; ** \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OPPIC6 OP POLICY ANO RESOURCE MANAGEMENT MEMORANDUM SUBJECT: Background Information on Environmental Status and Trends in Region 4 FROM Joseph A. Cannon Associate Administrator for Policy and Resource Management TO: The Administrator Attached is a summary of Region 4's Environmental Management Report (EMR) on environmental status and trends, the Region's most significant remaining and emerging environmental problems, and its recommendations on the actions Headquarters needs to take to enable it to more effectively address these problems. Each Region has developed an EMR as part of a broader effort to manage for environmental results. In brief, the Region emphasizes the following points (not ranked in priority order): o Air quality has significantly improved, but localized problems remain with TSP, ozone, and CO. o Despite large investments of resources to improve water quality, rapid population and industrial growth are exceeding our ability to provide resources for clean-up activities and several serious problems relating to conventional pollutants continue to exist, particularly with respect to municipal dischargers. o 1980-1981 monitoring data show severe water quality violations of designated, uses at 36% of the stations monitored. Conventional water problems have been over- shadowed by a new set of problems resulting from dramatic increases in chemical production and use, land development, and energy development. o Drinking water problems, caused by exceedences of bac- teriological MCLs along with monitoring and reporting violations are above the national average. ------- -2- o Ground water quality is an increasingly serious problem in localized areas and throughout much of Florida. Ground water contamination from hazardous waste sites is of particular concern, as is current inadequacy of ground water monitoring. 0 Pesticide use is extremely high in Region 4. While there have been reductions in pesticide misuse incidents, inspections still show a 60% violation rate. 1 hope you find this summary helpful. Attachment ------- Summary of Environmental'Progress, Remaining Problems, and Recommended Actions from 1983 Environmental Management Report Region 4 I. BACKGROUND This paper provides a brief summary of the major findings concerning current and emerging environmental problems ana the recommendations for Headquarters action contained in Region 4's recently completed Environmental Management Report (EMR). Region 4 worked closely with the States in the Region to develop its EMR. II. FINDINGS AND RECOMMENDATIONS The summary below presents information on (A) status and trends in each of the media areas, and (B) significant remaining and emerging problems and the Region's recommen- dations on Headquarters action needed in each problem area. A. STATUS AND TRENDS 1. Air Quality* Over the past 10 years, air quality in the Southeast has shown marked improvement, particularly in reduc- tions in TSP and S02* All TSP and SO2 emission sources are in compliance with emissions standards. The major work remaining is in reducing automobile- related air pollutants and maintaining the high degree of air quality thus far attained. Currently, about eleven million people, or 26% of the population, live in projected non-attainment areas. Specific trends are: TSP Down, But A Problem. The number of counties not meeting TSP primary or secondary standards has declined and is projected to be even lower in 1984, and TSP violations are also down somewhat. However, TSP is still a problem in portions of counties in Alabama, Kentucky, and Tennessee. Kentucky (where the problem seems to be related to fugitive dust from haul roads), Tennessee, and Alabama are vorkiny on resolution of the remaining problem areas. (A new inhalable particulate standard could reduce the number of projected nonattainment areas.) "Region 4 based its assessment of air trends below on ambient monitoring data. The Region said emissions data could also be valuable but that the current data are too incomplete to use. ------- -2- CO Progress Varies. Several areas within Region 4 have not met CO standards, and the Region projects possible increases in the number of CO non-attainment areas in 1984. CO violations have been quite variable. Excessive levels of CO seem to be due to growth in mobile emission sources, which are projected to increase even more if economic recovery occurs. Ozone A Problem. The number of counties not meeting ozone standards has decreased and the number of O3 violations/year has dropped dramatically from 1977 to 1981 (from over 200 to about 80.}. Nevertheless, the Region projects that several areas in Alabama, Florida, Georgia, and Kentucky will not be in attain- ment in 1984. SO? Standards Met. The Region believes all areas met the SO2 standards by December 1983. Few vio- lations have been reported since 1978. Lead and NO?. These pollutants have not been problems. 