ENVIRONMENTAL MANAGEMENT REPORT
1985 UPDATE
.S. Environmental
Regi on
September
Protection Agency
VIII
1985
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1985 Environmental Management Report
HE6I0N VIII UPDATE
CONTENTS
Page
Part I Regional Administrator's Overview I
Part II Regional Environmental Problems:
Ranking Criteria/Procedure 5
Hazardous Waste Control
Superfund 6
RCRA
8
Ground-Hater Contamination 1Q
Urban A1r Quality 22
Nonpoint Source Pollution 25
Toxic Substances 27
Clean-up and Disposal of Radioactive Waste 29
Acid Deposition In Western Wilderness Areas 21
Pesticides 23
Drinking Water Quality 26
Toxic Substances in Surface Waters 27
Part III Regional Recommendations for the Agency Priority List 30
Appendix A (Standard Table) i
Appendix B (Environmental Indicators) i11
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PART I
REGIONAL ADMINISTRATOR'S OVERVIEW
The Region VIII staff 1s growing to recognize the usefulness and
necessity of the Environmental Management Report (EMR) as a critical and basic
planning tool. The suggested format for the 1985 update further strengthens
the popularity and utility of this document In the Region. Excessive
narration 1s eliminated and major problems, solutions and results are
presented precisely and logically. This format allows for ease of comparing
and prioritizing problems across media as well as within and between regions.
We envision the EMR as becoming a mechanism In Region VIII which can allow the
integration of programmatic and management goals to enable the development and
implementation of programs to solve our significant environmental problems.
As we prepare the 1985 update, we find that the status of the priority
problems previously identified have not changed significantly and that the
rankings are essentially the sane. Nevertheless, some noticeable
environmental results have been achieved during the past year.
The report addresses the major problems in Region VIII listed 1n rank order:
Hazardous Waste Control (Superfund - RCRA)
Ground-water Contamination
Urban Air Quality
Nonpolnt Source Water Pollution
Toxic Substances
Clean-up end Disposal of Radioactive Waste
Acid Deposition in Western Wilderness Areas
Pesticides
Drinking Water Quality
Toxic Substances in Surface Water
HAZARDOUS WASTE CONTROL (Superfund - RCRA)
Hazardous waste control 1s ranked as the Region's most difficult
environmental problem and number one priority not only because of its
potential effects on human health and the High level of public concern it
generates, but also because of the overwhelming time, costs and complexity
involved 1n investigation, litigation and cleanup of waste sites.
During the past year, immediate public health or environmental threats at
seven NPL sites have been abated. These Involved contamination of a drinking
water supply, radiation hazards due to radon daughter exposure in structures,
and direct public contact with high concentrations of heavy metals and
pesticides In surface sails. Nwrfy *5,000 drums have been exhumed at the
Oenvtr-Arepahsa CMfftteal Waste Processing Facility (Aurora, Colorado) and
shipped out of state for disposal. This site provides striking evidence of
the degree of public concern regarding hazardous waste control: the public
hearings have been well-attended, media coverage has been extensive, and there
has been involvement by two citizen action groups and a task force established
by the Governor.
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Much of the creosote and pentachlorophenol in the ponds at the Union
Pacific Tie Treatment Plant in Laramie, Wyoming, have been shipped off-site.
With 160 acres of gross contamination reaching the aquifers and the nearly *
Laramie River, this facility has been a major environmental and regulatory
(RCRA/CERCLA) problem for the Region.
Other major closure/cleanup actions underway Include the Rocky Mountain
Arsenal, Martin Marietta, Burlington Northern and several oil refineries.
SROUMO-WATER CONTAMINATION
The potential for contamination of ground water, the major source of
water for drinking and agricultural uses in this Region Is the second highest
priority problem. Nearly ninety percent of regional public water supplies and
ninety five percent of rural supplies depend on ground water. Here in the
arid west, there are no viable alternatives to the continually expanding use
of ground water for potable, irrigation and industrial demands.
A major accomplishment during FY 85 was the organization and staffing of
the Regional Ground-Water Coordination Office. Even under ever compressing
schedules and sparse guidance, the office has made positive initiatives to aid
and encourage our states In formulating and upgrading ground-water protection
programs.
URBAN AIR QUALITY
Region VIII continues to experience a1r quality problems with carbon
monoxide, 02one, and particulate matter 1n the large urban communities.
Particulates remain the most widespread problem in the Region, affecting both
urban areas and many smaller towns. Over 3 million people are exposed at some
time to elevated levels of these pollutants. The air Quality control measures
projected in the 1984 EMR update are now in various stages of implementation.
The first year of the ride sharing program for Colorado was implemented last
November and lasted through January. Monitoring Indicated that the planned
one-day per week - no drive- portion of the SAP resulted in a vehicle mile
traveled (VMT) reduction of about 3*. The States goal for the program was a
5X reduction the first year, which was expected to increase to 15* by 1987 as
Individual behavior changed. Next year's program will emphasise high
pollution days. The effort to reduce driving on high pollution days had very
little impact, and there seemed to be little, 1f any, reduction in driving due
to either the program or forecast high pollution days. Citizen participation
did improve over the course of the urogram.
The orimarv contingency measure 1« the Colorado SIP is to use gasohol.
Testing on 52 vehicles has demonstrated that CO reductions of at least 20% can
be obtained from oasohol use. The State is now considering a voluntary
g«Sol !?ogrX EPA has authority under.ZH<€K4)- of the $l«an Air Act to
promulgate a mandator gasohol requirement, 1f it is necessary, to attain the
ambient air quality standard.
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NONPOINT SOURCE WATER POLLUTION
Recent water quality reports Indicate that approximately 75% of stream
segments 1n Region VIII meet Clean Water Act goals for flshable, swinmable
water. Reglonwlde studies have been performed to determine levels of
pollutant impairment to stream beneficial uses. Eighty-five to ninety percent
of all pollutants violating water quality standards and classified as
threatened, moderate or severe levels (as defined by ASIWPCA) can be
attributed directly to nonpolnt sources.
Major contributors to regional nonpolnt problems Include discharges of
heavy metals from abandoned or Inactive mines and severe loadings of
nutrients, sediment and salinity. Over the past eighteen months several
projects which contain major NPS components have been In progress.
Implementation of Watershed/Clean Lake projects at Lake Herman and Sylvan Lake
In South Dakota and at Splrltwood Lake, North Dakota are completed. Three
other projects have been Initiated 1n Utah. EPA has also Initiated a multiple
ownership planning/best management practices study of silviculture 1n Montana
and directed a large portion of Agriculture Conservation Program funds Into
NPS watershed activities.
Formal meetings and discussions have been held In each state between
leaders of agriculture agencies and the Regional Administrator's Office.
PESTICIDES AND TOXIC SUBSTANCES
Pesticides and toxic substances, though treated separately 1n this report
as media problems, are Inseparably Intertwined with the other priority
problems of hazardous waste control, groundwater contamination and drinking
water quality. Human exposure to these materials presents major health
concerns, yet our ability to control the presence of these materials in the
environment is limited and has serious reglonwlde Impact because they affect
the total population at some time 1n some way.
The major problem thrust of the discussion on pesticides and toxic
substances 1n the Regional Environmental Problems Section of this report, is
directed towards Influencing and obtaining Headquarter's action and support to
address and develop additional policies, regulations and training to promote
the safe and effective application, cleanup, removal and disposal of the
common and familiar toxic materials with which we live.
