REGION 8
FINDINGS AND RECOMMENDATIONS ON
EPA ENVIRONMENTAL PROGRESS
83001 REMAINING PROBLEMS AND NEEDED HEADQUARTERS ACTIONS
I. BACKGROUND
The Region 8 Environmental Management Report (EMR) was produced
to document current environmental conditions as a baseline of
environmental quality in the Region. "The Region plans to use the
information to help target abatement and prevention efforts more
directly on the most significant pollution,problems in the Region,
and to establish a benchmark against which future environmental
conditions can be measured.
The Report analyzes data from approximately 1977 through 1982.
Sources of information for the Report included nearly 20 separate
data bases.
II. FINDINGS AND RECOMMENDATIONS
A. Environmental Status
Region 8 is predominantly rural, with 7 million people
scattered across approximately 578,000 square miles of land.
One-third of the population l-ives in cities with populations
larger than 100,000; most people are in small towns.
The Region reported the following environmental status
information.
1. Air Quality;
The Regidn identified two classes of air quality
problems - those caused by urban and industrial development
and those resulting from development of natural resources
near Prevention of Significant Deterioration (PSD) areas.
Total Suspended Particles dfTSPJf have been the most
widespread problem,^throughout the Reg'ion. However, high
carbon monoxide (CO) concentrations in the" most populated
areas have affected the most people. Other pollutants
found to be in excess of the primary standard were Ozone
(03) and lead (Pb). These problems are discussed in detail
below.
TSP
TSP was the most widespread pollutant in the Region.
Sixty-three percent of the 49 counties in the Region with
monitoring stations having exceedences of a primary standard
had TSP exceedences. The TSP problems are from auto and
truck exhaust, power plants, smelters, steel plants,
unpaved roads, and construction work. Problems that have
contributed to the Region's difficulty in controlling TSP
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removal treatment processes and of high and low level
are the difficulty of controlling untraditional sources
like wood stoves and fireplaces, the dry conditions and
wind that create fugitive dust, and the lack of an inhalable
particulate standard.
CO is the most aggravating problem in the Region and the
air quality problem that affects the most people. Problems
are centered in the following areas:
Colorado - Denver, Fort Collins, Greeley, Colorado
Springs
Utah - Salt Lake City
Montana - Missoula, Billings, and Great Falls.
CO problems are caused by mobile sources; Region 8 re,-, irts
that controlling CO will require development of a Trai.s-
portation Control strategy that is afforadable and does
not entail severe social impacts.
Ozone
Ozone from motor vehicle, emissions is most severe in
Denver and in Salt Lake City. Four additional communities
have ozone violations. Region 8 believes these areas
should meet the ozone standard by 1987.
Lead
Lead is a problem in East Helena, Montana. The source
of the problem is a lead smelter. The cost of lead
clean-up is the barrier the Region faces in addressing
this problem.
Acid Deposition and Other Air Pollution Effects on Pristine
Areas
Air quality related values (AQRV), which are determined
based on visibility, flora, fauna, soils, and water, are a
concern in several PSD Class I areas in the Region. These
are:
the Colorado Flat Tops and Mount Zirkel Wilderness
areas, where problems have resulted from development
of shale reserves; and
the North Dakota Theodore Roosevelt National Park,
where air quality is threatened by new power plants,
synfuel plants, and.oil and gas fields.
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Acid deposition is both a recognized and an emerging
problem in Region 8. Acid deposition is already a problem
in several high altitude lakes of Colorado.
Barriers to the Region's dealing with these air quality
and acid deposition problems include:
o a lack of modeling- tools to quantify the source receptor
relationship between acid deposition and other pollu-
tants, and the AQRV; and
o lack of adequate date to determine baseline conditions
for AQRV.
Emerging Problems
- Acid deposition
- Emissions from diesel vehicles
- Organic compound and particulate emissions from wood
stoves and fireplaces
- Indoor air pollution
- Availability of terrain and long range transport and
diffusion models
- Cadmium and arsenic in East Helena, Montana
- Potential air quality problems on Indian Reservations.