2. Surface Water Region 4 reported that despite expenditure of more than $9 billion of public funds for wastewater- treat- ment in the Southeast, rapid population and industrial growth has outstepped the rate of expenditures for clean-up actions, and many historical problems with conventional pollutants still exist. In addition, the Region noted that these conventional problems have been overshadowed by a new set of problems resulting from increased chemical production, lana development, and energy development. The Region stated that as of 1978, at least 75% of the river basins in the South were affected by industrial discharges, and 91% by municipal discharges. Although not as severe as 10 years ago, the most wide- spread contamination problems continue to be bacteria, oxygen depletion, and nutrients. Major municipal dischargers are meeting current permit limits but need improvements such as pretreatment of industrial wastewaters to remove toxic chemicals. The Region noted that it is not possible with current monitoring data to establish precisely what percentage of the Region's waters violates use designations. However, water quality data for 1980-1981 show, for 189 monitoring stations, severe* violations at 36% of the stations (68) and some violations at 78% of the stations (147). •Footnote: Severe violations were defined as exceedences at least of one parameter value by 85% or more. ------- -3- Pollution control efforts have generally been more successful with industrial than with municipal dis- chargers. The Region did note that some significant water quality improvements have been made over the last decade. o &0D, pH extremes, oil and grease, and fecal coli- forms are usually within established limits although several localized exceptions remain. When there are exceedences, they seldom reach the extremes or duration of 10 years ago. o There have also been accomplishments in controlling toxicity: the "mercury scare" of the early '70's is under control and known persistent chemical substances such as PCBs and several pesticides have been banned or controlled. o The number of areas approved for shellfish harvesting increased in the Region by 13.5% over 1966 figures. Total open acres for shellfish harvesting in 1980 was approximately 2,750,000 as compared to approxi- mately 2,450,000 acres in 1974. (Alabama is an exception to this trend; there were severe declines in shellfishing waters in the State between 1974 and 1980.) 3. Drinking Water Although isolated problems exist, drinking water supplies are generally of good quality. Florida and Kentucky are experiencing high rates of persistent bacteriological violations well in excess of the national average. The problem also exists in Tennessee and Mississippi, although the violation rate is not as high. The high violation rates are attributed to the problems States generally have dealing with small systems. 4. Ground Water Almost 70% of the Region's population obtains drinking water from ground water sources. Severe ground water degradation problems tend to be highly localized, but in parts of the Atlantic-Gulf Coast Plains and most of Florida the problems are more pervasive. A 1978 study showed ground water contamination to be increasing from surface impoundments, although the full extent of ground water quality problems is not well known due to a lack of ground water monitoring. ------- -4- 5. Wetlands The average annual loss of wetlands from 1955 to 1975 was approximately 450,000 acres. This was checked by the Corps of Engineers* 1975 regulations (Section 404 of Clean Water Act), but loss still remains at about 2,500 acres per year. Region 4 faces major challenges to protect these areas. Some progress has been made to minimize environmental degradation. Work in progress includes an Environmental Impact Statement (EIS) addressing wetlands conversion to farming operations and an EIS for oil and gas exploration. 6. Solid and Hazardous Waste Region 4 has identified 2978 sites for the Superfund program's tracking system (19.3% of the national total) and 48 inactive disposal sites on the National Priority List (NPL) (11.5% of all NPL sites). Ten to 12 additional NPL sites are likely to be proposed for FY'84. 1111 preliminary assessments have been completed. 237 are remaining, most of them in Alabama (83), North Carolina (69) and Florida (21). Some progress has been made in cleaning up Superfund sites. o Of the 48 Region 4 National Priority List sites, Enforcement is pursuing cleanup at 30 of the sites, while fund financed cleanup is being pursued at 7 of the sites. Six of the sites are being held back due to lack of State funding. o Contamination at two sites in Mississippi and Georgia was completely removed during 1982. Cleanup of a third site was completed in early 1983. Hazards at another 18 sites throughout the Southeast have been removed via the immediate removal program. 7. Pesticides The use of pesticides is proportionately greater in Region 4 than in other parts of the country. By the mid to late 1970's nearly two-thirds of the 86 million pounds of insecticides and 26% of the 98 million pounds of herbicides used were used in the South. Over 300,000 private and 50,000 commercial applicators have valid certifications to apply restricted use pesticides in Region 4. The percentages of pesticides used in the future are not expected to decrease. ------- -5- There have been some notable trends. o Reductions in complaints of misuse of pesticides in aerial applications have been noted in Mississippi (from 411 in 1981 to 61 in 1982). The Region attributes this to efforts on training and enforcement. o Deficiencies in pesticide products have been reduced (based on a random sample survey) by 350%', from 17% in 1973 to 4.5% in 1983. This improvement was attributed to the Regional pesti- cide program. o Finally, the violation rate for use/misuse investi- gations associated with drift has decreased based on the most recent two years of data/ but the violation rate still exceeds 60%. III. REMAINING AND EMERGING ENVIRONMENTAL PROBLEMS Overall, two points were clear throughout the report: 1) Unclear policy guidance and inadequate monitoring systems in several media are growing issues of concern within the Region (e.g./ ground water/ toxics, wetlands management). 