ENVIRONMENTAL MANAGEMENT- REPORT
1984 UPDATE
S. Environmental Protection Agency
v- v.-
Region VIII
October, 1984
-------
EPA - REGION VIII
ENVIRONMENTAL MANAGEMENT REPORT
1984 UPDATE
I. REGIONAL ADMINISTRATOR'S OVERVIEW
EPA Region VIII administers federal environmental laws in the six-state
area which includes Colorado, Montana, North Dakota, South Dakota, Utah and
Wyoming. Much of the land in Region VIII is managed by the federal government.
These areas include pristine wilderness areas and Natiopal Parks, vast expanses
of forest and rangeland and extensive energy developments. Region VIII faces
the dual challenge of cleaning up existing pollution problems and protecting
unspoiled areas. Region VIII will face the major environmental problems listed
below over the next two years.
1. Hazardous Waste Control
The time, costs and complexity involved with the investigation, litiga-
tion, and clean-up of hazardous waste sites, makes this the most difficult
problem faced, by Region VIII. The potential effects to human health and the
high level of public concern make hazardous waste control the region's number
one priority, under the following two programs:
a. Superfund - the clean up of hazardous waste sites listed on
the National Priority List; and,
b. RCRA - the Resource Conservation and Recovery Act.
The major issues for RCRA include:
o Ground water concerns at land disposal facilities and wastewater
treatment units at refineries;
o Rocky Mountain Arsenal;
o Limited commercial hazardous waste disposal capacity in Region VIII;
o Permit issuance to treatment, storage, and disposal facilities (TSDF's);
o Non-compliance with RCRA by TSDF's and generators; and
o Closure of the Denver-Arapahoe Chemical Waste Processing Facility.
2. Ground Water Contamination
Ground water is a very difficult resource to understand and study, since
it is hidden from ready observation. Since ground water is the major source
of drinking water and of agricultural water in Region VIII, contamination is
widely recognized as a serious problem. The difficult nature of aquifer clean-up
intensifies the need for ground water control.
Ground water, especially in shallow aquifers, has largely been contaminated
by improper waste disposal, chemical usage, or well construction. Although many
federal and state programs provide protection for ground water quality, they
are generally designed to control specific problems such as hazardous waste
-------
-2-
disposal. Thus, because the approach has focused on narrow problem areas,
control has become highly fragmented. EPA and the states have recently begun
to take, a more comprehensive approach, including examining the activities of
agencies with ground-water protection responsibilities, identifying and
assessing uncontrolled sources of ground-water contamination, and devising
control measures.
The region and states have initiated several major actions to improve
their ability to deal with ground-water problems:
a. Region VIII has established a Ground Water Unit to develop
coordination for ground-water activities among EPA, states
and other federal government agencies. The Unit is assisting
states to develop strategies to deal with ground-water problems.
b. The Emergency Response team continues its work to clean up spills
which could contaminate ground water. A one million dollar Superfund
removal action to clean-up hazardous substances from a pesticide fire
in Brookings, South Dakota, led to investigations of pesticide con-
tamination around similar sites in the state.
c. Superfund grants to states allow them to investigate hazardous
waste sites with potential to contaminate ground water.
d. The Waste Management Branch is developing remedial investigation
plans for two major mine/mill sites which could affect ground
water: the Anaconda, Montana, site described below; and the
Cotter Uranium Mill, Colorado.
e. Wyoming is making significant gains in the control of unplugged
oil exploration holes.
3. Urban Air Quality
Urban air quality is still polluted by ozone, particulates, and carbon
monoxide in major metropolitan areas in Region VIII. Urban air quality is
a major concern because of the dangers to health in exceeding the national
standards, and because of the large numbers of people affected.
4. Nonpoint Source Water Pollution
Region VIII enjoys generally high quality water, and although we are
committed to restoring the quality of surface waters in the region, we are
also intent upon preserving the existing high quality waters so valued by
the people in the region. The overall quality of the surface water in the
region has not changed significantly in 1984. Of the stream segments
assessed in the states' 1984 water quality reports, approximately 75% met
the Clean Water Act goals for fishable, swimmable water.
The major nonpoint water quality problems in the region are loadings
of nutrients, sediment, salinity, and discharges of heavy metals from in-
active or abandoned mines.
-------
-3-
5. Toxics and Asbestos Contamination
Region VIII has been working closely with schools to assure implementa-
tion and compliance with asbestos regulations. The region hired an additional
staff-member to provide technical assistance to school districts; we began to
to inspect school districts in 1984. The major problem is the failure by dis-
tricts to notify Parent-Teacher Associations when asbestos is found during sampling.
In addition, many school districts do not have the money to remove or encapsulate
asbestos after it has been identified.
Region VIII performed 50% more PCB inspections in FY 1983 than it did in
FY 1982, but reported about the same number of violations. The region is ex-
ploring the problem of PCB contamination of mine waters.
Under the National Dioxin Strategy, state and EPA monitoring will soon
begin in Region VIII, to look for dioxin residues at sites where dioxin may have
been generated 1n the past. Monitoring at Tier 7 control sites has begun. The
cooperation being nurtured between state agencies and between programs within
EPA is a significant step toward enhancing the environment.
6. Acid Deposition
The effects of acid rain upon mountain lakes have not yet been fully
examined. Region VIII will expend much effort over the next four years
to study acid rain effects upon lakes and streams; and upon the wildlife,
fishing, and recreational activities which might also be affected.
7. Pesticides Exposure
In Region VIII, acute toxicity problems related to pesticides usage occur
infrequently. While much of the Regional enforcement work is directed toward
economic losses caused by improper pesticide application, most public concern
is health-related; and involves either longer-term, low-level exposures, or
"chemical trespass", the unknown or unwanted exposure caused by the movement
of pesticides beyond the application site.
Region VI11' s emphasis is focused on two approaches: increased com-
pliance with proper pesticide use and disposal procedures to prevent problems;
and cooperation with state agencies and other EPA programs to gather informa-
tion on existing and emerging problems, so that corrective actions may be taken.
Hazardous waste grants fund limited programs to collect and dispose of small
quantities of unwanted chemicals, mainly pesticides, from schools and farms.
Pesticide funding is, being used to study levels of pesticides in ground water,
drinking water, and wildlife tissue in several states within Region VIII.
8. Radiation
EPA's primary radiation role is to reduce unnecessary and avoidable
radiation doses from environmental sources. Although the Agency has worked
on discretionary sources, such as material for industrial and medical purposes,
where individuals are selectively exposed; the primary thrust is population
exposure to ambient levels, and avoidable increases to those levels. EPA
should therefore focus on control of naturally-occuring substances to reduce
-------
-4-
ambient radiation levels.
Region VIII expects significant reductions in environmental radiation
dose-over the next 5 to 10 years, because of controls on radioactive emissions.
Unfortunately, we also anticipate a dramatic Increase in dose to some people,
brought on by elevated levels of radon progeny 1n energy-efficient, sealed
homes. Also, expansion in the communications industry has increased exposures
of the public to non-ionizing radiation through microwaves and radiofre-
quencies.
9. Drinking Water Quality
Compliance with drinking water regulations has emerged as the one good
measure of how well the intent of the Safe Drinking Water Act is being met.
National guidance has set compliance targets for 1984 and beyond. Five states
in Region VIII needed definite improvement over 1983 to meet their targets.
The State of Colorado was at or near its targets already. Utah's level of com-
pliance 1n 1983 was one of the worst in the Nation. The Utah drinking water
program has instituted many changes to Improve compliance, but it will be the
highest priority for Region VIII oversight in the drinking water program for
the next several years. The strengthening and tracking of enforcement actions
will also be a priority. The region hopes to improve both bacteria and tur-
bidity compliance in all states.
10. Municipal Discharges
Municipal discharges of ammonia impede progress toward the Clean Water
Act goals for swimmable, fishable waters in the region.
11. Indian Lands
Region VIII contains many large Indian reservations which require the
identification and assessment of environmental quality, especially under
the PSD program.
12. Wetland Protection
Region VIII states contain a wide variety of freshwater wetlands
ranging from the extensive prairie pothole complexes 1n the Dakotas to the
high alpine wetlands of the mountain areas. These valuable areas are
becoming increasingly threatened by extensive water development projects
throughout the Region, recreational development in the mountain areas and
urban development along the Wasatch Front in Utah.
13. Federal Facilities
Region VIII currently has the fourth largest concentration of federal
facilities in the United States; with over 2,920 federal installations in the
region, encompassing more than 120 million acres. Environmental problems at
these installations include nonpoint source and other ground-water contamina-
tion from abandoned hazardous waste sites.
