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                          WASHINGTON, D.C. 20460

                            March 15,  1974
                                                                   OFFICE OF THE
TO:   All Participants in the Effort to Clean Our Nation's Waters

      It has been somewhat over a year since the two bills controlling
water pollution, with which this Strategy Paper is concerned, became law:
The Federal Water Pollution Control Act Amendments of 1972 and The Marine
Protection, Research, and Sanctuaries Act of 1972.  For EPA it has been
a year of challenge, as the Agency marshalled much of its resources to
respond to the comprehensive and demanding provisions of these Acts.
Retrospectively, much progress has been made--but it is only a start.

      The Federal Water Pollution Control Act charters a ten year program
whose goal is the achievement throughout this country, by 1983, of waters
in which we can swim and fish.  The task is enormous and can best be achieved
by proceeding in phases.  The Strategy is revised annually to recognize
this and the changing emphasis of the law.  While it presents an overview
of the total program direction and sequence, this edition concentrates on
the activities and priorities of the forthcoming fiscal year:  FY 1975.

      This Agency has found the Strategy Paper to be a most useful
tool in managing our programs.  It has helped the program offices
of EPA and the States to establish annual program objectives, allocate
resources in support of these objectives, and regularly report on
their achievement.  We realize that some of the directions may encounter
problems that were unexpected or only dimly perceived when they were
framed.  However, there is flexibility in the Strategy Paper to adjust
to these circumstances through periodic revisions.  It is not to be
viewed as infallible writ, but as a presentation of our best thinking
at this time.

      The Strategy Paper also functions as an exposition of policies
that may be implemented in the future.  Frequently these are courses
still being debated within EPA, on which a final decision has not been
made.  In this manner our prospective thinking can be anticipated and
a forum for discussion of these concepts sustained.
            U.S. Environmental Protection Agency
            GLNPO LiU-.rry Collection (PL-12J)
            77 West Jackson Boulevard,
            Chicago, it  60604-3590

      My predecessor as Administrator emphasized the important role
that is envisaged for the States in carrying out this legislation.   As
Bill Ruckelshaus remarked, in his introduction to the initial edition
of the Strategy, the States'  role is wholly appropriate, not only
because of the magnitude of the pollution control efforts that must be
undertaken, but also because the special and localized nature of many
of our water pollution problems must be recognized.

      I endorse that philosophy and policy.  The task ahead will not
be easy, but the different levels of government must join in a common
effort if it is to be accomplished.

                              SinCefeHy yours,

                                  ell E. Tra

                           WASHINGTON, D.C. 20460

                             March 15,  1974
                                                                    OFFICE OF THE
TO:  All Water Quality Officials

     In his introduction the Administrator mentioned the  use  of the  Strategy
Paper as a management tool.  It is critical that  all who  are  involved in
the effort to improve water quality understand what our Agency's priorities
will be this year.  It is also important that the right working relationship
be established at what is undoubtedly the critical interface  of water quality
administration at this point: namely, the relation between EPA Regions and
the States.  As a way of highlighting our strategy, I would therefore like
to include the following excerpts from recent guidance which  I sent  to the
Regional Administrators, concerning FY 1975 State programs:

      "...In developing the specific incentive grants for
     individual States the Regional Administrator will have discretion
     to modify the respective amounts for different program elements
     to reflect the needs and circumstances of each State.

          A definite effort should be made to conduct development
     of State Program submissions on a cooperative basis  (with EPA
     providing shirt-sleeve assistance to the States) and to  avoid
     excessive documentation in the State submissions in  order to
     keep them brief and to the point.

       ...On the basis of a full year's experience operating  under the
     new law, and in response to considerable feedback from both regions
     and States, we have kept changes in the key  program  elements  and the
     incentive funds to a minimum.  What changes  we have  made are  dic-
     tated by how we presently see the priorities necessary to implement
     the law.  The key program elements for FY 1975 are:

                    .municipal facilities management
                    .compliance monitoring

     As in FY 1974, it is the key program elements which receive
incentive funding.  By identifying these elements and the initial
distribution of funds we are providing a basis by which each
Regional Administrator can begin negotiations with the States.   I
encourage each of you to use the wide flexibility which the 106
regulations provide to shift funds and to use your authority to
work with each  State in producing a program tailored to that
State's needs.


     One key output is assumption of the NPDES program by each State.
Regional Administrators should make every effort to encourage and
assist States to assume this important responsibility.  The State
Program should include a projection of when the State will assume
the NPDES and should identify milestone dates as well as problems

     The second output to be addressed is the number of permits to
be issued, by type, during the year.  In the case where the State
does not have NPDES authority, the State program should specify the
extent of State participation in permit issuance.

Municipal Facilities Management

     The FY 1975 programs should concentrate on two critical aspects
of municipal facilities management, both of which involve important
delegation of functions to the States.

          -Plan and Specification Review.  The delegation of plan
and specification review continues to be a key program output.
Many States are just now acquiring the added staff needed to assume
this function as a result of FY 1974 emphasis.  This emphasis should
continue in FY 1975.

          -Operations and Maintenance.  In my memorandum to you
on December 28, 1973, I described the use of a three year permit to
be issued to publicly-owned treatment works which are unable to
achieve full compliance with the 1977/78 deadlines.  Such permits
will rely on conditions involving operations and maintenance and
minor facilities improvements.  If such conditions are to be effective,
the State program must provide for a well-run 0§M program	

     State assumption of the responsibility for review of operations
and maintenance manuals remains an important goal.


     Planning efforts during 1974 involved submission and
approval of each State's continuous planning process, identi-
fication and ranking of segments, and a focus on segment
analysis and waste load analysis in order to provide as broad
a basis as possible for issuing meaningful permits.  The
waste load analysis effort was considered so important that
we diverted $4.2 million to States (in addition to the
program grants made).

     The key outputs in FY 1975 State Programs should be completing
segment and waste load analyses begun in FY 1974, and continuing
progress on basin plans.  The schedule for completing basin plans
in each State should be carefully reviewed.  You should examine
the status of efforts to complete all basin plans within the State.
Where circumstances warrant you may extend the deadline for
completing a particular basin plan.

