/1. Additional suspected contamination sources include agricultural
sources, on-lot disposal, landfills, and oil and gas fields. The Region's
ground water compendium identifies 7 additional incidents.
State Summary
To summarize the trends in ground water contamination, the Ground Water
Incident charts illustrate the number of ground water incidents reported
in each State with the exception of the District of Columbia. The Region
presently has no ground water incidents reported for the District of
Columbia. However, as previously stated, the charts do not reflect the
seriousness of the problem in each state but rather the Region's limited
data base.
The following terms and definitions should be used in conjunction with the
Ground Water Incidents charts.
Community-public water supply system serving year round residents.
Non-community-public water supply system that is not a community
water system, such as a motel or campground.
State-wide - a contamination incident that is occurring throughout
the State.
2. Barriers to solution of the problem
In order to formulate the management of a comprehensive ground water
protection program, the following information is to be developed:
- maps of primary, secondary, and critical aquifer vulnerability
areas.
information on public water supplies.
- maps of hazardous waste sites, landfills/dumps, and land
treatment sites.
geohydrological data for all portions of each state (This is
due to gaps in the Region's reference library).
The development for such a data base is very resource intensive which
may cause some problems in completing the task in a timely fashion.
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GROUND WATER INCIDENTS
DELAWARE
i
i
r
!
17
0 1976 1977 1978 1979 1980 1961 TOTAL
MARYLAND
2 2
JLId
0
5
n
0 1978 1979 1980 1981 TOTAL
Community
Non-Community
State-Wide
-
PENNSYLVANIA
VIRGINIA
o o
:
WEST VIRGINIA
1 1
107K 107K 1077 1Q7« 1Q7Q 1QW1 1QH1 TDTAI
n 1977 197R 1979 19flf1
0 0
1977 1978 1979 1980 IflBI TOTAL
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3. Management implications
a. Regional actions
(1) EPA
The data base is to be developed by the Regional Office staff so
that existing problems can be better defined and future problems
avoided. The strategy to accomplish this is outlined in
Appendix B.
(2) States
As Appendix B shows, State coordination will be a continung
process. States have a more detailed ground water data base
than EPA, and will serve as a critical part of our strategy.
State meetings to share ground water information and to refine
our data base techniques have already been held in Delaware and
Maryland.
b. EPA Headquarters actions.
No EPA Headquarter's actions have been identified as being required
at this time. Obviously, information sharing and the solicitation of
guidance and support are generic to this and all Regional efforts.
4. Anticipated results
The successful completion of the strategy in Appendix B, the develop ment
of a ground water data base, accomplish the following:
a. Communicate to management regional ground water contamination
trends.
b. Technically aid the Regional Office in describing the relationships
between aquifer vulnerability areas, contamination sites, and water
supplies.
As the base grows in sophistication, we will become more efficient in
enforcement and protection actions, such as:
a. Take better enforcement initiatives because our ability to
screen potential cases/sites will improve.
b. Better ability to show the relative need to design protection
into sites.
c. Improve our ability to advise on site/water supply location.
d. Improve on our ability to determine cause/effect predictions.
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5. Emerging problems/issues
Several issues are becoming of more and more significance:
The relationship between the several Federally sponsored programs are
growing in importance, e.g., coordination of multijurisdictional
situations (Class I - Hazardous injection wells), the strategy for
handling increasing numbers of small system generators, and the need to
customize multifaceted programs to State-local needs. We are working on a
coordinated effort to handle most of the currently identified issues.
Additionally, the lack of a national ground water policy handicaps us in the
sense that Regional efforts lack national reinforcement.
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Hazardous Waste Problems - RCRA
The hazardous waste management program is relatively new, beginning with the
implementation of RCRA. Therefore, data collection systems are just being
developed which allow EPA to monitor hazardous waste activities.
Through RCRA permitting and compliance activities, Region III is beginning
to develop a data base whereby problem areas can be identified. Figure I
and Attachment A include an analysis of existing data. However, the lack of
a sound data base has prevented a detailed analysis and prioritization of
problem areas. Therefore, definition of problems within the hazardous waste
management program are based on less tangible criteria.
Relying on preliminary data acquisition and State and Regional knowledge of
the scope of hazardous waste activities, Region III has identified four
problem areas that are both current and emerging. They are:
Groundwater contamination
Siting of hazardous waste facilities
Hazardous wastes in sanitary landfills
Illegal dumping of hazardous wastes.
Region III believes that all four problem areas are significant enough to
merit the highest priority. We will continue to monitor incoming data to
refine the scope of these problems and to pursue feasible solutions.
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500-
400-
300-
200-
100-
STATUS OF RCRA FACILITIES
Legend
GENERATORS/10
TRANSPORTERS
TSD FACILITIES
INCINERATORS
LANDFILLS
wv
State
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Groundwater Contamination
1. Description of Problem
. Sources: Facilities with hazardous waste land disposal. These are
facilities with landfills, surface impoundments and land treatment.
The problems addressed here are facilities that have been active
after November, 1980.
Impacts: All facilities that treat or store hazardous waste in
surface impoundments or dispose of hazardous waste in landfills, have
a great potential to adversely impact the environment. The impact
could be permanent contamination of groundwater.
. Regional Significance: There are approximately 200 hazardous waste
treatment, storage, or disposal facilities (TSD's) in the Region with
active processes that require groundwater monitoring. The region, in
cooperation with the States, must identify sites where significant
contamination has occurred and implement measures to prevent further
contamination and restore groundwater quality, if possible.
. Regulatory Status: The Resource Conservation and Recovery Act (RCRA)
has required the installation of groundwater monitoring only since
November 1981. Initial reports were available since August 1982.
Contamination Indicator Reports were due March 1, 1983.
. Documentation: Since the regulations have recently required
reporting on groundwater monitoring, the information available
requires evaluation. There are problems with the quality of the data
as supplied by the facilities. Enforcement actions have been
initiated to require installation of wells, and submission of reports.
. Remedial Actions: A major problem is that the regulations do not
provide a mechanism for requiring prevention of and removal of
contamination until the facility is required to be permitted.
Therefore, regulatory concerns are on identification. Only where an
imminent hazard can be demonstrated, can the contamination be
addressed by regulations requiring cessation and removal of
contamination.
2. Barriers to Solutions
. Lack of Data: The information now available has been generated by
the facilities. There are many quality control issues. The proper
placement of monitoring wells, the proper sampling, and proper
analysis need to be evaluated. There are also facilities that should
have groundwater monitoring that have not been identified. Data from
authorized States is not readily available.
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. Lack of Guidance: There have been several regulatory changes that
have delayed this program. There has been proposed but never issued
guidance to the regulated facilities. There are several issues on
listing or de-listing hazardous wastes that impact the groundwater
monitoring regulations' applicability. The issues have not been
resolved. Where contamination has been identified, there is no
consistent approach to methods of preventing further contamination
and removal.
3. Management Implications
. States: (1) All States in the Region have agreed during FY 83 to
conduct thorough inspections at facilities with land disposal. The
inspections will concentrate on issues such as placement of wells and
proper reporting. Also, there will be a concerted effort to identify
those facilities with contamination or highest potential for
contamination. There is an ongoing program to find facilties out of
compliance with monitoring regulations.
(2) As facilities are called-in, in the permitting process, the
delegated States will have the regulatory powers to require cessation
and removal of contamination.
(3) The States have either proposed or have in effect regulations
that address contamination prevention and removal, such as
groundwater monitoring at sanitary landfills.
. EPA Region III: (1) The Region has initiated a concerted program
between RCRA, Groundwater Protection and Remedial (Superfund)
Sections to review data and take appropriate action.
(2) With the effective date of final Land Disposal Regulations,
January 26, 1983, the Region has called-in the Part-B's of those
facilities.
(3) Regional field personnel have initiated a program of sampling
with the facility, and splitting samples for analysis as a quality
control measure.
(4) Part B call-in facilities will be inspected by Regional
personnel, independently or jointly with the States.
(5) Where violations are detected that are imminent hazards, swift
enforcement action will be taken, regardless of delegation.
(6) Lesser violations, as identified, will be addressed to gain
compliance as soon as possible.
(7) The Region will upgrade staff personnel with expertise in
geology and hydrogeology, and provide this to the States where
necessary.
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. EPA Headquarters: (1) Guidance should be provided to the regulated
community.
(2) Consistent and effective regulatory guidance on groundwater
issues should also be provided
(3) Headquarters should resolve issues on waivers and definitions of
hazardous waste and processes that may or may not be regulated.
(4) Additional resources should be provided to the Region to
effectively conduct this program.
(5) Headquarters should coordinate and disseminate information
available from other Regions on this problem.
(6) Headquarters should revise, update, or expand groundwater
monitoring requirements, such as additional contamination parameters.
(7) Headquarters should also conduct research to determine the best
technology to prevent further contamination and restoration of
groundwater quality.
4. Anticipated Results
. The efforts of the States, the Region, and HQ should result in
identification of sites with contamination.
. Sites with severe contamination will be addressed quickly to prevent
further contamination.
. Firm decisions will be made on deciding where a restoration is
feasible, and if not, measures to prevent further deterioration.
. Violators will be identified and appropriate enforcement action will
be initiated.
. As this strategy is carried out, there should be the prevention of
new sources of contamination and a recovery of some sources. At some
sites the best result may be only maintainence of current
contamination levels without deterioration.
5. Emerging Problems
. The problem is well defined now.
. Issues as described above have emerged. An effective strategy to
address the problem is a current issue. Costs for prevention of and
removal of contamination will be a major issue.
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The issue to be addressed is that severe groundwater contamination
can result at facilities that have hazardous waste but do not use
land disposal. There are historic examples of groundwater
contamination resulting from improper handling and storage of
hazardous waste, or raw materials or products that could be
hazardous. Discharges of materials that are contaminants from drums,
tanks, or other containers can and have impacted the groundwater.
These types of storage are not regulated for identification of
contamination. Some States, for example, require groundwater
monitoring at sanitary landfills. Groundwater contamination can
occur from other sources than surface impoundments and landfills that
are not addressed by the regulations.
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Siting of Hazardous Waste Facilities
1. Description of Problem
. Problem: Hazardous waste disposal has for the most part been a
function of the private sector. However, it has become
increasingly difficult to develop new hazardous waste facilities,
particularly secure landfills.
. Cause of Problem: Most of the problems of siting such facilities
stem from opposition by the public and the lack of an established
means of resolving siting conflicts. Public opposition occurs for
several reasons. The public has an inherent fear of anything that
is potentially harmful and is suspicious because of accounts of
problems with existing or abandoned sites, e.g., Love Canal.
Therefore, it lacks confidence in industry's and government's
ability to manage wastes safely. There is also the perception of a
stigma of being a community in which hazardous wastes are managed
and the fear of deteriorating property values. Because of these
perceptions, the public has adopted a "not in our backyard"
attitude, feeling that another site would be better, either because
the wastes are generated elsewhere, or because another location may
be safer.
. Regional Significance: This reluctance on the part of the public
to allow new facilities has resulted, in some instances, in a large
gap between the volume of waste generated and the capacity for
treatment and disposal. In addition, Federal and State regulations
will inevitably force some existing facilities to cease operations,
further decreasing waste management capabilities. If new
facilities are not established, the present disposal capacity will
soon be exhausted and limit a State's ability to promote industrial
development and eliminate indiscriminate, unsafe disposal.
. Trends: The data base on wastes generated and disposal capacity is
just being developed. As the RCRA permitting process takes full
effect, there will be more information on the ability to handle
hazardous wastes at existing facilities and the extent of the need
for new facilities to properly manage the wastes being generated.
2. Barriers to Solutions
. The location of properly managed hazardous waste facilities will
depend on the State's ability to establish siting criteria and to
overcome public and local government opposition.
. Additional resources will be necessary to develop and maintain the
tracking systems used to monitor waste handling capacities.
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3. Management Implications
States: Recognizing the need for new facilities and the need to
overcome public opposition, many States are beginning to assume an
active role in the siting process. For States that have not done
so, they should establish siting boards that will preempt local
zoning laws, develop siting criteria, identify potential sites,
provide for local input, and review proposed sites and facilities.
Other innovative techniques the States may wish to utilize are to
establish State hazardous waste facilities, acquire land for use as
a waste facility, and issue industrial development bonds to finance
hazardous waste facilities.
The local governments also play a role in the site selection
process. Since the local authorities are often-times the first
ones to respond to problem situations, it is in their best
interests to provide input by reviewing contingency plans and by
interacting with State siting boards. Local governments may also
address problems or situations not dealt with by RCRA, EPA, or the
States, such as the preparedness for post-closure emergencies.
EPA Region III: The Regional office is encouraging the States to
assume primary responsibility for siting new facilities. The
States are the most appropriate level of government to plan for
hazardous facilities because of the regional nature of some of the
facilities and the States have broad police powers, including land
use and the right of eminent domain. These authorities are
desirable and may be essential in the site selection process. To
assist the States in this process, the Region will provide
technical assistance to the States on various aspects of siting and
in the development of public participation programs. The Region
may also assist the States in developing an adequate data base
whereby the amount of waste generated and waste handling
capabilities can be monitored.
EPA Headquarters: Headquarters assistance would oe most helpful in
the expansion of HWDMS to monitor generators of hazardous waste and
waste disposal capabilities. This information should be made
available to the Region and the States. Guidance on siting
criteria and public participation should also be provided to the
Region and the States.
4. Anticipated Results
The establishment of siting boards and siting criteria will provide
a means to locate hazardous waste facilities in the most
appropriate places.
Siting boards will be available to resolve conflicts between public
and private concerns.
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Development of a computer system will allow the States to monitor
their ability to properly manage hazardous wastes and plan for
future needs.
Involving the public in the siting process will help eliminate
opposition to the location of hazardous waste facilities.
5. Emerging Problems
As more data becomes available, the extent of the need for
additional disposal capacity and its implications will become more
evident.
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Hazardous Waste in Sanitary Landfills
1. Description of Problem
. Problem: It is believed that many small quantity generators are
taking their hazardous waste to less strictly-controlled sanitary
landfills. Approximately 90% of the generators of hazardous wastes
qualify as small quantity generators.
. Cause of the Problem: The criteria for small quantity generators
under the Hazardous Waste Regulations promulgated under Subtitle C of
RCRA, exempt those who generate under 1,000 kilograms per month of
hazardous waste from full regulatory requirements. It is believed
that many of these small quantity generators may be avoid-
ing regulated waste facilities in lieu of less-strictly controlled
sanitary landfills, because the regulated facilities may be rejecting
them due to their size and the fact that they are usually not covered
by a manifest.
. Regional Significance: Continuation of unabated midnight dumping
is likely. Hazardous wastes are accumulating in sanitary landfills
creating many potentially dangerous situations.
. Trends: There is currently no data available to identify trends.
However, the results of the dumping of hazardous wastes in
unregulated landfills precipitated the Superfund Program.
2. Barriers to Solutions
. Congressional proposals to amend the exemption criteria to 100
kilograms/month contains a short implementation timeframe which could
adversely impact EPA and the regulated community by causing resource
hardships on both.
. Solutions which address Subtitle C amendments would require
increased Agency and State funding.
. Solutions which address Subtitle D amendments would require that
Subtitle D funding be re-initiated.
3. Management Implications
. States: The States will basically follow Federal initiative.
Following are the results of a poll of Region III States on
tightening the requirements.
. EPA Region III: Region III should continue to support all National
activities to mitigate this problem. The Regional Office will
monitor States which control small quantity generators as part of
their more stringent State programs.
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. EPA Headquarters: EPA has recommended a longer timeframe for
implementation while the Agency monitors those States which have
imposed tighter limits on small generators. In addition, EPA has
recently initiated a two-year study of alternatives for regulating
the small quantity generators.
. One of the criticisms of tightening the exemption criteria is that
it would cause hardships on the regulated community. The Agency
could explore the use of some types of SBA loans to help these
small generators comply with the regulations.
. Another suggestion is to develop a less comprehensive manifest
procedure for use by small quantity generators.
. An amendment to the exemption criteria could be developed to
prohibit small generators from utilizing sanitary landfills with no
capability to handle hazardous wastes.
The above recommendations concentrate on the hazardous waste regulations.
However, the problem could be addressed by revising Subtitle D as follows:
. Design a collection system that is appropriate to the modified
standards. Impose groundwater monitoring requirements at these
municipal landfills to ensure early detection of any possible
contamination.
. Bring industrial landfills under Subtitle D standards.
. Provide funding to States to establish waste exchanges which can
operate as clearinghouses for small generators for the disposal of
their hazardous wastes.
4. Anticipated Results
. During Congressional Reauthorization Hearings there will probably be
continued efforts to amend the exemption criteria from 1000 kg/month
to 100 kg/month of hazardous waste as defined by Section 261.
5. Emerging Problems
. An amendment to the exemption criteria will affect EPA and State
resources, and will impact the regulated community.
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STATE POSITIONS ON SMALL QUALITY GENERATORS
PENNSYLVANIA
DELAWARE
VIRGINIA
MARYLAND
DISTRICT
OF
COLUMBIA
WEST
VIRGINIA
Not in favor of lowering kg limit. Feels it would be too
overwhelming a task and not accomplish a high degree of
environmental protection. Pennsylvania does, however,
require landfill operators to obtain written approval for
disposal of shipments of hazardous waste, not normally
covered under RCRA.
- No consensus of opinion. Certainly, if a survey showed
we were not regulating a large amount of waste because oi
the 1000 kg exemption, it may be worthwhile. It may also
be worthwhile as a revenue basis if a fee schedule is
established. However, in general, State feels that too
many small businesses (gas station and dry cleaners)
would be brought into the system. It would also be very
resource intensive and it is doubtful (without survey
results) that it would significantly increase
environmental protection.
- Virginia will follow Federal initiative.
- Supports a lower limit for exemption somewhere between
100 kg and less than 1000 kg.
- One year after the effective date of their regulations,
the limit will drop to 100 kg or less for small genera-
tors. The projection for this drop is August, 1984.
- West Virginia has no plans to drop the limit for small
generators. Small generators are required to maintain
records of how much and where their waste is disposed as
applicable to manufacturer.
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Illegal Disposal of Hazardous Wastes
1. Description of Problem
. Problem: One of the ever present problems concerning hazardous
wastes and its disposal is the existence of "midnight dumpers".
These illegal disposers offer a cheap and convenient method for
hazardous waste generators to avoid their responsibility of securing
a safe site for their wastes' disposal.
. Cause of the Problem: As mentioned above, one of the primary
advantages a "midnight dumper" has over a reputable disposer is the
amount of money he can charge for waste disposal. The "out of sight,
out of mind" outlook of hazardous waste generators towards their
disposal practices has allowed many illegal dumpers to practice their
trade.
. Regional Significance: This problem is not only a regional problem
but is obviously a national one. On the other hand, it seems
apparent that these practices have been prevalent regionally in years
past as witnessed by the number of inactive dumps being evaluated and
cleaned up under the Region's Superfund program.
. Trends: As industry and the public become more environmentally
educated, it will be more difficult for midnight dumpers to continue
to dispose of wastes illegally. The prevalent unsafe dumping of the
past was substantially curtailed with the inception of the Resource
Conservation and Recovery Act in 1980. Regulations promulgated under
this Act have placed anyone who generates, transports, treats,
stores, or disposes of hazardous wastes into a "cradle to grave"
tracking system of the disposal of that waste.
2. Barriers to Solutions
. Members of the RCRA regulated community who have complied with the
paperwork requirements are part of an administrative monitoring
system which can detect violators through such mechanisms as the
manifest system, annual reports, exception reports, and unmanifested
waste reports. The problem with detecting illegal disposers is that
most often they are not part of the RCRA reporting system and
therefore cannot be found in readily available data sources. From
this barrier, the problem of additional tracking resources arises.
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3. Management Implications
States- The States located in the Region would obviously be able to
' carry many of the Region's actions a step further. They also could
educate the public on the problem of "midnight dumpers and set up
hotline telephone numbers for tips and offer rewards. Their own
enforcement and environmental organizations could work together and
with local authorities to help crack down on illegal disposers. The
States could also step up their transporter inspections by spot
checking at weigh stations, interstate lines, and toll bridges.
. EPA Region III: Region III has already provided one solution by
establishing a toll free hotline telephone number to be called when
instances of dumping are witnessed. Part of this approach must
include making the public aware of the problem and relying on their
watchful eye to notify EPA of mysterious waste disposal practices.
Rewards could be made available for further incentive to call the
EPA. The Region must also strive for a close working relationship
with other local, state, and Federal law enforcement and
environmental agencies. These organizations could possibly come
across information regarding the illegal disposal of hazardous wastes
in their daily routine. Possibly the best way for the Regional
office to become involved on a first-hand basis would be to randomly
check on the middle link of the disposal chain - the transporter.
