ENVIRONMENTAL PROTECTION AGENCY
W \TKR QtAUTY OFFICE
OFFICE OF ENFORCEMENT & STANDARDS COMPLIANCE
ORGANIZATION & ACTIVITIES
OF
DIVISION OF FIELD INVESTIGATIONS
DENVER (ENTER
MARCH 1 971
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DIVISION OF FIELD INVESTIGATIONS
DENVER CENTER •
OFFICE OF ENFORCEMENT AND STANDARDS COMPLIANCE
WATER QUALITY OFFICE
ENVIRONMENTAL PROTECTION AGENCY
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TABLE OF CONTENTS
Page
I. Press Release 1
II. Functions of the Division 3
III. Activities 4
IV. Future Development 8
V. Organization Chart 10
VI. Listing of Personnel 11
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ENVIRONMENTAL PROTECTION AGENCY. WASHINGTON. D C 2 O 4 6 O
Deister (202) 632-7692
(Home) (202) 234-5641
Hoffmann (202) 632-7693
(Home) (703) 528-4186
FOR RELEASE - March 5. 1971
EPA FORMS NEW TEAM OF POLLUTION "TROUBLE SHOOTERS"
William D. Ruckelshaus, Administrator of the Environmental Pro-
tection Agency, announced today that he has formed a new team of
water pollution "trouble shooters" operating from a Denver head-
quarters.
"This group of scientists and technical specialists doubles the
EPA's capacity for quick reaction to water pollution problems/" the
Administrator said. "We already have a similar team of experts which
works out of Cincinnati and its success has convinced us that an
additional team should be formed."
The Cincinnati team played a significant Icole in the investiga-
tion of mercury pollution by the EPA. Also, it has provided data for
a number of enforcement actions by the EPA.
Ruckelshaus said the need grows each day for developing the facts
in a pollution problem as soon as possible and then submitting this
information with recommendations to Washington headquarters.
"We must have this information rapidly if we are to take
effective enforcement action against polluters," Ruckelshaus said.
The new pollution team—known as the Division of Field Investi-
gations, Denver Center—reports to Acting Commissioner David D.
(more)
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Dominick of the Water Quality Office of EPA through Murray Stein,
assistant commissioner for enforcement.
The 28-member Denver force of pollution investigators is directed
by Thomas P. Gallagher, 32, an engineer who was formerly chief of
engineering services in the Southeast Water Laboratory of the EPA
in Athens, Georgia.
In addition to reacting to emergency situations, the team
conducts investigations and studies for possible action against
violators of the Federal-State water quality standards. It also
prepares reports for enforcement conferences, court proceedings and
hearings.
•The special investigators initiate and distribute information
on toxic substances. They also furnish additional technical and
scientific assistance to the regional offices of the EPA when it is
needed.
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Division of
Field Investigations, Denver Center
Functions
Under the broad policy guidelines provided by the Assistant Commissioner -
Enforcement and Standards Compliance - Water Quality Office, plans,
manages and directs a national program of technical assistance, field
investigations and studies of water pollution problems. Provides
governmental, industrial and institutional coordination and liaison
to enhance water quality.
Provides technical consultative services to the Office of Enforcement
and Standards Compliance, EPA regions, other Federal agencies, State,
and interstate, municipal and public and private entities in planning
and conducting water pollution control activities. Examples of such
services include constituent analyses, treatment of industrial and
municipal wastes, field-laboratory analytical procedures, eutrophication,
subsurface waste disposal, agricultural and feed lot wastes, fish kills,
thermal pollution and toxic substances.
Initiates reports and distributes information on toxic substances dis-
charged to public waters. Provides information on methods and pro-
cedures for water quality analyses and field work through the develop-
ment and distribution of publications and lectures and the conduct of
on-site demonstrations.
Conducts water quality investigations and provides expert testimony and
advice on a wide variety of specialized technical subjects in support
of the Office of Enforcement and Standards Compliance in connection
with 180-Day notices, conferences, hearings, court proceedings, and
other activities.
Maintains a mobile group of experienced professional engineers, biologists,
chemists, microbiolegists, and other disciplines for emergency response
on a nationwide basis concerning pollution of the water environment.
Conducts, in cooperation with the regions, complex field investigations
requiring specialized interdisciplinary competencies to evaluate com-
pliance with water quality standards. Assists in the development of
regional personnel through on-the-job training during water quality
surveys, lecturing on field methods in EPA training courses, and by
other appropriate methods.
Develops and improves field investigative techniques and procedures for
evaluation of water quality.