Compliance Monitoring

     Compliance monitoring is basically an enforcement function
which draws heavily on review of self-monitoring reports (where
States have issued NPDES permits), facility inspections, and
monitoring.  For purposes of program development, you should
examine the role the States will play in facilities inspections
and compliance monitoring.  In this examination, three separate
activities should be discussed:

          1)  facilities inspections for purposes of determining
progress on compliance schedules;

          2)  measuring of effluent to determine adequacy of
in-place controls; and

          3)  intensive surveys to determine changes in water
quality and prioritize follow-on enforcement activity.

Other Program Elements

     The §106 regulations identify seven program elements.  Not
all of these can be identified as key elements.  They all, however,
are highly important.  Each of the remaining program elements
deserves particular attention in the FY 1975 State Program.

           -Enforcement.   The FWPCA Amendments and the §106 regulations
place special emphasis on enforcement.  As more permits are issued,
EPA and States are building an ever growing enforcement workload.   The
time to build capability to handle such a load is now.

     A review of the FY 1974 programs indicates that some State enforce-
ment programs appear seriously deficient.  The State Program should
clearly identify how enforcement is to be carried out -- the enforcement
strategy, procedure, projected workload and available resources.
Particular attention should be paid to a problem which exists in
several jurisdictions wherein State Attorneys General have the
authority and responsibility but not the resources to enforce legal
sanctions against violators.  In such cases the Region, using the
State Program, should act as a catalyst to have the State agency
reach an agreement with the Attorney General in return for his
support of enforcement activities.

          -Monitoring.  Our review of FY 1974 monitoring activities
indicates that although considerable emphasis was placed on moni-
toring, there is still a need to establish a basic national direction
of effort.  In structuring the FY 1975 monitoring programs your
principal thrust should be on clear enunciation of the State's
monitoring strategy within the overall State strategy which will
lead to:

          . development of a high quality monitoring program which
serves the various data needs of the State

          . development of an adequate quality control program in
cooperation with the Regional S § A Divisions.

     As in any other program, resources for monitoring are clearly
limited.  Therefore, the State should pay careful attention to
priorities in terms of needs.

          -Public Participation.  In response to comments received
on the interim §106 regulations, we plan to revise the regulations
to include public participation as the eighth element in the State
program.  Additionally, you should recognize that there are two
separate aspects of an effective public participation program.  These
aspects are:

          1.  As part of the State program development process, there
must be ample opportunity provided to enable the public to react to
and influence the formulation of State program.

          2.  As an element of the State program, the State must
describe how it will provide for and assist public participation
in water pollution control activities.

     The State should provide for both aspects in an efficient
manner to minimize the volume of paperwork which otherwise
might occur.

Project Priority Lists

     Section 35.915 of the Title II regulations provides that
the State project priority lists shall be submitted as part
of the annual State program.  The State should be advised and
encouraged to submit a list containing a sufficient number of
projects so that construction grant awards may be made from
next year's allotment as soon as it is received and to enable
funding of additional projects if additional funds become
available (for example, from the reserve funds).  The Regional
Administrator approves only that portion of the list for which
funds are currently available.  Thus, when the next allotment
is received in January 1975, there need be no gap while the
region waits for the FY 1975 list to be submitted.  This concept
places heavy emphasis on each State having a valid municipal
discharge inventory, since the project priority list is a
"continuous" list deriving from the inventory.  Furthermore, it
depends on a State having a valid segment list (from which it
develops its discharge inventory)....

Program Content - A Plea for Simplification

     The State Program process established by the 106 regulations
deliberately provides a continuing means by which States and
Regions, working together, direct both Federal and non-Federal
resources in accordance with mutually agreed upon priorities to
clean up polluted waters in each State in the Nation.  It must not
be viewed as an annual requirement for each State to describe, in
minute detail, every facet of what it will do over the coming year....

     I am therefore asking each  [Regional Administrator] to personally
insure that the State program [application] size be kept to an absolute
minimum.  We should ask a State to submit only what is absolutely
essential to describe its program.  A streamlined program submission
together with [the] faceTto-face meetings with each State agency head
this spring and again at the mid-year evaluation in December is the
best way to encourage the free flow of information while minimizing
the flow of paper."

     If these central points of content and procedure are understood,
I feel confident that the Water Strategy can provide a good basis for
next year's Federal and State water pollution control programs.   We
have shifted from a stage of preparation to a stage of implementation-
which, for most of us, means our work is just now beginning.

                                Sincerely yours,
                                     R. Quarles, Jr.
                                Deputy Administrator

     This March 15, 1974 edition of the Water Strategy has been
prepared for use and review by Federal, State, and local government
officials, and for the information of the public.  It reflects the
final decisions on the Federal Government's FY 1975 budget.  Major
changes to the 1973 edition have been made, and the discussion has
been broadened to include several new areas of program activity.

     The principal emphasis of the Strategy is on the implementation
of the Federal Water Pollution Control Act, for which EPA has the
major Federal responsibility.  EPA's role under the Marine Protection,
Research, and Sanctuaries Act in regulating ocean dumping is also
included, however.  Specific programs governing the protection of pub-
lic water supplies are not addressed in this Paper.

     Persons using the Strategy are reminded that the Strategy, while
based on the law, is not the law, nor is it a regulation mandated by
the law.  It is guidance prepared for use by government agencies in
implementing the Acts.  It is part of a management system whose purpose
is to insure that program activities, by conforming to a single strategy,
are consistent with each other.

     The Strategy Paper is written under the aegis of the Water
Planning Division in EPA Headquarters.  While much of its develop-
ment has been within this Division, it more fully reflects the work
of individuals within all EPA Headquarters program areas, and the
participation of EPA's Regional Offices and the States.