Inspections of trucks at various locations would allow EPA personnel
to examine manifests and validate the substances being shipped.
EPA Headquarters: Headquarters could also help with the strategies
mentioned above by providing guidance, additional resources, and
training. Resources would be needed for additional Federal
inspectors and state grants which would provide for State assistance
in tracking down illegal disposers. Also, a national reward bank
could be set up from which the Regions could draw when necessary.
EPA Headquarters could also establish working agreements with other
Federal agencies to provide information and assistance in finding and
enforcing against known violators.
4. Anticipated Results
As State, Regional, and Headquarters efforts increase in stopping the
illegal disposal of hazardous wastes, the environment will become
less vulnerable to these dumpers. As cases are brought to trial,
both criminally and civilly, the public will become more aware of the
problem and find it easier to help while the community of midnight
dumpers will see the penalties which result from their activities.
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5. Emerging Problems
The development of the RCRA hazardous waste program by EPA has been
going on for more than 5 years and is still changing and growing.
Establishing a system to catch the violators who exist on the outer
limits of the waste disposal universe will require large amounts of
time and money and it will depend upon the American public to make
the elimination of illegal disposers an important issue for this
program to succeed.
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Hazardous Waste Management - Superfund
Environmental Problem
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) was enacted to provide authority and funding for the cleanup of the
most hazardous waste sites in the Country. Because of the limited funding
and short duration of the so-called Superfund program, EPA must manage the
program activities in a cost-effective manner which provides measurable
evnvironmental results.
The National Priority List proposed in the December 30, 1982 Federal
Register contained 418 sites considered to be the most hazardous sites in
the country based as the Hazard Ranking System.
The program operations are broken down into emergency actions (those actions
required expeditiously to project the public health where an eminent danger
exists) and the remedial actions (those long term actions requiring detailed
planning where no emminent danger exists).
Emergency actions can range from securing the site to prevent public
exposure, the controlling of surface runoff, furnishing of uncontaminated
drinking water, on-site neutralization, to actual removal of the hazardous
material.
Remedial actions tend to larger scale solutions such as on-site
encapsulation and/or contaminated soil removal in combination with other
types of actions.
The Problem
Region III staff has identified the following problems involved with the
efficient, cost-effective management of the Superfund remedial program.:
a. Priority Ranking of Sites
The first problem with designing a cost-effective remedial program
is the process of priority ranking of sites and the selection of an
appropriate indicator of environmental results. Fortunately, the
Superfund program has such a process in the Hazard Ranking System
(HRS) promulgated as part of the National Contingency Plan. The
HRS, in considering character and quantity of waste, routes of
exposure and the release or threatened release of contaminants,
evaluates hazardous waste sites based on their relative threat to
populations and the environment. Therefore, by addressing sites in
priority order as determined by the HRS, EPA is assured, within the
limits of its knowledge at a given time, that it is proceeding in a
manner that will yield the greatest environmental results.
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Th e system does have its limits, particularly since not all
potential sites have been investigated and the HRS has not been
applied to all those which have been. Also, the HRS does not
consider public concerns or interactions which could raise a
particular site to a higher level of attention. Despite these
limitations, the HRS provides a useful indicator for effective
environmental management. In order to assure that potential sites
are ranked by HRS, the Region has devoted approximately 80% of its
available contractor (FIT) resources and six manyears of staff
effort over the balance of FY'83 in an attempt to screen and rank
the remaining remedial sites. Some states, most notably the
Commonwealth of Pennsylvania, are also devoting a significant
amount of resources to this effort. We expect all of the states to
assist in this effort once the § 3012 grants are in place. These
grants represent the number one priority for Headquarters action in
this area.
b. Time Required to Clean Up Sites
One of the criticism of the Superfund program is that it moves too
slowly in cleaning up sites. With respect to the NPL sites, it may
take approximately two years per site before the remedial program
completes the necessary studies, design work and administrative
steps needed, and finally proceeds with cleanup. Few citizen
organizations are willing to wait two years for a cleanup after
becoming aware that a hazardous site exists in their community.
c. State Costs
A significant problem arises with the inability of a State to
provide its cost share for the clean up. Clean up operations are
very expensive and some States are experiencing considerable
difficulty in providing their cost share.
Regional Significance
Forty-nine of the sites on the National Priority List are located in Region
III. A list of the 49 sites in HRS priority order is included in Appendix A.
Maps which identify the location of the sites within each state are also
included.
Remediation of the hazards identified to date at the forty-nine Region III
National Priority List (NPL) sites will be pursued under one of four
mechanisms: 1) voluntary cleanup undertaken by a responsible party; 2)
fund-financed cleanup (followed by recoupment, where appropriate); 3)
cleanup resulting from federal or state enforcement; and, 4) cleanup of a
site using both enforcement tools and fund financing ("dual-track").
Of the forty-nine NPL sites, Region III has identified 27 sites where either
federal or state enforcement mechanisms are or will be used to effect
cleanup of the sites. Superfund financing is expected to be required for
the cleanup of at least fifteen of the sites. The remaining seven sites
will be on a "dual-track" where fund-financed investigation and cleanup
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actions will be undertaken concurrently with enforcement efforts. For
purposes of this discussion, sites where we anticipate voluntary cleanup
have been included with those subject to federal or state enforcement.
Appendix A lists those sites where remedial action is planned or underway in
fiscal year 1983. In accordance with our current obligation on strategy, in
fiscal year 1983, Region III intends to complete 29 Remedial Action Master
Plans (RAMPs), 17 Remedial Investigations/Feasibility Studies, and 3
remedial design and construction projects. The cost to Superfund for these
activities is estimated to be $9-12 million.
Region III has the second highest number of removal projects in the nation
with over a dozen completed to date, at a cost of some four million dollars.
Under the removal program seven Voluntary Compliance Actions have been
initiated to date, one planned removal action has been completed and two
others are under way. One Enforcement Referral has been sent to
Headquarters and an additional eight are being processed in the Region.
Trends
As more investigative actions are taken, more sites are discovered. As
these sites are ranked, they will be added accordingly, to the National
Priority List.
Barriers to Solution of the Problem
Once a site is properly identified and ranked, there are a number of
barriers which may impede progress in cleaning up the NPL hazardous waste
sites. These include inability of a state to provide the required cost
share for the study or remediation of a problem at a site; fund balancing
requirements of CERCLA necessary to administer the limited of funds
available for cleanup; and, the potential inability, in certain instances,
of enforcement mechanisms to effect an expeditious cleanup of a site.
Of these potential barriers to the cleanup of a site, the most serious is
the inability of a state to provide its required cost share for the
cleanup. Any delay or failure on the part of a state in committing or
providing its cost share will significantly delay the cleanup of a Superfund
site. Several states in the Region are encountering difficulty in securing
funds for the required cost sharing.
The Pennsylvania legislature established a $1 million Waste Abatement Fund
which has been completly allocated as the State's 10% share of cleanup
activities for four NPL sites. Although other small sources of funding may
exist in the State, the NPL listed 26 other sites in Pennsylvania which may
require cost sharing with Superfund for cleanup. Recently, the State DER
has sought from the legislature an additional $3 million in matching funds
for the period July 1983 - June 1984.
The Commonwealth of Virginia currently has no funds available for its
required cost share. Funding for construction activities undertaken at
Matthews Electroplating may be provided by the County.
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For its cost share, the Delaware Legislature provided the State with bonding
authority for $100,000 in 1982. Additional authority is being sought for
fiscal year 1983.
The State of West Virginia currently has no appropriation for Superfund
remedial cost sharing. The State Legislature is giving consideration to a
hazardous waste tax which would provide a source of funding for the State
cost share; but, this would not be available until January, 1984 at the
earliest.
There is no separate appropriation in the State of Maryland for State cost
sharing at Superfund sites. If necessary, some funds may be drawn from the
State's operating budget.
The most effective manner to at least partially alleviate this problem and,
as a by-product, to improve EPA-State relationships, would be for
Headquarters to make a policy change requiring a match only for design/con-
struction funds. This action would free up limited available funds for
actual construction.
Emerging Problems
We anticipate one emerging problem in the Superfund program. Some sites
which have a real problem, will not rank high enough on the HRS to receive
Superfund monies. We can not ignore these sites; thus, enforcement action
may be the only solution. Enforcement action, though, implies that there is
someone with sufficient funds to enforce against. As we have found often in
the past - and used as a justification for Superfund passage - this
situation does not always exist.
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PESTICIDE PROBLEMS
Environmental Problems
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as amended,
was implemented to regulate the marketing of pesticide products and devices
by means of registration (the devices themselves are exempt from registra-
tion) and labeling procedures which require registrants to present evidence
of the safety of these pesticide products when used as directed and to be
effective for the purpose claimed on the product labels.
FIFRA is the only law that allows the intentional introduction of a toxicant
into the environment. Again, by FIFRA regulations, the beneficial effects
of these pesticides must outweigh their harmful effects to man and the
environment, if used as directed.
Regionally, commercial pest control operators, in residential areas, are the
single group contributing to the major number of confirmed mis-use investi-
gations and potential for harm to either man and/or the environment in
residential areas. Whether this is a significant factor cannot be
determined.
Barriers to the Problem
Under FIFRA, Section 12(a) (2) (G) reads: "It shall be unlawful for any
person to use any registered pesticide in a manner inconsistent with its
labeling." As interpreted, all pesticide mis-uses are after-the-fact
violations.
Management Implications
EPA Headquarters issues program guidance which the regional office requires
the States to follow in submission of requests of financial assistance for
their pesticide enforcement program. The States must establish enforcement
priorities that permit the most efficient use of resources and personnel.
The priority setting process enables States to concentrate its training,
compliance monitoring and enforcement programs on specific pesticide
activities which pose a risk to health or the environment. In setting
priorities, States analyze their records of pesticide use complaint investi-
gations and assign harm or potential harm factors to each use violation. The
areas of highest harm factors are given the highest priority.
Anticipated results
By the establishment of a base line, it is anticipated that in future years,
it can be shown that by concentrating resources in areas of highest priori-
ties, harm or potential harm can be reduced.
Emerging Problems/Issues
States are dedicated to the protection of humans and the environment from
adverse effects of pesticides. The only forseeable problem would be the
reduction of federal funds available to the States.
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RADIATION PROBLEMS
1. Environmental problem
a. The problem
The major activity of the regional office radiation program is
review of emergency preparedness plans around nuclear power
plants. The Federal Emergency Management Agency (FEMA) has primary
responsibility in this function. In addition, the region reviews
environmental impact statements, provides technical assistance to
the States and keeps the ERAMS system current (ERAMS is a radiation
monitoring system which is fully activated when an atmospheric
nuclear test is conducted, or some other event that would result in
widespread radiation. Some routine sampling is also performed.)
b. Cause of the problem
There are eight nuclear power plants in operation or under
construction in Region III. In addition, the ten-mile zone for
emergency planning for the Salem nuclear power plant in Region 11
extends into Delaware.
c. Regional significance
Region III is therefore responsbile for review of plans around nine
nuclear power plants. This means that plans must be reviewed for
five states and twenty-eight counties and many municipalities
within the ten mile zone. Some additional review is conducted to a
fifty-mile radius for food and water contamination, but this is not
a major part of the review function. Draft plans have been
reviewed for all jurisdictions. Final submittals have been
received from several states.
2. Barriers to solution of the problem
There are no significant barriers from an EPA perspective.
3. Management implications
Once State and county radiological emergency plans are in place and
during their development, the plans must be tested. Each nuclear
facility, each State and each county must participate in a full-scale
exercise at least once per year. Region III supplies an observer as
part of the exercise procedure.
4. Anticipated results
The specialized expertise of the radiation representative is used in
this case to assure that monitoring and projected dose calculations are
performed correctly. Nine full-scale exercises are performed in Region
III each year.
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The attached map shows the location of nuclear power plants in Region
III and the Canonsburg inactive uranium mill tailings site.
1. Environmental problem
Cleanup of the Canonsburg inactive uranium mill tailings site.
a. The problem
In Canonsburg, Pennsylvania, a major inactive uranium mill tailings
site is about to be stabilized under the Uranium Mill Tailings
Radiation Control Act of 1978. (UMTRCA)
b. Cause of the problem
The Canonsburg site is located within the Borough of Canonsburg,
Washington County, in southwestern Pennsylvania. It lies
approximately 20 miles southwest of downtown Pittsburgh. The
former Vitro Rare Metals Plant property (18.5 acres), now the Canon
Industrial Park, is the site area designated by the UMTRCA as
containing the radioactivity-contaminated material. The former
Vitro property is divided by Strabane Avenue and Ward Street into
three separate areas. The only developed area and contains the
existing Canon Industrial Park buildings. The other areas are open
areas along Chartiers Creek. Two other areas of the expanded site
adjacent to the Canon Industrial Park, i.e., the former Georges
Pottery property (6.1 acres) and the seven residences situated on
Wilson Avenue and George Street (5.4 acres), are needed to complete
some of the remedial-action alternatives (on-site stabilization).
The expanded 30-acre site is bounded by Chartiers Creek to the
north, west, and east, and by the ConRail right-of-way to the
south. The expanded site is located in a densely developed urban
area; e.g., across the ConRail tracks there are residences as close
as 250 feet to the site.
From 1942 through 1957 the Virto Manufacturing Company (Vitro), and
its successor, the Virto Corporation of Amercia, owned and operated
the paint on the Canonsburg site, which was used to process on-site
(contractor-owned) residues and ores, and government-owned ores
concentrates, and scrap, to extract uranium and other rare metals.
During this time various ores, concentrates, and scrap materials
were brought from different AEC installations to the Canonsburg
site for uranium recovery. The end products of these processes
were delivered to the Atomic Energy Commission (formerly the
Manhatten Engineer District) in accordance with terms of govern-
ment procurement contracts. All solid process wastes were stored
temporarily on the site. Liquid wastes were discharged into a
swTp in Area C, which drained to Chartiers Creek. THIS swamp has
since been filled in.
In late 1956 to early 1957 about 11,600 tons of wet Aerial
-------
-82-
CANONSBURG INACTIVE
URANIUM MILL TAILINGS SITE
-------
-83-
Indiana County, about 51 miles northeast of Canonsburg. The
Burrell site covers approximtely 49 acres; it is an undeveloped
plateau along a bend of the Conemaugh River at the southern
boundary of Indiana County in southwestern Pennsylvania. Its only
significant surface features are three steep-banked ponds in the
western area that are remnants of an old disposal pit. Disposal of
the 11,600 tons of material removed from the Canonsburg site took
place within a 9-acre section in the western portion of the Burrell
site. The residues were brough in by railcar, dumped into the
disposal pit, and covered with an uneven layer of uncontaminated
material.
In 1962 Virto's real property was sold to developers, with Vitro
retaining title to the remaining radioactive material. In an
effort to decontaminate the immediate plant area, in 1964 all the
materials then considered contaminated were consolidated into one
pile in Area A. This pile was eventually moved to Area C in 1965
and buried beneath a relatively impermeable layer of steel-mill
slag. Vitro1s source-material license was then terminated, and the
Viti-v t ."'-f-v was developed into its present use as the Canon
Industrial Park.
c. Regional significance
The Canonsburg site is the first inactive uranium mill tailings
site scheduled for cleanup by DOE. It will therefore set the
precedent for other cleanup actions in other parts of the nation.
It is therefore necessary that particular care be exercised in
assuring that the cleanup is planned and conducted in compliance
with EPA's standards for remedial action. A major part ot this
action has been review of the EIS, in which Region III was assisted
by Headquarters and laboratory components of EPA and by Region VIII.
d. Trends
In the absence of a cleanup activity, the trend would be a
continuation of the current problem. This consists of excessive
public exposures to radon gas from the tailings and contamination
of groundwater and surface waters from radionuclides in the waste
materials. In the absence of any regulation, the problem would
worsen because the tailings are an attractive material for use as
fill (except for its radiological hazards). Left uncontrolled,
human activity could aggrevate the problem by removing material
from the site for other uses.
2. Barriers to solution of the problem
With the promulgation of final EPA cleanup standards and review of the
EIS, all barriers to solution existing in EPA have been removed. The
only potential barrier existing at this time is some interest on the
part of a small number of Congressmen in diverting the cleanup funds for
other uses.
-------
-84-
IBUTLERI \ ICOUNTYl
0
lARMSTRONGI
O a IBEAVERI
MAJOR STREAMS
(OHIO RIVER WATERSHED)
IALLEGHENYI
QICOUNTY]
r**^ (j
PENNSYLVANIA ROUTE
t AIHPOHT
IWESTMORELANDl [COUNTYl
iy ICOUNTY]
WASHINGIO
CONNELLSVILLF
IFAYETTE
UNIONTOWN
FIGURE 1-1
MAP OF SOUTHWESTERN PENNSYLVANIA
SHOWING THE LOCATION OF
THE THREE SITES - CANONSBURG,
BURRELL TOWNSHIP AND
HANOVER TOWNSHIP
GREENE! ICOUNTY
-------
-85-
3. Management implications
a. Regional actions
(1) EPA
Since the cleanup is a DOE responsibility, there is little
involvement on the part of Regional management. Review of the
EIS has been one of our major roles. A future decision will
have to be made as to the extent of EPA monitoring of the
cleanup operation itself.
(2) State
Pennsylvania is involved in the cleanup effort because, by
law, 10% of the cleanup funds have to be provided by the
State. The State is expending this share of the cleanup cost
mostly in aquisition of the affected properties. EPA is not
directly involved in this process.
b. Headquarters
The main EPA Headquarters actions on this problem uc.,. ---!,. been
performed. These are promulgation of the cleanup standards and
assisting in review of the EIS.
4. Anticipated Results
The anticipated result will be the long-term stabilization of the
Canonsburg site and therefore the removal of any threat to public health
from contaminated material. This is to be accomplished by the
Department of Energy.
-------
-86-
EMERGING ISSUES - RADIATION
1. Indoor Radon
Recent changes in construction and insulation techniques in response to
the high cost of energy have caused the problem of indoor radon to
surface. Radon is a natural product of uranium-bearing soils and would
not be a problem except for the tight weather sealing on modern homes
which limits ventilation. Recent articles in newspapers and the popular
press have caused increased public interest in the problem. Since most
soils contain some uranium, it is impossible to tell whether a house
contains excessive radon levels without making a measurement. This is
therefore not a problem that can be easily dismissed when an inquiry is
received. (In comparison, most inquiries on non-ionizing radiation can
be easily evaluated by telephone.)
Since the indoor radon problem is probably much more pervasive than we
now realize (for lack of measurements), there is a strong likelihood
that large numbers of people are exposed to excessive radon levels
without anyone knowing it. Two actions from headquarters are needed on
this problem: 1) develop an inexpensive and rapid survey method to be
used in field studies, 2) conduct a survey of indoor radon levels
thoughout the U.S. This would then identify the true scope of the
problem which we do not now know. Does the problem affect 100, 1000,
10,000 or 100,000 residences?
2. Non-ionizing Radiation
Since publication of The Zapping of America and several other articles
in the popular press, there has been a small but constant flow of
telephone calls on non-ionizing radiation. Most can be answered
relatively easily by doing a simple calculation or informing people that
microwave communication towers operate at very low power levels even
though the horn antennas look imposing. However there are some
persistent individuals who refuse to be swayed by logic and in other
cases there is a real possibility of excessive exposure. Thus
non-ionizing radiation represents a small but constant workload for the
region.
Our needs from headquarters is a continuation of the work that is being
carried on by ORP on the subject. The level of support to date has been
satisfactory.
3. Uranium Mining in Virginia
There is a likelihood that uranium mining will begin in southern
Virginia. Since this activity is covered under the proposed emission
standard for radionuclides, it will be necessary for EPA to become
involved to enforce the emission standard when it is promulgated in
final form. This could become a significant part of the radiation
program workload.
-------
-87-
4. Decommissioning of the Shippingport Nuclear Power Station
In the next few years, the Shippingport nuclear power station (one of
the first in the nation) is scheduled to be decommissioned. This will
mean removing the spent fuel in the core, disassembling the reactor and
disposing of the waste material. This presents a number of
difficulties: There is no disposal facility available for the spent
fuel, so it will have to be stored until such a facility becomes
available. There are only three disposal sites for the low-level waste,
none in Pennsylvania. The radioactive materials in the structure and
the reactor will therefore have to be shipped out of state for
disposal. The Department of Energy is responsible for the
decommissioning.