Provides assistance to improve the operation of existing waste water
treatment plants and develops and improves criteria for the design of
new plants.
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Division of
Field Investigations - Denver Center
Activities
The following surveys and studies have been accomplished, or are projected,
for the Denver Center during calendar year 1971:
A. National Heavy Metals Investigation
This Division, in cooperation with the Cincinnati Division and the
Headquarters Office of Enforcement and Standards Compliance, has been
assembling data on the occurrence and effects of discharges
of toxic materials, particularly heavy metals. A preliminary report
has been prepared on the status of water quality standards as well as
effects on man and aquatic life of six heavy metals. Information is
being developed on probable sources and a suggested sampling program
is being evolved. It is anticipated that participation and conduct of
a National heavy metals investigation will be a major function of this
Division during F.Y. 72.
B. National Shellfish Investigation Program
This Division has developed a National plan for the conduct of major
shellfish investigations in areas where pollution abatement would result
in redress of economic grievance and increased water use. The plan
contains a description of 11 major problem areas throughout the United
States, personnel and budget estimates required, and a schedule of
accomplishment. An initial investigation has been conducted in
Galveston Bay, Texas. Further studies are programmed for Lake Charles,
Louisiana, and Atchafalaya Bay, Louisiana. Reduction of data concerning
shellfishing areas in the Pacific Northwest is now ongoing.
C. Region IV -- Atlanta, Georgia
1. Municipal and Industrial Waste Inventory, Dade County, Florida
Investigation of sources of municipal and industrial waste in
Dade County, Florida has been completed. This investigation
'showed that 98 percent of the municipal waste water in Dade
County is not receiving adequate treatment according to Florida
Water Quality Standards. Industrial wastes in the vicinity of
the Miami International Airport may be causing problems due to
the introduction of toxic materials to the ground water. Recom-
mendations are made concerning pre-treatment of industrial wastes
and treatment required prior to discharge to ocean outfalls.
These findings will be presented at the next Session of the Dade
County Enforcement Conference.
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2. Municipal and Industrial Waste Inventory. Broward and Palm
Beach Counties, Florida
A request has been received to continue and extend the inventory
recently completed by the Denver Center in Dade County to Broward
and Palm Beach Counties. This work is anticipated to require
approximately three to four months, beginning in May 1971. In-
formation developed will be used for recommending either 130-day
violation notices or Refuse Act prosecutions, and to evaluate
effluent discharges for the Permit Program.
3. Miscellaneous
The Denver Center is participating in completion of reports on
the Upper Savannah River (Augusta, Georgia area), and evaluation
of impoundment operations at West Point, Georgia. Assistance is
also being provided in the design of a biological survey in
Ponce and Tallaboa Bay, Puerto Rico. This area receives extensive
industrial waste discharges, particularly petrochemicals.
D. Region VI -- Dallas, Texas
1. Galveston Bay, Texas
A report detailing the effects of waste discharges to the Houston
Ship Channel in Galveston Bay, Texas has been prepared. This
investigation showed that oil and hydrocarbon residues in oysters
taken from open areas in Galveston Bay are from two to six times
greater than those for which the State of Massachusetts closed West
Falmouth Harbor as a health hazard. Concentrations of heavy
metals in the receiving waters were, in many cases, thousands of
times greater than natural background. The State of Texas effluent
permits, as of 1968, were permitting the discharge of more than
55,000 pounds per day of oil, although this is in violation of the
Federal Water Pollution Control Act. Recommendations include an
examination of each waste discharge for the development of a
specific abatement program and schedule of compliance. A ban on
oyster harvesting in Galveston Bay is recommended until the health
hazard associated with the waste discharges is eliminated. Recom-
mendations require extensive follow-up investigations to establish
an enforcement program for the entire estuary.
2. Lake Charles, Louisiana
An inventory of the municipal and industrial waste complex at
Lake Charles, Louisiana is presently underway and effluent
sampling will be conducted for possible enforcement action under
the 1899 Refuse Act. An attempt will also be made to detail
effects of waste discharges on the receiving waters. As in
Galveston Bay, the discharge from the petrochemical industries
may be contaminating oysters in approved areas of Calcasieu Bay.
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3. Atchafalaya Bay, Louisiana
An investigation of the economic damage caused by municipal and
industrial pollution in several shellfish growing areas, in and
around Atchafalaya Bay, will be conducted. Recommendations will
be made concerning waste abatement for discussion at an Enforce-
ment Conference or through other administrative or judicial
Enforcement procedures.