CLEAN UP AND DISPOSAL OF RAPIOACTI\€ WASTE
The CERCLA National Priorities List of December 30, ig82, provided
authority for expenditures from CERCLA Superfund resources for site
Investigation, cleanup (where justified) and disposal of 31 former radium
processing sites. Since 1979, EPA and State Surveys have Identified 44
properties 1n the Denver Metropolitan area with possible low-level radioactive
contamination. These properties, collectively known as the Denver Radium
Site, were added to the Superfund NPL in 1983. Under a cooperative agreement
with EPA, the Colorado Department of Health has developed seventeen individual
site engineering assessments and remedial action plans.
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Remedial action on the Vitro Mill Site 1n Salt Lake City got under way
early in July 1985 when the first rail shipment was made to the CUve, Utah
depository about 80 miles east of Salt Lake City. Completion of this cleanup
1s set for 1st Quarter 1988. Another favorable action was achieved in July
for the disposition of the Durango, Colorado mill tailings. The 8odo Canyon
site was officially selected by DOE as the depository for Durango Tailings.
Remedial Action 1s scheduled from 3rd Quarter 1986 thru 1st Quarter 1988. At
Edgemont, South Dakota remedial action on vicinity properties is expected to
be completed by October 1986 rather than the summer of 1987.
ACID CPOSITION
Region VIII states and EPA are currently being called upon to make
multl-million dollar PSD permit decisions and adequate information on acid
deposition Impacts Is not available. The situation 1s aggravated by the large
number of Class I wilderness areas 1n close proximity to existing and proposed
air pollution sources. These sensitive alpine ecosystems may also be Impacted
by other major sources including existing and projected upwind smelters.
Several representative lake and watershed studies have been conducted
over the past three years at sites representative to typical high elevation
ecosystems. Several Federal agencies have been Involved in these studies
which are basically designed to provide valuable detailed information on the
sensitivity of lakes to acidic deposition and to detect any trends 1n acid
rain effects. Detailed chemical and biological data have been collected at
lakes In the Wind River Range of Wyoming and In the Mt. Zirkel Wilderness Area,
Flattops Wilderness Area and Rocky Mountain National Park 1n Colorado.
These studies will continue during the 1985 field season and are planned as
long term monitoring sites for atmospheric deposition effects. In 1985, an
additional site Is planned in the San Juan Mountains of southwestern Colorado
based on the potential acidic deposition impacts from the Four Corners Power
Plant and the copper smelters in southern Arizona and northern Mexico.
DRINKING WATER QUALITY
Compliance with drinking water regulations has emerged as the best
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. The five
states In Region VIII, which have accepted delegation of the program, needed
definite Improvement to meet their targets.
In the last EMR, one state 1n particular, Utah, was singled out for its
very low level of compliance with bacteriological requirements. Compliance in
Utah continues to lag behind Regional and National levels, but there has been
a significant and steady increase 1n compliance over the last two years, a
trend which Regional ftnd National levels have failed to meet.
TOXIC SUBSTANffS IN SURFACE WATERS
Approximately 10 to 15* of the water quality standards violations in the
Region can be attributed directly to point sources. These sources are
extremely significant because they are the major contributors of toxics to
stream systems. Critical monitoring activities are proceeding at industrial,
mlnina and municipal facilities to identify constituents of point source
pollution. Also, regional staff are assisting state counterparts to develop
more sophisticated bioassay techniques and subsequent site-specific stream
standards.
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PART II
REGIONAL ENVIRONMENTAL PROBLEMS
Ranking Procedures/Criteria
The Senior Staff studied and ranked the list of "most significant
environmental problems" for the Region's 198S EMR Update. Although there were
problems differing in levels of concern and severity, 1t was agreed that when
all criteria were examined that practically all of these problems were
essentially reglonwlde in geographic scope.
Ranking criteria Included: Level of impact to human health (with ranges
from psychological to physical discomfort and fatal potential; Number of
persons exposed; geographical land area affected; level of public concern and
1f due to first hand physical observation (brown cloud), media coverage or
nationwide concern; programs existing 1n EPA to combat the problem (for
funding, legislation, regulations 1n place); needed Headquarters' actions; and
cross media dependence and implications.
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mZARDOUS waste control
Super-fund - Hazardous Waste Site Cleanup
Problem Assessment
The cleanup of uncontrolled hazardous waste sites 1s a regionwide
problem. Nearly 700 sites are now Included on the Region's Inventory of
potential hazardous waste sites. Additional site entries are expected 1n all
states. 34 sites In Region VIII are targeted on the proposed and final
National Priorities Lists for Investigation and remedial action. The sites
tend to fall Into one or more of five major categories: mining sites, federal
facilities, wood-treating facilities, radioactive sites and landfills.
Superfund sites pose multi-media problems. Groundwater 1s potentially or
actually threatened at 29 of the 34 sites. Contamination of soils and surface
water Is also prevalent. Contaminants of concern are far-ranging. Superfund
hazardous substances Include heavy metals, radionuclides and organlcs. The
level of public concern and public participation 1s high 1n Region VIII.
Active citizen Involvement occurs throughout all phases of Superfund -
discovery, Investigation and cleanup (Anaconda Smelter, Lowry Landfill,
Harrlman Park, South Adams County).
As the Region moves Into the design and construction phases at the NPL
sites, we are encountering these problems:
Off-site Disposal Capacity: The recent off-site disposal policy should
help Insure that wastes from Superfund sites are taken only to disposal
facilities in compliance with RCRA requirements. However, the more stringent,
new RCRA standards coupled with public opposition to siting new facilities
will limit the availability of facilities for off-site disposal of Superfund
wastes. In Region VIII with a preponderance of radioactive sites, the lack of
an approved low-level radioactive waste disposal site has already held up
cleanup of one site.
Alternative Technologies: The off-site disposal policy also encourages
the use of permanent treatment technologies over land disposal. But in most
cases this approach Is prohibitive because proven methodologies are few and
the capacity of acceptable technologies, e.g. incineration, is very limited.
Cleanup Standards: Do current standards provide long-term reliable
protection of public health and the environment? For most toxic substances,
standards do not even exist. The Region needs guidance on assessing the risk
posed by complex mixtures of hazardous substances at Superfund sites and on
selecting cleanup levels for both water and soils.
Federal facilities constitute a significant portion of our priority
sites. We have experienced difficulties in negotiating formal'agreements for
CERCLA studies and cleanup with the majority of Region VIII facilities. These
sites tend to be very large geographically (square miles) and involve
extremely dangerous contaminants (plutonium, nerve agents, pesticides).
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Regional Agenda
The Regional goal 1s to move projects expeditiously through the
Investigation and cleanup phases. Both fund-financed and enforcement methods
are heavily used. State participation In meeting this goal 1s increasing.
States are assuming a greater role both as lead agencies (Utah) and assisting
the Region (Colorado, Wyoming). In the past year, Colorado has removed a
major program obstacle by creating a fund to provide the State match required
before Superfund money can be spent for cleanups at any site. Utah has
assumed the lead management role at four NPL sites, up from zero the year
before. The investigation phase has improved over 1984. Steps were taken to
address delays in the remedial Investigation/feasibility study (RI/FS)
process, Including:
Publication of final RI/FS guidance.
Increasing contract lab program capacity.
Streamlining REM contracting procedures.
Limiting negotiations with potentially responsible parties.
Barriers that still remain 1n this area are:
Poor quality data from the contract laboratories. (At one site,
this may add at least $100,000 in costs and three months to the
schedule.)
Lack of standard protocols for groundwater sampling. Existing
monitoring technologies may not be sufficient to define the extent
of groundwater contamination.
Headquarters Actions Needed
o Develop alternative technologies for treatment of contaminated
water and soils,
o Increase permanent treatment capacity,
o Develop guidance for establishing cleanup levels,
o Develop standard protocols for groundwater sampling,
o Focus research efforts on determining the reliability of remedial
actions.
o Strengthen the existing Memorandum of Understanding with the
Department of Defense by requiring site-specific agreements.