-------
-88-
FEDERAL FACILITIES
GENERAL
Based on GSA inventory records, there are 2,214 Federal Facilities in
Region III. These facilities encompass 4,496,062 land acres. There are
40,191 buildings located on this land area with the total value of both land
and buildings of $11.44 billion. Over 25 percent of the total civilian
government workforce resides in the region and over 95 percent of all
governmental "command" or Headquarters offices are located within the region.
Regarding Pollution Abatement, there are currently 503 active pollution
Abatement projects ongoing at various federal facilities in Region III.
When com^o-,, ', f^se projects will be valued at $661,785,400.00. These
costs represent over 25 pe^_, : c f-he total National Federal Pollution
Abatement Budget of $2.3 billion.
AIR SOURCES
There are 144 major (100 ton per year potential) sources in Region III.
The number of minor sources, conservatively estimated could number in the
thousands. Only five major sources are known to be out of compliance and
each is operating under an acceptable abatement schedule. The most current
records indicate that 48.6 percent of these sources have been inspected.
NPDES SOURCES
There are currently 256 NPDES applications on file. Based on our records
31.6 percent are out of compliance with their permit conditions, 25.6 percent
are in compliance with their permit conditions and 32.8 percent are of
unknown compliance status. The reason for this last category being so high
is due to delegation of the federal facility permit issuance authority to
several of our States where they are not required to report to EPA on minor
sources. This should be corrected because of our overview responsibility
for federal facilities. Also, a large number of these facilities are
currently operating under expired permits. The delegated States as well as
regional permits staff should be encouraged to give re-issuance of these
permits a high priority.
RCRA SOURCES
There are currently 36 federal facilities that have submitted Part "A" kCRA
applications. As of April 1, 1983, ten federal facilities had a RCRA
inspection conducted with two reported as having violations. Corrective
actions are being taken.
As the review process proceeds, more facilities will be inspected and
evaluated with regard to their need for a permit. This review process will
be conducted in the same manner as for the non-federal facilities (i.e. as
they come up on the list).
-------
-89-
"SUPERFUND" SITES
Responsibility for investigation, study and clean-up of DoD "Superfund"
sites has been delegated by the President to DoD (Executive Order (EO 12316),
Under EO 12316 EPA will play predominately an "advisory" role. The Region
has however, a very good working relationship with DoD in this matter. The
DoD has an ongoing Installation Restoration (IR) program. This program has
4 phases.
PHASE I - Installation Assessment. File reviews, interviews of current
and key former employees, assessment of terrain, hydrogeulogy ar>d past
and present waste disposal practices are reviewed. Twenty-three Phase i
studies have been completed in Region III.
PHASE II - Confirmation Phase. A comprehensive survey is conducted to
fully define the facility's problems through environmental sampling and
analysis. Eleven Phase II studies are ongoing in Region III.
PHASE III - Technology Base Development. If control technologies do not
exist, they are developed at this phase. No Region III installations
require a Phase III study at this time.
PHASE IV - Operations Phase. This phase includes design, construction
and operation of pollution abatement facilities, and the completion of
remedial actions. As of this date, no Phase IV studies have been
initiated.
As the reports in the various installations are completed, they are provided
to the Region for our review. At that time if additional data is requested
by EPA, it will be provided to EPA by DoD as soon as is practicable. It is
hoped that sharing this information will eliminate duplication of effort and
serve to be the most cost effective procedure for both EPA and DoD. Any
remedial actions determined to be necessary by DoD will be coordinated with
both EPA and the effected State organization.
-------
Appendix A.
Supporting Documentation
-------
Introduction
Appendix "A" contains the supporting documentation for the material
presented in the main report. This information is presented in a media-by-
media format.
-------
A-l
AIR QUALITY PROBLEMS
The following chart gives population densities in counties in Region III.
By comparing this map to those of non-attainment areas it may be seen that
Population correlates well with TSP point source emissions ana somewhat with
S02 emissions and ozone planning counties. Actual non-attainmnt problems
(as opposed to emissions) for TSP and SC>2 do not seem to correlate as well
with population density. This reflects a different mix of sources in highly
populated urban areas.
-------
A-2
PENNSYLVANIA
-------
less than SO
50 - 100
100 - 1000
1000 - 10,000
greater than 10,000
Persons per square mile
POPULATION DENSITY 1980
-------
A-4
The following charts give NAAQS violation days as a percentage of total
monitors operating in a State. A violation day is defined as any
measurement within the state boundry that exceeds NAAQ Standards. If more
than one monitor within the State exceeds a standard on the same day it is
considered only one violation day. This procedure allows trends to emerge
despite a change in the number of monitors with time and differences from
state to state. Each State is charted separately. Where a bar does not
appear, no violation of the standard was measured. The charts give data
from 1975 through 1981.
These maps represent standards violations or air quality problems indicated
by 1980-1981 data. The do not necessarily correspond with the official
designations under section 107 of the Clean Air Act.
-------
TOTAL SUSPENDED PARTICULATE
4-1
METRO construction
period
Legend
CJ 1975
Bl 1976
a 1977
ZZl 1978
ES 1979
CZ3 1980
CQ 1981
-------
A-6
. .
1
SULFUR DIOXIDE
0.40-
0.35-
0.30-1
Q£
P
fc
Z 0.25-
O
^
<: 0.20-
Q
g
< 0.15-
I
O
>
0.10-
0.03-
0.00-
'
i i 1
.
.
.
'
.
'
Legend
CD 1975
« 1976
C3 1977
n za 1978
^ SS3 1979
L §s£ QD 1980
^ (00 1981
! 1" 1"» I
DE DC MD PA VA WV
-------
OZONE
O
9-1
8-
7-
6-
2 4-
O
§
O 3H
2-
Legend
CH 1975
m 1976
C3 1977
ZZ3 1978
Effl 1979
CO 1980
SXJ 1981
WV
-------
A-8
CARBON MONOXIDE
Legend
CD 1975
I 1976
C3 1977
KZ3 1978
OS 1979
Q3 1980
TO 1081
PA
VA
WV
-------
A-9
The following maps show the attainment status by county of Region III .
Companion charts of emission and the location of steel-making sources are
included for comparative purposes. It can be seen that the TSP
non-attainment areas correlate remarkably well with steel-producing
activities but not well with TSP point source emissions. This gives a
graphic indication of the ambient problems associated with the steel
industry. For SC>2, it can be seen that high emission density does not
necessarily lead to NAAQS violations because of the effect of stack height
and source distribution within the counties. S02 sources do not tend to
cluster together as do sources of particulates in the steel-making
industry. Ozone planning counties generally reflect areas of high emissions
of non-methane hydrocarbons while CO problems follow from areas of high
traffic density.
-------
A-10
primary
secondary
r It h vlolal
n* off tH» MAAQQ for r> a r t I o u I a * » In 1 O 8 O - 1
-------
Source: NEDS data base
(POINT SOURCES ONLY)
COUNTIES WITH TOTAL SUSPENDED PARTICULATE EMISSIONS GREATER THAN 10,000 TONS PER YEAR
-------
A-12
REGION III STEEL PLANT LOCATIONS
-------
Counties with violations of the NAAQS for sulfur dioxide in 1980-1981
-------
A-14
Source: NEDS data base
COUNTIES WITH SULFUR DIOXIDE EMISSIONS GREATER THAN 5O.OOO TONS PER YEAR
-------
OZONE PLANNING COUNTIES
-------
A-16
Source: NEDS data base
COUNTIES WITH VOLATILE ORGANIC COMPOUND EMISSIONS GREATER THAN 25,000 TONS PER YEAR
-------
Counties with violations of the NAAQS for carbon monoxide in 1980-1981
-------
A-18
Source:NEDS data base
COUNTIES WITH CARBON MONOXIDE EMISSIONS GREATER THAN 1OO.OOO TONS PER YEAR
-------
Source: NEDS data base
COUNTIES WITH OXIDES OF NITROGEN EMISSIONS GREATER THAN 25,000 TONS PER YEAR
-------
A-20
The following maps show the present and planned acid rain monitoring network
in Region III. In addition, a national map of acid deposition shows the
national hot spot to be in Regions II and III. This necessitates continued
attention to the problem by the regional office.
-------
A-21
Mean Annual Acid Deposition in
Precipitation for Period 1976-1979
(Deposition values are
derived from mean pH and
mean annual precipitation)
Source: February 1981 Interim
Reports by Work Groups under
U.S.-Canada Memorandum of Intent
on Transboundary Air Pollution,
Work Group 1, p. 3-9, and Work
Group 2, p. 6-4.
-------
State 105 Agency Acid Precipitation
Networks Station Locations
Existing
O Planned 2/10/83
A-22
-------
A-23
The following chart gives information on the number of schoolo aflecced by
the asbestos-inschools program. It can h» cccu cnat a large number of
schools are involved and «-hat tracking is difficult for lack of a reporting
-------
A-24-
ASBESTOS-IN-SCHOOLS PROGRAM
DC DE MD
PA
VA WV TOTAL
Public Schools
Total Number of
Public Schools
Number of School
Districts
Public Schools In
spected to Date
Public Schools which
need Corrective Action
Corrective Action
to Date
Number of Students
196 193 1,332 3,736 1,750 1,250 8,457
0
16
24
511
95
55 702
196 193 1,300 3,407 1,062 1,165 7,323
0 149
575 98 98 l.OJO
8 3 UK UK 109 120
91,828 92,646 721,841 1,839,015 975,727 400,000
Non-Public Schools
Total Number of Non-
Public Schools
Non-Public Schools
Inspected to Date
Non-Public Schools Which
need Corrective Action
Corrective Action Taken
to Date
120 99 367 2,230 384 97 3,387
14 UK
UK UK
UK
UK
604
147
UK
UK
UK 618
UK 147
UK 24,112 133,485 394,099 71,395 13,000
-------
A-25
SURFACE WATER QUALITY
Introduction
The water quality problems in Region III will be described through analysis of
the following parameter groupings which are closely associated with the
identified pollutant sources:
Parameters Major Sources
ph, Iron, Sediment Coal Mining (Active and Inactive)
Toxics (organic & inorganic) Industrial Point and Non-Point
Nutrients, Sediments Domestic Waste*, Agricultural and
Urban Runoff
-.-"fa Domestic Waste*, Agricultural and
Urban Runoff
Dissolved Oxygen Domestic ,,c... "' , T"Hv<3trial Point
Since these parameter groupings are strongly associated with a particular
source category or categories, the resolution of these problems can be viewed
in programmatic terms.
For the purposes of this report, a water quality problem is one which results
in stream use impairment. In determining stream use impairment, Region III
did not rely solely on numerical standards violations. The streams and lakes
designated as having impaired uses were those for which there was evidence of
one or more designated uses being precluded or limited as a result of
pollution.
Use impairments were classified as severe, moderate or potential. Several
criteria were used including degree of impairment, type of impairment and the
duration of the impairment. If one or more designated uses were completely
precluded for a significant period of the year, the impairment was considered
severe (e.g., absence of aquatic life, shellfish closure). Severe impairments
sere also designated where pollution resulted in a significant health risk
(e.g., exceedance of FDA Action Level for toxics concentration in fish). A
oderate impairment was designated where use was only limited (e.g., shift to
less desirable aquatic species, insignificant duration of impairment). A po-
tential impairment was designated where professional judgement of available
information found the possibility of a problem (e.g. appearance of toxics
levels whose effects are unknown at this time. Due to an inadequate data
base, severe versus moderate impacts were also distinguished through best
professional judgement.
*Includes combined sewer overflows.
-------
A-26
Table 1 estimates stream length of use impairment in Region III.* Figures 3
to 9 identify, by parameter, problems greater than 5 miles in length. Lakes
which had an adequate data base (primarily developed under the Clean Lakes
program) were also included in this report.
Information in Table 1 (and Appendix A) was attained from State 305(b) Reports
and State Water Quality Management Agency staffs. Comprehensive lists of
specific waterbodies with use impairment can be obtained from these sources or
EPA Region III.
*The relative degree of use impairment from state to state is expressed in
Impaired Stream Miles per 1000 square miles due to lack of reliable total
streamlength figures.
-------
A-27
TABLE 1
SUMMARY TABLE: WATER USE IMPAIRMENTS - REGION III
STREAM MILES OF USE IMPAIRMENT (SEVERE, MODERATE, POTENTIAL)
PROBLEM
PARAMETERS
pH, Iron,
Sediment
Hutrients
Sediment
Toxic s
Organic/
Inorganic
Bacteria
PA
S-1815
M-0
P-0
S-0
M-233
P-0
M-271
P-434
S-195
M-170
P-35
S-0
M-0
P-0
MD
S-74
M-0
P-0
WV
S-238
M-748
P-54
S-4 S-0
M-430 I/ M-112
P-10 P-C
*Total Impaired
Stream miles 2,744
Area in Square
Miles 45,333
S-13
M-18
P-0
S-0
M-0
P-0
S-44
M-171
P-0
600
10,577
21
61
S-9
M-3
P-15
57
S-l
M-2
P-0
S-0
M-lll
P-0
S-5
M-336
P-0
S-0
M-0
P-0
1,543
24,181
64
VA
S-245
M-20
P-0
S-28
M-67
P-107
S-91
M-25
P-0
S-138
M-102
P-33
S-250
M-147
P-64
1,024
40,817
25
DE 4/ DC
S-0
M-0
P-0
S-3
M-L7
P-0
S-3
M-0
P-52
S-3
M-2 3
P-0
S-119
M-31
P-0
150
2,057
S-0
M-0
P-0
S-8
M-ll
P-0
S-8
M-ll
P-0
S-0
M-8
P-0
S-8
M-19
P-0
67
S-0
M-0
P-l
S-7
M-2
P-46
73
S-7
M-ll
P-12
S-0
M-0
P-0
Region III
S-2372
M-768
S-4 3
M-8 70
P-107
S-115
M-436
P-486
S-341
M-639
P-&8
S-4 11
M-3b8
P-64
6,088
23,032
49
S-25
M-18
P-74
Impaired Stream
Miles per 1000
sq.rai.
Number of
Lakes With
Impaired
Uses 3_/
*»ote: Some stream segments may be double counted if more than one grouping of problem
parameters contributes to the impaired use. However, for the total miles impaired
there is no double count included.
II Does not include upper Chesapeake Bay which is moderately impaired.
If Does not include upper Chesapeake Bay which is potentially impaired.
3/ Only the severe and moderately impaired lakes are identified on the nutrients/
sediments/lakes map.
4/ Six instances of potential use impairment were identified where stream length
" was either inappropriate (e.g., a bay) or unknown. Four were potential toxics
problems; two potential bacteria problems.
-------
A-28
pH, Iron. Sediment
Use impairment by this parameter group is due to active and inactive aban-
doned coal mining sites, with the latter predominating. Based upon the
summary table, coal mining causes the most extensive and severe stream
impairment of any problem category in Region III. About 49% of the impaired
streams in Region III are due to coal mining impacts. These impacts occur
primarily in Pennsylvania and West Virginia. Use impairment is severe in
Pennsylvania and northern West Virginia, where drainage is highly acidic.
Discharges in southern West Virginia are not highly acidic, but still contain
excessive levels ofmetals and sediment.
- -.-.- ~w values and high levels of heavy metals typical of many mine drainage
impacted streams a.c '-'hat to aquatic life. In addition, the persistence of
acidic conditions in natural watero t- .*~°J1v ensures that the effects of
mining will be felt far downstream of the actual soun_t ~ ~;--o affected by
coal mining may also seriously impair contact recreation, domestic ami .^^s
trial water supply, aesthetics and pre-maturely corrode man-made structures.
Nutrients, Sediments
Nutrient problems are typically due to either domestic waste or agricultural
runoff. Urban runoff also contributes. Sediment problems (in addition to
those created by mining) are primarily agricultural in origin. Problem areas
are in watersheds with large population centers or heavy agricultural land use
or a combination of the two. About 14% of the use impaired streams in Region
III are attributed to Nutrient and Sediment contributions. In addition, the
Upper Chesapeake Bay is considered to be nutrient enriched.
Sediments destroy bottom habitat suitable for fish reproduction by smoth-
ering the benthic organisms and by filling in suitable spawning and growth
habitats. Sediments which settle in a reservoir diminish its capacity,
reducing the life of a reliable public water supply. Sediments also act as
the vehicle for transport of attached nutrients from non-point sources.
Excessive levels of nutrients, primarily nitrogen and phosphorus, cause
overproduction of aquatic plant life, eg., eutrophication. Lakes or other
slow moving bodies of water are particularly sensitive to this problem.
Excessive plant growth will produce large fluctuations in dissolved oxygen
causing significant stress on other aquatic life. In addition, algae produce
an undesirable taste and odor to water and diminishes its desirability or
useability as a domestic water source.
The use impaired lakes in Region III are shown on the Nutrients/Sediments
map. Eutrophic conditions in lakes reduce the recreational value (ie:
swimming, boating, aesthetics), the aquatic life productivity, and the poten-
tial for domestic water supply. Through the Clean Lakes programs, comprehen-
sive information is available on most of the lakes in Delaware. This is not
the case for the other states in the Region.
-------
A-2 9
Evaluations have indicated that 117 lakes in the Region would be classified as
eutrophic. Of these, 42 lakes have been identified as having significant use
impairment (24 severe, 18 moderate). Non-point sources were deemed to be
significant in all but one case. Potential impairments were not identified on
the Regional map since all of the remaining eutrophic and mesotrophic lakes
fit this category. (See Figure 4.)
-------
FIGURE 3
pH/lron/Sediment
Key
Severe
Moderate
Potential
t
y\ ) >£n
-------
FIGURE 4
Nutrients/Sediment
Key
^ Severe
Moderate
Potential
Lake Use Impairment
7
/_
y
P
s
v>
Vs
>.
*. y
NJ
"~"t
\ »
A \
v v--
*, -x
^ ;
V
\
r
4
" (,
^50
X ' s
( ^S \
\ \J
\
1
1
1
//'
/:'
-------
A-32
Dissolved Oxygen (DO)
DO problems are typically caused by organic enrichment from municipal and
industrial point sources. Therefore, DO problems may be expected near indus-
trial or population centers. There are a substantial number of DO problems
created by the discharges of small communities into small streams. Region-
wide, about 9% of the use impaired streams are due to inadequate DO levels.
Due to the tremendous capacity of stream systems to recover from organic
enrichment, DO problems are not extensive, especially in terms of length of
stream affected and duration of use impairment. This self-purification
ability of streams is a key factor in minimizing the length of streams being
impaired by DO. Generally, DO problems produce a subtle use impairment
characterized by a shift in the resident biota to less desirable species.
(See Figure 5.)
Bacteria
Municipal point source, combined sewer overflows and urban runoft are prime
sources of bacterial problems in Region III. Although there are many areas in
Region III with significant violations of numerical bacteria standards, these
violations were not considered to be use impairing unless they directly
contributed to a shellfish or designated swimming area closure. The
protection of shellfish from bacterial contamination requires maintenance of a
significantly lower bacteria population than for the protection of bathing
beaches. Some of the identified closures are due to natural conditions or
simply due to the proximity of the shellfishing beds to a wastewater discharge
without consideration of the bacterial water quality. Regionwide, this
problem accounts for an estimated 12% of the impaired stream miles. (See
Figure 6.)*
Toxics
Most of the toxics problems identified are generated from industrial dis-
charges and are concentrated downstream of large industrial centers. A
comprehensive identification of toxics problems is limited by a minimal data
base, despite recent data gathering efforts. Since additional data is
expected to identify more use impairment, this may be considered an emerging
problem.
Toxics impacts on water bodies can be intermittent or persistent. Inter-
mittent problems are often the result of spills from a variety of industrial
sources. Industrial spills have the potential to contaminate public water
supplies with substances ranging from those causing taste and odor problems,
e.g., phenols (defined as a moderate impairment), to those with potential
public health effects (defined as a potential impairment), e.g.
trichloroethylene. Though spill data exists for many areas, current
monitoring efforts generally are not sufficient to define the extent of this
problem on a Regional basis. For more analysis, see Spills below.
*Bacterial related use impairments in Delaware, through identified in Table 2,
are not mapped in Figure 6.
-------
A-33
Many waterbodies are affected by persistent toxics levels resulting in
contamination of the sediments and fish. Toxic levels can be high enough to
eliminate aquatic communties or violate toxic criteria for fish tissue,
resulting in prohibitions on fishing e.g., lower James River due to kepone
levels. Both of these types of impairments are considered severe. The
longevity of this type problem is presently unknown. Generally, data
indicates that levels of some toxics in fish and sediment have decreased in
recent years, particularly where control programs are in place, e.g., PCB.