     Comments on the Strategy are welcomed.  They should be addressed

          Walter S. Groszyk, Jr.
          Chief, Water Program Planning and Accomplishment Branch
          Water Planning Division (AW-454)
          Environmental Protection Agency
          Room 815, East Tower, Waterside Mall
          401 M Street, S.W.
          Washington, D.C. 20460

A limited number of additional copies of the Strategy Paper can be
obtained upon request by writing to the above address.  For those seeking
a more general discussion of this area, EPA's Office of Public Affairs
has prepared several pamphlets describing the provisions of the Act, and
will have available a summary primer covering the contents of this Strategy

                            I.   OVERVIEW
      Summarized in this part of the Water Strategy are the near-term
and the long-range views of EPA on the control of water pollution.  Sec-
tions A and B chart EPA's goals for the next twelve months (Fiscal Year
1975).  Sections C and D put these goals in the broader perspective of
the next decade.  The 1977-1983 sequence of the Act is discussed, and
the direction of the program is laid against recent and projected trends
in water quality.

      The first two sections, in the form of themes and outputs, give
verbal and numerical images of EPA's immediate concerns.  It will be
evident that not all of the themes can be translated into or measured
by numbers.  Conversely, not all of the output categories represent pro-
grams to be given top priority in the next year.

      Output values are, in reality, surrogate measures for the desired
end result, which is the in-stream improvement and maintenance of water
quality.  Data on ambient conditions should appear in future versions
of the chapter on Water Quality and the Water Strategy, as these data
become available.


      The following major themes indicate the program emphasis in Fiscal
Year 1975.  They combine retained emphasis of the past year, new thrusts,
and adjustments to program objectives.  The effect of these themes is to
establish priorities among program areas which are summarized at the end
of the section.

      1.  A Continuing Commitment to Outputs

          In important respects, this edition of the strategy is a con-
tinuation of last year's strategy.  The priorities that were assigned to
permits and construction grants are retained.  Not only are they the most
visible program areas, but they also will result in the most immediate
improvements in water quality.

          For some EPA program areas and for some States, monies are not
at desired levels to effectively carry out all the program efforts and
responsibilities under the Act.  In other instances, it is taking time to
bring additional personnel and resources to bear.  EPA recognizes that the
difficult challenge of the Act means that there will not be achievement of
all the near-term program requirements by all the implementing parties all
at the same time.  However, the Agency believes that through a proper emphasis
on priorities, critical program areas can be accomplished within a reasonable

          The Act introduced some very fundamental changes in the way of
doing business.  A period of transition, greater than anticipated, has been
needed to bring about this turn-around and accommodation.  This has resulted
in less than full accomplishment of the outputs anticipated for 1973, and
probably will also in 1974.  Much of the hurdle of transition has been
passed and it is expected that program outputs directly improving water
quality will markedly increase.

          Issuance of Permits--Assigned high priority in FY75.  Improvement
in water quality rests ultimately on the exertions of the individual dis-
chargers who now use navigable waters of the United States to dispose of
their wastes.  These dischargers, through the permit, must know what abate-
ment measures are expected of them.  After sixteen months, EPA and the States
have issued 5,200 permits of the estimated 75,000 to be issued in the first
round.  A major task remains and demands that Federal and State agencies
continue to focus on applying resources to this effort.

          Award of Construction Grants--While privately owned sources are
expected to bear the costs of environmental controls themselves, publicly
owned sources are eligible for Federal financial assistance.  As the Fed-
eral source for these funds, EPA is currently emphasizing the construction
of those municipal projects which form the central core to any achievement
of both the effluent and the water quality requirements of 1977/1978.  After
sixteen months, a little over a third ($1.85 billion) of the total of $5.0
billion made available to the States for grant awards for FY 1973 and FY 1974
has been obligated, and it appears that about $3.4 billion will be obligated
by July 1974.  Last year's strategy projected a total of $4.9 billion in grant
awards through FY74.  Various impediments to the grant award process have been
identified, some of which result from new requirements under the Act, some
which result from changes in historical practices, and others which result
from procedures established to carry out the Act.  These latter areas were
subjected to a recent joint Federal-State review resulting in revised grant
regulations.  To follow up on this, a coordinated effort by EPA, States, and
communities will be undertaken to help municipalities comply with the condi-
tions for a grant award, and to see that applications are quickly processed
and awarded.

          Completion of Basin Plans--The development of water quality manage-
ment plans for each basin is an essential component in the development of the
annual State strategy, and to provide a framework for managing the achievement
of the 1977 and 1983 goals.  Basin plans are to be developed over a period of
time, with the periodic phase-in of additional elements.  The high priority
in last year's strategy to conduct water quality analyses and prepare waste
load allocations has resulted, in sixteen months, in States having adequate
data to perform these analyses in the majority of the 1,588 water quality
segments which require it, and completing over 1/4 of the waste load alloca-
tions.  This priority effort should be continued into the summer of 1974 to
provide the necessary data for the issuance of permits.

          These three key outputs, which were of top priority last year,
will continue to be tracked.  Quantified outputs representing other elements
of program activity, as represented in the discussion on priorities, will
be developed, as appropriate, to provide measures of program progress.

      2.  Steady Decentralization of the Responsibility for Water
          Pollution Control

          The Act argues strongly for the decentralization of water
pollution control subject to a Federal overview.  While the citizen,
the Congress, and State and local governments have recourse to EPA,
the Agency ultimately responsible for the implementation and achieve-
ment of the Act's requirements, fundamental responsibility for conducting

much of the effort should reside with State and local governments.   The
tasks are too many and too sensitive to local conditions to be success-
fully managed in detail on a national scale.  Agencies that are closer
to the origins of water pollution must provide the direction for its

          Involvement of State Agencies--States should assume the respon-
sibility for planning to meet water quality standards.  Through the first
sixteen months, eight States qualified to administer the NPDES permit system;
others have applications under review.  EPA will continue to encourage
other States to participate in this system, and in the interim period before
formal assumption, develop, with the States, cooperative program efforts.

          Review of Federal Requirements --The bodies of government to
whom authority would be delegated must be able to understand the terms
of delegation and agree that they are reasonable.  Decentralization
must be attractive to work.  To this end EPA will screen its regulations
in such areas as permits, State program grants, and basin planning, to
be sure that the procedures presented are necessary and stated as straight-
forwardly as possible.  A continuing assessment will be made of resources
available in Regional Offices and States in relation to expected outputs.