Negotiate Memorandum of Understanding with Department of Energy.
Environmental Results
While the site Investigation process under Superfund has Improved, major
changes are still needed 1n order to expeditiously complete site cleanups.
Region VIII plans to delete one site from the NPL during FY 8Su This is the
only site 1n the Region where remedial action 1s complete and monitoring data
shows that the remedy is effective.
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HAZARDOUS HAS IE CONTROL
Resource Conservation and Recovery Act (RCRA)
Problem Assessment
With the economic and population growth In the West, a wide spectrum of
hazardous waste 1s being generated by the newer "high-tech" Industries, as
well as the older ones such as oil refineries, wood preservers and chemical,
paint and steel manufacturers. There 1s great concern about the Impacts and
risks which mismanagement of these wastes poses, for without proper control,
these wastes can contaminate the environment by way of spills, "midnight
dumping", leachate from land disposal units and leaks from underground storage
tanks.
Regional Agenda
With the additional authorities provided by the amendments to RCRA, the
Hazardous and Solid Waste Act of 1984 (HSWA), the Region and Its five
authorized States have been moving ahead vigorously to control the hazardous
waste problems. A variety of actions have been taken or placed on the agenda
this year:
Permits: Part B permit applications have been requested for all 'land
disposal' facilities. These requests Include the new HSWA requirements on
exposure assessments, releases and old solid waste management units. Training
seminars have been held to assist permit applicants. One of the barriers is
the lack of timely policy decisions and guidance manuals on permit issues.
Progress has been made in the Issuance of permits for commercial treatment,
storage, and disposal facilities. Solvent recyclers in Colorado and Utah
obtained their permits and the application for a major disposal facility in
Colorado has been declared complete. There is still a great need for
additional commercial capacity, as noted 1n previous EMRs. Permits for new
facilities will be a top priority.
Major closure/cleanup actions underway Include the Rocky Mountain Arsenal,
Martin Marietta, Burlington Northern, Denver-Arapahoe Chemical Waste
Processing Facility, Union Pacific Tie Treatment Plant and several oil
refineries.
Compliance: The Region and States have maintained an aggressive
inspection and enforcement program with regard to generators, transporters and
TSD facilities. Ground water contamination has been the primary focus.
Comprehensive groundwater monitoring evaluations have been conducted at more
than half of the 'disposal* facilities, and the remainder have'been
scheduled. The Regional Office 1s preparing several enforcement actions which
draw upon the new Corrective Action Order authority provided by HSWA. A number
of combined RCRA/CERCLA actions have been taken.
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•Disposal' facilities have been notified regarding the November 8, 1985,
deadline for certification of compliance with the groundwater monitoring and
financial assurance requirements. The Impacts of the resulting loss of
Interln status and subsequent closure actions will be substantial, for both
the facilities and the Regional Office and States.
Community Relations: S1te-spec1f1c and general communication strategies
have been developed to educate the public and the regulated community about
hazardous waste control. Through community outreach efforts, the fears and
opposition of the public to legitimate waste handling techniques may be
minimized. Informational brochures, meetings and various media are being used
to help Industry, small businesses 1n particular, to better understand the
importance and methods of compliance with the hazardous waste regulations.
Headquarters Actions Weeded
o HSWA contains provisions for dealing with the significant problem of
Leaking Underground Storage Tanks (LUST). While Congress Intended that the
States Implement the LUST Program, 1t failed to provide adequate funding. We
need Headquarters to obtain enough funds to carry out this large and Important
program. Estimated amount needed: $2 million for Region VIII alone In FY-87,
compared to the $14 million budgeted nationwide.
o Another area which requires Headquarters action concerns data processing
of the Biennial Hazardous Waste Reports from generators and TSD facitities.
We need some follow-through on the plan to make this information (which has
been sent to Headquarters and entered Into a database) accessible to the
Regions and States. It 1s this kind of data on the types, amounts and
disposition of wastes which 1s needed for environmental Indicators and trends
analysis.
Environmental Results
Based upon the Regional and National agenda, we can expect several
specific outcomes in the area of hazardous waste control. The number of
facility closures will continue to Increase as a result of the permit requests
and the inability to certify compliance by November 8, 1985. Permit issuance
will be slow, due to the new, complex HSWA standards and the community
Involvement requirements. Efforts In the area of groundwater monitoring and
corrective action should begin to show significant results. Implementaton of
the LUST program will begin to characterize the extent of the leaking
underground tank problem.
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GROUND WATER CONTAMINATION
Problem Assessment
Of the total number of Region VIII public water systems dependent on
ground water, 17* (438 systems) reported some measure of contamination 1n
1984. Tons of hazardous materials have been Introduced Into the environment
due to years of a concentrated mining, industrial and agricultural
activities. The contaminants Involved, which threaten ground-water quality,
are often highly toxic and some are known carcinogens. The nature of these
substances 1s such that many damaging health effects may not be apparent for
several years and may pose a threat to future generations. As a result, the
level of concern for public health Is very high. Home owners have reported
detecting volatile fumes In basements and well contamination due to leakage of
petroleum products from underground storage tanks. Septic systems have leaked
Into an undetermined number of private wells. A contamination incident,
caused by leachate seepage from a landfill known to have accepted hazardous
chemical wastes, resulted 1n closure of the facility.
Wood preservative wastes in burled disposal pits have migrated Into area
water wells, thus prohibiting at least one community from Irrigating with
ground water.
Nonpolnt source contamination incidences also effect ground-water
quality. There is an Increase In the appearance of pesticides and fertilizers
1n rural drinking water wells. This Is mostly because of poor Irrigation and
application practices. Mining operations, many of which have been abandoned,
contribute acids, metals and PCB's to ground water. Residents of one
conmunlty, located 100 miles downstream from a mining site, were forced to
construct an alternative water system due to the deposition of mine wastes in
the sediment of the river system.
Regional Agenda
The Region VIII Ground-Water Coordination Office (GWCO) has awarded five
of the States the $100,000 supplemental 106 funds to begin activities in state
ground water programs for FY85. The sixth state 1s in the process of applying
for this grant. Most of the states have already submitted draft ground-water
workplans for FY86 as part of the State/EPA agreement. In addition to
admlnlstration of these grants the GWCO Is assisting the states by providing
and indentlfylng ground water training opportunities. Procedures to enhance
technological transfer and identify state research needs have been initiated.
Technical and program support has been provided to state agencies through
staff activities. Efforts to Initiate the Ground-water Classification system
will continue.
State legislation pertaining to ground-water Issues remains fragmented.
The region, under the Resource Conservation and Recovery Act amendments, is in
the process of Implementing the Leaking Underground Storage Tank program.
This includes the registration of tanks by the owners and operators and
requires new facilities be constructed with non-corrosive materials.
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Headquarters Actions Needed
o Continue to provide support funds for growing State ground-water
protection programs and consider need for larger allocations. Also,
consider changing 106 grant allocation formula with emphasis on States
with large aquifers and which attempt strict protection efforts for
noncontamlnated ground water.
o Provide much needed training to State and Regional ground-water
personnel. State funds for training purposes are available through the
106 ground-water allocation but, travel monies are limited by the State
legislatures. The Office of Ground-Water Protection must therefore take
a lead role 1n emphasizing the necessity of training on a State and
Regional level.
o Office of Research and Development should continue efforts to identify
and prioritize state research needs pertaining to ground- water issues.
More emphasis must be placed on the transfer of technology from the
research community to the states. Special attention to field
applications of new monitoring and analysis technology 1s essential.
o Ground water classification efforts need to be realistic yet provide a
basis for stringent control programs where warranted.