There is evidence that toxics levels have gone down in some waterbodies due to
decreased industrial production and improved treatment e.g. Monongahela
River. Overall, however, the public health effects of current toxic levels in
the region still have not been adequately defined. For a more detailed
anaylsis of PCB's, see PCB Compliance Monitoring Program below.
In Region III, an estimated 16% of the impaired streams are due to toxics.
In addition, localized areas in the Chesapeake Bay contain levels of heavy
metals which represent a potential problem.
-------
FIGURE 5
Dissolved Oxygen
Key
Severe
Moderate
.Potential
-------
FIGURE 6
Bacteria
Key
Severe
Moderate
-Potential
V \ y _
-------
FIGURE 7
Toxics
Key
Severe
Moderate
Potential
-------
A-37
Spills
Spills of oil or hazardous substances can pose a substantial threat to human
health or aquatic life. Due to the potential acute effects of spills,
emergency response action is required.
Region III received notice of 765 oil spills and 377 spills of hazardous
materials from October 1, 1981 to June 30, 1982 (3/4 year). The quantity of
materials spilled varied from a few gallons to thousands of gallons. In each
case, confirmation was made by phone or site visit, that appropriate
corrective actions were taken. At this time, the number of gallons of oil
removed from the environment during cleanup and relative number of stream
miles affected by spills have not been identified.
PCB Compliance Monitoring Program
Polychlorinated biphenyls (PCB's) are (1) highly toxic to aquatic life at
extremely low concentrations, (2) persisitent, thus posing long-term risks to
human health, (3) known carcinogens, (4) bioaccumulative, thus adversely af-
fecting growth and reproduction in fish and other biological life. The
primary objective of the PCB Compliance Monitoring Program is to keep PCB's
from entering the environment. By establishing an enforcement presence and
inspecting for compliance with the regulations, the region influences the
regulated community to properly dispose of PCB's and minimizes the affects of
spills to the the nation's waterways.
The following table summarizes Regional compliance status for FY'81 and
FY'82:
Total Case Violations
Inspections Complaints Informal Number in
Review Issued Actions 2 Compliance %Compliance
FY'81 80 7 38 35 43
FY'82 "l 19 27 29
1 Total reports reviewed as of 12/17/82. Total FY'82 inspections - 116.
2 Includes notices of non-compliance, letters, verbal communications with
documentation.
Of the 46 documented violations as of 12/17/83, seven (7) were cases where the
Region is now or has already forced the cleanup of PCB's that had entered the
environment. Therefore, at least 6% of the 116 inspections for FY 82
definitely resulted in environmental cleanup. Certainly many of the marking
and similar-type violations discovered and corrected will prevent PCB s from
entering the environment. Because of these environmentally-significant
results? Region III is continuing to follow the PCB Enforcement Strategy
modified to handle Region Ill's problems.
-------
A-38
Region III has over 3500 facilities which use a toxic chemical, PCB, in
certain operations. These do not include the large commercial buildings that
have transformers throughout our cities. With present resources, it will take
over 20 years to inspect the 3000 remaining potential PCB users that have not
been visited. Figuring 6% of 3000, there are at least 180 sites in Region III
where PCB's will affect or have entered the environment. Also figuring that
we are finding only 40% compliance status, this means that approximately 1800
facilities in Region III are in violation of the PCB rule. Additional
resources must be allocated to more quickly address these problems.
In addition to the toxics parameter group, these additional emerging water
quality problems were identified:
Acid Precipitation
Acid precipitation is emerging as a problem of serious public concern. It has
been theorized that air emissions from coal fired power plants and other
sources are indirectly producing acid precipitation which may be responsible
for serious declines in the pH of waterbodies in the U.S. and Canada, particu-
larly lakes. Unfortunately, documented trends in pH of waterbodies have been
difficult to establish with past data and current monitoring efforts.
Historical pH data is limited in value, due to variable methods of sampling
and analysis, while current pH monitoring programs have not been properly
planned for assessing impacts of acidic precipitation on waterbodies.
However, it is probable that some documentation of acid precipitation impacts
on water quality exists but has not been made available to EPA Region III at
this time. Overall, current and projected effects of acid precipitation on
waterbodies of Region III have not been adequately documented.
Wetlands
Located at the interface between receiving waterbodies and terrestial sources
of pollution, wetlands have been found to reduce sediment loads, nutrient
levels and toxic chemical concentrations in the water column. All of the
staces in Region III, except West Virginia, have implemented wetland
protection laws due to their positive effect on water quality. These laws
vary in their effectiveness and generally provide adequate protection to
coastal systems, but limited protection to inland, freshwater systems. Table
2 and Figure 8 identify the lost and threatened wetlands in Region III.
Some of the major activities which threaten existing wetlands are: im-
poundment, fill and drainage projects, water port development, non-point
sources of nutrients, sediment and pesticides, mining, and land development.
Some significant threatened wetlands in Region III are: 1. the Upper Chesa-
peake Bay, (where water quality may be causing losses in submerged aquatic
vegetation), 2. Pocono Region in PA (due to peat mining operations and home
development), 3. Philadelphia, Baltimore and Wilmington areas (Port
development activities) and 4. Canaan Valley, WV (potential pump storage
project). (See Figure 8).
-------
A-39
Oil and Gas Operations
Impacts of oil and gas drilling and recovery operations are responsible for
significant surface water use impairment in western Pennsylvania and north-
western West Virginia. Excessive levels of sediment, total dissolved solids,
a variety of toxic compounds and high or low pH due to oil and gas operations
severely degrade aquatic communities and aesthetics, and increase water treat-
ment costs. Sources associated with these problems include: 1) discharges of
highly acidic, alkaline or toxic drilling wastes from storage pits, 2) spills
of oil and gas, 3) chronic leaks of oil and gas from pipe systems, 4)
discharge of brines (with high levels of dissolved solids)and 5) erosion from
operation sites. Pennsylvania has identified at least 40 miles that are
severely impaired while West Virginia has identified areas of major
impairment. As data gaps on this problem are filled, additional impairment is
expected to be identified. The number of permitted operations have grown
significantly over the last five years and associated water quality problems
are suspected to be growing steadily.
-------
A-40
TABLE 2
WETLAND ISSUES
Region III
ThreatenedArea
1. Upper Chesapeake, MD
2. Baltimore, MD
3. Indian River Bay, DE
4. Rehoboth Bay, D
5. Wilmington, DE
6. Pocono Region, PA
7. Philadelphia, PA
8. Erie, PA
9. SE Virginia (SMSA)
10. St. Mary's River, MD
11. Ware Creek, VA
12. Beaverdam Swamp, VA
13. Assamoosick Swamp, VA
14. Upper Chester River, MD
15. Canaan Valley, WV
16. Chincoteague, VA
17. Armstrong County, PA
18. Wheeling Creek, PA
19. Pohick Creek, VA
20. Nibbs Creek, VA
21. Bush River, VA
22. South Anna River, VA
23. Great Creek, VA
24. Cedar Run, VA
25. Davis Trucking Mine, WV
26. Holly Grove Mine, WV
27. Chesapeake, MD/VA
Wetlandsize
40,000 ac. (SAV's)
80,000 ac.
150 ac.
300 ac.
700 ac.
7,500 ac.
3.600 ac.
4,500 ac.
100 ac.
40 ac.
50 ac.
100 ac.
600 ac.
50 ac.
35 ac.
100 ac.
90 ac.
30+ ac.
ThreattoResource
NPS nutrients,
sediment, pesticides
port development
nutrients, residential
development
nutrients, residential
development
port development
peat mining, home
development
port development
port development
port developmen
impoundment
impoundment
impoundment
impoundment
drainage project
impoundment
development (fill)
development (fill)
impoundment
impoundment
impoundment
impoundment
impoundment
impoundment
impoundment
mining
mining
multiple dredge & fill
projects
-------
FIGURE 8
Areas of significant wetland: water
quality interrelationship
o
D
O
A
Multiple source impacts
Impoundment and drainage
projects
Port development
Mining impacts
Significant enforcement
efforts
Note: The relative size of the
symbols indicates the
relative size of the
wetland resource involved. '
O
-------
A-42
TABLE 3
Priority Ranking System
The following outline describes the system and assumptions used to indenti-
fy high priority water quality problem streams and rivers in Reigon III. In
many cases, precise data and information was not available and best judgement
was used in assigning point values and interpreting the 305(b) report
information. Therefore, the system should be considered a rough, first cut
approach in screening the problems identified in Appendix A.
The maximum score under this system is 100 points.
1. Degree of Use impairments (Max. 20 points)
. Severe (one or more designated uses completely precluded
such as aquatic life or shellfishing) 20 points
. Moderate (partial duration or limited impairment) 10 points
2. Value of Use Impairment
(Add impaired uses but do not exceed 30 points) (Max. 30 points)
. Public Water Supply - health related 25 points
. Commercial Fishing 15 points
. Public Water Supply - aesthetic only 10 points
. Cold Water Fishing 10 points
. Swimming 10 points
. Warm Water Fishery 8 points
. Trout Stocking 8 points
. Aesthetics 6 points
3. Significance of Resource (Max. 30 points)
. Regional or national value 30 points
. Statewide Significance 20 points
. Only Local Significance 10 points
4. Population Impacted (County or SMSA) (Max. 20 points)
1,000,000 20 point s
500,000 - 1 million 15 points
100,000 - 500,000 10 points
30,000 - 100,000 5 points
30,000 3 points
Errata:
Figure 2 -
Severe DO Impairment for Delaware should be indicated as an estimated 3
miles. Moderate DO impairment should be indicated as zero miles.
-------
A-43
Figure 6 -
Delaware streams impacted by bacteria are not mapped,
Buntings Branch, a stream segment in southern Delaware severely
impaired by toxics, has been incorrectly mapped. It is located in
the northeast portion of Pocomoke River headwaters.
-------
A-44
OCEAN PROBLEMS
Summary of U.S. EPA
Dumpsite
Old sewage sludge
site (1961-1973)
Interim sewage
sludge site
(1973-1980)
Acid-iron waste
site (1969-1977)
Arsenic waste site
(1966-1974)
Region III Dumpsite-Total Wastes Dumpe
Coordinates
Waste Type (Latitude, Longitude) (th
Sewage sludge
Sewage sludge
Acid
Caustic
38°45'N,
75°47'W
38°20'-33025IN
74°10'-74°20IW
38030'-38035'N
74°15I-74°20IW
38°00I-38°20IN,
73°00'-74°20'W
d
Quantity
ousand metric tons)
3750
4110
5060
110
-------
Ocoan Dump Silos
Incineration Site
OldSovrage Slto
Acid Iron Site
Interm Sewage :
Arsenic Site
Dredged Spoils Site
-------
A-46
Potential 301(h) Applicants
Virginia
VA0024457
VA0025003
VA0051756
VA0021288
VA0062618
VA0064459
Maryland
MD0020044
MD0020401
Delaware
DE0005008
DE0020028
DE0021512
Pennsylvania
PA0025671
PA0026689
PA0026662
U.S.A. Wallops Island (NASA)
Portsmouth - Pinners Point
Town of Chincoteague
Town of Cape Charles
HRSD - Atlantic
HRSD - Nansemond
Ocean City
Chesapeake City
South Coastal WWTP
Rehoboth
City of Lewes STP
City of Philadelphia
City of Philadelphia
City of Philadelphia
-------
Potential 3O1 (h) Cities
? L.
Philadelphia
apeake City
.Lewes
'South Coastal
'Ocean City
G hlncoteague
Wallops Island
Cape Charles
Lamberts Point Chesapeake Elizabeth
Nansemond -
Atlantic
-------
A-48
Approved Drilling Mud types
1. Seawater/Freshwater/Potassium/Polymer Mud
Components
KC1
Starch
Cellulose Polymer
XC Polymer
Drilled Solids
Caustic
Barite
Seawater or freshwater
2. Seawater/Lignosulfonate
Components
Attapulgite or Bentonite
Lignosulfonate
Lignite
Caustic
Barite
Drilled Solids
Soda Ash/Sodium Bicarbonate
Cellulose Polymer
Seawater
3. Lime
Components
Lime
Bentonite
Lignosulfonate
Lignite
Caustic
Barite
Drilled Solids
Soda Ash/Sodium Bicarbonate
Seawater or freshwater
Authorized Range
pounds per barrel
5.0 - 50
2.0 - 12
0.25 - 5
0.25 - 2
20.0 -100
0.5 - 3
0.0 -450
As needed
Authorized Range
pounds per barrel
10.0 -
2.0 -
1.0 -
1.0 -
25.0 -
20.0 -
0.0 -
0.25-
50
15
10
5
450
100
2
5
As needed
Authorized Range
pounds per barrel
2.0
10.0
2.0
0.0
1.0
25.0 -180
20.0 -100
0.0 - 2
As needed
20
50
15
10
5
-------
A-49-
4. Nondispersed
Components
Bentonite'
Acrylic Polymer
Barite
Drilled Solids
Seawater or freshwater
5. Spud
Components
Lime
Attapulgite or Bentonite
Caustic
Barite
Soda Ash/Sodium Bicarbonate
Seawater
Authorized Range
pounds per barrel
5.0 - 15
0.5 - 2
25.0 - 180
20.0 - 70
As needed
Authorized Range
pounds per barrel
0.5 - 1
10.0 - 50
0.0 - 2
0.0 - 50
0.0 - 2
As needed
Seawater Freshwater Gel
Components
Lime
Attapulgite or Bentonite
Caustic
Barite
Drilled Solids
Soda Ash/Sodium Bicarbonate
Cellulose Polymer
Seawater or freshwater
Authorized Range
pounds per barrel
0.0
10.0
0
0.0
20.0
0.0
0.0
5 -
2
50
3
50
100
2
2
As needed
7. Lightly Treated Lignosulfonate Freshwater/Seawater
Components
Lime
Bentonite
Ligonsulfonate
Lignite
Caustic
Barite
Drilled Solids
Soda Ash/Sodium Bicarbonate
Cellulose Polymer
Seawater to Freshwater Ratio
Authorized Range
pounds per barrel
0.0 - 2
10.0 - 50
2.0 - 6
0.0 - 4
1.0 - 3
0.0 -180
20.0 -100
0.0 - 2
0.0 - 2
1:1 - approx.
-------
A-50
8. T.fffrnmm fonate Freshwater Authorized Range
pounds per barrel
Components *
0.0 - 2
Lime . 10.0 - 50
Beutonite 40 _ 5
Caustic Qi0 _45Q
Barite 20>0 _1QO
Drilled Solids 0 0 - 2
Cellulose Polymer n'n - 2
Soda Ash/Sodium Bicarbonate As'"needed
Freshwater
-------
A-51
DRINKING WATER PROBLEMS
According to the latest inventory, of the 5,854 community water systems in
Region III, 5,272 are small water systems serving fewer than 3,301 people.
Thus, the vast majority of community water systems would be considered small
water systems. Although this represents only 9.1 percent of the total popu-
lation served by community water systems, approximately 98 percent of the
persistent violations of the SDWA requirements occur in small systems.
These violations involve failure to meet Monitoring and Reporting (M/R)
requirements or failure to comply with a Maximum Contaminant Level (MCL)
requirement. M/R requirement specifies how frequently a system must sample
and report for each contaminant. MCL requirement specifies the quality
standard for each contaminant.
During FY'82 there were 1,463 systems with violations; of these, 1,388
systems involved small water systems. There were 480 systems with
violations persisting over three months in FY'82.
Regional and state-by-state data on public water supply systems and
violations are presented in the accompanying graphics.
Region III is pursuing the Small System Strategy developed by the Office of
Drinking Water as a means of dealing with this problem. This strategy
establishes priorities for those systems having greatest affect on the
greatest number of people. It encourages technical assistance and operator
training activities to improve operational functions. It suggests providing
the small systems with direction to existing financial subsidy programs, and
consolidation of small systems into regional water systems as an economic
solution.
These strategies will bring about significant reductions in the number of
problem systems. The provision of safe drinking water to the public must,
however, be continuous and ongoing, with a comprehensive program for
monitoring systems and dealing with contaminants as they appear.
-------
A-5 2
REGION III DRINKING WATER COMPLIANCE
COMPARISON BY SYSTEM SIZE*
FISCAL YEAR 1982
100
SOURCE:
FEDERAL REPORTING
DATA SYSTEM
4/5/83
COMMUNITY SYS <3300
COMMUNITY SYS >3301
DE
171
16
MD
540
55
PA
2106
292
VA
1729
134
WV
726
85
POP
2.2M
22.4M
CALCULATED BY COMPARING NUMBER OF SYSTEMS
WITHIN A SIZE CATEGORY TO THE TOTAL NUMBER OF
SYSTEMS IN VIOLATION WITHIN SAME SIZE CATEGORY
-------
100
REGION III DRINKING WATER COMPLIANCE
MAX CONTAMINANT LEVEL - FY 82
Legend
ess BACH
CZ: TURBIDITY
I CHEMICAL
SOURCE:
FEDERAL REPORTING
DATA SYSTEM
3/11/83
DE MO PA VA
SYS<3300 171 510 2106 1729
TOTAL SYS 187 395 2398 1863
WV TOTAL POP
726 2.2M
811 22.4M
-------
A-54
100
REGION III DRINKING WATER COMPLIANCE
MONITORING/REPORTING -- FISCAL YEAR 1982
Legend
Kffl BACTI
CZD TURBIDFTY
CHEMICAL
SOURCE:
FEDERAL REPORTING
DATA SYSTEM
3/11/83
-------
A-55
GROUND WATER PROBLEM
Criteria for Selection of Significant Problem Areas
Four major areas of concern were identified to represent the categories
of importance in selecting significant problem criteria. Within each category
more specific point scoring criteria was established and assigned based on
various considerations. The scoring system is prescribed below.
Health (0-40 points)
- Population Impacted
Types of Contaminants
Feasibility (0-40 points)
Technically Solvable
- Funds Available
T oeal Authority
Relationship with Other Programs
Program Integration (0-10 points)
Relationship to SMSA
Population (0-10 points)
Scoring ranged from 9 to 87 points. Fifteen areas were selected representing
significant areas that deserve special focus in the future. These fifteen
areas represent approximately 30 percent of the projects rated. All areas
were rated based upon available data pooled by various Division offices.
Table 1 presents all projects. It should be noted that some data was not
available and thus lowered the project's score. Efforts will be needed to
complete the data table in order to upgrade the significant area s list.
This will be done in consideration of available resources.
It should be emphasized that the criteria used for selecting significant
ground water problem areas is somewhat different from the Mitre model usea
to select Superfund sites. The criteria used in the GWEMR focuses solely
on its impact and relation to ground water, while the Mitre model incorporates
additional criteria. However, the Mitre model takes precedence for the
selection of Superfund sites.
Significant Problem Areas
Based upon the selection analysis presented above, fifteen (15) areas have
keen selected. These areas are deemed significant in consideration of their
fcigh relative rank and should represent area, in which substantial effort »
Jded to correct the identified problem(s). Table 2 presents Significant
froblem Areas and Figure 1 map locates these areas.
-------
A-56
TABLE 1 PROJECT SCORING
Area/Site Health
Delaware
Llangollen 40
Landfill
Tybouts Corner 30
Witco Chemical 20
Co.
Shelly Farms 15
Stauffer Chem. 20
Co.
New Castle Skel. U
Plain
Wildcat Landfill U
Maryland
Limestone Road U
Site
Middletown Road U
Site
Sand, Gravel & 15
Stone Site
Pennsylvania
West View Water
Auth. (under
Consent Order
West Orrarod Cotnm.
Ass.
Hatfield Boro.
Water Auth. (SF
Enf. Site)
Warminster Hgts.
Dev. Co. (SF
Enf. Site)
Hatboro Sub. Auth.
(SF Enf. Site)
Phila. Sub. Water
Co. (SF Enf. Site)
Seven Valley 10
Landfill
Feasibility RelatL
25 10
34 7
19 7
4 2
23 5
11 7
11 7
16 5
11 5
13 5
Under Consent Order
See He leva Land till
SF Enforcement Site
See Fisher & Porter
See Fisher & Porter
See Stanley Kessler
16 5
7
7
1
5
Total
82
78
53
22
53
25
25
22
17
34
Kimberton
15
21
38
10 51
-------
A-57
Area/Site Health Feasibility Relationship SMSA Total
Blosenski Land-
fill
Brodhead Creek
Bruin Lagoon
Centre Co. -
Kepone Site
Craig Farms
Douglesville
Disposal Site
Drake Chemical
- .' OQ Ave
Fisher & Porter
Havertown PCP
Site
He leva Landfill
Hranica
Lackawanna
Refuse
Lehigh Electric
Lindane Dump
Lord-Shope
Malvern TCE Site
McAdoo Ass.