          Public Participation--A logical extension of decentralized
management is to provide the opportunity for involvement for those who
will both pay and benefit as the Act is carried out.  This means providing
for public participation in the decision-making process.  Regulations
promulgated by EPA under the Act address this subject; EPA and the
States will continue to follow their provisions by introducing opportu-
nities for the voicing and incorporation of public comment and wishes.

      3.  Maximizing Environmental Effectiveness

          The vastly increased resources devoted to water pollution
control will continue to be subjected to a variety of tests to assure
their cost and environmental effectiveness.  Habits developed over
decades of control practice may have to be modified.  EPA and the
States must guard against an application of standards which overlooks
intended results.  Common sense dictates that the economic and environ-
mental effects of a course of action should be considered together,
and that there be a regular comparison of these with the costs and
benefits of other courses of action.

          Environmental Assessment--Treatment methods must be judged
by their net environmental effect.  Care should be taken that pollutants
germane to the local water quality problem are addressed in the design
of treatment works, and that abatement practices do not merely shift
an environmental problem from surface water to other, less remediable

media.  In this regard EPA will use, as its tools of analysis, environ-
mental impact statements and assessments which the law specifies for
Federally funded projects and new source permits.  Regulatory standards
will be likewise subjected to a similar level of review.

          Cost-effectiveness--Cost-effectiveness considerations will
become important as individual dischargers explore the ways of meeting
the effluent standards which have been set and the water quality standards
which are to be achieved.  At the heart of cost-effectiveness is the
development and pricing of alternatives before construction.  These alter-
natives may variously involve land treatment, treatment and discharge to
navigable waters, or reuse of wastewater, flow reduction measures (including
the correction of excess infiltration); the treatment of overflows; alter-
native system configurations; or improvement in operations and maintenance.
EPA will require that the appropriate alternatives be considered for any
projects it helps to fund.  Equally important, it expects that market forces
will foster similar comparisons of techniques by private dischargers.

          Control of Non-Point Sources--Non-point sources of pollution
result in an important number of cases where either it is not efficient
to use higher levels of point source control as a means of improving water
quality, or water quality goals are actually impossible to reach without
the management of non-point sources.  These will therefore merit closer
attention as alternatives and supplements to point source abatement.
Guidelines for their identification and control have been published by
EPA, and demonstrations of control technology will be continued.  These
should assist States and areawide authorities as EPA begins to implement
section 208 of the Act to lay the foundations for comprehensive source
control.  In FY 1975 EPA anticipates the designation of a significant
number of areawide authorities, equipped to plan for the balanced control
of pollution from all non-point and point sources within their jurisdiction.
These authorities will work directly towards the achievement of the 1983
goals of the Act.

      4.  Managing for Results

          Water pollution cannot be solved in a brief space of time, and
once it is solved the accomplishments can be undone.  In these circumstances
the national pollution control program requires an information system which
gives a continuous picture of the relationship between program actions and
environmental results.  The size of the total water quality problem requires
that agencies organize their activities to seek immediate results, and
inform the public of progress made.

          Program Management--A management process involving a national
strategy, State strategy responses, State and Regional reporting programs,
and the use of program objectives and output measurements has been intro-
duced.  The next year should  complete the implementation of these systems
as the major management tools for Federal and State governments.

         Environmental Results--Emphasis will be placed on the develop-
ment of a monitoring program to gather information on water quality.
States should initially report on the quality of their waters, and the
relative pollutant contribution of point and non-point sources, by April
1975, with subsequent annual follow-ups that will become increasingly
more comprehensive.

     5.  A Continuing Attention to Program Problems

         The initial sixteen months of operating under the Act have often
been difficult.  While not unforeseen, the scope and nature of problems
that have arisen during this period compel EPA's continuing attention to
quickly recognizing and addressing policy and program problems.

         The fundamental effluent and water quality requirements for
1977, and especially 1983, represent national program goals that are
basically sound and can be achieved.  Some of the steps, especially
during the initial period, may lag.  Others may proceed in less than
optimal phasing.  There is a responsibility on EPA's part to make appro-
priate program adjustments that recognize these situations, while still
maintaining the general charted course under the Act.

         Areas of program adjustment are being undertaken.  Construction
grants requirements have been reviewed and simplified; permit goals
reflect the technical and administrative burdens on that program; basin
planning schedules are being relaxed.  Other problem areas remain--municipal
construction schedules and industrial participation under regionalization
are not synchronized; incorporating pretreatment requirements into
municipal permits poses schedule and technical difficulties; adjusting
to new procedures and the lack and phasing of resources disrupts program
momentum.  Program outputs are often contingent upon a quick resolution
of significant problems that appreciably impede progress.  The highest
priority within the Agency is to be given to effecting this timely resolution.
         From the discussion of these five themes the following priorities
can be established between and within program areas for FY 1975.  The fol-
lowing guidance should form a general framework in assigning program resources,
remembering that Regional and State priorities may differ somewhat to reflect
the nature and dimensions of individual pollution problems.  These indices
do not negate the most important element in any water pollution control
program--that it be balanced.  Resources should not be exhausted on selected
program areas, leaving others without coverage.

      Priorities between program areas:

      Permits and construction grant awards share equally as the most
important program areas.  Enforcement, monitoring, and planning form a second
level of priority.  Non-point source control is a matter of regional or State
initiative.  Oil and hazardous spill prevention and control should receive
a sustained emphasis.  Water quality standards review has the lowest program
area priority.

      Priorities within program areas:

      Permits for major dischargers and new sources should receive precedence
over minor discharger permits.

      In construction grants, Step 2 and 3 projects awards and review have
highest priority followed by awards and review of Step 1 projects.  A high
near term priority is assigned audit and distribution of reimbursement funds;
appreciably lower in priority are OlijM surveys; and manpower operator training.

      In planning, waste load allocations for permits has highest priority
followed by setting 208 designations and initiation of areawide planning
and development of 303(e) basin plans.