Environmental Results
Positive changes and environmental results will be identified more
readily as better monitoring data becomes available. We expect that, as a
result of regional activities, samples from regional ground-water monitoring
wells will show a decrease in the contaminant levels being tested.
Consideration for ground water supplies should increase due to classification
efforts. This trend would be evidenced by land use patterns which 1n turn
reflect a concern for underground sources of drinking water. Siting of waste
disposal facilities or other sources of contaminant discharge will tend to be
strategically positioned according to the recharge and use characteristics of
the underlying ground water.
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URBAN AIR QUALITY
Problem Assessment
Region VIII continues 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. The Denver area has one of the most severe air
pollution problems 1n the country. In 1983, the levels of both carbon
monoxide (24 ppm, 8 hour average) and TSP (147 mg/1113 annual geometric mean)
1n Denver were the highest 1n the nation.
The "Brown Cloud" haze, comprised of extremely fine particulate matter
continues to appear quite frequently over Oenver In the early part of the day
and Is one of the main reasons for the high level of public concern for
improved air quality. The haze Is caused by extremely fine particles
representing only a portion of the TSP in the air. Eight to 33% of the
particulate matter causing the haze comes from residential wood burning and
partially toxic dlesel emissions. In many mountain communities, wood-burning
1s the only significant source of particulates other than fugitive dust. Many
mountain areas have exceeded the annual TSP standard every year since
monitoring began. Several areas 1n Montana have a particulate problem due to
both residential wood burning and prescribed burning on forest lands.
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 unciassiflable under the
Rural Fugitive Dust Policy.
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; Provo, and Salt Lake City, Utah; and the Montana cities of Missoula,
Billings, and Great Falls. Denver and Salt Lake City are the only two areas
1n 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 1n Montana.
Regional Agenda
The Region sees a continuing need for technical and financial assistance
to states to determine the contribution of woodburning and dlesel emissions
to the existing TSP problem and the potential PMiq problem.
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The Region funded a Colorado woodburnlng survey for urban areas; and
co-sponsored a workshop on woodburnlng 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 woodbumlng devices.
Power plants 1n 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 Oenver "Brown Cloud". Colorado 1s
considering additional controls for emissions from woodburnlng and from mobile
sources, such as dlesel vehicles. Region VIII Is encouraging consideration of
the use of methanol as a fuel in dlesel engines, especially for buses 1n the
Oenver area.
Several Colorado communities have begun to address the woodburnlng 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
woodburnlng, and educate the public on the propoer methods to burn wood, while
lessening particulate emissions. The Colorado A1r Quality Control Commission
has received legislative authority to develop emission limits for woodburnlng
stoves and to desl^i specifications for fireplaces Installed after July 1,
1987.
Region VIII has provided (100,000 in grants to Colorado In 1985 to assist
In the r1de-shar1ng effort, and plans to provide an equal amount 1n 1986. The
Region has requested additional funding from Headquarters. The Regional EPA
and GSA are coordinating a major r1de-shar1ng 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.
Headquarters Actions Needed
o The fugitive dust policy, which was written to apply only to TSP, states
that areas with low population (under 50,000 1n the West) will not be
considered as non-attainment areas if there are no industrial sources of
particulate matter. Since fugitive dust would be the principle cause of
high levels 1n such areas and since most fugitive dust 1s larger
non-resplrable particles, the policy had considerable justification.
However, the policy has been proposed to be continued under the new
PM]q standard. Since all PMio is respirable, the justification is
much weaker for continuing a fugitive dust policy. The present policy
will have to be rewritten to apply 1t to PM]q» and until It is, the
control requirements for low population areas with high PMio levels is
very much in doubt. There are many such areas with suspected high PM]q
levels in Colorado, Utah, Wyoming and Montana. Headquarters OAQPS must
develop a new fugitive dust policy on particulate control as soon as
possible. States need to address both known TSP violations and probable
PMio violations. EPA also needs to make the PMio standard final.
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o The Federal high altitude standards for motor vehicles have contributed
to the attainment of CO and ozone standards In Denver and Salt Lake
C1ty. 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.
o Headquarters support will be needed for the approval of the Denver CO
plan with the possibility of an EPA promulgated gasohol program as a
contingency measure to assure attainment by 1987.
o Headquarters support to determine extent of toxic air contamination due
to woodburnlng and dlesel emissions.
Environmental Results
The attainment of the CO and Ozone standards will be possible by 1987,
but gasohol may have to be required by EPA to meet the standard In Denver.
Attachment of the particulate standards will be * longer process, and
residential woodburnlng may have to be discontinued 1n some areas.
The ride-share program can effect a noticeable difference In Denver air
quality, particularly 1n the winter months.
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NONPOINT SOURCE POLLUTION
Problem Assessment
Approximately ninety percent of the water quality standards violations In
Region VIII are attributed to nonpolnt source pollution. Agricultural
nonpolnt pollution, mostly the result of Irrigation practices* 1s the most
serious problem 1n Region VIII. In Montana and Colorado, abandoned mines are
a' major NPS source. Abandoned hard rock mining Best Management Practices
(BMPs) are not yet well developed, and progress 1s slow. The sllvaculture
problem relates mostly to road construction. Nonpolnt source pollution from
Federal lands, which comprise 32% of the land area 1n Region VIII, is a
growing concern. Colorado, South Dakota, Utah, Montana, and Wyoming have
considerable Federal land area and all report problems working with Federal
agencies. The problems range from a lack of resources and uncooperative
attitudes to failure to implement BMPs as per their own policies, and NPS
strategy.
Salinity, associated with Irrigation and other agricultural practices,
continues to be a problem In the arid West, provoking both Interstate and
International concern. The Region VIII states have experienced, loss of land
suitable for farming due to saline build-up in soils and saline seeps in some
dry land areas. The problems associated with salinity appear to be growing
and adequate measures for controlling the problems are being Investigated.
Regional Agenda
The primary focus of the Region VIII program is on agriculture NPS since
1t Is the most serious problem and the one for which BMP's have been developed
and limited funding is available through USDA. Silviculture problems are
occurring for which BMP's are known, but multiple ownership Implementation
procedures are not yet developed. A silviculture NPS specialist Is being
hired. Construction NPS Is ready for control by cities and counties, but
urban runoff cost-effectiveness Is still under study.
Federal lands compliance with nonpolnt sources 1s developing as a major
activity 1n Region VIII. The lands Involved are primarily those of the Forest
Service and BLM. In the deliberations of the National NPS Task Force, major
efforts will be made to assure adequate attention to NPS Forest plans and
Resource Management Plans and their Implementation 1n subsequent activity
plans.
The Regional NPS Strategy 1s to support each state to the maximum by
utilizing existing resources to Implement state and national goals and the
National NPS Policy as reflected In the individual Task Force Agency
Strategies. State and EPA tasks and milestones to achieve these strategies
will be documented In each State/EPA Agreement. Regarding Federal lands, the
Regional Strategy 1s to work for closer cooperation between each State and
their respective Federal land management agencies to resolve the problem
Issues and to support each Federal Agency in implementing their strategy.
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The major emphasis *111 continue to be placed on lands managed by the Forest
Service and Bureau of Land Management, and on programs provided by the Son
Conservation Service, Agricultural Stabilization and Conservation Service and
the Extension Service for Agriculture. Ifrban construction strategies are
being deferred awaiting completion of the National Urban Runoff Project
reports. Major leadership for urban construction 1s presently being provided
by several areawlde NPS agencies through 205(j) funding and Clean Lakes
projects. Development of an abandoned hard rock mining source strategy will
have to await availability of resources and cost-effective BMP's.