-------
-5-
II. REGIONAL ENVIRONMENTAL PROBLEMS
The major environmental problems facing Region VIII over the next
two years are detailed below.
1. Hazardous Waste Disposal
a. Superfund - Hazardous Waste Site Clean-Up
Region VIII has 18 sites on the National Priority List. A list of these
sites and the major concerns for each, appears on Attachment B-l. The major
environmental issues associated with these sites are:
o Contract lab program backlog delays site investigations (pre-NPL
listing) and remedial investigations at NPL sites. The problem is especially
acute for organic chemical analyses, especially in the summer when Region VIII
conducts most of its sampling. The problem may be alleviated as new labs
enter the system;
o Many sites are very large; laboratory and personnel resources are not
adequate to properly address all issues in a timely manner. For example,
the Anaconda NPL site is 10,000 acres;
o Project officers have to spend considerable time justifying RI/FS
workplan scopes to potential responsible parties; and,
o Requests for voluntary PRP-lead cleanup at non-NPL sites is resource
intensive.
Proposed additions to the NPL list, displayed in Attachment B-2,
also present difficulties:
o Ground-water and related contamination caused by mining operations;
o Pesticides ground-water contamination at Rocky Mountain Arsenal;
o Plutonium and other radioactive contamination in a water supply
reservoir near the Rocky Flats facility; and,
o Federal facility contamination such as buried mustard gas can-
nisters, phosgene gas, and munitions manufacturing wastes.
b. Issues under RCRA
(1) Ground Water Concerns at Land Disposal Facilities and Wastewater
Treatment Units at Refineries
Sixty-two facilities are required to meet ground-water monitoring require-
ments under RCRA, the Resource Conservation and Recovery Act* About 60% of
these sites have surface impoundments, waste piles, and landfills. Because of
their impact upon ground-water, about 50% of these sites are in a ground-water
monitoring assessment phase. Also, about 40% are refineries which use land-
-------
-6-
fills, land treatment, and waste piles for management of their hazardous waste.
There are wastewater treatment units at refineries which are not explicitly
regulated, but could threaten nearby rivers. Region VIII believes that haz-
ardous waste deposited into these units could leach into ground water. Refin-
eries vehemently object to having new wastewater treatment units regulated.
(2) Rocky Mountain Arsenal, Commerce City, Colorado
A major environmental problem at this site is contamination of ground-water
by constituents specific to the manufacture of chemical warfare agents used by
the Army, and pesticides manufactured by Shell Chemical Company. Contamination
is caused by the chemical manufacturing processes and poor waste management
practices. Over 25 different constituents are being examined by the ground-
water monitoring program at the Arsenal: Di-isopropyl-methylphosphonate (DIMP),
Di-bromo-chloropropane (DBCP), Di-cyclopentadene (DCPD), and several pesticides.
There is extensive contamination of a large-volume ground-water aquifer,
and environmental concerns over the storage of hazardous waste in containers
and in surface impoundment. The public is highly concerned over studies showing
off-site contaminant movement which could affect heavily-populated areas and
agricultural zones. Regulatory authority is divided among RCRA, Superfund, and
Underground Injection Control (UIC). The Army sued Shell, its tenant, for over
$1 billion, for ground-water contamination. Possible airport expansion onto this
site increases environmental concern.
(3) Limited Commercial Hazardous Waste Disposal Capacity in Region VIII
Region VIII has only one operating commercial landfill, which is located
in a remote area in Clive, Utah. The site, owned and operated by U. S. Pollu-
tion Control, Inc., has limited landfill disposal capacity, but does have
large capability for land treatment of wastes such as oils. EPA is evaluating
a permit application for the Highway 36 Land Development Corp. facility near
Last Chance, Colorado. The permit proposes that sixteen 3001X6001X30' cells be
built over ten years. Unlike the Utah site, this one is subject to intensive
opposition from "Concerned Citizens of Eastern Colorado". Hazardous waste gen-
erators who are unable to recycle their waste, must ship them to disposal sites
as far away as Alabama. Costs for disposal are high and present additional con-
cern for transport safety. Colorado is concerned about the landfill capacity
and has a statute which provides for site designation based on technical issues.
(4) Permit Issuance to Treatment, Storage and Disposal Facilities (TSDF's)
There are 129 treatment, storage and disposal facilities that require
RCRA permits. Region VIII has requested 35 applications from storage and
treatment facilities, 3 from sites which have incinerators, and 28 from land
disposal units. There are 21 high priority land disposal facilities whose
permits pose environmental concern over improper management of wastes. Per-
mits for these sites must be issued with conditions for addressing these
environmental concerns. About 50% of the facilities opt to close rather than
obtain a RCRA permit. These closure approvals are often complicated by environ-
mental concerns which need to be addressed, and by the ambiguity of the closure
regulations.
-------
-7-
(5) Non-Compliance with RCRA by TSDF's and Generators
Over the past 4 years, the Region VIII has aggressively pursued non-compliance
incidents at facilities which generate, transport, treat, store or dispose of
hazardous waste. During 1984, non-compliance appears to have decreased from
earlier years, but it is still evident, especially in ground-water monitoring.
Non-compliance with regulations occurs in all six regional states. Impacts
are greatest in the more industrialized areas: Denver and Salt Lake City metro
areas; and at refineries throughout Utah, Colorado, Montana, Wyoming, and North
Dakota. Since the media and the public are keenly interested in RCRA non-
compliance, Region VIII frequently issues news releases on enforcement actions.
(6) Closure of the Denver-Arapahoe Chemical Waste Processing Facility (DACWPF)
In June, 1982, the Colorado Supreme Court ruled that the hazardous waste
disposal activities at the DACWPF were illegal. The end of disposal activities
affected most of the states in Region VIII, since this was one of only two
commercial facilities in the Rocky Mountain area.
Inspections of waste generators were intensified to reduce and prevent
illegal disposal incidents. Despite these efforts, several instances of
abandonment of drums containing hazardous wastes occurred. Public concern has
been very high and and wel1-organized. The media often spotlight the facility's
problems. In addition, industries have had to use other disposal facilities,
in some cases as far away as Texas, California, or Alabama.
Formal closure of the facility pursuant to RCRA interim status regulations
was recently initiated with the issuance of an EPA-modified closure plan. The
plan involves exhumation of all wastes buried in the landfill. The plan requires
off-site redisposal of bulk wastes, liner material, and contaminated soils. On-
site disposal can occur in a new burial cell, reconstructed from the existing evap-
orative ponds, only if approvals are obtained from state and county agencies. If
approvals are not obtained by April, 1985, the plan required that all waste and
contaminated materials be shipped to an off-site facility.
The public has participated in two public hearings and three comment periods
on the proposed plan. Two citizen action groups and a task force established by
the Governor are also involved in monitoring closure activities. The public is
especially concerned about the site, because the Superfund site, Lowry Landfill,
is located approximately one mile south.
2. Ground Water Contamination
Ground water contamination is caused by a wide variety of factors:
(a) Tank, Pipe and Impoundment Spills, and Leaks - Chemical, oil, and
brine spills and leaks are a continuing problem in all Region VIII states,
especially in or near urban areas. Buried tanks and pipelines cause
special concern and are a major study item at present. Currently there
is a lack of both state and local authority and funding for the control
and cleanup of spills.
-------
-8-
(b) Abandoned Waste Facilities - Numerous old hazardous and
municipal waste facilities exist in all Region VIII states. Many of
these sites have been identified, but no assessment of their poten-
tial'on ground water has yet been made. Region VIII and the states
are inspecting and assessing sites to determine 1f they should be placed
on the NPL. Many of the abandoned municipal sites are located 1n old
gravel pits in floodplains. Access to these sites is difficult and makes
assessment very costly.
(c) Septic Systems - All Region VIII states have identified septic
systems as a potentially major source of ground-water contamination,
caused by improper construction and design. System failures have led
to increased nitrate levels; which can contaminate the low yield, frac-
tured rock aquifers found in many mountain areas. The actual magnitude of
septic tank problems in the Region is still unknown. The use of septic
tank cleaners and their effect on ground water needs to be studied.
(d) Chemigation - Chemigation is the application of fertilizer,
pesticides, or herbicides through a central pivot sprinkler system.