Metal Bank of
America
Moyer Landfill
Old City of
York Landfill
Osborne Landfill
Palmerton Zinc
U
U
30
15
U
U
U
20
40
20
U
U
U
20
U
U
U
25
25
U
U
U
U
10
18
5
23
11
3
23
23
2 /
11
11
23
16
23
23
23
13
23
23
23
13
23
8
7
5
0
5
2
5
5
10
i n
7
5
5
5
5
5
5
5
7
10
5
5
5
5
10
8
0
6
6
5
8
10
10
10
8
0
8
8
4
7
10
7
10
7
7
5
0
27
31
58
49
19
13
36
63
87
4/
24
28
29
56
32
35
28
62
68
25
25
33
13
Pile
-------
A-58
Area/Site Health Feasibility Relationship SMSA Total
Presque Isle
Resins Disposal
Site
Stanley Kessler
Company
Voortman Farms
Wade Site
Westline
Virginia
Roanoke Co./
Matthews Elec-
troplating
Chisman Creek
West Va.
McClintic Wild
Life Station
Fike Chemical Co.
Koppers Co./
Colliers Land-
fill
Follansbee Sludge
Fill Area
Leetown Pesticide
10
U
25
U
25
U
20
U
U
25
25
30
U
23
23
23
6
23
13
23
6
15
23
3
15
18
5
5
10
5
7
5
5
3
5
7
5
7
5
7
0
10
8
6
0
6
0
0
6
0
0
0
45
28
68
19
61
18
54
9
20
bl
38
52
23
Pile
DC
None
-------
A-59
Letter
A.
B
C
D
E
F
G
H
I
J
K
L
M
N
0
Note:
Points
87
82
78
77
68
63
62
61
61
58
56
54
53
53
52
Letters correlate to map.
Area
Fisher & Porter
Army Creek
Tybouts Corner
Stanley Kessler
Metal Bank/Amer.
Enterprise
McAdoo Assoc.
Fike Chem. Co.
Wade Site
Bruin Lagoon
Lehigh Elec.
Matthews Elecptg.
Witco Chem. Co.
Staffer Chem. Co.
Follansbee Sludge
State/County
PA/ Bucks
Del/New Castle
Del/New Castle
PA/Phila.
PA/Phila.
PA/Phila.
PA/Schuylkill
W.VA/Kanawha
PA/ Chester
PA/ Butler
PA/Lackawanna
VA/Roanoke
Del /New Castle
Del/New Castle
W. VA/ Brooke
-------
FIGURE 1
Significant
Problem Areas
-------
A-61
Hazardous Waste Problems - RCRA
The most efficient means of characterizing Region Ill's hazardous waste
management program is through the RCRA permitting process. Although current
data is sparse, data collection systems continue to be developed which will
allow EPA to track hazardous waste activities and assure proper management
of hazardous waste facilities.
Under RCRA, all persons engaged in hazardous waste activities are required
to notify EPA. A total of 7556 hazardous waste activities wcr
-------
800
STATUS OF RCRA FACILITIES
700 :
600
v>
.^ 500
.O
40°
3 iOO
2.
200
100-
o
1"
DC
DE
Legend
EZ3 GENERATORS/10
CTS TRANSPORTERS
S3 TSD FACILITIES
EZZ! LANDRLLS
MD PA
State
WV
-------
A-63
PART B PERMIT APPLICATIONS CALLED-1N
(March 16, 1983)
District of Columbia
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
Total
Treatment and/
or Storage*
2
12
11
56
22
20
125
Land Disposal**
0
2
2
6
2
2
Incinerators*
0
2
2
6
1
3
14
14
* - Called-in FY '82
** - Called-in FY '83
-------
A-64
REGION III RCRA INSPECTIONS
Part B
State
0
0
0
0
0
4
Submittals
EPA
0
0
0
10
0
4
Part A Wit
State
0
0
0
12
0
3
:hdrawa!
EPA
1
0
0
1
0
4
District of Columbia
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
Total 4 14 15
-------
REGION III
Facilities Requiring
Groundwater
Monitoring
-------
A-66
Region III Required Groundwater Monitoring
No. of Facilities No. of Processes
D.C. 0 0
Delaware 3 4
Maryland 24 32
Pennsylvania 88 106
Virginia 33 50
West Virginia 2J3 3J2
168 226
-------
A-67
Hazardous Waste Problems - Superfund
NATIONAL PRIORITY LIST SITES
HRS SCORE
Site Name HRS Population
1. Tybouts* - DE 73.67 T
2. Bruin Lagoon - PA 73.11 T
3. Army Creek -DE 69.96 T
4. McAdoo Associates* - PA 63.03 T
5. Osborne Landfill - PA 58.41 R
6. Douglasville Disposal - PA 55.18 T
7. Saltville Waste Disposal Ponds - VA 53.23 T
8. Hranica - PA 51.94 R
9. Lindane Dump - PA 51.62 T
10. Chisman Creek - VA 47.19 R
11. Malvern TCE Site - PA 46.69 T
12. DE Sand & Gravel - DE 46.60 T
13. Palmerton Zinc Pile - PA 46.44 T
14. Heleva Landfill - PA 41.79 T
15. Sand, Gravel & Stone - MD 41.08 R
16. Enterprise Avenue - PA 40.80 U
17. Centre County Kepone Site - PA 39.44 T
18. Lord Shope - PA 38.89 R
19. Drake Chemical - PA 38.52 T
20. Havertown PCP Site - PA 38.34 U
21. Tris Spill Site - DE 38.33 T
22. Resins Disposal Site - PA 37.69 R
23. Moyer Landfill - PA 37.62 T
24. Presque Isle - PA 37.20 U
25. Follansbee Sludge Fill - WV 36.89 T
26. Leetown Pesticide Pile - WV 36.72 R
27. Wade - PA 36.63 U
28. Lackawanna Refuse - PA 36.57 T
29. Fike Chemical - WV 36.30 U
30. WV Ordnance - WV 35.72 R
31. U.S. Titanium - VA 34.78 R
32. Old City of York Landfill - PA 33.93 T
33. Stanley Kessler - PA 33.89 U
34. Metal Bank of America - PA 33.26 U
35. Matthews Electroplating* - VA 31.86 R
36. Westline - PA 31.85 R
37. Brodhead Creek - PA 31.09 T
-------
A-68
38. Harvey Knott Drum Site - DE
39. Wildcat Landfill - DE
40. Blosenski Landfill - PA
41. DE City PVC - DE
42. Limestone Road Site - MD
43. New Castle Steel Plant - DE
44. Lehigh Electric - PA
45. Kimberton - PA
46. Middletown Road Site - PA
47. Fischer Porter - PA
48. Craig Farms - PA
49. Voortman Farm - PA
30.77
30.61
30.57
30.55
30.54
30.40
30.26
29.48
29.36
29.07
28.71
28.62
R
T
T
R
T
T
T
T
T
U
R
R
*State Priority Site
R
T
U
Rural
Town
Urban
-------
A-69
DELAUARE
1. Tybouts Corner Landfill (Wilmington)
2. Army Creek Landfill (Wilmington)
3. Delaware Sand and Gravel (Wilmington)
4. Delaware City PVC Site (Delaware City)
5. Harvey-Knott Drum Site (Kirkwood)
6. New Castle Steel Site (New Castle)
7. Tris Spill Site (New Castle)
8. Wildcat Landfill (Dover)
-------
A-70
HARYLAND
1. Sand, Gravel and Stone Site (Elkton)
2. Limestone Road Site (Cumberland)
3. Middletown Road Site (Annapolis)
-------
A-71
PENNSYLUANIA
1. Lehigh Electric (Old Forge)
2. Bruin Lagoon (Butler Co.)
3. ABM-Wade (Chester)
4. Lord Shope (Erie Co.)
5. Lindane (Allegheny Co.)
6. Osborne (Mercer Co.)
7. Drake (Lock Haven)
8. McAdoo Associates (Hazelton)
9. Craig Farm Drum Site (Parker)
10. Hranica Landfill (Butler Co.)
11. Blosenski Landfill (Chester Co.)
12. Brodhead Creek (Stroudsburg)
13. Centre County Kepone Site
14. Douglasville Disposal Site
15. Fisher and Porter (Warminster)
16. Havertown PCP Site
17. Heleva Landfill (Lehigh Co.)
18. Kimberton
19. Lackawanna Refuse (Scranton)
20. Malvern TCE Site
21. Metal Banks of America (Philadelphia)
22. Moyers Landfill (Collegeville)
23. Palmerton Zinc Pile
24. Presque Isle
25. Resin Disposal Site (Allegheny Co.)
26. Stanley Kessler (Montgomery Co.)
27. Enterprise Avenue (Philadelphia)
28. Westline (McKean Co)
29. Voortman Farms (Lehigh Co.)
30. Old City of York Landfill
(Seven Valleys)
-------
A-72
VIRGINIA
1. Matthews Electroplating (Roanoke Co.)
2. Chisman Creek (York Co.)
3. U.S. Titanium ( Piney River)
4. Saltville Waste Disposal Ponds (Saltville)
-------
A-73
UEST UIRGINIA
1. West Virginia Ordnance (Point Pleasant)
2. Follansbee Sludge Fill Area (Follansbee)
3. Leetown Pesticide Pile (Leetown)
4. Fike Chemical (Nitro)
-------
A-74
Sites Where Action Is Planned or Underway
FY'83
RAMPS
Old City of York Landfill
Westline
Wildcat
Sand, Gravel & Stone
Limestone Road
Middletown Road
Presque Isle
Heleva Landfill
Douglasville Disposal
Malvern TCE
Kitnberton
Tybouts
Osborne
Delaware City PVC
Delaware Sand & Gravel
U.S. Titanium
West Virginia Ordnance
Army Creek Landfill
Lackawanna Refuse
Witco
Leetown Pesticide
Moyers
Havertown PCP
Blosenski Landfill
Saltville
New Castle Steel
Brodhead Creek
Palmerton Zinc
Tris Spill
RI/FS
Tybouts
McAdoo (Phase 2)
Osborne
Delaware Sand & Gravel
Drake
Harvey & Knott
Leetown Pesticide
WV Ordnance
Havertown PCP
Presque Isle
Army Creek
Sand, Gravel & Stone
Douglasville Disposal
Moyer Landfill
Westline
Blosenski
Lackawanna Refuse
Des ign/Cons true t ion
Bruin Lagoon
Lehigh Electric
Matthews Electroplating
Enforcement Action Underway
Fischer & Porter
Stanley Kessler
Metal Bank of America
Fike (Consent Decree signed 11/82)
Wade
Resins Disposal Site
Non-Federally Funded Actions
Saltville Waste Disposal Ponds
Hranica
Lindane
Lord Shope
Centre County Kepone Site
-------
A-75
PESTICIDE PROBLEMS
Chart A
Section 1 is a bar graphic of the total number of incidents per site investi-
gated by a state in relation to the total of confirmed mis-use incident(s)
as a result of those investigations.
Section 2 is a bar graphic indicating the total number of incidents as
related to the total harm factor. Total harm factor based on Final FY 1982
Cooperative Agreement Program Guidance, PTSED, Headquarters (see attachment).
-------
A-76
CIIAKT A
TYPE
, i .ii-nt i .1 1
ll< >m<>' iWllf-r
Pest Con i i "i
Opera! i < >n
(It IllM lit I. rill
Aqr icul tural
Ground
Appi i cai i "ii
AIM i .1 I
l i cation
ni 1 1 1 i
Non-Ut I'.in
i I. ii' hy
30 40
I
HI i,'(IN III
STAIKS SIMMAKY
Number of Inciflenta by Total *Harm Factor Per Type
ID
40
GO
N.I. - ToMl Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
U.K. - Total Harm Factor
* Harm Factor assigned per type based on Final FY82 Cooperative Agreement Program Guidance, PTSF.D, Headquarters
-------
CHART A
TYPE
!' : . i -I,'Ml i -i I
Homeowner
Commercial
Pest Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
Section 1
Number of Incidents - by Type
10 20 30 40
50
Section 2
Number of Incidents by Total *llarm Factor Per Type
10 20 30 40 50 GO
N.I. - Total Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
II. F. - Total Harm Factor
* Harm Factor assigned per type based on Final FY82 Cooperative Agreement Program Guidance, PTSED, Headquarters
-------
A-78
CHART A
WI.ST VIKCINIA
TYPE
i .. . i.|. nl i i I
Homeowner
Commerr i .\ \
Pest Control
Operat in
ill In-1
Ag_ r_i£ uj_ tural
Grouiul
Application
Acri.il
Application
Other
Non-Ur b.m
Ml
VI
Nl
I
!!
Mi
VI
HI
II!
Section I
Number of Incidents - by Type
10 20 30 40
Section 2
Number of Incidents by Total *Harm Factor Per Type
10 20 30 40 50 60
N.I. - Total Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
II. F. - Total Harm Factor
* Harm Factor assigned per type based on Final FY82 Cooperative Agreement Program Guidance, PTSKI), Headquarters
-------
TYPE
Residential
Homeowner
Commercial
Pest Control
Operation
Other Urban
Agricultural
Ground
Application
Aeria I
Application
Other
Non-Urban
I
Section 1
Number of Incidents - by Type
10 20 30 40
50
Section 2
Number of Incidents by Total *Harm Factor Per Typo
10 20 30 40 50 GO
fj I
IF
11
ii
HI
11
N.I. - Total Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
H.F. - Total Harm Factor
* Harm Factor assigned per type based on Final FY82 Cooperative Agreement Program Guidance, PTSED, Headquarters
-------
A-80
DISTRICT OK CIII.IIMIHA
;m
Agricultural
Ground
A|>|> 1 i ' >' i ' "i
AIM i .1 1
A|i|>l i < at ion
01 ll.'l
Hon-Urban
Nl
VI
Nl
V,
Nl
VI
Nl
VI
Nl
VI
Nl
III'
Number of Incident;; iiy 'I'yi"1
10 20 30 40 50
P
Number o£ Incidents by Total *»arm Factor Per Type
10 20 30 40 50 60
Nih
"EL
Nil 1
"fHIHB
Nih
1
Nl
III
Nl
IIF
Nl
IIF
N.I. - Tot-;il Numlmr of Incident Investigations
V.I. - Number of Confirmed Mis-Use
II. F. - Total ll.irm Factor
* Harm Factor assigned per type based on Final KY82 Cooperative Agreement Program Guidance, PTSED, Headquarters
-------
TYPE
Residential
Homeowner
Commerci a I
Pest Control
Operat ion
Other Urban
Agricultural
Ground
Appl ication
Aerial
Application
Other
Non-Urban
Section 1
Number of Incidents - by Type
10 20 30 40
50
Section 2
Number of Incidents by Total *Harm Factor Per Typo
10 20 30 40 50 GO
N.I. - Total Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
H.F. - Total Harm Factor
* Harm Factor assigned per type based on Final FY02 Cooperative Agreement Program Guidance, PTSED, Headquarters
-------
A-82
CIIAKT A
Section 1
Section 2
VPH
T 1 1 .
KI>S ill i-n t i .1 1
M. .in.- iwner
Comitu' i i .1 1
Pest Control
Ope rat ion
01 II.T l)r li.m
Agricultural
Ground
Appl icat i "ii
Aer inl
Application
01 lli-t
Non-Urban
Number of Incidents - by Type
10 20 30 40 50
NI [ )
vi MB
NI
vr
Nl
VI
NI
VI
3
D
N, [
VI
T
UK
Number of Incidents by Total *Harin Factor Per Type
10 20 30 40 50 GO
.'.'.' -a*
NT
HF
N.I. - Total Number of Incident Investigations
V.I. - Number of Confirmed Mis-Use
H.F. - Total Hiirm Factor
* II,-, rn. Factor assigned per typo based on Finn.I FYH2 Cooperative Agreement Program Guidance, PTSED, Headquarters
-------
A-83
Chart B
Section 1 lists actual numbers of incidents per site investigated by a state
as related to the total number of confirmed pesticide mis-use incident(s),
and the percentage of mis-use by type.
Section 2 again lists actual numbers of incidents. Sections 1 and 2 do not
logically match in that alleged pesticide mis-use incidents reported to a
state and investigated by the concerned state may prove not to be pesticide
related, or an incident may be investigated but a state inspector may be
unable to prove a mis-use due to inconclusive evidence, although harm may
have occurred.
Date
Five (5) States and the District of Columbia voluntarily agreed, prior to FY
1982, to furnish the Regional Pesticide Office information as to date, type,
adverse effects and enforcement action, if any, on all incidents investigated
by the states on a Summary Form devised and adopted for use by the States.
As per the 1982 Enforcement Agreements, States are not committed to any
reporting requirements, except for reporting total numbers on a quarterly
basis. All States have agreed to maintain files on all mis-use
investigations and make the files available for EPA review.
-------
CHART B
A-84
REGION III
STATES SUMMARY
Section I
Section 2
TYPE Number of Incidents - by Type Number of Incidents-by
Number of
Number of Mis-use Confirmed Percent of Total *Total Harm
Incidents by Investigation Mis-use by Type Incidents Factors
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
12 3 7.5
48 20 50.0
17 3 7.5
25 4 10.0
8 6 15.0
16 4 10.0
12 16
33 61
13 26
19 39
8 11
9 12
Total Harm 1
Percent
by Type
9.7
36.9
15.7
23.8
6.7
7.2
TOTAL
126
40
100.0
94
165
100.0
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
Section 1
Section 2
TYPE Number of Incidents - by Type Number of
Number of
Number of Mis-use Confirmed Percent of Total
Incidents by Investigation Mis-use by Type Incidents
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
3 0 0
12 4 57.0
20 0
40 0
2 2 28.6
10 1 14.3
3
12
2
4
2
5
Incidents-by
*Total Harm
Factors
4
22
3
4
2
6
Total Harm
Percent
by Type
9.8
53.7
7.3
9.8
4.8
14.6
TOTAL
33
100%
28
41
100%
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
CHART B
A-86
VIRGINIA
Section 1
Section 2
TYPE Number of Incidents -
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
TOTAL
Number of
Number of Mis-use Confirmed
Incidents by Investigation
2 1
13 7
4 1
17 3
4 3
4 2
44 17
by Type
Percent of
Mis-use by Type
5.9
41.3
5.9
17.6
17.6
11.7
100%
Number of
Total
Incidents
2
6
4
12
4
2
30
Incidents-by
*Total Harm
Factors
3
12
8
29
5
4
61
Total Harm
Percent
by Type
4.9
19.7
12.1
47.6
8.1
6.6
100%
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
CHART B
DISTRICT OF COLUMBIA
TYPE
Section 1
Number of Incidents - by Type
Number of
Number of Mis-use Confirmed Percent of
Incidents by Investigation Mis-use by Type
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
TOTAL
10 0
4 1 100
60 0
TT T 100%
1 2
4 8
2 3
7 T3
Section 2
Number of Incidents-by Total Harm Per Type
Total *Total Harm Percent of Harm
Incidents Factors by Type
15.4
23.1
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
A-88
CHART B
MARYLAND
Section 1
Section 2
TYPE Number of Incidents - by
Number of
Number of Mis-use Confirmed
Incidents by Investigation
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
1 0
12 4
2 1
1 1
0 0
0 0
Type Number of
Percent of Total
Mis-use by Type Incidents
0
66.6
16.7
16.7
0
0
1
5
2
1
0
0
Incidents-by
Total Harm 1
*Total Harm Percent
Factors
2
10
5
3
0
0
by Type
10
50
25
15
0
0
TOTAL
16
100%
20
100%
*Harm Factors assigned per -incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
CHART B
Section 1
Section 2
TYPE Number of Incidents - by Type Number of
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
Number of
Number of Mis-use Confirmed Percent of
Incidents by Investigation Mis-use by Type
21 20
53 60
10 0
20 0
11 20
00 0
Total
Incidents
3
4
1
1
1
0
Incidents-by Total Harm
*Total Harm Percent
Factors by Type
3 15
7 35
5 25
2 10
3 15
0 0
TOTAL
11
100%
10
20
100%
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarter?
-------
A-90
CHART B
WEST VIRGINIA
Section I
Section 2
TYPE Number of Incidents - by Type Number of
Number of
Number of Mis-use Confirmed Percent of
Incidents by Investigation Mis-use by Type
Residential
Homeowner
Commercial Pest.
Control
Operation
Other Urban
Agricultural
Ground
Application
Aerial
Application
Other
Non-Urban
21 25
21 25
21 25
1
1
1 A 25
Fotal
Incidents
2
2
2
1
1
2
Incidents-by
Total Harm Per Type
*Total Harm Percent of Harm
Factors by Type
2
2
2
1
1
_2
20
20
20
10
10
12.