Headquarters Actions Heeded
In order to effectively approach the problem, 1t 1s necessary to:
o allocate resources and positions to the nonpolnt program for regional
offices rather than continue to fund positions from other programs.
o develop stronger regional and National cooperation with the key Federal
land agencies and Department of Agriculture (SCS, ASCS, etc.).
o include enforcement of EO 12088 and EO 12372 for Federal agencies as
needed.
o develop more Implementation resources to control the problems at the
sources. (106 grants, nonpolnt pollution grants, Clean Lakes grants).
o resolve sensitive areas of conflict such as water conservation and water
rights laws vs water quality considerations.
o strengthen the nonpolnt public awareness programs.
o provide funding for complete data entry to STORET and develop programs to
effectively analyze problems and situations.
o Increase implementation effectiveness monitoring efforts.
o strengthen the EPA policy regarding use of the General Permits approach
to contact of quasi-point sources such as feedlots, construction runoff,
placer mining, etc.
o Improve National NPS Technology Transfer activities.
o define sediment criteria In terms of fishery impacts.
Environmental Results
During the last year, Watershed/Clean Lake project implenjentations have
been completed at Lake Herman and Sylvan Lake 1n South Dakota and at
Spirltwood Lake, North Dakota.
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TOXIC SUBSTANCES
Problem Assessment
TSCA Issues which the Agency needs to address include:
- Disposal of household chemicals, such as caustics, pesticides, wood
preservatives, paints and motor oils, In landfills not designed to contain
such liquid wastes.
- Inadequate regulation and training of asbestos removal and encapsu-
lation contractors and their employees, with the result that workers, building
occupants and school children receive unnecessary exposure to asbestos.
- Need for improved air sampling and analysis techniques for asbestos
identification and fiber count, 1n order to better identify and quantify small
fibers. Important issues to be Investigated relate to sample collection,
sample handling, membrane type, and the development of a generally accepted
method for determining fiber count.
- Disposal of PC8-conta1n1ng equipment in underground mines. PCB's
in this equipment can contaminate ground and surface waters as the abandoned
mines flood.
Regional Agenda
EPA Region VIII sponsored a successful collection day for household
chemicals run by the Tr1-County Health Department, Colorado, 1n the Fall,
1984. Several other Colorado counties are sponsoring similar programs in
1985. The Toxics Branch has begun to educate hospital administrators about
proper asbestos handling and removal procedures, in an initial effort to
address asbestos in public buildings. Region VIII has had limited experience
with the scanning electron microscopy (SEM) method for asbestos analysis, and
as a result of this experience, has identified four Issues which the Agency
needs to address. PCB inspections in underground mines have been routine in
Region VIII for several years.
Headquarters Actions Needed
Disposal of Household Chemicals:
o Either the Toxic Substances Control Act or the Solid Waste Disposal
Act/Resource Conservation and Recovery Act grant program should be
expanded to fund additional Innovative demonstration and long-term
collection programs for household chemicals.
o Headquarters staff should rely heavily on input from Regional RCRA and
TOSCA programs for design and Implementation of this activity.
Inadequate Regulation and Training of Asbestos Removal and Encapsulation
Contractors:
o OPTS should develop a certification and inspection program for asbestos
removal and encapsulation contractors, possibly modeled after the
commercial pesticide applicator program. All contractors should be
required to follow current best management practices for asbestos removal
projects.
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o In an effort to educate the workers who actual ly do the removal, OPTS
through Its three asbestos training centers, should fund mandatory '
one-day safety workshops for contractor employees and laborers.
Need for Improved Air Sampling and Analysis Techniques for Asbestos:
EPA OPTS and the Office of Research and Development should work with
NIOSH to conduct research on the following Items:
o Evaluation of alternative air sample cassette design to avoid the
electrostatic buildup on filter membranes and to promote an even fiber
distribution across the membrane face.
o Evaluation of the use of silver, "Nuclepore" or other alternative
membranes 1n conjunction with scanning electron microscopy/energy
dispersive X-ray (EM) analysis.
o Evaluation of the effect of sample rate and sampling duration on the
results of total asbestos fiber capture.
o Evaluation of alternative point (fiber) counting methods to be used in
conjunction with SEM.
After these studies have been done, EPA and NIOSH should Jointly
publish a recommended sampling procedure which Improves on the current
procedure.
Disposal of PCB-Containinq Equipment 1n Underground Mines;
o OPTS Office of Compliance Monitoring should revise its Priority
Inspection Plan to specifically Include underground coal and hard rock
mines.
o The Office of Compliance should require the Regions to negotiate informal
local agreements with their local Mine Safety and Health Administration
(MSHA) Offices to have MSHA personnel train EPA PCB inspectors on proper
safety equipment and procedures for "going underground*. (EPA inspectors
would not be allowed underground without this training).
Environmental Results
The major focus of these Initiatives Is the prevention of underground,
surface and air quality problems. Because prevention is usually less
expensive than environmental cleanup, it should be possible to calculate the
environmental results 1n terms of cleanup dollars saved, and water supplies
protected. For asbestos, the results could be the reduction of
asbestos-related diseases.
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CLEANUP AND DISPOSAL OF RADIOACTIVE HASTES
Problem Assessment
Sixteen of the twenty-five designated DOE Mill Tailings Remedial Action
Project (UMTRAP) sites are located 1n Region VIII. The Uranium Mill Tailings
Radiation Control Act of 1978 (Public Law 95-604,42 USC 7901) authorized the
Department of Energy (DGE) to undertake remedial action at 24 designated sites
and associated vicinity properties. This act was amended in January 1983 by
Public Law 97-415 to perform remedial actions at vicinity properties at
Edgemont, South Dakota. (Cleanup of the Eagemont processing site is TVA's
responsibility.) Assessments have been made on twelve Denver properties
adjacent to original properties requiring possible remedial action. A major
unresolved problem with cleanup of the Denver radium sites 1s the fact that
the State of Colorado has been totally unsuccessful in providing a disposal
site for the contaminated soil, building material, etc. to be removed.
According to the latest (6/3/85) Colorado LLW Siting Schedule, a site will be
proposed in Fall of 1986, but waste will not be accepted until Spring of 1991.
Regional Agenda
The Region VIII Regional Office continues to perform health risk
analyses, provide technical assistance and radiation detection and monitoring
equipment, on occassion, to the contractor's field study personnel, provide
overview monitoring of work being performed and assessment of the feasibility
study reports as generated. At the present time there are only two or three
sites where personnel working In buildings on the property are being subjected
to working levels of radon progeny which are marginally acceptable.
For several years the Regional Office has engaged In a fairly constant
Interface with activities of the Albuquerque, New Mexico UMTRA Project
Office. A considerable number and variety of documents have been reviewed and
comments furnished for each site. These included Preliminary and Final Drafts
for Engineering Assessments, Environmental Impact Statements, Environmental
Assessments, Remedial Action Designs, etc.
Nearly all of the UHTRA/STATES and Tribes quarterly meetings have been
attended by a regional representative who participated in the discussion of
problems, plans, schedules, public meetings, EPA environmental requirements,
site selection, etc.
Headquarters Actions Needed
Environmental quality assurance procedures by the Regional Office will
require analyses of soil samples and filters from RPISU Radon Progeny Sampling
Units.
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Environmental Results
The completion of remedial action contracts on designated Oenver Radium
Sites and the twelve vicinity properties should totally eliminate nubile
health concerns.
Completion of remedial actions on the designated Uranium M111 TaiUnas
sites and the associated vicinity properties should relieve the general public
of any radiological health concerns from radon progeny for the next century
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ACID DEPOSITION IN WESTERN WILDERNESS AREAS
Problem Assessment
Acid rain 1s an Issue of growing concern 1n the western United States.