Chemigation can cause ground-water contamination in two ways: (1) over-
application of chemicals, resulting in contamination of shallow ground
waters; and (2) back flow of the chemical directly into the aquifer via the
supply well. Agricultural areas which use central pivot systems are
prevalent in all six Region VIII states. The system's economic advan-
tages may lead to its increased use.
(e) Water Well Construction - Improperly constructed water supply
wells exist in all Region VIII States. Most of these wells are for
private, domestic use. The principal construction defect is lack of
a proper seal around the well to prevent surface contamination from
entering the aquifer.
(f) Mining Wastes - Ground-water contamination from mine waste
has occurred at several locations in Colorado, Wyoming, Utah and Montana.
Preliminary studies show a potential for increased levels of heavy metals
in shallow aquifers. Several mine/mill sites have been placed on the
National Priority List (NPL) of hazardous waste sites, and are in various
stages of remedial investigation. Waste Management Branch is investigating
several other sites for possible inclusion on the NPL.
Several existing programs assist with ground-water contamination
problems:
a. Hazardous waste contamination - Superfund program;
b. Hazardous waste generation, transport, storage and disposal-
Resource Conservation and Recovery Act (RCRA) program;
c. Underground injection of materials - Underground Injection
Control (UIC) program; and
d. Pesticides use - Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA) program.
-------
-9-
The RCRA, UIC, and FIFRA programs can delegate authority to the states.
Ground-water protection activities in these programs are on-going, and emphasis
will be similar to previous years. Major resource increases in Superfund will
result in increased program activity.
The Ground Water Protection Unit has responsibility for implementing the
National Ground-Water Protection Strategy in the region, including: proposing
methods for improving coordination of efforts among regional programs, states,
and other federal agencies; and working with states to identify needs and
to develop comprehensive programs.
Region VIII has the following priority concerns:
a. Assessing the impacts of leaking gasoline/oil storage tanks on ground
water. States with sufficient information should proceed to investigate their
authorities and alternatives for control.
b. Assessing the ground-water impacts from the direct application of
fertilizers and pesticides through central pivot irrigation (chemigation).
EPA needs to develop guidance and recommendations for controls of ground-
water contamination.
c. Increasing aquifer assessment to identify new areas of concern and
to improve information on known problems, such as improper well construction
and improperly constructed septic systems.
Region VIII requests the following actions from Headquarters:
a. Speed up the development of guidance on alternatives for control
of contamination by oil/gasoline or chemical storage tanks (OPTS, OSWER).
b. Complete verification of the results of the Surface Impoundment
Assessment (SIA). Develop guidance for the states to implement the SIA
recommendations (Office of Drinking Water).
c. Make the Sole Source Aquifer (SSA) regulations final. Strengthen the
criteria defining which federally-funded projects can be reviewed in the SSA
process, including any direct federal actions. Develop guidance clarifying
state role in SSA activities (Office of Drinking Water).
d. Develop guidance on coordination of state ground-water data bases
(OGWP).
CASE STUDY: CLARK FORK RIVER, MONTANA
The Clark Fork River flows approximately 350 river miles, carrying more
surface water out of Montana than any other river. The river and Lake Pend
Oreille, Idaho, are used for recreational activities, drinking water, and
irrigation, but communities and industries also discharge wastewater into
the Clark Fork.
Contamination of the Clark Fork could affect both public health and the
environment in Montana, Idaho and Washington. Environmental concerns center
-------
-10-
on the effects on fishing and other recreational activities, such as boating
and swimming. Contamination of drinking water supplies is a primary public
health concern, especially for the ground-water aquifer serving Spokane.
Significant heavy metal contamination sources include Silver Bow Creek, the
Anaconda smelter and Mi 11 town waste site.
The Montana Department of Health and Environmental Sciences (MDHES) has
held public hearings on its proposed modification of Champion Paper's
wastewater discharge permit. The hearings attracted many concerned citizens
from both Montana and Idaho. The governors of the two states held signifi-
cantly different opinions, and only after MDHES planned a comprehensive study
of the Clark Fork did public opposition to the permit modification subside.
In response to a request from the Montana, Region VIII reprogrammed EPA
state water program grant funds to support a comprehensive study of the Clark
Fork. Corrective actions will be proposed after the study is completed in
July, 1986. Region VIII and its Montana Operations Office will coordinate the
efforts of Idaho, Montana, and Washington, in conjunction with Region X. EPA
needs to provide funding needed to complete the work by June, 1986, when many
NPDES permits are due for renewal.
CASE STUDY: ANACONDA SMELTER, MONTANA
The Anaconda Smelter, covering 10,000 acres in Anaconda, Montana, was listed
on the National Priority List of hazardous wastes sites in December, 1982. The
site's copper smelting activity has caused heavy metal contamination of build-
ings and soils. Tailings may have contaminated surface and ground waters, en-
dangering public health. This contamination could affect surrounding ground
water, which is a source of drinking water; and the Clark Fork River, described
above. Airborne contaminated soils might be inhaled by the surrounding
population.
The public is highly concerned with the site and with the potential health
problems posed by both the current demolition activity, and by the actions pro-
posed to correct contamination effects. The community of Anaconda is struggling
to balance its opposing needs for employment by the demolition crew, and its
fears of exposure to heavy metals.
Region VIII has placed an on-scene monitor on smelter hill to oversee
demolition activity, requesting $120,000 to continue monitoring during 1985.
Region VIII has requested $1.6 million to work with Montana and with the
Anaconda Minerals Company to assure that remedial actions will be performed
by 1986.
-------
-11-
3. Urban Air Quality
Region VIII will continue to address the major urban air quality problems
associated with particulates, carbon monoxide and ozone. Particulates are the
most widespread air problem in the Region, affecting both large urban areas
and many smaller towns. Future violations are probable of both the current
standard for total suspended particulates (TSP) and of the proposed standard
for fine particulates (PM"|o)«
The particulate problems in Region VIII are generally caused by auto and
and truck exhaust, power plants, smelters, steel plants, unpaved roads, wood-
burning stoves, fireplaces, and construction work. The principal barriers
to achievement of the TSP standard include:
a. The difficulty and cost of controlling non-traditional sources
such as fireplaces, wood stoves, street cleaning, sanding and
construction work;
b. The dry, windy conditions typical in the region, which encourage
reentrainment of fugitive dust; and
c. The uncertainties associated with the proposed change to the PM]q
regulations.
The Denver metropolitan area has the most serious air pollution problem
in Colorado. The "Brown Cloud" haze, visible over Denver on many mornings, is
very familiar to the public. The haze is caused by extremely fine particles
representing only a portion of the TSP in the air. Eight to 33% of the particu-
late matter causing the haze comes from residential wood burning. In many moun-
tain communities, wood-burning is the only significant source of particulates
other than fugitive dust. Many mountain areas have exceeded the annual TSP
standard every year since monitoring began.
EPA has not yet addressed the relationship between wood combustion and
exceeding the TSP standard. Although control has been effective with stationary
source violations in Denver, the area still exceeds the national standard by 100%.
Mountain communities are still unclassifiable under the Rural Fugitive Dust Policy.
Wood-burning will be a critical issue when developing the State Implementation
Plans (SIP's) for PM^q in projected non-attainment areas.
Several Colorado communities have begun to address the woodburning issue
themselves. Aspen and Crested Butte have established building codes which
prohibit more than one wood combustion unit per building, unless the additional
units meet clean burning specifications. Other communities have launched public
information programs that identify the problems from woodburning, and educate the
public on the proper methods to burn wood, while lessening particulate emissions.
The Colorado Air Quality Control Commission has received legislative authority to
develop emission limits for woodburning stoves and to design specifications
for fireplaces installed after July 1, 1987. The state has also begun a
testing program to develop reasonable emission limits and to design fireplace
specifications prior to the rulemaking effort.
-------
-12-
Region VIII assists local communities and the State of Colorado through
technical advice and grant funds when possible. The region funded a Colorado
woodburning survey for urban areas; and co-sponsored a workshop on woodburning
attended by all six regional states, and some local representatives. Recently,
"Colorado received a $75,000 grant amendment increase to test and set emission
limits, and to design specifications for woodburning devices. The region sees
a continuing need for technical and financial assistance to states. EPA must
address the contribution of woodburning emissions to the existing TSP problem
and the potential PM]q problem.
Power plants in the Denver area are replacing.scrubbers with baghouses, which
will provide more effective control of fine particulates, and should reduce power
plants' contributions to the Denver "Brown Cloud". Colorado is considering ad-
ditional controls for emissions from woodburning and from mobile sources, such
as diesel vehicles.