2) Limited funds, particularly at the State level, limit ^ progress-on programs such as Superfund. The EMR did not rank significant problems across media, but did rank some of them within media. Following is a brief discussion of the significant problems outlined by media, followed by Headquarters actions the Region recommends on significant problems. A. Air Quality 1. Problems o Ozone and TSP are the primary problems in the majority of non-attainment areas in Region 4, with CO, ozone, and TSP problems in extension areas. There are 29 "Tier 11° non-attainment and 23 emerging and continuing non-attainment areas; approximately 11 million people, or 26% of the Region's population, are affected. o Region 4 has the highest incidence in the nation of tampering with vehicular pollution control devices (22%) and fuel switching (19%). This may be negating progress made through Transportation Control Measures. ------- -6- o Problems with TSP arise because States have not been successful in getting approval for or adopting State Implementation Plan elements. Problems with total reduced sulfur emissions in Region 4 are illustrative of the need for effective plans for noncriteria pollutants. o Rapid growth in both Class I areas and marginal air quality areas presents emerging problems of visibility, acid rain, and PSD increments. One example: large fish kills at a hatchery in the Southern Blue Ridge Province occurred within 2-4 hours after heavy rainfall." o Monitoring coverage has been narrowing due to reductions in networks and personnel. Poor data collection has been aggravated by States' reluctance to report data that might lead to non-attainment designations. o Less formal administrative actions are slowly replacing active enforcement procedures. As a result, compliance rates are becoming lower. 2. Headquarters Action Recommended o EPA policy on non-attainment areas needs to- be finalized. o State/local programs need information regarding the types of air toxics that should be controlled, and how emission/ambient standards should be established. o OAQPS needs to help resolve modeling issues related to generic State regulations. o OAQPS needs to assist in eliminating ambiguities in State regulations for national consistency. For example, OAQPS will likely have the lead in developing intermittent and fugitive dust test methods. o Headquarters should provide guidance on the effect of the economic turndown and its relationship to non-attainment status. o Headquarters should issue guidelines emphasizing the need to adopt all required SIP elements and to recognize that certain elements, which may be low priority nationally, are of greater concern in some Regions. o Contractual workshops for State and local programs, for such areas as operation and maintenance prac- tices, VOC inspections, and continuous emission monitoring, should be continued. ------- -7- o A national group to track meteorological conditions, should be established, and an emissions inventory should be developed that would better inform us about acid rain. o Increase support of Southern Blue Ridge Province Acid Rain Study. B. Surface Water The water quality problems in Region 4 were identified based on professional judgment of Regional staff using STORET data, State 305(b) water quality reports, and State and Regional review. Problems were ranked as high, medium, or low. 1. Problems a. Domestic and industrial waste discharges, causing toxic problems, oxygen depletion, and sanitary quality problems (High). o Pollution from agricultural and organic chemi- cals along with wastes from pulp mills are a high priority problem in 15 rivers and bays in Region 4. o Mercury, PCBs, DDT, Trichloroethylene.and Chlorine were described as widespread problems, attributable to discharge of toxics, natural conditions and historical land use activities. o Low dissolved oxygen and sanitary quality problems are attributed to poor municipal waste treatment plants, magnitude of discharges downstream, and non-point source pollutant loads. b. Land Development (High) o Canalization, filling and development of coastal wetlands has resulted in hazardous waste, fecal contamination and severe impacts on estaurine productivity and hydrology. c. Mining (Medium) o Many streams in Kentucky and Tennessee are exhibiting direct and indirect effects from runoff of toxic metals in coal mining; high dissolved solids from peat mining may be a problem in Eastern North Carolina? nutrients from phosphate mining may be a problem in central and south Florida; and oil and gas drilling causes problems in Kentucky and Eastern Tennessee. ------- -8- d. Electric Power Generation (Medium) e. Agricultural Practices (Low) o Runoff of sediments and pesticides from agri- cultural lands and lake quality are lower priority problems still needing action. f. Lake Quality (Low) 2. Headquarters Action Recommended o Assure that adequate toxics monitoring programs are maintained and develop a strong policy for toxicity testing and biomonitoring in the NPDES program. o Support a program of Operation and Maintenance training. o Work with the Food and Drug Administration to develop a national policy or procedure on the responsibility of each Agency toward developing sewerage facility plans for discharge to shellfish harvesting areas. o Promote and fully fund programs to protect wetlands. Strengthen EPA's 404 review role. o Encourage States to establish strict siting laws for power generation facilities. o Apply critical review relative to the Corps' issuance of general permits and subsequent trans- fer of the administration of these permits to the States. o Discussion with the Corps needs to emphasize Agency concerns about the Corps' solution to several wetlands problems: development of a mechanism to resolve exemption discrepancies and set enforcement priorities is badly needed. C. Drinking Water 1. Problems o Bacteriological Maximum Contaminant Level (MCL) and Monitoring and Reporting (M/R) violation rates are in excess of the national average, with the smallest systems (6.9% of community water supply systems) experiencing highest rates of violations (50%). Specific problem areas were: ------- o MCL violations in districts in Kentucky and Flordia; organic contamination of ground water in South and Central Flordia; turbidity, moni- toring and reporting violations in Kentucky? water shortage problems, especially on the East Coast of Flordia. 