It 1s an issue of Intense Interest to the scientific and regulatory communities
and the public. Several reports have recently claimed that many sensitive
western ecosystems have already been affected by both local sources and remote
major sources of SO2 and N0X such as the copper smelters 1n southern
Arizona and northern Mexico. EPA has Insufficient Information at this time to
substantiate these claims of damage. We 1n Region VIII have Initiated efforts
In concert with several state and federal agencies to develop a comprehensive
and responsible research and monitoring program to establish baseline
Information on "acid rain" and to develop knowledge on the sensitivity and
response of high elevation ecosystems to "acid rain". We believe the
opportunity still exists 1n the western U.S. to prevent "acid rain" effects,
yet without reliable Information, our ability to make reasoned decisions 1s'
seriously Impaired.
Despite the lack of definitive data on western atmospheric deposition,
Region VIII Is currently facing a number of difficult decisions relating to
acid rain control within the PSO permitting process. One example 1s the
pending PSD permit for the proposed Chevron Oil Shale project which would emit
3500 tons per year of SO2 and 35,000 tons per year of N0X . At these
emission rates, the project would adversely effect nearby wilderness areas.
Therefore, the PSD permit currently calls for an 80% N0X reduction at a
projected annulal cost of $30 to $87 million to the company. These types of
regulatory decisions are complicated by our lack of knowledge on the issue and
the high probability of the permit being litigated by either the company or
environmental groups.
Regional Agenda
Region VIII (1n concert with several state, federal and private
organizations) has formed the Western Atmospheric Deposition Task force
(WADTF) to help ensure the coordination of research activities, the
development of comparable data bases, and to jointly identify research needs
and priorities. The task force does not deal with policy matters but serves
primarily to share technical Information. John Welles of EPA chairs the WADTF.
Current actlvites of the WADTF are focused on defining research needs and
gathering baseline data on acid deposition in the alpine west especially in
those areas potentially threatened by energy resource development. The major
effort 1s to modify existing mesoscale air quality models used for predicting
downwind environmental Impacts so that acid deposition and visibility impacts
can be more accurately analyzed.
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Regional Agenda (continued)
EPA and the Forest Service have completed specific plans, under a
Memorandum of Agreement recently signed by the Administrator of EPA and the
Chief of Forests, to sample 425 high mountain lakes in 74 Federally-designated
wilderness areas of the Western United States. This Is part of the Western
Lakes survey portion of the National Surface Water survey to evaluate the
extent of water resources sensitive to addle deposition.
At Region VIII's initiative, several western states have joined together
to conduct an analysis of Issues relating to atmospheric deposition in the
western United States. This major study has been funded through a grant from
the U.S. Environmental Protection Agency (Region VIII) and will provide a
detailed emission inventory of all SO2 ang N0X sources 1n the western
U.S., northern Mexico, and southwestern Canada; an Identification of sensitive
areas to acid deposition and, an assessment of alternative control strategies
for acid rain. The management of this two-year study will be provided by the
Western governor's Association located in Denver, Colorado. Plan for the
project should be completed by early April 1985.
Headquarters Action Needed
0 Support the development of a responsible and comprehensive research and
monitoring program for western acid rain in Region VIII while the
opportunity still exists to prevent damage to sensitive western
ecosystems through the PSD permitting process. Present funding levels
(565,000) for aquatic studies are totally inadequate for addressing an
issue of this magnitude.
0 Assist Region VIII in developing a stronger dialogue with Headquarter's
policy and research programs 1n addressing western acid rain issues and
problems.
0 Conduct comprehensive evaluation of inpacts of smelters and other major
southwest sources affecting Region VIII and other western states.
Environmental Results
The studies now being made will provide a statistically valid data base
of lake water chemistry from which regional assessments of acid rain
sensitivity can be made.
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PESTICIDES
Problem Assessment
This many-faceted problem Includes concerns raised by both Regional and
State personnel:
dumping of liquid pesticide wastes after application
? failure to collect and contain rlnsates during flushing of equipment
and/or cleaning of aircraft
disposal of used unrinsed pesticide containers in sanitary landfills
or gravel pits, along fence rows or river banks
confusion among regulators and applicators about how the RCRA amend-
ments will apply to pesticide wastes
currently registered pesticides for which Insufficient health and
environmental fate data are available
difficulties 1n obtaining health or environmental data for pesticides
field misuse problems such as drift, failure to follow label directions,
spraying areas of human activity without advance notice
the lack of monitoring of intrastate agricultural commodities for
pesticide residues.
possible groundwater contamination due to application of pesticides
through chemigatlon equipment.
concentrated pesticide use in urban/suburban areas which can result
in surface or groundwater contamination.
Regional Agenda
Several Region VIII states are conducting limited ground water quality
monitoring efforts which include monitoring for some pesticides. Although the
Regional Office could conduct special site specific pesticide contamination
studies, there are no funds available for laboratory analyses of samples. The
Regional Toxicologist and other program staff work closely with state and
local officials, citizens and pesticide applicators to prevent or minimize
human exposure to harmful pesticides. To get access to more data, the Toxics
Branch has broadened its literature searching capabilities to include
additional commercial, EPA and government computer data bases. Colorado
developed a slide-tape program on chemigatlon which was co-sponsored by the
Region.
Headquarters Actions Needed
Improper Disposal of Pesticides:
o The Office of Pesticide Programs (OPP) should negotiate with
manufacturers to develop detoxification mechanisms and/or procedures for
their products geared to use by the applicator in the field. This
detoxification mechanism should accompany the product when It is sold by
the dealer. If manufacturers refuse to develop these mechanisms or
procedures, the Office of Research and Development (ORD) should initiate
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an aggressive research and field testing program. If this approach Is
not feasible for some pesticides, the Agency should consider requiring
manufacturers and formulators to sell certain toxic pesticides pre-mixed
to reduce the amount of concentrated wastes which would have to be
disposed.
o OPP should fund a collection center for used pesticide containers in any
Interested state. Existing collection schemes such as the one in
Alberta, Canada, could serve as basic models. Another option which OPP
should explore Is the development of national or model state regulations
requiring pesticide dealers to accept and recycle used pesticide
containers, as Is now the case in Maine.
o OPP should assess the problems associated with Improper disposal of
pesticide containers, and conduct research into ultimate disposal options
for used pesticide containers - can they be safely Incinerated, recycled
as scrap, reused?
o In FY'87, If not before, OPP, RCRA, the Regions and SPIRES should package
a training session which could be put on 1n each state concerning the
requirements for small quantity generators of pesticide wastes.
Improper Use of Pesticides:
o OPP should allocate additional funds on an ongoing basis for Region VIII
laboratory support on special site specific pesticide contamination
studies.
o OPP and the Office of Research and Development (ORD) should request more
resources to expedite the data call-in and research efforts on
environmental fate and chronic health effects of existing pesticides.