Headquarters OAQPS must develop a policy for revising SIP's on particulate
control as soon as possible. States need to address both known TSP violations and
probable PM^q violations. EPA also needs to make the PM]g standard final.
Carbon Monoxide and Ozone
Carbon Monoxide (CO) concentrations in the region's populated areas
continue to be the most aggravating problem and affect the most people.
Carbon monoxide problems all stem from mobile source emissions in urban areas:
the Colorado cities of Metro-Denver, Fort Collins, Greeley, and Colorado Springs;
Salt Lake City, Utah; and the Montana cities of Missoula, Billings, and Great
Falls. Denver and Salt Lake City are the only two areas in the region which
have not attained the ozone standard. Caused primarily by vehicle emissions,
the ozone problem may be reduced to the standard by 1987. Public concern over
air quality is high in Denver, moderate in Salt Lake City, and low in Montana.
Region VIII has or will approve SIP's for all areas. The Region proposed
to disapprove the Colorado SIP's plan to abate CO in Denver, which called for
voluntary non-drive days and the need for legislative authority for portions
of the inspection/maintenance program. Colorado has responded to the proposed
disapproval with innovative approaches to the CO problem such as a gasahol
research program, and with additional information. The notice published in
the Federal Register, March 5, 1984, requires Colorado to submit before
approval of the CO portion of the SIP, the following assurances:
a. The demonstration of capability to predict high CO levels;
b. A monitoring plan to drive participation in the voluntary
ride-share program;
c. Revaluation of the ride-share program after one year; and
d. An implementation schedule for contingency strategies such as gasahol,
mandatory ride-sharing, or warranty enforcement.
Region VIII will provide $100,000 in grants to Colorado this year to assist
in the ride-sharing effort, and plans to provide an equal amount in 1986. The
Region has requested additional funding from Headquarters. The Regional EPA
and GSA are coordinating a major ride-sharing campaign this year for the Federal
agencies' 40,000 employees and for Colorado. Entitled "Better Air - You Hold the
Key", the state campaign has an estimated budget of $500,000 per year.
-------
-13-
In. January, 1979, Utah submitted a revision to its SIP, citing inadequacies-
in the county-operated inspection/maintenance (I/M) program in Davis and Salt Lake
Counties. The I/M program's deficiencies led to EPA's proposal to disapprove that
portion of the Utah SIP, and to issue a construction ban for the two counties for
major CO and volatile organic compound (VOC) sources. Utah has now obtained
legislative authority to adopt and enforce its I/M program. Schedules and regu-
lations were submitted for enforcement mechanisms in the counties' I/M program.
The counties have geared their efforts to meet the scheduled November, 1985,
attainment date for ozone; and the November, 1986, attainment date for CO.
The region submitted a Federal Register notice for Headquarters' approval and
signature in May, 1984.
If the CO and ozone SIP's are approved as anticipated, the region must
then continue to monitor progress toward attainment and compliance, under the
requirement for Reasonable Further Progress (RFP). The federal high altitude
standards have contributed to the attainment of standards in Denver and Salt
Lake City. Colorado receives funds to perform the Federal Test Procedure
at high altitude to determine how well vehicles comply with the standards.
The Office of Mobile Source Air Pollution Control (OMSAPC) must continue to
fund this program to insure continued progress by manufacturers, and by states
such as Colorado and Utah, toward the goal of attaining CO and ozone standards.
EPA must also develop guidance and procedures on RFP in order to assure
attainment by 1987.
4. Nonpoint Source Water Pollution
Nonpoint source pollution is the cause of water quality problems in 5 out b
states in Region VIII, affecting approximately 3 million people. Some states
report that over 90% of their water quality problems are caused by agricultural,
natural, and human-induced activities. Nonpoint pollutants include sediment,
nutrients (nitrogen and total phosphorus), salinity (total dissolved solids) and
fecal coliforms. Nonpoint pollution from stock raising activities, such as run-
off from croplands, rangelands, pastures and farmsteads, is responsible for most
use impairment in the region. These pollutants most frequently impair recrea-
tional and aquatic life uses. Public water supply and agriculture uses are
affected to a lesser extent.
The region has been very active both nationally and regionally in nonpoint
efforts. Examples of current activities include: Lake Herman, South Dakota, Model
Implementation Project in agriculture; Oakwoods-Poinsett, South Dakota, and Snake
Creek, Utah, Rural Clean Water Projects; Fifteen-Mile Creek, Wyoming, Study; and
Spiritwood Lake Watershed Project, North Dakota. All of the state programs for
control of agricultural nonpoint source pollution involve voluntary participation
emphasizing education, demonstration projects and technical assistance. Coordina-
tion of nonpoint source implementation activities with Soil Conservation Service,
Agricultural Stabalization and Conservation Service, state Game and Fish Depart-
ments, and other local entities, has achieved significant success within states.
However, many of the region's nonpoint source water quality problems are
still unsolved. Success in correcting nonpoint source problems in the region
is limited by difficulties in implementing changes to land use practices and by
lack of funds. Although Section 208 planning grants provided financial assistar
to states for nonpoint source development, EPA has failed to continue state
assistance specifically directed toward implementing programs to control nonpoint
sources.
-------
-14-
A1though some state nonpoint source activities are eligible for funding,
competing priorities have allowed only a small percentage of funds to be directed
toward non-point source activities. State Programs have relied on funds from the
Agricultural Conservation Program; Clean Lakes; State Game and Fish Departments;
Soi^ Conservation Service; and local funding. However, this approach has had
substantial limitations.
Region VIII will continue to assist states to secure implementation funds and
to provide technical assistance. The ongoing actions of the National Nonpoint Source
Task Force, and the legislation pending in Congress, will significantly affect the
nonpoint source program. Headquarters efforts should be tailored toward developing
policies and guidelines for regional implementation of a nonpoint program (even
lacking legislation or new funding). The policies and guidelines should assist
states to reprogram existing grants funds (106, 205j, and 206g) to solve nonpoint
problems and to provide a framework to use new EPA funds. EPA also needs to al-
locate personnel resources for the implementation program, and for personnel ex-
changes between EPA, other federal agencies and states. Intergovernmental ex-
changes can foster program development and cooperation. Funding should also be
available for extramural nonpoint projects in regions. OFA and 0W should focus
attention upon federal lands' compliance with nonpoint source activities.
a. Salinity
Salinity (total dissolved solids) is a major basin-wide water quality
problem in the Colorado River system. The salinity issues concern seven
basin States: Wyoming, Utah, Colorado, New Mexico, Nevada, Arizona, and
California; three EPA Regions: VI, VIII, IX; and the Departments of
Interior and Agriculture. In addition, the United States has treaty obli-
gations limiting the salinity of the waters delivered to Mexico. Current
salinity damages in the Lower Basin are approximately $113 million a year.
The Department of Interior expects a rise to $267 million a year by 2010,
if adequate salinity control is not provided. Salinity in the Colorado
River results primarily from nonpoint source pollution. Virtually any water
or land use activity can affect salinity.
EPA Region VIII is the lead coordinator for the activities of the Colorado
River Basin Salinity Control Forum and the Interagency Salinity Control
Coordinating Committee.
Several EPA programs address salinity control: (1) Water Quality Manage-
ment Planning, (2) Water Quality Standards, and (3) National Pollutant Dis-
charge Elimination System (NPDES) permits. States have the primary role in
directing these programs; EPA retains the critical role of oversight and
and approval. EPA also influences salinity through its review responsibilities
under the Environmental Impact Statement (EIS) program.
In the future, EPA must become more involved in the planning and develop-
ment of Federal salinity control projects. Region VIII needs continued Head-
quarters support on regulatory reform, examining innovative approaches to
salinity control, such as the off-set and bubble policies. Headquarters
should keep regions informed on the progress of proposed legislative amend-
ments to the Colorado River Basin Salinity Control Act.
-------
-15-
b. Abandoned/Inactive Mines
Inactive and abandoned mines throughout Region VIII, primarily found in
Colorado, Montana and South Dakota, continue to pose significant environment-
al- problems. Neither the states nor EPA has established policies for control-
ing the pollution, particularly acid mine drainage, at mine sites. Seepage
from old mine tailings and discharges from abandoned mines have polluted
streams and rivers.
Heavy metals such as copper, zinc, lead and cadmium; dissolved solids;
and acidic water pose the greatest threat to aquatic life. Montana lists
six stream segments affected by mine drainage. Colorado is most affected by
mine drainage, particularly the following streams: Clear Creek, Arkansas
River, Red Mountain Creek, Oak Creek, Kerber Creek, Animas River, and
Peru Creek.