      Enforcement actions against violators of schedules of compliance gen-
erally should receive a higher priority in the near term than actions against
discharge conditions.  Compliance monitoring to support this receives a fairly
high priority.

      In monitoring, water quality analyses to support permits are assigned
a high priority, followed in time and by a somewhat lower priority by inten-
sive surveys and ambient monitoring and water quality reports under sections
104 and 305.

      Response efforts to oil and hazardous spills should receive higher
emphasis than development of contingency plans.  Oil should receive more
focus than hazardous materials.

      For non-point sources, the assessment of regional and local problems
is assigned precedence, followed by the establishment of State/local manage-
ment authorities.  Implementation of regulatory and other controls is assigned
a lesser priority.

      In water quality standards, focus should be placed on thermal standards

                                          MAJOR PROGRAM OUTPUTS
                                                             FY 1974
                   FY 1975
(EPA §
(EPA $
(EPA $
(EPA $
Construction Grants
No. of Construction Grant
Dollar Value of
Facilities Plans
Construction Grant

Awards (Millions)



Planning and Monitoring

  303 Basin Plans:
    Water Quality Limited (WQL)  Segments with Adequate Data
        Segment Analysis (Load Allocation)  Completed
    Management Information Completed for the Entire Basin

  208 Planning Areas Designated

  Surface Water Trend Monitoring Stations

    24 Basins


   450 (Expect Additional
        Segments to be
   643 Basins

                                     ALL OUTPUTS ARE NON-CUMULATIVE



      EPA has received approximately 65,000 permit applications.  An
additional 10,000 applications are still expected from facilities which
will fall mostly in the municipal category.   About 15,000 permits are
forecast for issuance through the end of FY 1974.  Another 32,000 permits
have been identified by the Regions to be issued by EPA and the States
in FY 1975.  These are in the municipal and industrial areas.  The remain-
ing permits (for which no output is shown) are in commercial and other
business areas, governmental activities other than treatment plants includ-
ing applications for filter backwash from water supply plants, agricultural
classifications, vessels, and privately owned treatment works.

      Construction Grants

      A total of $9 billion has been made available to the States from
FY 1973-75 monies under the Act.  Approximately $7.7 billion of this is
expected to be obligated by the end of FY 1975.  It is anticipated that
dollar awards in FY 1975 will more than double FY 1974 funding and reflect
the increased number of grant applications meeting prerequisite require-
ments.  These requirements account for the relatively modest increase in
the amount of construction grant awards in FY 1974 ($2 billion) above
FY 1973 ($1.6 billion), when many of the requirements were not in effect.
To achieve the FY 1974 goal, nearly $1.6 billion in awards needs to be
made before the end of FY 1974.

      A fifty percent increase in the number of 201 facilities plans is
forecast from FY 1974 to FY 1975.  This reflects a drawdown of the "on
the shelf" plans and specifications as grants for construction are awarded.
The number of plans is less than the number of project awards as a plan
may cover several separate facilities, and much equivalent planning work
has already been done.

      Planning and Monitoring

      The States' delineation of basin boundaries increased the number of
basins for reporting purposes from 267 (the figure used in the previous
Water Strategy) to over 670.  For each basin there will exist a basin plan
under section 303 to govern the process of source control.  Section 303
basin plans will have an increased content over time.  Only 5% of the plans
will have reached an intermediate level of management information by the
beginning of FY 1975.  However, most plans will be complete with respect
to water quality analyses to support the issuance of permits in water quality
limited segments.  This conforms generally to the strategy goal of having
such data available by this date.  As of January 31,  1974, only six States
or Territories have completed their segment identification and classification.
Incomplete segment lists have been provided by 47 States and 3 States have
not provided any lists at all.   A total of 3,103 segments have been identi-
fied,  split nearly evenly between water quality and effluent limited.

      There will be no actual increase in the number of monitoring stations
in FY 1975, but significant relocations and changes in sampling frequency
will occur.  This should result in a substantial enhancement of data recording.
      No particular quantitative outputs have been established for either
0§M inspections or enforcement actions.  For the former, definitional prob-
lems preclude an application of the existing data base, and it is felt that
it is inappropriate to include any goals for the latter category in this


      This section relates the various program activities discussed in
this paper to the time requirements of the Act, and is outlined by the flow
chart on page 15.   The final objective in this sequence is to achieve the
Act's 1983 water quality goals.

      The Act targets two dates, July  1977 and July 1983, to serve as major
mileposts.  There must be achieved by  each date a national base level of
technological control.   In addition, by 1983 the Act provides for the attain-
ment of a level of water quality in the country that will support fishing
and swimming.  In 1977,  in contrast, there is no legislatively specified
ambient goal, although applicable local water quality standards are still  to
be met.  EPA has determined that, generally, these local water quality stand-
ards should provide for recreation on  the water and protection of aquatic  life.

      The period 1973-1977 is generally referred to as Phase I of the Act's
implementation, and 1978-1983 as Phase II.  The distinctions between Phase I
and II are sometimes blurred, especially in programs which are not geared
to the periodicity set essentially by  the issuance of permits.  These others
include large areas of research, enforcement, and the response to unique
or accidental spills.

      Phase I emphasizes the issuance  of permits and the award of construction
grants.  Its goals provide the basis for meeting much of the 1983 goals, and
for some pollution sources achieving the 1977 requirements will be all that
is necessary for 1983.  Most of the pollution problems being addressed in
this phase are well identified and, compared to many of the problems which
will remain, readily correctable.  Much of the Phase I effort proceeds from
the work of the State and the Federal  Government in past years.

      Phase II will be a period when solutions become more subtle and
the alternatives for abatement more conflicting.  It will demand a better
understanding of the cause-effect and  cost-benefit relationships between
objectives and results.  This will be  the period for implementing most

of the plans for controlling non-point sources and the more difficult
point sources of pollution.  A solid start toward addressing these problems
will already begin, however, during Phase I.