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\ 2. Water Quality
Region 8 maintains very good water quality. Less than half
of the Region's streams are moderately impaired, and less than
10% are severely impaired. The challenge the Region faces is to
maintain high water quality.
The Region estimated that 90% of its water quality problems
are from non-point sources, particularly acid mine drainage.
However, the Regions said municipal discharges present the greatest
impediment to meeting the 1982 goals ot the Act.
Region 8 noted that more monitoring and biological data are
needed in order to do an adequate job of assessing water quality.
In particular, the Region noted:
o the scarcity of Regional monitoring data from water
segments that would be potential problems;a
o the fact that biological data are virtually absent;
o the lack of water quality oata and flow monitoring data
necessary to know whether high quality streams are being
maintained.
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The Region also strongly emphasized the lack ot sufficient
funds, qualified personnel, and data to implement the .use-oriented
water quality control program that the Office of Water currently has
proposed in regulation.
3. Drinking Water Quality.'
Seventy percent of the community water systems in the Region
serve fewer than 1,000 people. These small system's (are the ones
that have the most problems^] in consistently supplying safe drinking
water. They rely on untreated ground water, unfiltered surface
water or poorly protected springs.
During FY 1979, there were 643 violations of maximum contami-
nant levels for bacteria throughout the Region. Since then, the
violations have decreased markedly due to improved treatment and
sampling techniques. Moreover, the number of persistently violating
systems (i.e., those that violate the bacteria standard 4 or more
months a year) has decreased from 19% (in 1979) to 10% in 1982.
Over 100 community water systems, or 3% of the Region's totil,
have been found to exceed the standards set for inorganic chemicals
which are known to have public health implications. There are 86
communities exceeding the fluoride standard, 33 exceeding nitrate
standards, 8 exceeding the selenium MCL, and 5 exceeding the arsenic
standard. These incidents result from the presence of natural
contamination in ground water or poor well drilling practices.
Trihalomethanes (THM) and other organic chemicals may be a
problem in the future. THM has been found in only 2 of 106 systems
large enough to test for THMs. A change in treatment technique may
be required. The Office of Drinking Water conducted ground water
sampling in 1980 that showed that, for Region 8 drinking water
systems using ground water, over half of the samples tested contained
either traces of THMs or volatile organic chemicals, and that 18%
of the samples contained only trace amounts of volatile organics.
Drinking water quality on Indian lands is a problem because of
inadequate treatment and little or no operation and maintenance.
4. Ground Water Quality .
90% of Region 8's drinking water systems rely on ground water,
and about 95% of the Region's population in rural areas (two-thirds
of total) depend on ground water as their sole water supply. There
have been few reported cases of waterborne disease or chemical
poisoning (possibly because adverse health effects are often not
noticed over the short-term and are seldom reported). /There have
been salinity increases','due to irrigation practices in a number of
areas including the Arkansas Valley and the northeastern plains of
Colorado, the Vinta Valley of Utah and the Grand and. Uncompahgre
Valleys.'f|VThere have also been increases in nitrates^in the Big
Sioux Valley in South Dakota and the South Platte Valley in Colorado.
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Local "hot spots" hav.e posed health risks in isolated areas
due to hazardous wastes, solid waste, leaking underground
tanks, injection ot oil and gas brines,"acid mine drainage, and
accidental industrial spills.
5. Hazardous Waste/Superfund
Region 8 has 14 NPL sites on the proposed National Priority
List (NPL) — 6 in Colorado, 4 in Montana, and 1 each in Utah,
Wyoming, North Dakota, and South Dakota.vX^ignifleant progress
has been made in cleaning up Hazardous Waste sitesjin the
Region. Agreements are now being prepared'to conduct remedial
investigations for 4 NPL sites, agreements are completed at 6
sites, and there are 3 additional investigations now under
way. Region 8 also has 5 sites that require attention although
they are not on the NPL. Seven Federal facilities are actual
or potential health and environmental concerns. These are
Rocky Mountain Arsenal (Denver) and Pueblo Army Depot (Pueblo),
the Leadville Drainage Tunnel, Dugway Proving Ground, Tooele
Army Depot, Odgen Army Depot, and Hill Air Force Base. In
each case there is actual or potential contamination of ground
water.