Clean-up of some of these segments has been accomplished. Feasibility studies
are under way for other problem sites, hopefully to take advantage of the reclama-
tion dollars funded through the Abandoned Mine Land Reclamation Program; but as
yet, little has been done for water pollution control. EPA must first develop
and then implement a water control policy, and assist states in the discharge of
similar actions.
5. Toxic Substances
Region VIII has identified three toxics priorities which should be addressej
by the Agency: asbestos in public buildings, PCB's in underground mines, and th
disposal of small quantities of chemicals.
a. Asbestos in Public Buildings
EPA Headquarters is currently developing regulations for the control
of asbestos in public buildings. Although the regulations will begin to
close a substantial gap in public health protection, Region VIII is concerned
that current resources are inadequate to assist building owners with compliance.
b. PCB's in Underground Mines
PCB-containing equipment has traditionally been widely used in underground
mines for two major reasons: (1) the need to minimize high fire hazards in coal
mines and heavily timbered hard rock mines; and (2) the small size of PCB trans-
formers, which require less rock removal for substation construction. Our ex-
perience has been that this equipment is often abandoned underground when a mine
is closed because it is not cost-effective to bring it to the surface, even if
the equipment is in good working order.
Thus far, Region VIII has inspected only hard rock mines. We have found
extensive use of PCB equipment, along with a high rate of violation. We expect
that coal mines employ even more PCB's than do hard rock mines, because of the
greater potenial fire hazard. Our inspectors have found large quantities of
PCB's in newer mines, and in associated mills and other surface structures,
such as those at the Henderson molybdenum mine near Empire, Colorado.
-------
-16-
We have also discovered PCB's in many older mines on the verge of abandon-
ment. Older mines, such as the Eagle Mine in Gilman, Colorado, pose serious
problems, since abandoned equipment can contaminate ground or surface waters.
If Region VIII had not entered the Eagle Mine under an emergency Superfund re-
moval action to remove PCB transformers and capacitors, 3000 pounds of PCB's
would have been left in the mine to be eventually inundated by 400 feet of water.
The equipment then would have been irretrievable, and certainly unexaminable.
As the water levels inside the mine rose, PCB's from the abandoned equipment
could have been carried into to Eagle River, and then into the Colorado River.
Generally, there are no written records maintained for PCB's in these older
mines. Employees working in the mines are the only ones who know what kinds
of equipment were used or left underground; and when'a facility closes, this
knowledge disappears.
Equipment abandoned in underground mines is not only a regional issue, but one
which can have serious consequences to ground or surface water wherever under-
ground coal or hardrock mining takes place. We recommend that additional Agency
Agency resources be devoted to addressing this problem.
c. Disposal of Small Quantities of Chemicals
EPA needs to fund and encourage the safe disposal of small quantities of
unwanted chemicals, including household products, pesticides, paints, and other
chemicals. Many concerned homeowners wish to dispose of such materials in an
environmentally-sound manner, but don't know where or how to do so. Several
hazardous waste (RCRA) grants have been awarded to fund collection and disposal
programs for pesticides, but they have been limited in scope and not widely
publicized.
Unfortunately, most of these chemical wastes are probably dumped into
sewers, or end up in sanitary landfills not designed to handle them. The
amount of waste discarded by any one household may not seem substantial;
however, when one considers the number of households in large urbanized areas,
the amounts become significant. Unsafe disposal of these chemicals could lead
to ground and surface water contamination. Preventive measures are the most
environmentally-sound and economical means to address potential water contamina-
tion problems. EPA needs to educate the public about the environmental impacts
of improper disposal, and to develop collection and disposal programs similar
to the one initiated by the State of Florida.
6. Acid Deposition and PSD
The Clean Air Act gives managers of Class I areas the responsibility
to protect land values related to air quality. These values include plants,
animals, soil, water and visibility. The Prevention of Significant Deteriora-
tion (PSD) regulations require investigations of source emissions in Class I
areas. Findings of potentially adverse effects can lead to permit denial.
Region VIII is now particularly concerned with the values for Colorado
Flat Tops and Mt. Zirkel Wilderness, and for the North Dakota Theodore
Roosevelt National Park. The large scale development of oil shale reserves
could affect environmental values in Colorado. Values in North Dakota and
Wyoming are being threatened by new power plants, synfuel plants, and
oil and gas fields.
-------
-17-
Acid rain (acid deposition) may already be affecting high altitude lakes
in Colorado, which are extremely sensitive to changes wrought by acid rain.
Large scale industrial development could impair visibility in the Flat Tops
Wilderness and Colorado's western slope. Knowledge and concern about acid
rain -continue to grow in the public mind, especially in Western tourism areas.
Much of the concern over acid rain effects has been focused on the North-
east. A limited, but growing body of data indicates that acid rain conditions
exist in the West, including Region VIII. These data suggest the possibility
of significant environmental problems. Region VIII has therefore participated
in an intensive lake study in Flat Tops Wilderness, and a reconnaissance study
in the Mount Zirkel Wilderness, both in Colorado. In addition, the Region has
assisted the Forest Service in its intensive lake studies in the Bridger/
Fitzpatrick Wilderness areas in Wyoming, and is participating in an intensive
lake and terrestrial study in Mount Zirkel.
Emissions trading will be tested and applied in the western half of North
Dakota, since the Class I increment of sulfur dioxide (SOg) has already been
consumed by sources surrounding Theodore Roosevelt National Park. Changes to
the increment have been granted to energy companies to construct facilities
near the park. These variances will increase ambient SO2 levels by approxi-
mately 15%, according to a 1982 EPA study. The same study also concluded
that participation in the emissions trading program would allow increases in
power generation and gas production over the current amount without degrading
ambient air quality at the park.
The question of how permitted sources may affect the air quality of
Class I areas is one of the major concerns in permitting programs, such
as PSD and New Source Review, for major energy development areas. EPA
needs to develop a model which can accurately predict the creation and
effects of acid rain, by using proper chemical, dispersion, and deposition
inputs to the model.
EPA also needs adequate data bases for each of the high altitude Class I
areas in order to predict the problems that might arise, or to assess the mag-
nitude of existing problems. Major studies are now underway in the Northeast
to collect and analyze baseline data on acid rain, but only a pilot study is
planned for the West. It is imperative that similar studies be conducted to
address the extent of the problem in Region VIII.
Western regions need the support of EPA research and development
funding in the following areas:
(1) Collection of background data in Class I areas, and
(2) Development or modification of mesoscale models to predict
acid rain effects.
-------
-18-
7. Pesticide Contamination
The problem of ground-water contamination cuts across all of the environ-
mental media; however, few baseline data are available on water quality or
ground-water movement and depth. Pesticide applicators seem unaware of the
potential for ground-water contamination. Consequently, potentially harmful
practices are common, such as improperly applying perticides through irrigation
systems, or applying pesticides without knowledge of water table depth. In
addition, pesticide use enforcement is based upon whether the applicator followed
the directions on the label. Current labeling doesn't provide sufficient infor-
mation or advise applicators on appropriate precautions and procedures. These
factors, plus the difficulty of cleaning up contaminated aquifers, make ground-
water contamination a very serious problem throughout the region.
Region VIII had been concerned about the improper disposal of used pesticide
containers. Many used containers were classified as hazardous waste under RCRA,
making disposal difficult and costly. Containers were also being put to inapprop-
riate uses such as barbeque grills or pier supports. However, Increased public aware-
ness of the hazards of pesticides, and the fact that triple-rinsed containers do not
need to be treated as hazardous waste, have led EPA to view the container disposal
issue as more of an economic problem than as an environmental one. Of greater
concern than the containers is the disposal of unusable pesticides and the
rinsates from washing pesticide equipment. The problem is widespread, involving
everyone from the homeowner to the large commercial pesticide applicator. Most
people cannot afford to ship the material to hazardous waste landfills or to
incinerators, and very few persons are even aware of the requirements for safe
disposal. Economics and ignorance set the stage for illegal dumping, with all
of the associated health and environmental consequences.
8. Radiation
a. Indoor Radon Progeny
Several areas in the nation experience elevated levels of radon gas
exhaled from soils. These are typically mineralized areas such as the
Rocky Mountain Region. When radon is released to the atmosphere, it is
immediately diluted to inconsequential concentrations by the ambient air,
especially by breezes. Radon which finds its way into homes, however,
becomes trapped and decays to further radioactive species which can
accumulate to levels that are associated with significantly Increased
lung cancer risk. Energy conservation measures which reduce ventilation
rates also increase the radon daughter concentrations in homes.