4. Navaio Lake, New Mexico
A request has been received from the State of New Mexico concern-
ing sources of interstate pollution discharging from Colorado into
Navajo Lake. Preliminary indications are that the high mercury
concentrations in fish taken from Navajo Lake are due to acid mine
drainage in Colorado. Available data will be evaluated before
commitment of field activities on this request.
E. Region VII -- Kansas City, Missouri
1. Homestake Gold Mine
Extensive field investigations are being developed to determine
the effects of previous mercury and present cyanide discharges
from the Homestake Gold Mine. The Division is currently
evaluating interim alternative abatement proposals to eliminate
the excessive concentrations of cyanide presently being discharged.
Recommendations' will be made imminently concerning establishment of
an abatement program. Preliminary surveys have indicated that
extensive reservoirs of mercury in the sediment may be present and
that the cyanide discharge has increased nearly three-fold since the
change in the amalgamation process.
2. Miscellaneous
A report will be completed on water quality in the Kansas River
at an early date. Recommendations have been made and meetings
have been scheduled concerning the mercury discharges from the
Lake City Army Ammunition Plant.
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F. Region VIII -- Denver, Colorado
1. South Platte River
The final date for compliance with Enforcement Conference recom-
mendations on the South Platte River is June 30, 1971. There is
excellent reason to believe that some of the waste discharges will
not be in compliance by that date. A field investigation to de-
termine the status of Enforcement Conference recommendations will
be made after June 30. It is expected that this will involve
extensive waste source and water quality sampling.
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2. Bear River
Little or no progress has been made toward meeting the recom-
mendations of the Bear River Enforcement Conference. A request
to detail the status of compliance with these recommendations
has been received. Because of the seasonal nature of the canning
and sugar industries, sampling of the waste effluents will be
deferred until the late Summer or early Fall of 1971.
G. Region X -- Portland, Oregon
1. Middle and Upper Snake Rivers
A reconnaissance of water quality in the Upper and Middle Snake
Rivers will be done in cooperation with the State of Idaho, at
the request of the Regional Office. If interstate effects of
pollution are being observed in the Boise, Idaho area due to the
complex of potato processing plants, an intensive waste effluent
and water quality survey will be conducted in the Boise area during
the Fall of 1971. Recommendations concerning the convening of
an Enforcement Conference and/or 180-day violations will be made
upon completion of this survey.
2. Shellfish Investigations
A thorough evaluation of economic damage and possible field in-
vestigations in the Northwest Region related to pollution of
shellfish will be made. This evaluation will include the re-
duction of available technical and economic data, as well as
facilities in the Region for the conduct of the recommended
investigations.
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Division of
Field Investigations - Denver Center
Future Development
A. Remote Sensing
In areas where there is a multiplicity of waste discharges, as well
as in sparsely populated sections of many river basins, the concepts
of remote sensing to determine the characteristics of effluents and
their effects on water quality are particularly applicable. The
principles of remote sensing have been sufficiently proven to merit
application on a regular basis in many water pollution enforcement
cases. For instance, this Division utilized National Aeronautics
and Space Administration aerial photographs of Galveston Bay to
analyze waste transport, as well as meteorological and hydrographic
conditions which cause damage to oysters. The additional information
gained can lead to stronger technical evidence in enforcement cases.
Manpower savings are also a major asset.
This Division has made contact with the National Aeronautics and
Space Administration to determine the availability of equipment and
methodology. A physicist will be employed in the near future with
extensive experience in the field of remote sensing. Contact will
be made with EPA's Radiation Surveillance Program at Las Vegas.
During the projected South Platte survey in Summer 1971, aerial
photography will be employed to determine the efficiency of the
recommended waste abatement program. The Division plans to extend its
capability in the remote sensing area in the future.
B. Process Control
The complex nature of many waste discharges are^-not adequately reflec-
ted by the standard parameters used to measure water quality, nor are
the waste abatement methods generally employed successful in removing
some of these deleterious compounds. A thorough knowledge of indus-
trial processes is required such that a systematic examination of a
particular waste source will reflect an accurate characterization of
the compounds in the effluent which may deleteriously affect water
quality. Recommendations concerning abatement of wastes should be
based on considerations of in-plant control, as well as reclamation
and reuse, rather than a dependence upon external abatement facilities
alone. Greater emphasis should be placed on utilizing the technology
developed through the advanced waste treatment program of EPA in
recommending corrective action in enforcement cases. As a result of
an exhaustive evaluation of the milling process used at the Homestake
Gold Mine, a wider consideration of acceptable control plans is being
made. It is necessary to extend this capability to other major indus-
trial processes, particularly petrochemicals. An industrial waste
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specialist and a chemical engineer are being employed by this
Division to form the nucleus of a process control and analysis group.