2. Headquarters Action Recommended o Reduce State budget cuts and continue emphasis on bacteriological contamination. o Develop health effects data on organic contami- nation — particularly for toxics not reviewed by National Drinking Water Advisory Council. o Develop a coordination program to address emerging water quantity problems and involve numerous Federal agencies responsible for water resources. Ground Water 1. Problems There is much variation in the nature and severity of ground water problems. Severe problems stem from: 1) spills and leaks; 2) uncontrolled sites; 3) RCRA land disposal 'sites; 4) oil and gas development; and 5) surface impoundments. Moderate problems result from mining and septic tanks. Limited problems are from agricultural activities, injection wells, landfills (other than RCRA sites)/ ground water development, and land application. Two areas where ground water problems appear to be most critical are the Biscayne Aquifier in Southeast Florida, which is the principal drinking water source for more than 3 million people, and oil .producing counties in eastern Kentucky contaminated by concen- trated salt brine. 2 . Headcuarters -Action Recommended EPA's ground water policy needs to be finalized with some additions including; o classroom and in-field training for State employees or. proper ground water monitoring procedures; o need for State resources to establish or expand monitoring networks, sampling and analysis and data management; and ------- -10- o revisions to Federal statutes to fill gaps or enable EPA to control waste disposal practices that threaten ground water but are beyond its jurisdiction. E. Hazardous Waste 1. RCRA a. Problems Region 4 described the RCRA program as not being old enough for a well defined data base which would allow specific environmental problem defini- tion. The Region also said State information is not timely. Some regulatory and management problems, though, were identified. They include: o Inadequacy of regulations in addressing synfuel facilities, hazardous air emissions, recycling, and burning of hazardous fuel. o Potential due to projected industrial growth for an increase in small generators of hazar- dous waste, increasing solid waste disposal, and greater need for recycling and alternative technologies, although EPA's policy currently de-emphasizes these areas. o Pending problems: lack of ground water moni- toring; inconsistency in training of State personnel under RCRA; possible loss of State authorization due to failure to receive final authorization by statutory date; and permits of land disposal facilities and CCRCLA planned actions. b. Headquarters Action o Expedite regulation development regarding synfuel facilities, recycling, and burning of hazardous fuel. o Develop ground-water monitoring regulations. o Shift RCRA funding to training of State personnel. o Extend the final authorization deadline. o Develop more stringent regulations to include small quantity generators. ------- o Resolve the question of whether CERCLA remedial and planned actions are subject to RCRA permit requirements. o Set up enforcement of permit quality requirements. 2. Superfund a. Problems Management problems were: o Cleanup of sites is hampered by requiring States to match funds throughout the remedial process. Only 3 Region 4 States have any method of cost sharing. o Policy guidance for cost recovery actions is ambiguous and/or nonexistent. o Emergency response program suffers from a variety of problems (e.g., lack of resources, reporting problems). o The most significant geographical concern is hazardous contamination of ground water. _o An average of 3-4 years is required from project initiation to project completion. Radiation 1. Problems o Insufficient shallow land disposal sites for low- level radioactive waste due to nationally accepted criteria and standards. o Accumulation of radon gas (a carcinogen) in struc- tures built on reclaimed phosphate lands, attributed to lack of a material standard. o Diminished quality of Nuclear Power Plant Utility/ States drills of radiation emergency response plans due- to economic and staffing constraints. 2. Headquarters Action Recommended o Need comprehensive and nationally accepted criteria for low-level disposal sites. o Generic national standard needed to control accuraula tion of radon gas. o Need standards regarding acceptable radiation levels ------- Pesticides 1. Problems o Aerial drift was singled out as a major priority problem. The violation rate per inspection for both agricultural and nonagricultural pesticide use has decreased but is still above 60%. This high rate is attributed in part to misuse of insecticides and termiticides. o Pesticide poisoning associated with product misuse is still a major concern. Data available from southeastern hospitals show that the yearly incident level for 1974-1976 has remained constant, with 45 hospitals reporting admissions due to pesticide poisonings. 2. Headquarters Action Recommended o Better guidelines for enforcement are needed in the areas of correct application and acceptable residues both on surfaces and in the ambient air. ------- |