In 1978 the Montana Department of Health and Environmental Sciences
discovered elevated radon daughter levels which exceeded EPA guidelines in
many homes in Butte. Realizing the public health Implications of radon in
homes and the state of the art of radon daughter measurement, the Office
of Radiation Programs sponsored a study of measurement techniques using
Butte as a laboratory. This was the most extensive study of radon daughter
measurement techniques ever attempted. However, the study did not address
techniques for lowering the radon daughter concentrations in homes. Many
such remedial alternatives have been proposed and implemented, but no
-------
-19-
study comparing cost and effectiveness has been attempted. The results
of such a study would be very important as the nation strives to tighten
residences against air infiltration.
"b. Superfund (CERCLA) Actions
Under the authority of Superfund, the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), sixteen uncontrolled radio-
active hazardous waste sites have been identified in Region VIII. The sites
are concentrated in Colorado, with several other sites located in Utah, North
Dakota, and South Dakota. All sites are associated with past generations of
mining, milling, or refining of radioactive material. In some cases, ore was
processed for the radioactivity content (uranium or radium); and in others, such
as vanadium production, the radioactivity was an unwanted contaminant. In all
cases, the radiation issue results from technologically-enhanced, naturally
occurring radioactivity remaining 1n the waste materials. These are subject to
further degradation, and are a source of radiation exposure to the public.
c. Inactive/Abandoned Uranium Mills
In November, 1978, the Uranium Mill Tailings Radiation Control Act (UMTRCA)
became law. In the Act, Congress ordered EPA to develop standards for the de-
commissioning of 24 inactive uranium mill sites and surrounding contaminated
properties. The law was designed to manage the health risks associated with
uranium mill tailings, which pose a greater long-term Ingestion hazard than
than does high level waste from nuclear reactors.
EPA published Its standards for the 24 inactive mill sites in January, 1983.
Sixteen of the 24 sites are in Region VIII. We hope that within 7 years, every
one of the 24 sites will have been decoirmissioned. However, delays and rising
costs jeopardize the prospects for a complete cleanup.
d. Active Uranium Mills
The Uranium Mill Tailings Radiation Control Act also specified that EPA
develop standards to protect public health and safety from hazards associated
with tailings at active sites. EPA issued draft standards in 1983. These
limited emissions of radiation and hazardous materials from active and decom-
missioned facilities to prevent the spread of contamination. For years, a
number of tailings impoundments were designed to leak to discharge excess
water. Contaminated aquifers have been the result. The "active mill tailings
standards," will insure that such designs are not used in the future.
The active site standards may also be used to delineate cleanup criteria
for aquifers and lands which have become contaminated by accidents or leakage
currently licensed mills.
e. Radioactive Waste Disposal
Since the December, 1980, Congressional legislation for Regional com-
pacts for disposal of low-level wastes, the states have divided into inter-
state compact groups. In Region VIII, states have divided into three compacts,
-------
-20-
with one state negotiating with two compact groups. Colorado produces by far
the largest quantity of wastes, and has taken the lead, financed by the Depart-
ment of Energy, in completing the Rocky Mountain Compact. Since two states in
the region have not elected to affiliate with the Rocky Mountain Compact, leads
for negotiations Involving those states are outside Region VIII.
Our current primary concern is an apparent lack of commitment by some
states to form timely and economically feasible compacts. It appears that the
states' main interests are in minimizing their role and liability. Region VIII
is also concerned with the timely development of EPA low-level waste standards,
which will affect regional waste management policy to b,e published in draft form
in late 1985.
Another radioactive waste disposal issue is high-level waste. Military
high-level and transuranic wastes are the sole responsibility of the federal
government, and they are temporarily stored at Federal facilities. Spent fuel
assemblies from commercial nuclear power plants are currently kept in rapidly-
filling storage pools at the plant site. Storage pools are nearing capacity,
since the federal policy 1s not to reprocess spent fuel in order to prevent
Plutonium proliferation.
Although the region is not affected by the shortage of storage space, one
of the prime areas under review for a waste disposal repository is located
in Utah. This site 1s being considered for inclusion in a list of five
candidates from which the best site will be selected in 1985, with construc-
tion scheduled to begin about 1990. As might be expected, the site has
caused considerable controversy which should increase dramatically as the
Congressionally mandated dates draw nearer.
9. Drinking Mater Compliance
The Public Water System Supervision Program fPWSS) now has several years
reliable compliance data on Public Water Systems (PWS's) to use as a basis for
program action. Since the emerging trends have not well defined compliance im-
provement, national program guidance began to set specific compliance targets
for bacteria and turbidity (cloudiness). Because of their universality and acute
hazard, EPA emphasizes these two contaminants. Attachment A compares the 1983
compliance levels for Region VIII states, and the nation as a whole with the
bacteria targets.
As the chart shows, Region VIII levels of compliance were slightly lower
than the national averages, and both were short of the 1984 targets. Colorado
appears to have high levels of compliance, whereas Utah's level is average.
Data verifications have shown Colorado's level to be slightly higher; Utah's
level, slightly lower; and accuracy in the levels of the remaining states.
The data from South Dakota were not confirmed, since the state accepted
enforcement delegation last January. Wyoming is the only state which has not
yet accepted delegation of the program.
Utah's compliance 1s low, not only compared with other states in the region,
but also compared with the other 56 states and territories. Utah's 1983
maximum contaminant level (MCL) compliance rate for bacteria is higher than only
-------
-21-
five territories: Virgin Islands, American Samoa, Northern Mariana Islands, Guam,
and the Trust Territories of the Pacific. Utah's compliance level for bacteria
monitoring surpasses only those of Alaska and the Trust Territories.
Thus, Utah is the region's highest oversight priority 1n Drinking Water.
Improvement may begin to show soon, however. Utah has a vigorous, dedicated,
well-staffed program; and has instituted many changes which should lead to
increased compliance over the next few years. Utah is unique in that a large
number of systems rely on spring water, and in that it lacks requirements for
mandatory disinfection of water systems. The state will have to contend with
both of these factors in order to improve upon its current compliance rates.
Other oversight priorities Include bacteria monitoring in Montana, bacteria
levels in North Dakota, and turbidity compliance in all states in the region.
A few violations of chemical and radiological MCL's have occurred,
primarily in the two Dakotas. About 90 PWS's have slight violations of the
flouride MCL. EPA must resolve the controversy surrounding the national
flouride standards. The region will continue to focus its efforts upon
compliance with the regulations and meeting our compliance targets. The
new initiatives both for program oversight and for direct implementation
of drinking water regulations are:
a. Implementation and refining of compliance strategies;
b. Emphasis on elimination of persistent violators;
c. Quarterly updates of compliance data and verification;
d. Increased enforcement activity; and
e. Improved tracking of enforcement.
Region VIII will also consider waterborne disease outbreaks, particularly
in the primacy State of South Dakota, and in the non-primacy State of Wyoming.
The Region will need to increase program efforts toward non-community systems,
which have been neglected in the past.
10. Municipal Discharge
Over the last several years, all six regional states have identified
increasingly significant levels of ammonia discharges into streams receiving
wastewater treatment discharges. Each state has at least 3 facilities violating
water quality standards for ammonia. Ammonia was discovered in 27 stream segments
at various levels. Levels of aranonia can affect fish and other aquatic life.
High levels of ammonia can be caused by needs for plant upgrading, operational
or maintenance problems, or inexperienced personnel; but not all problems can
be directly attributed to these factors.
Region VIII reviews all NPDES permit renewals, and new permits for
ammonia limits. Municipal permit self-monitoring data and ammonia in-stream
surveys by states have provided important information on toxicity to aquatic
life. The region has advised states to concentrate efforts on stream segments
with potential use impairment. A list of potential advanced treatment pro-
jects within the region has been shared with states, and the region will
provide technical assistance to evaluate projects and to develop alternative
solutions to advanced treatment.
-------
-22-
Region VIII has conducted 3 on-site acute and chronic bioassays with its
newly completed mobile lab, in Rapid City, South Dakota; Dickenson, North
Dakota; and in Longmont, Colorado. Bioassays develop information on toxics to
support the need for ammonia control. The region will assist states to strengthen
their capability to perform more on-site bioassays.
All states in Region VIII continue to build their capability to perform
wasteload allocations (WLA's). Ammonia toxicity issues are still the central
focus. The region must assist states to integrate new Headquarters guidance
into existing state procedures, in concert with sound technical approaches
to WLA development. EPA needs to fund field studies to improve state WLA's.