6. Hazardous Waste (RCRA)
Since EPA has regulated active hazardous waste handlers
generators have begun changing their production processes in
order to reduce waste. Recycling of hazardous waste has
increased and there is a growing trend toward the installation
of pretreatment units which discharge non-hazardous waste.
Due to a lack of .commercial disposal capacity, there has
been an increased economic pressure to engage in unsafe disposal
practices.
7. Radiation
Significant reductions in radiation exposure are expected
in the next 5-10 years. Internal radiation doses are expected
to be more significant than external exposure because of the
severity of internal doses.
Because of a lack of regulation, Uranium doses are increasing
significantly.
8. Toxics and Pesticides
There have been significant decreases in pesticide poison-
ings, possibly because of child proofing and more public aware-
ness of the potential hazard of organophosphate pesticides.
Significant quanities of PCBs are being moved into disposal
facilities.
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No trends were reported for pesticide drift, disposal of
pesticide containers, or for asbestos exposure in schools as
data was not yet available.
Although there are no available statistics on asbestos
found or removed from schools, asbestos inspections were made
by the Regional Asbestos Technical Advisors in 615 of 746
school districts in the Region, not including Montana, where
268 of 393 school districts responded to a questionnaire indicat-
ing that they had inspected their buildings.
MAJOR REMAINING PROBLEMS
1. Air
The Region is experiencing air quality violations for the
following pollutants.
- CO
- TSP
- Ozone
- Lead
2. Water Quality
o Non-point source loadings of nutrients, sediment and
salinity.
o Lack of funding and resources is impeding the implement-
ation of use-oriented water quality control strategies
outlined in proposed regulations, as resources continue
to be directed toward treatment technology control.
o Although there "is a significant effort to address the
salinity problem in the Colorado River Basin, there
are major salinity problems throughout the Region
which are not being adequatly addressed.
o Loss of inland and coastal wetlands.
o Conditions and best management practices in Nationwide
Permits fail to protect wetlands.
- The Corps of Engineers has promulgated new regu-
lations which allow dredge and fill activities in
wetland areas under a Nationwide Permit without
review of that area for compliance with Nationwide
permit conditions.
o Fishable/swimmable standards of the Clean Water Act (CWA)
will not be met in 1983 due to municipal discharges of
ammonia, chlorine, organic material, bacteria, and non-
municipar discharge of heavy metals from inactive/abandoned
mines.
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o Depletion of stream flows by increasing amounts of con-
sumptive use threatens nonconsumptive uses.
3. Drinking Water Quality
o 70% of the community water systems in the Region serve
fewer than 1,000 people.
o 3% of the Region is in violation of inorganic chemical
standards—due to the high cost of removal.
o Limited sampling has identified Trihalomethanes
in small water systems.
o Contaminants which are not regulated by MCLs continue
to be discovered.
o Poor treatment, operation and maintainance result in
intermittent quality of drinking water on Indian reservations.
4. Ground Water Quality
o Traces of Trihalomethanes of volatile organics in
56% of community well systems.
o Increased concentrations of- contaminants observed
throughout the Region.
o Most major sources of contamination are inadequately
addressed.
contaminant cause
salinity dryland irrigation practices
nitrates agricultural use of fertilizer
selenium, fluoride, uranium natural conditions
heavy metals mining (at least 39 known sites
with significant ground
water problems)
o Inconsistent and incomplete State laws on Ground Water
protection, leaving major causes of contamination
unregulated.
5. Hazardous Waste (Superfund)
o States may not be able to provide matching funds needed
to attain Superfund money.
o Site cleanup may not be completed when Superfund expires
in seven years.
o For high priority sites rio'C on NPL, Region must locate
a "deep pocket" or cleanup cannot begin.
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o Federal facilities are slow to clean up their own problems.
6. Hazardous Waste (RCRA)
o Ground water contamination is being caused by inadequate
waste disposal practices and unsafe waste management by oil
refineries, recyclers, and in mining areas.
o Lack of enforced pretreatment plans allows some hazard-
ous waste generators to avoid proper handling of waste.
o Lack of adequate commercial disposal capacity.
o Waste facilities are avoiding permit regulations by
storing waste less than 90 days.