      The Act also contains the goal of no discharge of pollutants for
1985.  This goal cannot be implemented under the authority of the existing
Act.  Furthermore, EPA foresees that universal achievement of "no discharge"
by 1985 may not be either feasible or environmentally desirable.  Indeed,
for the 1983 ambient water quality goal as well, the present interpretation
of the legislative caveat "where attainable" recognizes that naturally
occurring conditions, or uncontrollable non-point source pollution, could
result in a failure to meet the 1983 goal everywhere.  However it is not
intended that point source pollution, whether individual or aggregate, be
the prevailing reason for its non-achievement.

      Since the beginning of Phase I, States have had under way a pro-
gram of dividing all basins into hydrological segments.  Where the
application of best practicable technology for industries and secondary
treatment for municipal plants will result in meeting 1977 water quality
standards, the segment will be categorized as an effluent guidelines lim-
ited segment.  Where this technological base will be insufficient for the
necessary level of water quality, the segment will be classified as a
water quality limited segment.  Where there is significant doubt, a seg-
ment will be considered as a water quality limited segment, subject to a
later reclassification.

      Plans of differing complexity are prepared for the two types of segments,
the water quality limited segment planning being more complex.  Permits may
be written immediately, on the basis of guidelines, in the segments that are
effluent limited, as well as selectively in the water quality limited segments,
where non-critical parameters are involved, or where the water quality analysis
for load allocations has been performed.  Permit issuance in the remainder
of the water quality limited segments will properly wait until water quality
analysis has been completed, or until it is clear that the analysis cannot
be done in time for the December 1974 deadline  (at which time permits may be
written based on guidelines).  Funding will not necessarily favor proj ects
located in one type of segment over those in another, since treatment works
providing secondary treatment may be urgently needed in an effluent limited
segment to meet water quality standards.

      Within water quality segments, an analysis based on monitoring surveys
and other data will develop maximum daily loads for pollutants and establish
target effluent reductions for dischargers.  These, rather than effluent
guidelines, will form the basis of permits in both Phase I and Phase II.

      This scenario underlines the importance of having established water
quality standards as a fixed point against which to measure loadings at
the beginning of both Phase I and II.  Revisions of water quality standards
during the first 18 months after passage of the Act were made to establish
consistency.  For the most part, they continue to apply criteria values
established over five years ago.  Revised criteria are being developed,
and new or adjusted criteria values will be incorporated in a revision of
standards in 1976.

      At or by the beginning of Phase II, revision of standards, prin-
cipally to upgrade those use designations that presently call for a class
of water quality less than that required for 1983, should have been accomp-
lished, or planned.  Research on criteria areas where present biological,
physical or chemical knowledge is inadequate should be completed in time
to affect the final refinement of standards in 1978.

      The initial review of water quality to assign segment classifications
has the limited focus of preparing the data necessary to support the
issuance of first round permits.  This review will be supplanted, in
the 1975-78 time period, by a continuing State program to (a) analyze all
waters against a more complete series of water quality criteria parameters;
(b) classify those segments which will be water quality limited in 1983;
and (c) assign load allocations in these segments further reducing point
source and non-point discharges to achieve the 1983 ambient water quality

      Permits will be issued as soon as possible during Phase I to set
compliance with the 1977 requirements.  A second round will occur within
five years to set compliance with the 1983 requirements.

      For industrial point sources, the first round of permits will be based
on the best practicable effluent guidelines developed for many major
industry categories, or on the basis of water quality analyses prepared for
much of water quality limited stream segments.  Additional data on water
quality for all waters, and more complete guidelines coverage of industrial
categories, will be available for the second phase of permit issuance.

      Periodic reviews will be conducted to evaluate those categories or
classes of dischargers which are presently excluded from coverage by permits
under effluent guidelines because of their small size (such as many agricul-
tural dischargers), or because of the difficulty of uniform abatement
(such as storm sewers).  It is expected that dischargers presently administra-
tively excluded will increasingly be brought under the control of the program.
A continuing effort will be undertaken to modify municipal permits to reflect
pretreatment requirements.

      In the municipal field, where there has been historical relationship
between the levels of government, Federal financial assistance is provided
to communities to help meet the terms of permits.

      During Phase I, construction grant awards will continue to be con-
centrated on historically eligible projects such as treatment plants, rather
than newer eligibilities such as collection sewers.  This priority focus
recognizes the enforceable requirements of the law in contrast to those
areas where construction may be desirable, but is not mandated.

      To achieve immediate water quality improvements, permits for existing
facilities will emphasize operations and maintenance steps that can be
achieved with minimal capital investment.

      During the 1974-1976 period, communities and States should intro-
duce within the State priority list, facilities plans to study and develop
proposals for the abatement and control of combined and storm sewer flows.
As the backlog of treatment plant construction is funded and under way,
the major focus is expected to shift to an abatement of pollution from
combined and storm sewers.  This is likely to be necessary in some areas
to meet the 1983 water quality requirements.

      As most plants achieve the minimum technological standards that
are required (secondary treatment by 1977-1978, which may also suffice
as best practicable treatment in 1983), some facilities, because of
growth or water quality requirements, must employ higher levels of treat-
ment.  They will undertake increasingly important studies to achieve a
cost-effective solution to their problems.  They will select between
major alternatives, including:  (1) the type of treatment:  recycling,
land disposal,  or surface water disposal; (2) the increase in capacity
versus correction of infiltration/inflow; and (3) the sources to be
treated--whether combined sewer overflows or higher plant efficiency.

      The Federal funding program will continue to be oriented towards
the correction of existing problems, and not towards a perpetuating
level of assistance.  It is expected that with the completion of that
construction necessary to meet the 1983 water quality requirements, State
and local government will move to an era of financial self-sufficiency.

      Facilities planning is an integral step to the construction
of municipal treatment facilities.  Their completion will be emphasized
during the next several years so that construction of treatment works
can proceed expeditiously.  Over time, these plans will be incorporated
into and in some respects, supplanted by, planning which will take place
at the areawide level.   However, areawide planning is not intended as
a substitute for all the elements of a facility plan, and facility plans
will remain a precondition to the award of a Step 2 or 3 grant.