11. Indian Lands
Indian tribes in Region VIII are generally very interested in preserving
their excellent air quality. The Northern Cheyennes and Flathead Indians of
Montana have already redesignated their reservations to PSD Class I. Develop-
ment of energy resources near reservations may create Class I or Class II
PSD increment violations on the reservations. Other reservations, such as
the Crow Indian Reservation, are interested in developing their mineral re-
sources. Such development could produce air quality problems on reservations
and neighboring lands. Presently, EPA grants are being used by Indian tribes
for baseline data collection, regulation, development and redesignation studies
for PSD areas.
12. Wetland Protection
Region VIII states contain a wide variety of freshwater wetlands ranging from
the extensive prairie pothole complexes in the Dakotas to the high alpine wetlands
of the mountain areas. These valuable areas are becoming increasingly threatened
by extensive water development projects throughout the Region, recreational devel-
opment in the mountain areas and urban development along the Wasatch Front in Utah.
13. Federal Facilities
Region VIII has over 2,290 Federal installations, covering more than 120
million acres. The most significant environmental problems at these instal-
lations entail ground-water contamination resulting from abandoned hazardous
waste disposal sites, and the storage and disposal of hazardous waste. The
regional office provides technical assistance to the Department of Defense
installations, and occasionally acts as a cooperating agency. State and local
pollution agencies are encouraged to monitor federal facilities and to share
the data obtained with the regional office.
The public concern for environmental problems at federal installations is
very high because of the toxicity of the substances involved. And, there is
a perception in the private sector that there is less enforcement of regulations
at federal facilities than at private installations. Region VIII, with the
cooperation of NEIC, has developed a multi-media ranking of selected federal
installations according to their relative potential for environmental problems.
Approximately 42 installations were identified as having problems, ranging form
major to minor.
-------
-23-
14. Energy Development
EPA Region VIII states contain an abundance of the Nation's energy resources
1n the form of coal, oil shale, uranium, oil, natural gas and tar sands. With over
half the Nation's surface mineable coal and uranuim; and essentially all of the
economically attractive oil shale and tar sands, Region VIII states contribute
significantly to the Nation's energy needs. Such development, if improperly done
can exact a significant environmental cost.
The Region will continue to emphasize environmentally sound energy development
through existing regulatory programs, cooperation with state and federal agencies
and the development and review of Environmental Impact Statements.
-------
-24-
III. REGION VIII RECOMMENDATIONS FOR AGENCY PRIORITY LIST 1986 - 1987
Region VIII recommends the following items for inclusion on the Agency
Priority List for fiscal years 1986 - 1987.
1. Hazardous Waste' Control - contain hazardous materials through control,
investigation and cleanup actions
a. Superfund (CERCLA) Actions - (1) investigate and perform removal and
remedial actions for sites on the National Priority List; and,
(2) perform removal actions at spills and at non-NPL sites when
there is immediate and significant risk to human life or health
or to the environment.
b. Resource Conservation and Recovery Act (RCRA) Actions:
° Insure through oversight of delegated programs that states
are effectively carrying out implementation of RCRA;
° Through inspection, permit programs, and oversight, ensure that
ground water contamination at TSDF's is addressed;
° Issue (or deny) RCRA permits to the Highway 36 Land Development
Corporation and the U.S. Pollution Control Incorporated commercial
disposal sites in Colorado and Utah respectively and to remaining
non-commercial TSDF's;
° Develop regulations or guidance at the national level to remove the
many RCRA exemptions, regulatory loopholes and ambiguity pertaining
to:
- Mining, energy exploration, and fly ash exemptions;
- Recycle exemption for a characteristic waste;
- Closure of a site with a characteristic waste;
- Wastewater treatment units at refineries under RCRA; and
- Closure/post-closure clean-up standards.
2. Ground Water - Region VIII recommends that Priority Number 6 concerning
implementation of the Ground Water Strategy remain as is on the Agency
FY 86-87 Priority List. Needs for ground water protection efforts will
remain as a top Regional priority.
3. Enforcement - enforcement of all environmental legislation and
regulations for all EPA programs should be a high-level priority
throughout the Agency.
-------
-25-
3. Urban Air Quality - continue efforts to abate the high levels of ozone,
particulates and carbon monoxide; increase funding for state efforts;
finalize the PMio standard; develop guidance and procedures to assess
reasonable further progress; and continue to fund high altitude
emission testing for motor vehicles.
4. Nonpoint Source Water Pollution - implement strategies to control surface
water loadings of nutrients, sediment, and salinity from nonpoint sources.
Closely monitor federal facilities and assist with ground-water control.
5. Toxics and Asbestos Contamination -
a. prevent future groundwater contamination problems by developing
broad-based, economical collection and disposal systems for
small quantities of unwanted chemicals, including household
products, pesticides, paints, etc.
b. expand effort to inspect underground mines for PCB-containing
equipment, and require removal of PCB's before mines are closed.
c. publish Agency regulations on asbestos in public buildings;
provide Regions with additional resources for implementation.
6. Acid Deposition - fund studies of acid rain effects on Western Regions,
and develop dispersion models to predict deposition and effects.
7. Pesticides Contamination - increase compliance with use and disposal
procedures; collect information on problems; monitor control sites for
such pesticides as dioxin. Regional priority ranking of pesticides is:
a. Ground water Contamination by Pesticides,
b. Pesticide Misuse,
c. Pesticide Drift,
d. Pesticide Disposal, and
e. Pesticide Contamination of Wildlife.
8. Radiation - change the priority list in the following ways:
a. Insert after #8: Implement a study of indoor radon progeny con-
centrations, and cost-effective control measures for new and ex-
isting structures.
b. Insert after #20: Issue standards for the control of ambient levels
of microwave and radiofrequency radiation.
9. Drinking Water Quality - The Region VIII drinking water program agrees
with the current priority list in the 1985-6 guidance, as long as the
fluoride MCL problem gets resolved (part of priority on top of page 14)
and the regional program receives adequate resources to handle new
efforts, e.g., VOC monitoring.
10. Municipal Discharges - develop strategies to control ammonia levels in
surface water discharged by municipal wastewater treatment facilities.
-------
ATTACHMENT A
too?;
3-OK
s&k.
y 70K
i
d eo*
& SOK
U1 4U.K
O
tx
m
a 30K
20K
1 OK
OK
FY S3 BACTERIOLOGICAL MCL
/ / /
¦/'/,
89%
v
-r
ND
77/
/ / .•••'
'V / ..¦
77'
i
'//>
/ v
X//A
¦' / /
\///<
///<
•vv,
777/
91.5%
y 77
vfry
/ /.
•V
/ /
/
'///
57.5%
fr/z.
S / /
;///¦
¦7/7
•vtv
V /
^ y v
&//.
7 y t s
yyy.\
•///
s
90%'"
SD
UT
VfV
>
y / X
(///
y//
///;
~T~7
'Wy1
/// J
y
'///
r ///
' / / /
86%'
90%
TARGETS
.3-5 YR (95%)
'FY84 & FY85 (93%)
VMl
NATL.
iook
3-OK
SOK
70S
'//
'fry'/
-'y'/'A
w /
r77/
/ / t <
/ ¦* /
/' /¦' /¦'
65.5%
""r-
f / / /
S/
¦' i
/ J
VA"
V.I I
r-
X//1
7 x*
f'
¦ iii
r-*"-
NATL
•3-5 YR (90%)
-FY85 (85%)
•FY84 (79%)
-------
-26-
11. Indian Lands
Wotk with Indian tribes to implement a program which begins to identify
and assess environmental quality, especially under the PSD program.
12. Wetland Protection
a. Resolve outstanding Section 404 issues between EPA and the
Corps of Engineers;
b. Enforce Section 404 more vigorously;
c. Increase use of Section 404 (c);
d. Increase emphasis upon wetland protection and mitigation
in the EIS process; and
e. Increase emphasis on wetland research and wetland information
transfer.
13. Federal Facilities - control ground water contamination and nonpoint
surface water pollution resulting from abandoned hazardous waste.
-------
ATTACHMENT B-l
EIGHTEEN NPL SITES
Site/State
Broderick Wood
Commerce City,
Colorado
California Gulch
Leadville, Colorado
Central City
Clear Creek,
Colorado
Denver Radium Sites
Lincoln Park
Canon City,
Colorado
Lowry Landfill
Arapahoe County,
Colorado
Lead
Federal
Enforcement
Federal
Enforcement
Federal
Response
Federal
Enforcement
Not Deter-
mined
Federal
Enforcement
Major Concern
Groundwater contamination
resulting from wood treat-
ment process firm.