7. Radiation
o Uncontrolled radioactive waste sites have resulted in
transfer of radioactive material.
o Inadequate disposal facilities and processes for low-level
and high-level radioactive waste.
8. Toxics and Pesticides
o Each State in the Region is concerned with unique
pesticide problems including:
- pesticide contamination of wildlife particularly the
high Endrin levels found in waterfowl and upland game
animals in Montana
- pesticide misuse such as the violation of pesticide
label conditions which cause damaged crops, human
effects, environmental residues and accumulation of
chemicals
- pesticide orift which occurs when applicators inadvert-
ently spray neighboring fields.
RECOMMENDED ACTIONS FOR HEADQUARTERS
1. Air
o The Region communicated a strong need for additional
research and data. Specific requests were made for research
on urban haze, emission and .control strategies for residential
combustion of wood and coal, on the contribution of diesels
to particulate loading, visibility reduction problems and
the presence of non-criteria pollutants that would allow
development of complex terrain and long range transport
and diffusion models, predictive models to estimate the
effects of various pollutants, including acid deposition,
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to define baseline conditions for significant Air Quality
Related Values (AQRV), to quantify source receptor
relationships between various pollutants, and to develop
control techniques and to determine health effects of
indoor air pollution.
o Promulgation of exhaust emission standards for diesels
is recommended.
o A decision on the proposed inhalable particulate standard is
requested.
o Control techniques for lead smelter emissions of air toxics
and assistance in evaluating and identifying individual
lead sources and appropriate control techniques are
requested.
2. Water Quality
o Implementation of Water Quality standards which would
maintain the high quality of those water bodies already
surpassing 1983 goals.
o Funding for qualified personnel.
o More biological data is necessary to redirect programs
from control technology based programs toward beneficial
- use - oriented strategies outlined in proposed regula-
tions.
3. Drinking Water Quality
o Completion of revised MCL regulations.
o Coordination among State and other federal agencies,
to direct funding toward systems with known public
health problems.
o Coordination of efforts of all Federal agencies to ensure
delivery of safe drinking water on Indian reservations.
4. Ground Water
o The Region proposes a number of approaches relying on
current Federal authority to promote the identification
and control of significant sources of groundwater
contamination.
o Promote development of a centralized ground water data base
and develop a coordinated Federal and State monitoring
effort whose results would be readily available.
o Expand the list of parameters for which monitoring
should be required to allow adequate assessment of
health risks.
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o Expand the urban runoff program to include efforts to
identify the role dry wells or drainage control wells
play in ground water contaminating.
5. Hazardous Waste (Superfund).
o Federal government must set example for private industry
by cleaning up Hazardous Waste sites at Federal facilities,
6. Hazardous Waste (RCRA)
o To support assessments by facilities more guidance and
technical information is needed on many ground water
contamination and monitoring issues including waiver
provision, well location and construction standards,
and designation of aquifers.
o More urgent and thorough implementation of pretreatment
standards.
o Clarify regulation of mining wastes.
o Close policy gaps with regard to recyclers— go beyond
provisions of regulatory changes proposed April 4, 1983.
7. Radiation
o Modify the Hazard Ranking system to more equitably
consider radiation sites.
o Develop a clear,, policy under CERCLA on radiation sites.
o Develop a check list with examples of all documents
required for Superfund consideration of a site.
o Clarify interpretation in the reference in inactive sites
to EPAs Hazardous Waste Management Program.
o Work toward getting lead authority and appropriate funding
for indoor air pollution problems.
o Provide clear guidance for the Superfund program to
States on various radiation issues pertinent to their
responsibility.
o Provide guidance or standards for uranium in drinking
water and radioactivity in water used for live-stock
and agriculture.
o Appropriate procedures and standards are needed for waste
removal treatment process.es and of low level
waste disposal.
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8. Toxics and Pesticides
o Work closely with States to implement programs for the
proper use of the pesticide 1080.
o Maintain enforcement of pesticide misuse through inspection
of users.
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