       The areawide planning effort under section 208 will be initiated
in 1974.  Because of the comprehensiveness of these plans, including
their coverage of all point and non-point sources and their effective
control of land use, they will not affect decisions on programs or source
abatement during Phase I.  They will be the basic structure for the imple-
mentation of nearly all of Phase II, however, within the areas they
cover.  Areawide plans should be completed no later than 1978, and should
focus especially on severe sources of pollution which threaten the areawide
achievement of 1983 requirements.

      States will develop basin plans for all waters in the State.  This
effort is under way, and basin plans will serve as a structure under which
the more detailed facilities and areawide plans can be integrated.  Most
State basin plans are presently limited to segments, sub-basins and those
elements necessary to support the issuance of permits.  The initial sub-
stance of these plans will be revised to incorporate:  water quality
analyses conducted during 1975 through 1978; inventories of the sources
of pollution; upgradings of water quality standards; results of facilities
planning under Step 1 of the construction grant process; introduction of
programs to abate non-point sources and residual waste; and program proposals
developed under the areawide planning process.  These revisions should be
finished and basin plans completed by the end of 1978.

      As the abatement of point sources is achieved, the scope and nature
of non-point source pollution will become increasingly obvious.  During
Phase II, NFS control may become the major program emphasis.  Preparation
for this will occur in Phase I, during FY 74-76.  EPA will expand its
information and guidelines on non-point source control methods and tech-
niques, and with the States undertake cooperative demonstration projects.
Guidelines will be issued for the establishment of the appropriate State
and areawide planning processes and management capabilities, under Sec-
tion 208.  States and areawide agencies are expected to have developed
NPS control strategies in 1976-77, but States may initiate efforts earlier.

      The relationships between all program activities and results will
be determined through a monitoring program.  It will be based on measures
of water quality, supplemented by program assessments and reports.

      The major monitoring activities will be encompassed within the
National Water Quality Surveillance System of paired stations, intensive
surveys, and the States' primary monitoring networks.  This will be
supplemented by monitoring done by other government agencies.

      Much of the data developed will come frbm State water quality
analyses conducted under 303(d) and  (e) during 1975-1978; hence the
system will not have full scope until 1977-1978.  Relatively complete
information on existing water quality conditions across the Nation should
be available for Phase II of permit issuances.

                              1173    .    H74
                                                     1I7S    .     IBM     .    1177     .    1171
                                                                                 MM    ,   1!


P 0 T W's




                    REVISE WATER DUALITY
                     REVISE WATER QUALITY
                             CONDUCT WATER QUALITY ANALYSES AND LOAD
                                    ALLOCATIONS FOR  1983
         GROUP 1
       EFF'. GUIDE
     GROUP 2
                             INTERIM GOAL
                             BPT AND
                                                                              ISSUE SECOND ROUND OF PERMITS    DISCHARGE
                                                                                                            , COMPLIANCE
                                                                      CONSTRUCTION OF ADVANCED TREATMENT
                                                                        COMBINED / STORM SEWAGE FACILITIES
                                                     WATER DUALITY
                                                            COMPLETE MOST
                                                       PLANS COMPLETE
                                                    \ INITIAL PLANS
                                                                            BASIN PLANS
                                                           CONTINUES ANNUALLY
                                                    STATE WATER
                                                    QUALITY REPORT
                                    STATE ASSESSMENT
                                    OF PROBLEM
                                                                                       TO LOAD
                                                                  PREPARATION OF
                                                                 -CONTROL PROCEDURES
                                                                                            -»•• CONTINUES

      Analyses made from NWQSS data will ascertain the progress of the
pollution control effort.  The emphasis will be on the total water quality
picture, distinct from the specific requirements of the Act.

      Compliance monitoring and enforcement activities, while intrinsic
elements in any accomplishment of the objectives of the Act, represent a
continuing scope of effort and do not cycle or phase as do other areas
in the sequence.  Specific program guidance for these areas can be found
in Part II--Individual Program Strategies.

      Finally, preparation must be made for resolving future problems.
As water conditions reach the required levels of quality in 1977 and
1983, increasing emphasis must be placed on maintaining and preserving
these levels.  Economic and social pressure to accommodate increased
flows and new sources will develop, and will often threaten water quality
achievements.  Precluding this will require an increased reliance on
policies and regulations on antidegradation, flow reduction, permits
and growth, land use, and land management.

      Many of these issues must be addressed in a provisional way during
Phase I, and a start will be made earlier to protect waters which are
already of a quality higher than the 1983 standards, but further develop-
ment and application of policies in these areas must be a prime concern
during Phase II.


     EPA's sequence of implementation, described in the previous section,
is based on certain assumptions concerning the present quality of waters
in this country, the causes of pollution where it exists, and the trends
and progress that can be made in pollution abatement.  This section presents
a selection of ambient and program data on the subject, together with

     1.  Inland Surface Water.

     Water pollution affects inland surface waters in all States and in
almost every river basin.

     In 1971 approximately one-third of the stream miles of the United
States were estimated by the Regional Offices of EPA to be violating water
quality standards.  In 1973, an inventory of river segments by the States
showed that:

     a.  Pollution exists in 3100 water segments of varying lengths
         and areas, in 53 States and Territories reporting.

     b.  About half of the segments are so heavily polluted the
         dischargers located on them will be required to go beyond
         1977-level pollution controls to enable water quality
         standards to be met:

         Effluent guidelines limited segments          1515
         Water quality limited segments                1588

         Total segments identified by States           3103

These "segments" are the basic units which will be planned for and included
in State basin plans under section 303.  Since it is not yet known what
portion of all the nation's waters the segments represent, no comparison
can be made with the "one-third of stream miles polluted" figure of 1971.

     c.  Based on the State problem assessments now available,
         one-third or more of the segments may be able to meet
         water quality standards by 1977:

         Standards to be  met by 1977                   1190
         Standards to be met by 1978-1983              1116
         Standards to be met after 1983                 119
         Not stated/not applicable                      678