This will increase our capability in making suitable recommendations
concerning abatement and control of complex industrial wastes to the
Enforcement and Standards Compliance Program and to Regional Offices
of EPA.
C. Student L.IW Intern Program
Arrangements are being made with the University of Colorado Law
School and the University of Denver Law School to employ, on a part-
time basis, students majoring in various aspects of environmental
law. These students will receive experience in the development of
technical evidence in enforcement situations. The Division hopes to
have this program operational by Summer 1971.
D. Hazardous Materials Investigations
The President has recommended to the Congress, as a result of a
report prepared by the U. S. Coast Guard, that a national classification
scheme for hazardous polluting substances is needed, backed up by a
national laboratory system for determining or confirming the nature of
these substances. A national organized reporting system, so that
knowledge of a discharge can be conveyed as quickly as possible, was
also recommended. The capabilities of this Division for field investi-
gations on an emergency response basis, to determine effects of complex
toxic or hazardous discharges will be increased. Expertise will be de-
veloped toward the recommendation of technical criteria necessary to
establishing meaningful standards for these hazardous materials. The
discovery of oil and hydrocarbon residues in oysters of Galveston Bay
in concentrations which constitute a health hazard is an example of the
activities of this Division in this regard.
E. Use of Television in Gathering Technical Evidence
The problem of demonstrating the chain of custody of samples, as well
as verifying the proper procedures used in sample collection, is a major
problem when pollution.cases reach the adjudication stage. The use of
hand-held television cameras and closed circuit receivers during the
collection and transfer process would provide visual evidence on proper
procedures. Colorado State University has a Communications Department
with considerable experience in closed circuit documentary television
productions. Contact has been established to determine whether these
concepts can be applied to pollution field investigations for enforce-
ment purposes. Advice will also be sought from the EPA legal staff
concerning implementation, of this procedure, possibly on a pilot or
demonstration basis.
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ORGANIZATION CHART
DIVISION OF FIELD INVESTIGATIONS - DENVER CENTER
ASSISTANT COMMISSIONER ENFORCEMENT AND STANDARDS COMPLIANCE
I
OFFICE OF THE
DIRECTOR
o
I
ADMINISTRATIVE
SERVICES SECTION
LABORATORY SERVICES
BRANCH
POLLUTION EVALUATION
BRANCH
BIOLOGY
SECTION
CHEMISTRY
SECTION
JEVIEW AND
iVALUATION
SECTION
FIELD
OPERATIONS
SECTION
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PERSONNEL
DIVISION OF FIELD INVESTIGATIONS - DENVER CENTER
Employee Position Title
GALLAGHER, Thomas P.
METZLER, Albert E.
E.O.D. July 1
SQUIRES, Marjorie R.
LEYBA, J. Gilbert
SPEDON, Mary G.
Biology Section
SCHNEIDER, Robert G.
WARNER, Richard W.
E.O.D. May 1
E.O.D. May 1
Chemistry Section
MEIGGS, Theodore 0.
CONNOR, John G.
E.O.D. May 1
BLACKMAN, Wm. C. Jr.
MeANALLY, Shirley J.
Review & Evaluation Section
VINCENT, James R.
SOTIROS, Richard
BAEZ, Cesar P.
WOODHOUSE, Ann
ROBERTS, Donald R.
BROWN, Alice M.
* HYATT, M. Leon
Field Operation Section
HARP, Robert D.
ROUSE, Jim V.
HELTON, Michael R.
HATHEWAY, James L.
KING, Robert L.
E.O.D. May 1
WALZ, Laurence R.
LAUCK, Norma G.
OFEi.cc of the Director
Director
Assistant Director for Management
Industrial Waste Specialist
Secretary
Administrative Services
Administrative Assistant
Administrative Clerk
Laboratory Services Branch
Chief
Biologist
Microbiologist
Biological Technician
Chief
Chemist
Chemist
Pollution Evaluation Branch
Chief
Secretary
Chief
Sanitary Engineer
Hydrologist
Program Analyst
Engineering Technician
Statistical Clerk
Hydrolegist
Chief
Physical Science Administrator
Sanitary Engineer
Sanitary Engineer
General Engineer
Chemical Engineer
Environmental Health Technician
Clerk-Stenographer
* Detailed to National Water Commission, Washington, D. C.
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