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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.

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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

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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:

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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

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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.

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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

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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.

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