OPP and 0R0 should fund research on health effects of exposure to
combinations of pesticides. After data has been reviewed for a
pesticide, OPP should act within one year to require use restrictions or
revised labels as necessary to protect human health and environmental
quality.
o The Agency should computerize existing and future data on pesticides in
ground and surface waters, using a widely known and accessible system
such as STORET. The Agency should broaden its current efforts to expand
Cooperative Agreements and Memorandums of Understanding with other
federal and state agencies and research organizations to do joint
monitoring or laboratory analyses, and to get resulting data into the
centralized system.
o 0R0 should continue to develop and Improve environmental fate models for
pesticides, such as LEACH and PRZM. ORD should conduct a'1-2 day
detailed training program for Region VIII and State personnel on how to
set up and use each of these models.
o OPTS should improve Regional access to EPA Headquarters health effects
Information and data bases for pesticides by providing the Pesticides and
Toxics Program in each Region with an annual, comprehensive list of the
in-house, federal, state and commercial data sources which HQ uses to
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obtain toxicity and environmental fate Information. Based upon their
Interest, Regions should be given access by OPTS or other Agency offices
to any in-house data files. The Agency should increase its efforts to
get direct Regional access to toxicity, environmental fate and pesticide
monitoring data collected by other agencies, such as the Center for
Disease Control, U.S. Geological Survey and the U.S. F1sh and Wildlife
Service.
o OPTS should revise existing Confidential Business Information (CBI)
procedures for registration of pesticides to Improve Regional, State and
public access to toxicity and environmental fate Information for those
products. OPP and the Office of Drinking Water should Increase their
efforts to share data and Information on pesticides with the potential to
be found 1n drinking water sources.
Chemlgatlon:
o The OPP and the Office of Drinking Water (ODW) should expand and continue
their joint study of pesticides 1n groundwater beyond Its current FY'87
expiration date, and Include those pesticides which are being used In
chemlgatlon systems. As a result of these studies, OPP should develop
labeling requirements for pestldaes used 1n chemlgatlon systems which
will adequately prevent groundwater contamination.
o OPP and the Regions should work with SFIRE6 to develop and disseminate
updated training programs and audio-visual materials on chemigation,
environmental fate of pesticides and groundwater Issues. Two such
programs should be developed in FY'87. for use by VO-AG classes and
persons conducting training seminars for applicators.
o OPP and the Office of Research and Development should perform and require
bench testing of chemlgatlon equipment, especially valves.
Concentrated Urban-Suburban Pesticide Use:
o OPP should develop updated training programs and audio-visual materials
for local officials and the general public on proper usage of pesticides
and Integrated pest management techniques.
Environmental Results
It has been estimated that 14X of all Superfund sites have contamination
by one or more of a dozen hazardous pesticides. As pesticide misuse and
disposal are more closely regulated, and as access to health and environmental
fate data improves, future ground and surface water contamination should be
prevented or minimized.
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DRINKING WATER QUALITY
Problem Assessment
Most contaminants are regulated based on harm anticipated from a lifetime
exposure; however, bacteriological quality 1s regulated to prevent exposure to
contaminants which can have 1mned1ate Impacts on health. All PWS are subject
to bacteriological monitoring and MCL requirements. Surface water systems,
which generally have the most difficulty 1n making water bacteriologically
safe, are also subject to turbidity monitoring and MCL requirements.
(Turbidity 1s used as an Indicator of adequacy of treatment and potential
interference with disinfection.) Bacteriological quality 1s a very old
concern and technology to address the problem has been around for a long time,
but It continues to be a major concern 1n Region VIII, both In primacy and
non-pr1macy states. Currently the problem 1s measured by determining the
number of PWS complying with the monitoring and MCL regulations. Average
levels of compliance In Region VIII with bacteriological standards are
slightly below the national averages for FY 81 through 84 and both Regional
and National levels are below the national targets for compliance set by the
Office of Drinking Water. More significantly, the trend 1n regional
compliance over the four years shows no Improvement and even a slight
decrease. In part this trend can be explained by Improved reporting of PWS
violations by State programs to EPA; however, real improvements 1n compliance
are needed. The majority of the problems continues to be with small water
systems.
Regional Agenda
Region VIII works with state agencies (or in the case of Wyoming and
Indian Tribes, Region VIII acts as the State) to improve compliance by PWS.
Complete drinking water programs are 1n place but need to be focused on
violators, particularly persistent violators, and on those systems deliver-
ing unfiltered surface water. Region VIII 1s working with the states to
insure that they have adequate data management capabilities to identify and
track violation cases and that they begin to make their enforcement activities
more effective. All states have written compliance strategies and have signed
enforcement agreements with EPA agreeing to compliance targets for
bacteriological and turbidity requirements. When the national computer system
(FRDS) 1s programmed to provide data for rolling years, Region VIII will
analyze data quarterly for the preceding 12 months to spot trends and give
feedback to States earlier than Is now possible. More attention will be given
to whether state action on PWS violations 1s timely and appropriate. More
attention will also be given to Investigation of waterborne disease outbreaks,
especially for systems using surface water. Currently little information
exists on waterborne outbreaks except for the State of Colorado.
Headquarters Action
o Continued development of Health Advisories and toxicology technical
assistance 1s something in which the states are particularly interested.
Further guidance addressing the problems of small water systems and the
regional role In waterborne disease outbreak investigation is needed.
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o Resources to tackle compliance tracking and follow-up for non-community
PWSs Is needed. Exposure to water from non-community systems may be
brief but since the threat from bacteriological contamination Is acute,
these systems deserve more attention. Sufficient resources should be
made available to add any new effort, such as VOCs.
o It would be to EPA's benefit to lobby Congress to fund the Indian Health
Service at a level where they can provide more technical assistance and
training for Indian water systems.
or Care must be taken 1n creating new program measures - see Appendix B.
Environmental Results
Currently, the best measure we have Is number of systems (In or out of
compliance). The more that systems are 1n compliance, the lower will be the
frequency and duration of people's exposure to contaminants known to be
harmful.
TOXIC SUBSTANCES IN SURFACE UA1ERS
Problem Assessment
The problems of toxic substances 1n Region VIII surface waters encompass
a variety of media and programs. Present concerns are associated with
municipal publlcally owned treatment works (POTW's) industrial waste pass
through, oil refineries, steel milling operations, active and Inactive mines,
federal facilities, and a variety of hazardous waste and superfund sites.
Areas Region VIII Is actively addressing are:
- Nonpoint sources from abandoned mining operations and agriculture which
have a decisive effect on toxics in surface waters.
- POTW problems which range from chlorine and ammonia to pass-through of
toxic substances from Industrial input. Construction grants for advanced
treatment are frequently Issued to control arrmonia toxicity problems.
Approximately 314 grants have been Issued to 60 facilities for advanced
treatment, while another 60 facilities have avoided going to advanced
treatment by using land application or other no-discharge alternatives.
Region VIII 1s working on ammonia secondary Biological Oxygen Demand
(BOO), as the next step 1n controlling ammonia toxicity.
- The problem of pretreatment and the pass-through of toxic substances and
heavy metals 1s a prime concern. Monitoring Is beginning to determine
the extent of the situation.
- Industries, Including, oil refineries, steel milling operations, ore
processing, high technology facilities and mining operations which nave
all contributed to past and present toxic pollution. Mining operations
affect the water quality 1n all six Region VIII states. Colorado and
Montana report the greatest problems. Over 120 miles of stream have been
severely polluted below the Anaconda site in Montana as evidenced by fisn
kills and stream sediment analyses. Since the milling operation has
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ceased, some aquatic life has begun to return to the area. Colorado
reports that 450 stream miles have been Impacted by acid mine drainage.
Restoration and feasibility studies are underway. WMtewood Creek 1n
South Oakota had been severely damaged by Homestake Mine. The State, EPA
and Homestake have worked to eliminate the discharge of toxics.
Whltewood Creek 1s showing distinct Improvement since the discharge has
been curtailed.
- Federal facilities 1n Region VIII, which Include military bases, an army
munitions depot, Rocky Flats, Rocky Mountain Arsenal, and Dugway testing
grounds. Pollutants range from organic chemicals to heavy metals.
Several sites have been Included on the National Priority List (NPL).
Region VIII states are working with these facilities to control both
point and nonpolnt pollution. The Region 1s working with POTWs to ensure
that blomonltorlng programs are Included in their pretreatment programs
and assisting them 1n identifying metals 1n their headworks.