Toxic metals in ground and
surface waters - from mine
operations.
High concentrations of
metals in surface water
from acid mine drainage.
Low level radiation con-
tamination at 31 sites
throughout Denver.
Groundwater contamination
due to past co-disposal at
landfil1.
Groundwater contamination
due to past co-disposal at
landfill.
Marshall Landfill
Boulder County,
Colorado
Negotiated
Response &
Federal
Enforcement
Landfill contamination into
ditch used as drinking
water supply.
Sand Creek Federal Old 1anfill, refinery, pes-
Commerce City, Enforcement ticides formulator, acid
Colorado waste disposal ponds con-
taminating area - 300 A
max.
Actions
Draft Workplan for RI/FS
in review.
Community Relations Plan
ongoing. RI/FS started.
Workplan to start RI/FS
underway - by
CH2MHill.
Workplan revisions for
disposal site selection
in process.
EPA & State coordination
investigation - license
renewal by state.
Negotiating RI/FS with
PRP's. Denver construct-
ing treatment facility
in compliance with 106
Order - civil action
filed against Denver
for 106 violation.
Initial Remedial Measure
(IRM) i.e. pipeline in-
stall across landfill to
protect water supply.
Leachate collection
system pending.
RI/FS(initial stage) un-
derway - immediate re-
moval underway at pesti-
cide site. Also, D.O.J,
involved in responsible
party not complying in
order.
-------
ATTACHMENT B-l
-2-
Woodbury Chemical
Denver, Colorado
Anaconda Smelter
Anaconda, Montana
East Helena Site
Helena, Montana
Libby Groundwater
Libby, Montana
Mill town Reservoir
Montana
Silver Bowl
Deer Lodge, Montana
Arsenic Trioxide
Southeastern North
Dakota
Whitewood Creek
Lead, South Dakota
Rose Park Sludge
Salt Lake City, Utah
Baxter/Union
Pacfic Site
Laramie, Wyoming
Federal
Response
Negotiated
Response &
Federal
Enforcement
Federal
Enforcement
Negotiated
Response &
Federal
Enforcement
Federal
Response
Federal
Response
Negotiated
Response &
Federal
Enforcement
Negotiated
Response
Negotiated
Response
Negotiated
Response &
Federal
Enforcement
Pesticide contaminated
rubble.
Cleveland Wrecking selling
arsenic contaminated
material to buyers.
Heavy metal contamination
of surface/groundwater &
dust in air due to smelter
operation.
Hydrocarbon contamination
at tie treating plants.
Reservoir contaminated with
heavy metals from mining
activities.
Sediment from mining opera-
tion washed downstream into
reservoir.
Elevated arsenic in public
groundwater supplies - pos-
sibly due to heavy use of
arsenic pesticides.
Gold mining tailings along
18 miles of Whitewood Creek
- Arsenic contamination of
ground & surface water.
Refinery sludge seepage to
surface & potential G.W.
contamination.
Ground & surface water con-
tamination due to railroad
tie treating.
Site secured with fence.
RI/FS to be completed
December 84.
Issued 106 Order to de-
contaminate, material
being removed.
Expect to have 106 Order
signed by 4 Sep. ASARCO
to do ground/surface
water & risk assessment.
Issued 106 Order - May
have second responsible
party - FIT Team inves-
tigation.
New distribution system
under construction. Next
issue: What to do with
reservoir.
State has cooperative
agreement to conduct RI/
FS - concern about ade-
quate funding for state.
RI/FS in progress. Ex-
pected completion in FY
86.
Homestake, EPA & state
complete three party
investigation agreement
by December 1, 1984.
Cleanup completed. Site
deletion pending.
Unio Pacific is conduct-
ing RI/FS, RO/RA - under
consent order.
-------
ATTACHMENT B-2
PROPOSED NPL LIST - NOT FOR PUBLIC RELEASE - TO BE FINALIZED BY FY'86
Site Name Lead Major Concern
Acid mine drainage.
Eagle Mine
Gilman, Colorado
Rocky Flats
Golden, Colorado
Rocky Mountain Arsenal
Denver, Colorado
Smuggler Mine
Aspen, Colorado
Federal
Enforcement
Federal
Enforcement
Federal
Enforcement
Uravan Uranium
Project
Uravan, Colorado
Burlington Northern
Tie-Treatment Facility
Somers, Montana
Idaho Pole Wood
Processing Plant
Bozeman, Montana
Mouat Industries
Columbia, Montana
Hill Air Force Base
Ogden, Utah
Mayflower Mountain
Tailings
Wasach County, Utah
Ogden Defense Depot
Ogden, Utah
unknown
Federal
Enforcement
Not
Determined
Federal
Enforcement
Federal
Facility
Not
Determined
Federal
Facility
Plutonium & other radioactive contamination in
nearby water supply reservoir.
Groundwater contamination by pesticides by Shell
Chemical, 2 munitions manufacturing.
Lead, zinc, & cadium contamination in old mine,
2 mill tailings, blowing dust, ground & surface
water contamination.
~Potential child health study for lead
scheduled for September '84.
Low-level radium radiation due to wind blown &
water contamination.
Tie-treating contamination within 2,000 feet
of city water intake.
Shallow groundwater contamination due to
tie-treating process.
Chromium Ore Processing - suspected soil/ground
& surface water contamination - on & off site.
Arm^ordnancejuried on site. Organic contami-
nation found'in seepage impacting surface water.
Existing precious metal tailing ponds that leak,
contaminating surface and groundwater. Potential
ski area and resevoir proposed downgradient.
Buried mustard cannisters, phosgene gas
container on site - Other wastes (metals,
organics) buried on site.
-------
ATTACHMENT 8-2
Monticello Radioactive
Mill Tailing
contaminated site
Southeastern Utah
Olsen/Neihard
Reservoir
Wasach County, Utah
Portland Cement
Kiln Dust - Site 2 & 3
Salt Lake City, Utah
Sharon Steel
Midvale Smelter
Midvale, Utah
Toole Army Depot
Toole, Utah
-2-
Federal Radioactive mill tailings used in structure and
Fund backfill around residential structures.
State
One and one/half mile downstream from mountain
reservoir - potential surface and groundwater
contamination.
Federal High concentration^of heavy metals in
Enforcement airborne kiln dust in residential area.
State
Smelting slags, approximately 2 million tons -
potential ground & surface water contamination.
Federal Existing arsenic, TNT, & DNT found in ground &
Facility surface water & soil. Army depot is doing RCRA
groundwater assessment program.
-------
ATTACHMENT C
EPA REGION VIII
1984 EMR UPDATE
MOST SIGNIFICANT ENVIRONMENTAL PROBLEMS
Characterizations
Relative ranking of
Environmental ProtTTems
Hazardous Waste Control
Ground-Water
Contamination
Urban Air Quality
Nonpoint Source Water
Pollution
^sbestos
PCB's
Acid Deposition
Pesticides
Radiation
Drinking Water Quality
Municipal Discharges
Geographic
Scope
Region-
wide
Region-
wi de
Major
Impact
Potential
threat to
ground water
Threat to
drinking
water
Level of
Concern
High
Moderate
to High
Major
Sources
Abandoned
sites
Contaminants
of Concern
Hazardous
materials
Chemigation
and other
factors
Region- Threat to
wide,esp. human health
Denver,
Salt Lake
(2M people)
Very High Vehicle
in cities emissions
Pesticides
Ozone, CO,
Particulates
Region-
wi de
Region-
wide
Region-
wide
Region-
wi de
Region-
wi de
Region-
wide
Region-
wide
Region-
wide
Water uses
of about 3
million people
Public
health
Potential
threat to
ground water
Water uses
Threat to
drinking &
ground water
Potential
threat to
human health
Threat to
human health
Water uses
Moderate
Moderate
to high
Moderate
Moderate
to high
Moderate
to high
Moderate
Moderate
Moderate
Agriculture, Nutrients,
live-stock sediment,
Building
Insulation
Underground
transformers
in mines
Needs to
be studied
Several
factors
Several
factors
Several
factors
Municipal
facilities
salinity
Asbestos
PCB's
Sulphur,
nitrogen
compounds
Dioxins,
others
Indoor
radon
progeny
Bacteria,
turbidity
Ammonia
------- |