TOTAL
10
100%
10
10
100%
*Harm Factors assigned per incident based on Final FY82 Cooperative Agreement Program Guidance, PTSED,
Headquarters
-------
Table 3:
A-91
List of Suggested Weights for Harm
Resulting from Pesticide Use
A.
Fishkills
Weight
2
5
10
25
50
Harm
A fishkill of less than 200
A fishkill of at least 200
but less than 1,000
A fishkill of at least 1,000
but less than 10,000
A fishkill of at least 10,000
but less than 100,000
A fishkill of more than 100,000
B. Losses of crops, livestock and posessions
Weight Harm
1
2
5
10
25
Animals or plants show symptoms
of pesticide exposure, but
fully recover
A loss valued at less than $500
A loss valued between $500 and
$4,999
A loss valued between $5,000 and
$19,999
A loss valued at $20,000 or more
C. Harm to Human Beings
Weight
1
Harm
Exposure of a child or adult to a
pesticide; no specific harm or
symptoms are observed
Ingestion of pesticide by a child;
no specific symptons are observed
Short-term symptons of pesticide
poisoning (less than 4 hours);
no consultation with M.D. or
hospital visit
-------
Table 3; (Con't)
Weight
4
10
20
35
50
100
A-92
Harm
Symptoms of pesticide poisoning;
consulted M.D. or went to
emergency room. Symptoms
disappear within 4 hours.
Longer term symptoms of pesticide
poisoning (more than 4 hours);
no consultation with M.D. or
hospital visit.
Symptoms of pesticide poisoning;
short term illness of more than
4 hours but no more than two
days. Consulted M.D. or went
to emergency room.
Symptoms of pesticide poisoning;
an illness of more than 2 but
less than 7 days. Consulted
M.D. or went to emergency room.
Symptoms of pesticide poisoning
which persist between 7 and 20
days; consulted M.D. or went to
emergency room.
Symptoms of pesticide poisoning
persist 3 weeks or longer;
consulted physician or went to
emergency room.
Fatality due to pesticide poisining.
D. Contamination of Other Objects
Weight Harm
Minor contamination or food, feed,
or water supply. No subsequent
adverse symptoms in humans or
animals.
Moderate contamination of non-food
items (e.g., furniture, clothing,
etc.), but no subsequent human or
animal exposure resulting in
adverse symptoms.
-------
A-93
able 3: (cont'd)
Weight
5
Harm
Significant contamination of
food, feed or water supply,
but no human or animal exposure
resulting in adverse symptoms.
Extensive contamination of
non-food items, presenting
risk of significant human
exposure, but no observed
harm or symptoms.
If contamination of food, feed
or other object resulted in
human or animal exposure leading
to specific symptoms, assign
harm weights based on nature
of harm (See A-C above)
Unregistered Use of Pesticide
Weight Harm
Unregistered use no observed
harm, symptoms or contamination.
If harm or contamination occurred,
assign harm weight based on
nature of harm (See A-D above)
'. Improper Storage or Disposal
Weight
2
Harm
Improper storage or disposal
no observed harm, symptoms or
contamination.
If specific harm or contamination
occurred, assign weights based
on nature of harm (See A-D above)
-------
Appendix B.
Analyses of Regional Problems
-------
Introduction
Appendix "B" contains a detailed analyses of the problem and probable
solution(s) to the following four Regional problems which were considered to
be significant enough to warrant this in-depth analyses:
a. Violations of ozone standards
b. Surface water pollution by acid mine drainage
c. Non-point source pollution by nutrients and sediments from
agriculture
d. The development of a Regional ground water data base
-------
B-l
VIOLATIONS OF THE OZONE STANDARD
Ozone is the pollutant which is most frequently reported in violation of
primary standards and this occurs over larger geographic areas than any
other pollutant. During 1980 and 1981, the standard was exceeded in New
Castle County, DE, the Distirct of Columbia, Anne Arundel County, Baltimore
county and city, Cecil County, Montgomery County, Harford County, Prince
George's County, Howard County, Maryland, Allegheny County, Lehigh County,
Beaver County, Northampton County, Bucks County, Washington County,
Lancaster County, Lawrence County, Westmoreland County, Berks County,
Philadelphia County, Lackawanna County, and York County in Pennsylvania,
Arlington County, Fairfax County, Hanover County and Henrico County in
Virginia. Extensions for 1987 compliance dates have been granted for
Metropolitan areas surrounding Philadelphia, Baltimore, Pittsburgh,
Allentown, PA, Washington, D.C. and Wilmington, DE. Attainment by 1987 has
been demonstrated for all metropolitan areas except Philadelphia. For
Washington, D.C., it appears that it will be possible to attain the
standard, but the SIP submittal has not been reviewed by EPA at the time of
this writing because the submission is not yet complete.. The Maryland and
Virginia portions were submitted separately, and so do not suffer from this
problem. It appears that the reductions predicted to be necessary by the
model cannot be obtained in Philadelphia without additional control
measures. This problem is compounded by the State of Pennsylvania's failure
to enact a program for inspection and maintenance of motor vehicle controls
which further reduces the available reductions in organic compounds needed
to meet the ozone standards. A lawsuit on this issue and Pennsylvania's
failure to comply with a Federal Court order have resulted in imposition of
sanctions. No plans have been required for the Scranton/Wilkes Barre, PA
area, but recent data indicates that there may be a problem in this area.
Modeling future pollution levels is not an exact science, but the need to
model chemical as well as physical process makes ozone modeling especially
difficult. There is therefore a possibility that the ozone standard may not
be met where it is predicted to be met, in which case sanctions might be
applied under the 1977 Clean Air Act amendments. There is also a
possibility that the standard would be met in Philadelphia in spite of the
modeled conclusion that there will be a shortfall in available controls. An
attempt to further refine this modeling is contained in the northeast
corrider regional modeling project.
Management for Environmental Results therefore consists of the following
actions:
1. Tracking of ozone levels in all non-attainment areas as controls are
implemented to assure that ozone reductions occur which are commensurate
with emission reductions achieved. If any shortfalls are observed in
ambient ozone reductions, any needed replanning should be done prior to
the 1987 attainment deadline (unless that deadline is modified by
Congress). If available, the more sophisticated Airshed and Regional
models should be employed to assess progress.
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B-2
2. The issue of inspection/maintenance in Pennsylvania should be settled by
the State as required by the Court. The matter would then come under
EPA's normal administrative proceedings. In this context, the ozone
levels for Philadelphia and vicinity should be carefully tracked to
check for changes in required reductions which could change the control
requirements. (Note that the Clean Air Act requires I/M as a condition
for an extension to 1987).
Status of Processing 1982 Ozone/CO SIPs
1. Delaware - Full approval.
2. Virginia Portion of Metro DC - Full approval based on draft submittal.
3. District of Columbia - Portions of the D.C. Ozone SIP were submitted in
December, 1982.At~the time of this writing, the submittal is not yet
complete so a detailed review by EPA has not ben completed so no
detailed discussion is included in this document. Due to its similarity
to the Maryland and Virginia SIP's for the National Capitol AQCR, the
reader can obtain the flavor of the SIP by referring to those
discussions.
4. Maryland Portion of Metro DC - Approval of all portions except for
disapproval of the I/M portion.
5. Maryland (Baltimore) - Approval of all portions except for disapproval
of the I/M portion.
6. Pennsylvania:
a. Pittsburgh - Disapproval of I/M and public hearing requirements,
approval of all remaining portions.
b. Allentown-Bethlehem-Easton - same as for Pittsburgh.
Philadelphia - Diapproval of I/M, public hearing requirements
attainment demonstration, stationary source control measures for
100 tons per year sources, and reasonable further progress
portions. Approval of remaining portions of the SIP.
This listing of SIP status is current as of the time of its writing. Where
deficiences are noted, Region III will be working with the State involved to
remedy them. It is therefore possible that some of the deficiency may be
corrected prior to this report being distributed. An attmept will be made
to update this document until its final date of publication, but at some
point in the process it will be necessary to go to print with what is
available. Changes that occur after that time cannot be reflected here.
c.
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B-3
PENNSYLVANIA
Pennsylvania is designated as nonattainment state-wide. Three urbanized
areas, Philadelphia, Pittsburgh, and Allentown-Bethlehem-Easton, received
extensions of the attainment date. This encompasses a 12 county area. The
remainder of the State is either rural or projected for attainment by
December 31, 1982 though later date could add Scranton/Wilkesbarre to
planning areas. For the three urbanized areas, the planning commissions in
each area were designated as the lead transportation/air quality agency,
responsible for development of the transportation portion of the SIP. The
Pennsylvania Department of Environmental Resources (DER) was responsible for
stationary source portions of the SIP, and for providing information and
support to the local agencies. In addition, DER also retained overall
responsibility for 1982 Ozone SIP's. Another requirement for 1982 Ozone
SIP's is the commitment of an I/M program. This program was to have been
implemented in the three urbanized areas where extensions of the attainment
date were granted. The responsibility for this program remains with the
State.
Inspection/Maintenance
All major urban areas that needed an extension beyond 1982 to attain the
standards for 03 or CO were required to include vehicle inspection/
mainteriaee (l/M)'as part of the 1979 SIP revision. The requirements for the
1982 S-IP^fe*isi0s include any elements which remain to complete an
acceptable I/M
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B-4
SOUTHEASTERN PENNSYLVANIA AREA
Demonstration of Attainment/Modeling
The SIP includes valid and adequate input data for the City-Specific EKMA
model in the following categories
1. Mixing height rise (median of '79 - '80 data used for 1981)
2. Transport of Ozone
3. Precursor Transport
4. Post 8 a.m. Emissions (subcounty emission density, including
emission fractions).
5. Reactivity (Default Values)
6. NMHC/NOX Radio (design day average or median value).
Results of the modeling study are summarized in Table 1. The EKMA analysis
for the design day (June 24, 1980) indicates a design value of 0.171 ppm
measured at the Trenton, N.J. site, and a required reduction of VOC
emissions of 44 percent. Since the implementation of all reasonably
available control measures results in a total reduction of 38 per cent by
1987, it is evident that the plan does not demonstrate attainment. EPA
proposed approval of the modeling analysis, but disapproval of the
demonstration of attainment. Negotiations to remedy this problem are in
progress.
Reasonable Further Progress
The State's demonstration of reasonable further progress (RFP) consists of a
graphical presentation of the total VOC emissions for 1978, 1980 and 1987
with no intermediate dates. The RFP curve fails to demonstrate attainment
by December 31, 1987, and fails to indicate the date by which attainment is
anticipated. EPA proposed to disapprove the reasonable further progress
portion of the SIP since it fails to indicate the date by which attainment
is anticipated.
Seventeen major sources of VOC emissions in Philadelphia were identified.
Adequate controls have been implemented in all but four major sources.
These sources are:
Gulf Oil Co. - (barge loading - 700-900 TPY)
Smith-Kline Beckman (Pharmaceutical - 179 TPY)
E. C. Incinerator (municipal - 134 TPY)
N. W. Incinerator (municipal - 140 TPY)
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B-5
Philadelphia's Air Management Services has assured EPA that operating
procedures for the two city incinerators (high temperature operation plus
combustion in secondary chambers) are adequate to provide RACT control of
VOC emissions, and has committed to the study of RACT control measures for
the Gulf Oil Company and Smith-Kline Beckman sources.
For the remaining portion of the AQCR, the State has indicated that three
major sources not covered by CTG's exist. These sources are:
1. BP Oil Co. - (barge loading)
2. Sun Oil Co. - (barge loading)
3. Witco Chemical Co. - (chemicals)
The State is evaluating RACT control on these sources. However, no official
commitments to implement RACT regulations from either AMS or the State have
been received. Therefore, EPA proposed this portion for disapproval pending
official submittal of commitments with schedules for adotpion of RACT for
these sources.
Transportation Control Measures
The Delaware Valley Regional Planning Commission (DVRPC) was the lead agency
in the development of the transportation portion of the Philadelphia SIP.
The Technical Advisory Committee for Transportation, which included
representatives of local governments and transportation agencies in both
Pennsylvania and New Jersey, performed a preliminary analysis of 75
measures, which encompassed all of the reasonably available transportation
measures (RATM) identified in Section 108(f) of the Clean Air Act Of the
original 75 measures, 33 measures (15 in Pennsylvania 18 in ^Jersey)
were analyzed in detail and recommended for approval by the DVRPC B^rd
which subsequently approved the recommended measures for submission to the
State.
The total VOC ^tYel^rs/^I^Br^o Screen" S"
SIP was .de""!?",beoi9f 2 *;«ent of the shortLll in the Pennsylvania
portion^* d nal ^.surefwere reco-ended for further consideration
coments were included in the SIP revision.
Basic Transportation Needs have been adequately addressed i^theJIP, j.^
SSic-'piS^iS-^-p^Sl'^t^r^a throushout the develops
of the transportation control plan.
EPA proposes to approve the transportation portion of the Philadelphia SIP
based on the review above.
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B-6
THE SOUTHWEST PENNSYLVANIA AREA (PITTSBURGH)
The demonstration of attainment for the Southwestern Pennsylvania area
consisted of the use of the City-Specific Empirical Kinetic Modeling
Approach (EKMA), as recommended by EPA.
Ambient air quality data was provided by the Allegheny County Bureau of Air
Pollution Control (BAPC) for Allegheny County and by the Department for the
remainder of the planning region. A list of ozone exceedances for the years
1979, 1980, and 1981, by site, was prepared. The Department examined the
wind data for those days with ozone exceedances to determine those days
which needed to be modeled. The days selected for modeling also modeled if
the wind data indicated stagnant or variable wind conditions.
Data from the upwind sites for the days being modeled were used to determine
the quantity of ozone transported into the urban area. The control
requirement selected for the Southwestern Pennsylvania Regional Planning
Commission region was a 36.7% emission reduction. However these figures did
not conform to guidance from EPA dated December 3, 1981 ("Effects of
Chemistry and Meteorology on Ozone Control Calculations Using Simple
Trajectory Models and the EKMA Procedure"). In this guidance, EPA indicated
that the OZIPP computer model should predict the maximum ozone exceedance
which occurred on the day of interest.
If the predicted ozone exceedance is within + 30%, the EKMA analysis
performed on the computer generated ozone isopleths is acceptable. In the
case which yielded 36.7%, the OZIPP model predicted a maximum ozone level of
0.099 ppm. This figure was not within 30% of the maximum ozone exceedance
measured on July 20, 1979 (0.155 ppm).
Therefore, the Department performed two additional computer simulations. In
the first simulation the value for the maximum height was increased. This
analysis would require a 35.2% emission reduction. In the second
simulation, the value for aloft transported ozone was changed. This
analysis would require a 37.5% emission reduction. In both the 35.2 and
37.5% cases, the OZIPP computer model predicted a maximum ozone exceedance
measured on July 20, 1979 (0.155 ppm).
These numbers (35.2% and 37.5%) do not indicate the error range found in the
model. The EKMA procedure is neither as precise or as accurate as these
variations indicate. In accordance with the EPA mandated EKMA methodology,
either the 35.2% or the 37.5% figure is acceptable. A summary of the data
used in this EKMA anlaysis is contained in Table 2.
In developing the SIP for the Pittsburgh area, the Departent used the lower
reduction requirement (35.2%). A 35.2 percent reduction translates to a
50,665 ton reduction by 1987 (based on the 1980 emission inventory). The
demonstration for the Southwestern Pennsylvania portion demonstrates that
this reduction in emissions will occur, and that attainment will occur by
1987. Expected reductions will amount to 57,452 tons, providing a margin of
5,787 tons by 1987. The methodology used by DER in this EKMA analysts has
been reviewed by EPA and conforms with EPA guidelines.
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B-7
This demonstration of attainment claimed reductions from I/M, which is not
being implemented. If final disapproval action on I/M is taken,
demonstration will be reevaluated to ascertain whether or not the standard
can be attained.
Reasonable Further Progress
Pennsylvania has submitted a graphical demonstration that Reasonable Further
Progress (RFP) will be accomplished. This demonstration for ozone shows
that attainment by 1987 will occur, and shows reductions that are expected
from stationary and mobile sources. Pennsylvania also has new source and
offset requiements which will be adequate to keep VOC emissions growth
within the RFP limitations and to maintain attainment of the NAAQS after
1987.
Pennsylvania's RFP graph showed ozone levels for 1980 and 1987 only, not the
interim years. RFP is supposed to show the incremental reductions for each
year from the base year to 1987. Although the RFP for the Pittsburgh area
did not show the interim years, it was assumed that a linear reduction would
occur, with equal reductions in each year.
The RFP claimed reduction from I/M, which is not being implemented. If I/M
is disapproved, a reevaluation of the RFP will be required to ascertain
whether or not attainment will be achieved.
Transportation Control Measures
The Southwestern Pennsylvania Regional Planning Commission (SPRPC) was
responsible for developing the transportation portion of the 1982 SIP.
SPRPC completed a detailed analysis of all reasonably available measures for
improving air quality. From this analysis, four measures were selected for
implementation: 1. expanded ridesharing program, 2. transit maintenance
program, 3. traffic operations improvements, and 4. a bridge repair
strategy. Any measures not selected were justified because of air quality
impacts, economic impacts, or consideration of acceptability of projects.
In addition, several measures proposed in the 1979 SIP were since rejected.
These rejected measures were also justified. Emission reductions claimed
from these measures are 3,350 tons of hydrocarbons per year. Although
commitments were made by SPRPC to the measures included in the SIP,
commitments from other State and local agencies involved were not
submitted. Therefore, letters of commitment from these other agencies (the
Port Authority Transit of Allegheny County and the Pennsylvania Department
of Transportation) were requested and received. Therefore adequate
commitments to these measures were received. SPRPC has indicated that Basic
Transportation Needs are being provided in the area, and that the ongoing
transit program will continue to provide for these needs.
As indicated above, the Southwestern Pennsylvania transportation portion of
the Pennsylvania Ozone SIP meets EPA's basic criteria for an approvable SIP.
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B-8
Stationary Sources
Requirements for the 1982 SIP's include Reasonably Available Control
Technology (RACT) for (a) all sources of Volatile Organic Compounds (VOC)
covered by a Control Techniques Guideline (CTG), and (b) all remaining major
stationary sources with the potential to emit more than 100 tons of VOC per
year. EPA requires that the submittal either include legally enforceable
measures to implement RACT for these sources, or else document the State's
determination that the existing level of control represents RACT for each of
these sources.
a. CTG Regulations: Pennsylavania has adopted acceptable RACT VOC
regulations for all categories of CTG sources except
Perchlorcethylene Dry Cleaning. The State has also comiitted to
adopt and implement RACT regulations for applicable VOC source
categories after future EPA guidelines are published.
b. Regulations for 100 Ton Per Year Sources: the other requirement of
stationary sources is control of all sources greater than 100 tons
per year that are not covered by a CTG, or a certification that no
such sources exist. For the five counties outside of Allegheny
County, DER has certified that no such sources exist. For
Allegheny County, this certification has not been included. EPA
beleves that such sources do exist in Allegheny County. The County
Bureau of Air Pollution Control has committed to develop a schedule
for study, development, and implementation of RACT regulations for
any such sources.
Proposed Actions: EPA proposes to disapprove the stationary source
control portion of the SIP because RACT regulations have not been
included for all 100 ton per year VOC sources in Allegheny County.
However, since the County is submitting a commitment with a
schedule to develop RACT regulations if needed, EPA will not take
final action on this until information is submitted by the County.
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B-9
THE ALLENTOWN-BETHLEHEM-EASTON AREA
Pennsylvania's SIP provides for bringing Lehigh and Northampton Counties
into attainment with the 63 standard by 1987. Attainment will be achieved
by substantially reducing volatile organic compound (VOC) emissions. The
SIP contains a mix of stationary and mobile source strategies that are
expected to bring about the necessary reductions. The SIP's main provisions
are discussed below.
Demonstration of Attainment/Modeling
Pennsylvania's SIP includes a demonstration that the Lehigh/Northampton area
will attain the 03 standard by 1987. EPA has reviewed this demonstration
and has found it acceptable. The demonstration consists of a determination
of the 1987 emission level consistent with attainment and a showing that
1987 emissions will be below that level.
Pennsylvania used the EPA recommended Empirical Kinetic Modeling Approach
(EKMA) to determine the emission level consistent with attainment. Using
this model, Pennsylvania determined that the 1980 VOC emission level of
23,935 tons per year must be reduced by 27.5% to 17,353 tons per year to
bring about attainment.