Regional Agenda
Now that the water quality criteria documents for toxic substances are
final, the region's primary concern 1s to effect the Inclusion of these
standards 1n the state standards. The states are also being encouraged to
address statewide toxic problems, establish numeric limits, and develop an
implementation procedure for narrative standards.
Region VIII 1s participating with on-site toxic surveys and assisting the
states 1n developing site-specific standards. Work with Ceriodaphnia sp. to
develop toxic screening procedures for major discharges 1s progressing. The
Water Quality requirements section and the Bloassay Work Group are
coordinating efforts to Identify reference streams to develop the
ecoregion/reference stream concept. This information is used to recalculate
site specific criteria.
All of the Region VIII states have stream segments for which adequate
standards have yet to be set. The permits, therefore, may not be adequate for
protecting uses. In review letters on water quality standards, states are
being informed that they need to Incorporate appropriate standards to protect
the beneficial uses.
Headquarters Actions Needed
o Headquarters must convince other Federal agencies such as the Forest
Service, Department of Defense, and Office of Surface Mining to cooperate
1n eliminating problem areas. It is important that the cooperation and
implementation continue down to the local facilities and field offices.
Guidance and consistent approaches are needed to address the problems
caused by Inactive and abandoned mines, a majority of which are located
on federal lands in Region VIII.
o Continued coordination between Water, Superfund, and the states is
necessary to address sites such as Anaconda, Montana, California Gulch,
Colorado, and Rocky Mountain Arsenal.
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Environmental Results
Region VIII has developed useful techniques to analyze and locate stream
standards violations. As toxic monitoring increases, monitoring stations
reporting standards violations will dictate where Region and state efforts
should be directed. Blosurveys conducted by the Region have given us the
ability to examine effects of current and past discharges, enabling the Region
to assist the states In developing numeric and narrative standards. The
Region 1s currently working on a use attainability survey on the Clark Fork,
Montana, and hopes to work on other streams 1n the Region.
It is estimated that 50% of the major permits have some kind of water
quality based limit. Advanced treatment is progressing 1n the Region. The
Region 1s working on Implementing total effluent toxicity limits.
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PART III
REGIONAL RECOMfCNDATIONS FOR THE
AGENCY PRIORITY LIST
Region VIII recomnends the following changes to the Agency Priority List
for Fiscal Years 1987 - 1988:
1) In reviewing this Environmental Management Report (EMR), it becomes
very apparent that public concern over priority environmental issues is a
prevailing theme throughout. Yet, at no place In the priority list has
outreach to the public to address their concerns been mentioned. This item
will certainly be factored Into future regional priorities and we recommend
that future Headquarters priority lists Include an Item such as,
"CONDUCT PUBLIC OUTREACH ACTIVITIES IN ALL PROGRAMS TO
ESTABLISH AND MAINTAIN TWO-WAY COMMUNICATION ABOUT
ENVIRONSNTAL ISSl£S".
2) The threat to every urban community resulting from failure to control
ha2ardous (toxic) air pollutants has potential to adversely affect more of
this country's population than any other environmental problem. Public
concern over this Issue Is extremely high. We recommend that Item #15 on the
Agency Priority List be moved to position #5 and that items 5-14 become
Items 6-15.
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APPENDIX A
EPA REGION VIII
T98FEHR" UPDATE
MOST SIGNIFICANT_ENyiRONMENTAL PROBLEMS
Characterizations
Relative Ranking of
tnvironmentai problems
Hazardous Waste Control
- Superfund
- RCRA
Groundwater
Contamination
Urban Air Quality
Geographic
"Scope
Region-
Mi de
Region-
wi de
Major
Sources
Abandoned
& active
sites
Leachate
and under-
ground tanks
Major
Impact
Level of Pub-
TTc Concern"
Region- Vehicle
wide,esp. emissions,
Denver, wood stoves
Salt Lake
Threat to
groundwater
S human health
Threat to
dri nklng
water
Threat to
human health
2 million
people
High
High
Very High
in cities
Contaminants
of Concern-
Hazardous
materials
and wastes
Hazardous
wastes and
products;
pesticides
Ozone, CO,
Particulate
PM10
Nonpoint Source Water Region-
Pollution wide
Toxic Substances
Region-
wide
Agriculture,
live-stock
Landfilis,
building
insulation,
underground
transformers
in mines
Water uses Moderate
of about 3 and
million people growing
Public
health,
potential
threat to
groundwater
Moderate
to high
Nutrients,
sediment,
salinity
Asbestos,
caustics,
and PCB's
Cleanup and Disposal Region- Mill
of Radioactive wide Tailings
Waste
Potential
threat to
human health
Moderate
to high
Radioactiv
Materials
Acid Deposition
Region-
wide
Needs to
be studied
Water uses
Moderate
to high
Sulphur,
nitrogen
compounds
Pesticides
Region-
wide
Drinking Water Quality Region-
wide
Agri culture
Several
factors
Threat to
drinking &
groundwater
Threat to
human health
Moderate
to high
Moderate
Dioxins,
others
Bacteria,
turbidity
Toxic Substances
In Surface Waters
Region-
wi de
Municipal
facilities,
industrial
and mining
di scharges
Degraded
water uses,
Human health
Moderate
to high
Amnion i a
toxics,
nutrients
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Characterizatlons
Relative-Ranking of Geographic Major Major Level of Pub- Contaminants
Environmental Problems Scope Sources Impact lie Concern of Concern
Waterborne Disease
Wetlands Loss
Poorly Planned
Development of
High Quality
Environment
Aircraft Noise
Region-
wide
Region-
wide
Multi-
State
Multi -
State
Surface water
systems
Land develop-
ment, agric.
Natural
environment
Aviation and
military
operations
Dr1 nki ng
Water
Ecological
Energy, min-
ing, recrea-
tion, water
development
Public
health, &
pristine
wilderness
Moderate Various
High in
rural
areas
High
Moderate;
high in
Metro
areas
Nutrients
and
sediments
N0x,S0o,
visibility,
nutrients,
sediment,etc.
Noi se
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appendix b
SUGGESTED ENIROMENTAL RESULT INDICATORS
Drinking Water
The drinking water program is a public health program so it would seem
appropriate that the best result indicator would be the number of persons
protected. However, our data is not in a form at this time that can yield
reasonable counts of persons affected. Counts of persons are not unique; in
some areas, public water systems are so complex and interconnected that the
persons they serve are counted several times, greatly increasing the state
totals of population served.
This 1s expecially true along the "front range" of Colorado and the
"Wasatch front" of Utah. For Colorado, the total population served by
community, active, public water systems 1n FY'84 is shown as 6,377,757 which
is 221X of the total population for the state in the 1980 Census and about
265% of the fraction of the state's population expected to be served by a
PWS. For Utah, the total served by PWSs is shown as 3,011,341 which is 206%
of the total 1980 Census population and about 250% of expected. The effect on
Regional totals 1s to make the population claimed, to be served by PWS in
Region VIII 164% of the total Census population and.about' 205* of what is
really expected. Real improvements in compliance are going to involve small
systems but their populations-served will make no dent in these greatly
inflated state and Regional totals. Right now the large systems have the best
compliance rates and they are also the ones doing the multiple counting, so to
judge the drinking water program on the populations served .is to see it as
being better than 1t is.
Currently, the best indicator we have is the number of systems (in or out
of compliance). The more that systems are in compliance, the lower will be
the frequency and duration of people's exposure to contaminants known to be
harmful.
Non-point Source Pollution
Suggested indicators are:
- Changes 1n priority water body lists
- Changes in pollutants causing non-support of designated beneficial uses
- Biological/use attainability criteria met.
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