Reasonable Further Progress
Pennsylvania has submitted a graphical demonstration that reasonable further
progress (RFP) will be accomplished. This demonstration shows that
attainment by 1987 will occur, and shows reductions that are expected from
stationary and mobile sources. Pennsylvania also has new source and offset
requirements which will be adequate to remain within the RFP limitations and
to maintain attainment of the NAAQS after 1987. In another section of this
notice, disapproval of the I/M program is discussed. Any action on I/M may
affect the RFP demonstration.
Transportation Control Measures
The Joint Planning Commission (JPC) of Lehigh and Northampton Counties was
responsible for developing the transportation portion of the 1982 SIP. The
JPC completed a detailed analysis of all reasonably available measures for
improving air quality. The JPC chose transportation measures including
traffic flow improvements, intersection improvements, corridor improvements,
replacing all-way stop signs with a minimum number of signs, and permitting
right turn on red for inclusion in its plan for reducing pollution from
mobile sources. The JPC estimates the average annual reduction in VOC
emissions due to the measures as 2.0 tons per year.
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B-10
Proposed Actions
Based on the review discussed above, EPA proposed the disapproval* of the
following portions of Pennsylvania's 1982 Ozone SIP:
1. The Public Hearing for the entire SIP
2. The Inspection/Maintenance Program (Statewide)
3. Portions of the Plan for the Southeastern Pennsylvania area,
specifically:
a. Demonstration of Attainment/Modeling
b. Reasonable Further Progress
c. Stationary Source Control Strategy
4. The stationary source portion of the plan for the Southwestern
Pennsylvania area.
* There is an ongoing effort with Pennsylvania to remedy the deficienceis
noted above. This could result in approval of portions of the SIP which are
listed for disapproval in this document.
EPA is proposing the approval of the following portions of the Pennsylvania
Ozone SIP:
1. Portions of the Plan for the Southeastern Pennsylvania area,
including:
a. Emission Inventory
b. Transportation Control Strategy
c. Additional Requirements
2. Portions of the Plan for the Southwestern Pennsylvania area
including:
a. Emissions Inventory
b. Demonstration of Attainment/Modeling
c. Reasonable Further Progress
d. Transportation Control Strategy
e. Additional Requirements
3. The entire ozone plan for the Allentown-Bethlehem-Easton area
(except for I/M and the public hearing as mentioned above).
EPA is not planning to take action at this time on the Perchloroethylene Dry
Cleaning regulations.
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MARYLAND
Metropolitan Baltimore AQCR
(1) Modeling/Demonstration of Attainment
Maryland's process to develop control procedures was babed c,a UK: revised
ozone standard (0.12 ppm, with expected exceedances being les, than or equal
to one). Maryland used an alternative of the city-specxfir. Empirical
Kinetic Modeling Approach (EKMA) technique, allowed by EPA document.
EPA-450/4-80-27, Guidelines for Use of City-Specific EKMA in Preparing Ozone
SIPs (Guidelines). This alternative procedure peraita uiotUiinfe based on a
statistically-determined design day or set of meteorological classes or
conditions.
(2) Site Day Selection
In order to determine the percentage in Reactive VolafciLs l»AK:miv. Compounds
(RVOC) emissions needed to meet the NAAQS for Ozoiies the Slate used a peak
ozone value determined to be the average value which occulted ou the days
described by a particular category. The State modeled each day with an
exceedance of the ozone standard rather than each modeling site, The State
selected the key day of July 17, 1980 where 0.183 ppm was ter.ordod at Ft.
Meade.
(3) Input Parameters to Model
(EKMA) which is the EPA recommended model, is a generally available model
with modest data requirements that considers local meteorological intluences
and atmospheric chemistry in evaluating control requirements. Max-land,
however, used a modification of the basic EPA approach^
The City-Specific EKMA model is a computer program created by EPA to
simulate the production of ozone by the complex chemical r&aetious which
take place between VOC and NOX. The program solves a simultaneous
chemical reaction equation based on factors which as emission patterns,
meteorological patterns, and the VOC/NOX concentration ratios for a given
specific area. Maryland also used the Ozone Isopleth Plotting Package
(OZIPP) which, when coupled with EKMA, enables the model to perform
simulation for different combinations of non-methane hydrocarbons (NMHC) and
concentrations. The ratio used by Maryland is 8=26:1.
The State of Maryland then developed a statistical methodology for the
development of a number of "design days" on which to base its control
estimates. The State used ten years of meteorological data to determine the
occurrence of types of days on which meteorological conditions were most
conducive to the formation of ozone. The State then compared the results
using this method with those derived by the use of other EPA methods.
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B-12
The parameters used in the EKMA methodology were dilution time, initial
precursor concentrations, temporal emission factors, and mixing height. Of
these parameters, the most sensitive factors were found to be the initial
concentration levels of reactive volatile organic compounds (RVOC) and the
range between initial and final mixing heights. The State then performed a
regression analysis to compare initial RVOC concentration levels against
wind speed conditions generated at the Baltimore-Washington International
Airport. The analysis revealed a correlation coefficient of 0.65 and 0.68
for the regression equations.
The State also analyzed the effect of transport on peak ozone concentrations
in Baltimore and determined that it could have a significant effect on the
resulting concentrations. Following the EPA guideline procedures for
determining background levels of ozone, the State considered a 0.05 ppm
ozone level to be a representative background value for the AQCR.
Demonstration of Attainment
The Maryland SIP for Baltimore requires a VOC reduction from 319 tons per
day in 1980 to 166 tons per day in 1987. The emission changes are to occur
as follows:
Emission Levels (Tons/Day)
Source 1980 1987
Stationary Sources 125 62
Mobile Sources (including I/M) 136 45
Area Sources 58 59
319 166
The State then performed a Level II analysis of EKMA, a more detailed
analysis than what EPA requires. The State concluded that the Level II
analysis more adequately represented the prevailing wind patters in
Baltimore and the EPA-recommended straight line trajectory was not
compatible with the gridded emissions inventory available for the region.
The State explains that the emission densities are not uniform in the
regions. Hence, Maryland employed the more sophisticated West wind field
model. Maryland also used a solar radiation factor oased upon Baltimore's
latitude and longitude.
This model was run for a number of high ozone days during the ozone season.
The results were used to compute emission fractions typical of the
Metropolitan Baltimore AQCR between 8:00 a.m. and 4:00 p.m. LST (Local
Standard Time).
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B-13
Model Results
Using parameters such as mixing height ranges that were representative of
peak ozone days, a 20% growth in NOX emissions between 1980 and 1987, and
a NMHC/NOX ratio of 8.26 to 1, the State determined that a 48% reduction
in VOC emission is needed to attain the NAAQS for Ozone by 1987. The State
had looked at data collected between 1978 and 1980. This result agrees
closely with a control requirement of 49% derived when only one year (1980)
was modeled and the second highest control requirement was determined.
EPA considers Maryland's modeling analysis to be adequate, since the results
validate favorably with EPA's recommended modeling protocol. While every
segment of Maryland's procedure does not necessarily agree with the EPA
guidelines, the Agency accepts Maryland's approach.
The State then determined that the 319 tons per day, assuming normal growth
patterns, would increase to 345 tons per day without any controls designed
to curtail emissions. The State then listed the control strategies that
would reduce VOC emission to the 166 tons/day target level by 1987:
Control Strategy Potential Reduction
1. Federal Motor Vehicle Control 99 tons/day
Program (FMVCP)
2. Inspection and Maintenace (I/M) 14 tons/day
Program
3. Transportation Control Plan (TCP) 3 tons/day
4. Stationary Source Control Measures 63 tons/day
179 tons/day
The State estimates that its currently-adopted stationary source control
regulation accounts for 54 tons/day. Therefore, the State determined that
it will be required to adopt additional stationary source control measures
designed to reduce VOC emissions by an additional 9 tons/day.
Reasonable Further Progress (RFP)
Maryland's 1982 SIP indicates that a 48% reduction of 1980 VOC levels will
be needed to attain the Federal Ozone Standard by 1987. This projection
includes an allowance for growth in several categories: 1) growth based on
projected estimates for future employment, housing and population in the
region to be used for planning purposes; 2) future aircraft activity; and
3) completion of a major new power plant (BG&E - Brandon Shores) in Anne
Arundel County. The projected inventories do not reflect any other growth
in either new or existing industrial sources. However, the
currently-approved Maryland SIP contains a new source review regulation
which contains an offset provision for any new source to be constructed in a
nonattainment area.
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B--14
The State's RFP tracking process for VOC will consist of annual reports to
EPA (required by the Clean Air Act) and \ipdated emissions inventory reports
for stationary and area sources. The Regional Planning Council (RFC), in
conjunction with the State, will track the RFP for mobile sources. The
mobile source reductions assume a July 1, 1983 date for implementing the
mandatory I/M program.
Siationary Source Control Measures
The State of Maryland has determined that stationary source control measures
will contribute 63 tons/day of the overall emission reductions needed to
attain the 03 standard by December 31, 1987. The State estimates that
Round 1 and Round II CTG regulations that are included in the approved »J1P
as well as the State's Photochemically Reactive Organic Solvents (PROS) and
Photochemically Reactive Organic Materials (PROM) regulations will account
for emissions reductions of 54 tons/day by 1987. Therefore, the State will
be required to develop, adopt, and submit additional stationary source
control. The Clean Air Act requires States to adopt regulations requiring
Reasonably Available Control technology (RACT). Therfore, as part of the
1982 submittal, States must include RACT for: (a) all sources of VOC's
covered by a Control Technqiues Guideline (CTG) published by EPA and (b) all
remaining major stationary sources with the potential to emit more than 100
tons of VOC per year.
Current. EPA policy issued August 11, 1982, allows the State to submit
schedules in lieu of adopted regulations as long as the schedules call for
adoption and implementation dates for the necessary control measures within
a time frame so as not to impede reasonable further progress towards
attainment.
The Maryland SIP contains no new adopted regulations designed to make up the
nine ton/day shortfall by 1987. However, the State has submitted a schedule
by which it will develop the regulations.
Transportation Measures
The RPC Plan consists of the following nine measures:
(1) Ridesharing - This measure consists of carpooling and vanpooling.
(2) Park and Ride/Park and Pool Lots - This measure consists of
providing parking spaces for commuters who transfer to public
transit or carpools.
(3) Bus and Rail Transportation - RPC's analysis shows that ridership
on the Baltimore Mass Transit Administration (MTA) has increased
over the past few years, and with the opening of the METRO in 1983,
will continue to increase between 1982 and 1987.
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B-15
(4) Traffic Flow Improvements - These improvements include, but are not
limited to, traffic signal and intersection modifications, parking
changes, and road and maintenance repairs.
(5) Employer-Based Programs - These programs include actions taken at
the employment site that encourage employees to rideshare, use
transit, or take other non-auto forms of commuting.
(6) Parking Management - Parking Management encompasses a range of
actions that alter the price, number or location of parking spaces.
Inspection and Maintenance (l/M)
All major urban areas that needed an extension beyond 1982 to attain a
standard for 03 or CO were required to include vehicle I/M as a portion of
the 1979 SIP revision. EPA evaluated and acted on the I/M portion of the
Maryland 1979 revision on August 12, 1980.
The State has submitted the following elements to satisfy requirements for
the 1982 SIP revision.
a. Public awareness plan
b. Mechanics training plan
c. Proposed emissions standards showing emission reductions based on a
program beginning in 1984.
The State has not submitted the remaining elements of an I/M program to
satisfy requirements for the 1982 SIP revision:
1. Inspection Test Procedures
2. Inspection Station Licensing Requirements
3. Emission Analyzer Specifications
4. Recordkeeping and Records Submittal Requirements
5. Quality Control Audit and Surveillance Procedures
6. RACT Compliance
Therefore, EPA is proposing disapproval of the State's I/M program since the
SIP contains no va.lid schedule and since the SIP contains no information on
most of the elements of the I/M program. Also, current EPA policy, as
published on January 22, 1981, does not permit a State to begin the
mandatory phase of any centralized I/M program after January 1, 1983, even
if emission standards are developed that are stringent enough to produce the
same emission reduction in less time.
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B-16
DISTRICT OF COLUMBIA (MARYLAND PORTION)
Demonstration of Attainment/Modeling
EPA has recommended and COG has used the city-specific Empirical Kinetic
Modeling Approach (EKMA) for evaluating achievement of the Ozone Standard.
The five days with the highest Ozone concentration within the past three
years at each Ozone monitor site in the region were considered for modeling.
Isopleth diagrams were created for each Ozone exceedance day as determined
from analysis of regional monitored data, and, for each Ozone exceedance, an
emission reduction requirement was calculated based upon the isopleth
diagram. After analysis of all isopleth diagrams, it was determined, based
on a 0.16 ppm Ozone value recorded at the Takoma Park monitoring site in
Washington, D.C. on July 16, 1980, that a VOC reduction of 46% from 1980
levels would achieve attainment of the 0.12 ppm Ozone Standard. This
translates into a VOC reduction of 157 tons/day from the 1980 total (342
tons). Since present estimates indicate that the region will reduce VOC
emissions by 118 tons/day by 1987 (from 342 to 224 tons), an additional
reduction of 39 tons/day is required to attain the current standard.
This 39 TPD reduction is a regional figure and the entities involved agreed
to equitably distribute a tons per day reduction target to each entity,
namely, Virginia, Maryland, and the District of Columbia. Because each
State's proportional contribution to the 1980 and 1987 inventories was
slightly different (due mostly to differential population growth), the COG
committees adopted a format setting ranges of emission reductions by State.
These VOC reductions were: Maryland, 14 TPD, D.C., 10 TPD, and Virginia, 16
TPD.
The Maryland plan clearly demonstrates a 7.5 TPD reduction and contains a
commitment to study and evaluate a mix of additional control measures,
including Stage II Vapor Recovery, in order to achieve an additional 6.5 TPD
reduction. This study will be completed by July 1, 1983.
Reasonable Further Progress
Maryland has submitted an adequate Reasonable Further Progress (RFP)
presentation and discussion in their SIP. Although the RFP curve does not
demonstrate attainment of the Ozone Standard by December 31, 1987, i.e., a
6.5 tons per day shortfall, Maryland has committed to study and implement
additional control measures in order to eliminate this shortfall and attain
the standard by December 31, 1987. Maryland has also certified that its
existing new source review and offset requirements will be adequate to allow
growth while remaining within the RFP limitation and to maintain attainment
of the Ozone Standard after 1987. However, the Marylnd RFP schedule, and
EPA's proposed action of same, assumes implementation of the State s
inspection and maintenance (I/M) program by July 1, 1983. Should Maryland
delay its implementation of the I/M program, it will be required to submit
to EPA a revised RFP schedule.
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B-17
Transportation Control Measures (TCMs)
In developing a regional transportation control plan as part of the overall
control strategy, COG examined the feasibility of applying the 18 categories
of measures listed in Section 108(f) of the Act and considered to be
"reasonably available." COG considered fifteen of these 18 categories to be
feasible for implementation in the National Capital AQCR. The COG then
considered 50 specific measures derived from these categories for inclusion
into the SIP. The State of Maryland has participated in analyzing the
relative effectiveness of these control measures. The State, in conjunction
with the District of Columbia, Virginia, and COG, analyzed the benefits
(regional emission reductions in tons per day, total energy savings in
gallons per weekday, and additional benefits which encompass other than air
quality goals). The State also analyzed the costs (capital, operating,
maintenance, other) associated with each prospective measure.
As a result of this analysis, COG has developed for inclusion in the
Maryland SIP the following transportation control measures that are designed
to reduce VOC emissions in the Maryland portion of the National Capital AQCR:
1. METRO
2. Parking Restrictions in District of Columbia CBC
3. Bicycle Improvements
4. Transportation System Management Improvements
5. Ride sharing Improvements
These measures, when fully implemented, are designed to reduce VOC emissions
in Maryland by 7.5 tons/day.
The COG transportation plan also identifies a recent study conducted by the
Urban Mass Transit Administration and Washington Metropolitan Area Transit
Authority (WMATA) that addresses basic transportation needs. Since the
completion of this study, WMATA and the local and State jurisdictions have
been implementing programs to expand and improve public transportation.
Inspection and Maintenance (I/M)
According to the currently approved Maryland SIP the State is to begin
implemenLtion of its inspection and maintenance (I/M) program by January 1,
1983. However, the State's 1982 SIP contains a statement that the
^rrently'pproved I/M schedule is invalid and that the I/M sta rt-up ^
is to be no earlier than 1984. No new schedule was submitted with this SIP
revision to replace the current schedule.
EPA is proposing disapproval of the State's I/M program since the SIP
contains no vaUd scheLle and since the SIP contains no information on most
emissions reduction in less time.
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B-18
VIRGINIA FORT ION OF THE NATIONAL CAPITAL
AIR QUALITY CONTROL REGION
Demon ft C .;
EPA ha-* xcccaaiatided and COG has used the city-specific Empirical Kinetic
Modeling Ippw.Gh n ViibmJited by Virginia contains a schedule under which the
f ,,., ;j>: nrrO.uate a mis of additional control measures and
;,,, . - ,, "'':..>-,?: 5.n o^rder to achieve the 6.1 tons per day shortfall.
A, .' . r ,.. c lAin Dc^edule. Virginia will complete the analysis of measures
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B-19
by July 1, 1985. Regulations, required to achieve the 6.1 tons per day
reduction, will be developed and promulgated by July 1, 1986. These
additional regulations will be designed to have full effect in time to
ensure attainment of the Ozone Standard by the 1987 deadline. EPA believes
this schedule is as expeditious as practicable and that reasonable further
progress toward attainment will be maintained.
Inspection and Maintenance (l/M)
On July 13, 1981, the Commonwealth submitted the l/M Administrative and
Procedural Regulations and on August 10, 1981, the Commonwealth submitted
the Mobile Source Emission Standard. These SIP revisions were reviewed and
approved by EPA on April 6, 1982. Although the Commonwealth has had a
viable, effective I/M program functioning since December 1981, certain
elements of the I/M program were not included in the previous submittals.
These elements are:
a. Under Recordkeeping and Record Submittal Requirements: Adequate
description of the inspection data that will be collected and reported
to EPA.
b. Under Quality Control, Audit & Surveillance Requirements: Description of
procedures to be followed by the State in conducting unannounced
unscheduled audits.
c. Submittal of a Pubic Awareness Plan.
These elements have now been submitted by the Commonwealth as part of the
SIP submittal for parallel processing by EPA. EPA has reviewed this
material and finds it satisfies EPA1s requirements for an acceptable I/M
program.
As EPA stated in its earlier rulemaking approving Virginia's I/M program, we
preliminarily determined that the program provides for the 35% reduction of
1987 emissions as well as a 20% failure rate, however, Virginia must submit
a complete analysis of its I/M program. This analysis must be submitted
after one full year's operation of the program, using Virginia-specific data
and 1980 census information. This analysis must be submitted in order for
EPA to finalize its determination of the overall effectivenss of Virginia's
I/M program.
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B-20
SURFACE WATER POLLUTION BY ACID MINE DRAINAGE
1. Description of Problem
. Sources: Active and abandoned deep and surface coal mines. However it
is estimated that at least 75% of the problem originates from aban-
doned mines.
. Impaired Uses: Aquatic life, industrial, domestic water supply.
. Method of Impairment: Abnormal pH and iron levels can be lethal to
fish, eliminate aquatic communities, and severely limit domestic and
industrial water use. Sediment eliminates the food sources and des-
troys reproductive habitat of fish.
. Regional Significance: By far the most devastating Regional problem in
terms of miles of impaired uses. 49% of impaired streams in Region
are due to mining (over 3000 miles).
. Trends: While more stringent effluent requirements (BPT & BAT) have im-
proved the quality of discharges from active mines, mine drainage
from abandoned mines has proven much more difficult to control. In
particular, there is increasing evidence that despite the use of
State-of-the-art technology for reclamation, acid mine drainage will
eventually develop in sulfur bearing areas. In-stream dredging of
coal fines constitutes an emerging problem.
. Affected Priority Water Bodies: Cheat River (WV), Mahanoy Creek (PA)*.
. Documentation: Problem has been thoroughly studied for the last 15
years.
. Treatability: For abandoned deep mines, control of drainage has been
difficult (see 'Barriers to Solutions' below).
2. Barriers to Solutions
. Lack of Technology: Mine sealing and mine flooding of abandoned deep
mines have met with minimal success to date. In addition,
reclamation of surface mines has sometimes proven to be only
temporarily effective in the control of mine drainage problems.
, Lack of Funding: Surface Mine Control and Reclamation Act provides for
some monies however, mitigation of water quality impacts receive
relatively low priority in this program.
. Legal: Legal responsibility for clean-up of abandoned mine discharges
has often been difficult to establish. In addition, there currently
are no regulations to control in-stream dredging activities.
Low pH levels are responsible for corrosion of public water supply system,
resulting in exceedance of Maximum Contaminant Levels for lead in drinking
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B-21
Existing Programs:
There are various federal/state programs which attempt to minimize the
environmental problems related to coal mine drainage. These programs
include:
. NPDES; The NPDES program regulates the quality of discharge waters eman-
ating from active mines. Existing mines are required to achieve Best
Practicable Treatment (BPT), which appears to be adequate for the
protection of water uses in most cases. New mining operations must
meet new source effluent standards which are slightly more stringent
than BPT. Prior to EPA issuance of new source NPDES permits, overall
assessments of environmental consequences must also be performed in
accordance with the National Environmental Policy Act (NEPA).
However, all States in Region III have been delegated NPDES authority
and are not required to provide NEPA reviews prior to permit
issuances. It is uncertain how environmental conditions are
considered by the State in determining NPDES permit conditions.
Therefore, Region III is presently developing a strategy for
oversight of NPDES permits for mining. Part of this effort should
include an assessment of existing State procedures in issuing new
source mining permits.
. Surface Mine Control and Reclamation Act (PL95-87) (Title V only):
Title V of the Surface Mine Control and Reclamation Act (SMCRA) re-
quires pre-mine planning to be conducted, subject to approval by OSM
or the designated state authority. The plan sets forth the coal min-
ing and site reclamation plans of the operator. In review of this
plan, environmental considerations are critical for approval. Opera-
tors are required to be bonded so that reclamation of the site after
mining is ensured. Section 522 of Title V also allows for the desig-
nation of areas which are unsuitable for coal mining.
It is uncertain that Title V is adequate in assuring that water
quality considerations are properly addressed for both new source
mining operations and future closures of existing mines. Therefore,
an assessment of existing OSM/State procedures in this regard should
be conducted to ensure that water quality considerations are properly
addressed. This should be accomplished through the development of
the Regional mining strategy.
Surface Min* Control and Reclamation Act (Title IV only): Title IV of
The SMCRA provides for reclamation of abandoned mine lands. However,
the SMCRA and pursuant regulations place a low priority on water
quality problems. That is, Section 403 of the SMCRA places the
priorities for funding as:
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B-22
(1) the protection of public health, safety, general welfare, and
property from extreme danger of adverse effects of coal mining
practices;
(2) the protection of public health, safety, and general welfare from
adverse effects of coal mining operations;
(3) the restoration of land and water resources and the environment
previously degraded by adverse effects of coal mining practices
including measures for the conservation and development of soil,
water (excluding channelization), woodland, fish and wildlife,
recreation resources, and agricultural productivity;
(4)
(5)
\(t)
Based on the above, the Office of Surface Mining has required that all
priority 1 and 2 problems be abated before priority 3 problems are
considered unless clean-up of a priority 3 problem is coincidental with
clean-up of a priority 1 or 2 problem. Mining related water quality
problems rarely threaten public health, safety, and general welfare.
Therefore, water quality problems are generally considered priority 3.
Due to the relatively long history of coal mining east of the Mississ-
ippi as compared to the western States, a large majority of the aban-
doned mine sites reside in the eastern States. Nationally, it is esti-
mated that a total of $3 billion will be collected throughout the reg-
ulatory life of the SMCRA. However, it is estimated that nationally $30
billion may be needed to reclaim all abandoned mine problems for
priorities 1 through 6. Furthermore it is estimated that $12 billion is
needed to reclaim all abandoned mine lands in PA alone. Surely the SMCRA
will not provide adequate funding to reclaim all abandoned mine lands,
particularly in the east. At this time the cost for priority 1 through 3
problems is not known, however, it is projected that few reclamation
grants will be awarded under SMCRA to abate water pollution in the States
of Virginia, Pennsylvania, and West Virginia. That is, generally only
priority 1 and 2 projects are anticipated to be funded in these States.
It is significant to note that, although existing OSM Policy will not
allow funding of many priority 3 mines related problems, a legal opinion
provided by E.H. Bonekemper, III (D.O.I. Assistant Solicitor) suggests
that priority 3's may be funded as long as the overall funding picture is
compatible with the SMCRA. Therefore, EPA should work to assure that this
flexibility allowed by SMCRA is exercised in OSM Policy.
State funded mine reclamation projects which are targeted towards im-
proved water quality exist in the Region. However, these programs his-
torically have been severely underfunded. Therefore, it appears that, if
the abandoned mine drainage problems in Region III are to be abated, some
modifications in OSM Policy will be required.
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B-23
4. Management Recommendation:
. States:
1. Identify stream segments which may be particularly sensitive to
new source coal mining similar to the mining areawide assessments
developed in West Virginia. Take special precautions in mine
planning to minimize impacts on these streams. In some cases it
may be necessary to deny a new source mining permit. Also,
implement Region III mining strategy. (target date: FY 84,
Responsible party: PA DER, Bureau of Water Quality, WV Division
of Water Resources, and Va. State Water Control Board, MD Office
of Environmental Programs).
2. In the next revision to the State 305(b) report, special
consideration should be given towards highlighting the extent of
the water quality problems relating to mine drainage. The
'visibility1 afforded by this effort could be instrumental in
achieving progress in developing programs to abate this difficult
and costly water pollution problem.
. EPA Region III:
1. Obtain agreement with pertinent States in the FY 84 SEA to
identify sensitive streams as described above. (Target date:
9/83, Responsible Party: State Branches, Water Division).
2. Finalize Strategy for NPDES mine permitting. (Target date: 6/83,
Responsible Party: Permits Branch, Water Division).
3. Obtain agreement with pertinent States in FY 84 SEA to implement
NPDES mine permit strategy. (Target date: 9/83, Responsible
Party: State Branches, Water Division).
4. Implement NPDES mine permit strategy. (Target date: FY 84, Re-
sponsible Party: Permits Branch, Water Division).
EPA HQ:
1. Establish a national work group to assess regulatory difficulties
of abandoned mine reclamation for control of water pollution and
make recommendations. (Target date: Initiate in FY 83).
Activities for this work group are:
. Provide recommendations for research on developing technology
to reduce drainage from abandoned surface mines, particular
research on overburden analyses and handling.
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B-24
. Finalize an interagency agreement between EPA and OSM on im-
plementation of the Surface Mine control and Reclamation Act.
. Develop guidelines or regulations to address in stream dredg-
ing of coal mines.
. Consider recommendations for modification of the SMCRA so
that water quality considerations may be adequately addressed.
. Consider methods to provide for bonding of mine operators to
ensure perpetual care of mine closures.
5.. Anticipated Results
The benefits anticipated in implementing the management alternatives are
threefold: 1) prevent further surface water degradation from future
mining operations utilizing existing laws and procedures, 2) fully
document and highlight the extent of mine drainage related water quality
problems and 3) develop technological, regulatory and financial means of
correcting water quality problems from existing abandoned mines.
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B-25
NON-POINT SOURCE POLLUTION BY NUTRIENTS
AND SEDIMENTS FROM AGRICULTURE
1. Description of Problem
. Source: Non-point source runoff of animal waste, fertilizer and sediment
from farmland activities, including cropland, pastureland, and feed-
lots. Primary pollutants of concern are various forms of nitrogen,
phosphorus and sediment.
. Impaired Uses: Aquatic life, domestic water supply, recreation, aesthet-
ics.
. Method of Impairment: Nitrogen and phosphorus promote excessive growths
of algae, particularly in lakes and estuarine systems. Algae can
cause large drops in dissolved oxygen (through respiration) which can
be lethal to fish, impart an offensive taste and odor to domestic
water supplies, impair boating and swimming and create aesthetically
offensive conditions. Algae have also been linked to infections in
humans through water contact recreation causing gastrointestinal,
respiratory and dermatalogical symptoms. Sediments, in addition to
transporting nutrients from farmland, reduce reservoir capacities,
degrade aquatic communities and increase water treatment costs.
Specific use impairments of the Chesapeake Bay that may be linked to
high nutrient levels are declines in 1) fresh water spawning fish
populations, 2) oyster spats and 3) submerged aquatic vegetation
(SAV).
. Regional Significance: Often both agricultural non-point source and mu-
nicipal point source nutrient loadings contribute to this problem,
which accounts for 14% of the impaired stream miles (over 1000) and
almost all of the impaired lakes and reservoirs in the Region (100
identified at this time). Data on streams impacted solely from sedi-
mentation in Region III is incomplete.
. Trends: Regionally, nutrient loadings from agricultural runoff have gone
generally uncontrolled. With the discontinuation of the 208 and
Clean Lakes programs, little improvement in this problem is
anticipated.
. Regional Priority Waterbodies: Upper Chesapeake Bay (MD), Lake Chesdin
(VA), Pymatuning Reservoir (PA) and Loch Raven Reservoir (MD).
. Documentation: For priority waterbodies, sources and effects of nutri-
ents have been well documented. However, in most cases, precise
determinations of nutrient cause/effect relationships are still
needed. Sedimentation problems are currently documented for only
Pennsylvania and Maryland.
. Treatability: Technologically, several practices have been demonstrated
to be effective in substantially reducing sediment/nutrient loads
carried by agricultural runoff. However, implementation of these
practices has been minimal.
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B-26
TABLE 1 - Non-ACP Implementation Funding
Area
Use Impacts NFS Loads
Source Amount
Federal Funding Necessary
Lock Raven
Reservoir,
MD
South Rivanna
Reservoir, VA
Chowan River,
VA
Conestoga
River Basin,
Appoquinimink,
DE
Double Pipe
Creek, MD
Nansetnond-
Chuckatuck
Basin, VA
. domestic
water supply
. recreation
. 34.3% of total P
NPS loads are from
controllable agricul-
. aquatic life tural sources (P is
limiting nutrinet)
. domestic
water supply
. aquatic life
. commercial
fishing
. swimming
. recreation
. domestic
water supply
. swimming
. aquatic life
98.9% N
91% P
. 32.5% P and 47.6% N
from agriculture
. currently
under study
. aquatic life . 100% N
. recreation . 80% P
. domestic
water supply
. currently
under study
. shellfishing . currently
. sport fishing under study
. swimming
. recreation
.' domestic
water supply
. aquatic life
Clean approx.
Lakes $ 760,000
Program
Clean approx.
Lakes $ 400,000
Program
Section $ 13,000
208
Program*
RCWP $1,448,000
RCWP $ 719,200
RCWP $2,892,478
RCWP $1,476,000
$3,000,000 (assuming 50%
match) to address critical
problems only.
($9,000,000 to address all
identified needs)
$1,200,000 (assuming 50%
match
Currently under study.
^Funded as a pilot demonstration project.
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B-27
2. Barriers to Solutions
. Lack of Incentives: Agricultural runoff controls (Best Management Prac-
tice) are applied on a voluntary basis and require substantial
financial investment by the farmer. To date, farmers generally have
not been convinced that this investment is in their best financial
interest. The more expensive BMPs (such as animal waste systems) are
usually implemented only when either Federal or State cost sharing
programs are available.
3. Existing Programs
Federal cost-share programs have provided the majority of BMP implem-
tation monies to date (approximately 75% federal, 25% landowner). BMP's
may be divided into the following categories:
1. Fertilizer management
2. Tillage practices
3. Non-structural runoff controls
4. Structural runoff controls
5. Animal waste management
The high cost of some structural runoff controls and animal waste
facilities limits their use to those areas where impacts are critical.
Non-structural practices are less costly but yield benefits primarily
where implemented on a large scale. Unfortunately, there are hidden
costs associated with some BMPs. For instance, conservation tillage
practices are usually accompanied by increased herbicide use, while
runoff controls increase the infiltration of nutrients and herbicides
into groundwater. On the other hand, many practices have direct
economic benefits to farmers in that conservation of topsoil and
reductions in commerical fertilizer useage save money in the long run.
It is generally acknowledged that federal cost-sharing is the major
incentive for a farmer to invest in controls, and that without future
cost-sharing, BMP implementation would be minimal. Federal funds for
this purpose have come from the following: Rural Clean Water Program
(USDA), Clean Lakes Program (EPA), Section 208 Program (EPA) and
Agricultural Conservation Program (USDA). In the former three cases,
all projects have been accompanied by water quality planning and
monitoring to assess the cost-effectiveness of BMPs. Projects funded
through these programs in Region III are summarized in Table 1.
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B-28
Several projects in the Region have received monies through the Clean Lakes
Program for water quality assessments and development of pollution abatement
plans, but have received no implementation monies to date. These projects
include Lake Chesdin, VA and Lake Wallenpaupak, PA. As noted in Table 1, some
implementation monies have been granted to Loch Raven Reservoir, MD, South
Rivanna Reservoir, VA and Chowan River, VA, but substantial additional funds
will be necessary according to plan recommendations. Pymatuning Reservoir, PA
has been identified as a priority waterbody which has yet to develop a
pollution abatement plan.
The Chesapeake Bay Program has been developing recommendations for control of
non-point sources which may be responsible for aquatic life impacts in the
Upper Bay. Though the exact cause of many specific effects have not been
identified, excessive nitrogen and phosphorus levels have been implicated as
contributing to the problem. During an average rainfall year, the Susquehanna
River contributes 77 percent and 43 percent of nitrogen and phosphorus loads
respectively to the Upper Bay, while during wet years, total loads are
doubled. As a result, control of non-point sources in the Susquehanna basin,
particularly agricultural runoff, will be necessary to affect necessary
improvements in water quality of the Upper Bay. This shall entail utilization
of some combination of the BMPs identified. The Chesapeake Bay Program is
currently developing control options. One option is 100% implementation of
conservation tillage (low cost) supplemented with other
structural/non-structural BMPs. It is evident that, given past precedent,
cost-share funds will be necessary for implementation of structural BMPs in
critical areas. The State of Maryland has instituted a cost-share program of
its own to provide funds, but federal monies may be required to significantly
reduce NPS nutrient loads, particularly in Pennsylvania. One major
implementation project is already underway in the Conestoga Creek Basin of
Lancaster County, PA (see Table 4).
Most of the Federal resources for implementation are administered by the U.S.
Department of Agriculture, which has several national programs that provide
educational, technical and cost-sharing assistance to agricultural operators
and land owners. Some of the programs are in part directed toward reducing
agricultural runoff through soil conservation, fertilizer application
recommendations and animal waste management. The Agricultural Conservation
Program (AC?) administrated by the Agricultural Stabilization and Conversation
Service (ASCS) is the principal program that provides cost-sharing to farmers
for application of conservation practices. This program received $150M
nationwide in Fiscal Year 1983. Some special projects with primarily a water
quality or soil erosion improvement focus are being funded under the ACP
program, but most of the cost-sharing resources are spread across the counties
in each State. In Region III, the FY'83 ACP resources were distributed as
follows:
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B-29
State
PA
MD
DE
WV
VA
Totals
State
Total
^Millions
3.85
0.87
0.32
1.25
2.63
$8.92
ACP
Special Water
Quality
$ 52,000
54,000
None
11,000
153,000
$270,000
Resources
Special Critical
Erosion Control
$250,000
None
116,000
None
150,000
$516,000
4. Management Recommendations;
The process of developing an implementation program has several required
elements which are summarized below:
. Water Quality Problem Identification and Evaluation: The planning pro-
cess should define the specific water quality problems including
water use impacts, sources of pollutants and target pollutant
reductions needed to meet the water quality goals. The results of
these evaluations should be documented in a water quality management
plan.
. Development of Non-Point Source Project Work Plan: The work plan estab-
lishes what measures must be taken to reach the goals identified in
the water quality management plan, who will do it, and how much it
will cost. The work plan must clearly identify all tasks, assign
roles and responsibilities, and establish schedules and milestones.
The plan must describe the various structural and management
practices that are recommended for implementation and the critical
areas of application. Financial arrangements for Federal or State
cost-sharing must also be included.
. Establishment of Institutional Arrangements: Experience has demonstrated
that the most successful approach involves a voluntary theme as long
as the basic laws and regulations are in place to handle flagrant
violators. Through aggressive local education and with some cost-
share incentives, the voluntary approach generally has been
successful in achieving 70 to 80 percent compliance with specific
eoals. Another basic requirement is the assignment of overall
management responsibility with one agency that has the appropriate
authority to carry out those functions.
Public Participation: This element is the most important ingredient of
' a successful program. Involving the affected agricultural community,
interest groups, and state and federal agency representatives during
all phases of planning will create a much clearer atmosphere for
eventual implementation.
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B-30
The following activities represent positive actions that could be taken to
develop these elements for remaining agricultural runoff problems in Region
III. Additional resources and positions must be made available to support
these activities.
. States:
1. Continue to identify priority watersheds where agricultural runoff
significantly impairs water uses.
2. Establish, with the appropriate 208 and county agencies, an educa-
tional program, (primarily for farmers in the priority areas)
which emphasizes the cost-effectiveness of BMP implementation.
3. Pursue State and Federal funding for cost-sharing of BMPs for pri-
ority watersheds.
4. Identify and protect priority wetland systems which act to buffer
non-point source pollutants.
. EPA Region III: Re-establish a focus on agricultural runoff control pro-
grams by:
x
1. Encouraging and coordinating proposed state and EPA HQ activities
(including 205(j) program).
2. Providing for more active management of and involvement in the on-
going NPS projects (208, RCWP, Clean Lakes).
3. Developing a Regional strategy for control of agricultural runoff.
4. Establishing a network of NPS constituencies (local, state, feder-
* al) and fostering greater recognition of NPS control needs
through periodic contacts and information transfer.
5. Coordinating regional agricultural program with other relevant
program initiatives, e.g., groundwater pollution control programs.
6. Work with States to develop a NPS management plan for the
Chesapeake Bay, building on Bay Program outputs.
. EPA - HQ:
1. Re-emphasize agricultural runoff as a priority problem and apply
appropriate resources. Place particular emphasis on programs
which address NPS controls for specific watersheds on a priority
basis (i.e., Clean Lakes, RCWP).
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B-31
2. Pursue increased funding of BMP cost-sharing programs of Federal
agencies, e.g., ASCS.
3. Re-emphasize wetlands protection as an important element in non-
point source control.
Anticipated Results
The benefits to be expected from there recommendation include: 1) an
accelerated development of agricultural runoff controls in priority areas
of the Chesapeake Bay basin, including watersheds in Pennsylvania, 2)
implementation of BMP's in watersheds where runoff is responsible for
increased water treatment costs and accelerated decrease in reservoir
capacities, 3) cost savings for farmers in the form of decreased top-soil
erosion and less commercial fertilizer useage.
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B-32
THE DEVELOPMENT OF A REGIONAL GROUND WATER DATA BASE
Detailed Analysis of Problem
Because of the lack of a detailed ground water data base, a strategy is
needed for its development. The following outlines the basic tasks for
developing a ground water data base as well as an estimation of the time
required to perform each task:
1. Define and locate major aquifers in each State that are currently
being used as a public water supply source, or have the potential
as a water supply source. Some of this information gathered would
consist of aquifer recharge area maps, hydrogeologic reports, and
well records.
Time frame: 3 months
2. Perform a hydrogeologic assessment of the major aquifers to determine
if they are protected from potential pollution by impervious over-
burden or strata.
Time frame: 1 month
3. Using the above aquifer recharge maps and information, hazardous
waste sites will be located (via overlay) to determine potential
pollution problems of aquifers.
Time frame: 1 month, concurrent with Task 2
4. Identify priority areas and develop monitoring plans to gather
supporting data.
Time frame: 1 month
5. For suspected contaminated aquifers, extend the monitoring analysis
to surface waters that are ground water fed to determine: 1) the
extent of pollution and 2) to determine if the surface waters are
impacted by aquifer contamination.
Time frame: 1 month
6. Meet with States to discuss gathering information.
Time frame: Continuous
Total time required: 6 months
The information will be obtained through existing library references, State
and Federal data base searches, and to a larger extent, meetings, with
the various State and other Federal agencies involved with the aspects of
ground water,( e.g., Virginia State Water Control Board, U. S. Geological
Survey). Reference is made to Figure 1 for a flow chart of the tasks pro-
posed, and to Table 1 for a summary of tasks, estimated costs and funding
sources, time frame and responsible agency.
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3 MONTHS
FLOW CHART OF TASKS
1 MONTH
1 MONTH
6 MONTHS
1 MONTH
1 MONTH
MONTHS
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B-34
Table 1
Estimated Cost/Possible Funding Source
Time Frame
Responsible Agency
$25,000 (UIC, Superfund,
5,000 (Public Water Supply)
5,000 "
6,500 "
6,500 "
2,000 "
3
1
1
1
1
Continuous
(EPA, States,
(Consultant)
1 - $50,000
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