         Total segments identified by States           3103

This projection represents a major and serious difference between the time-
table of the Act (meeting applicable water quality standards by 1977, and
meeting fishing and swimming water quality standards where attainable by
1983) and the States' own assessment of probable water quality improvement.
The projected shortfall by two-thirds in 1977 is due principally to forecasts
of the availability of Federal funds for the publicly owned treatment works
needed to meet standards, the lead times involved in the construction of
both public and private facilities, and an awareness of the dimensions of
non-point source pollution.  EPA plans to work intensively with the States
on a joint review of these projections.

     d.  The States have identified their most severe areas
         of water pollution.  Examples of some of these State-
         identified basins are given below.
   Severely Polluted Area
      Pollution Cause
New York
New Jersey
West Virginia







Lower Hudson River
Shellfish harvesting grounds
Brandywine River
Monongahela River

Illinois River
Jefferson County

Lake Pontchartrain

Arkansas River


Big Blue River

Santa Anna River

Southwestern streams
General mun/ind source loading
Vessel wastes, polluted rivers
Urban Runoff
Acid mine drainage, barge oil
Thermal discharges, mun/ind
Interbasin water transfer,
  low dilution ratio
Stormwater bypasses, recrea-
Naturally high dissolved
  solids, salts; industry
Injection wells, artificial
  recharge, mining
Agricultural, feedlot, natural
  runoff; mun/ind
Groundwater salinity, irriga-
  tion return flows
Overdeveloped septic tank
As the table shows, the causes of severe pollution are as varied as the
number of areas identified.  In this circumstance there are limits to national
strategies for water quality improvement.  States must undertake to plan for
these areas through the State continuing planning process--either in basin plans,
or in some cases through arcawide authorities set up under section 208 to
regulate all point and non-point sources within their jurisdiction.

     In addition to the inventory of river segments, EPA studied 22 major
rivers in detail in 1973.  The rivers were selected because of their length,
their flow, and their proximity to large cities.  The analysis sheds some
light on the kinds of pollution requiring controls and on recent trends:

     e.  The worst readings and trends are those for nutrients:
         from 25% to 541 of the reaches exceed EPA's phosphorus
         guidelines set to protect against accelerated eutrophi-
         cation in flowing streams.  Furthermore, from 50% to
         84% of the reaches show increased phosphorous levels
         in 1968-1972 over the previous 5 years.  The nitrogen
         nutrients, while generally not exceeding reference
         levels, have increased in 60-74% of the reaches mea-
         sured .

     f.  Other pollutants with high levels are phenols (indus-
         trial compounds which can taint fish flesh) and sus-
         pended solids (which interfere with some aquatic life
         processes).  These results are not as disturbing as the
         nutrient data, because in 70-80% of the reaches with data,
         phenols and suspended solids improved in the last 5 years.

     g.  The pollutants receiving the most widespread controls--
         bacteria and oxygen demand--show general improvement
         in the last 5 years.  Dissolved oxygen and oxygen-demand
         levels improved in 63-72% of reaches; bacteria in 44-75%.

These data point to the emergence of eutrophication as a potential
problem in the country.  The added fact that both the amount and con-
centration of nutrients rise in wet weather signals the future importance
of non-point source controls on urban runoff and agriculture in cor-
rect ing eutrophicat ion.

     The data also point, with eutrophication as an example, to the
growing complexity of the picture of water quality.  Oxygen demand and
coliform bacteria can no longer be taken as necessarily the best measure-
ment of the water quality problem; in some reaches other parameters are
clearly more critical.  Better analysis and a flexible control strategy
will be needed in Phase II to register water quality gains.  Thus the
1983 discharge standard for publicly owned treatment works continues
the secondary treatment levels for 1977, providing flexibility as to what
additional parameters (and urban sources) are to be controlled.

     All of the above trends run the risk of being aggravated in the
future.  Restrictions on intensive cultivation practices which encourage
erosion and on the use of fertilizer will run counter to a growing


demand for agricultural products.  Inorganic wastes from industrial
processes are a major problem, controllable by current treatment measures.
However, if their volume increases seven-fold, as is expected by 2020, a
major technical innovation will be required to develop effective treat-
ment methods for these compounds.  The expected doubling of municipal
water use and quadrupling of industrial use can result in reduced
dissolved oxygen levels, as a greatly increased volume in wastewater
would overcome the BOD removal efficiencies achieved by presently specified
methods.  Additionally, a doubling of electric power generation by 1990
could significantly aggravate the problem of thermal pollution.

     h.  The reported number of oil spills on inland rivers,
         Great Lakes, and coastal estuaries increased 171
         between 1971 and 1972, the last years with available

         1971 - 7000 reported oil spills
         1972 - 8300 reported oil spills (15 million gallons)
         1973 -  300 hazardous spills (2 million gallons)

These spills resulted in sudden, and sometimes devastating, environmental
degradation.  The increase in the reported number may partly reflect more
efficient reporting, but it also points to increased hazards in transporting
oil and hazardous substances.  It underlines the necessity of coupling
deterrence with long-range programs for spill prevention.

     2.  Groundwater.

     As of mid-1972, 246 subsurface injection wells had been constructed in
the U.S.--virtually all of them within the last ten years.  Of these wells,
more than ^0% were operated by chemical, petro-chemical, or pharmaceutical
companies and about 25% by refineries and natural gas plants.  EPA anticipates
that as a result of the Act there will be a dramatic increase nationally
in both the surface and subsurface disposal of wastes and wastewater, and
with this an increase in the danger of contamination of groundwater.  The
nation's petrochemical industry, in its production phase, uses waste injection
wells and settling pits, as do steel mills, metal plating establishments,
pharmaceutical laboratories, food processing plants, paper mills, oil refineries,
sewage treatment plants, water treatment plants, certain agricultural coopera-
tives, and geothermal power producers.

     The significance of this projection is apparent when it is considered
that groundwater is the origin of the base flow for most inland surface waters.
It accounts, in whole or in part, for the public water supply of one third
of the nation's 100 largest cities and 95% of its rural population, and
over half the water used for livestock and irrigation.  Groundwater is contained
in a geologically enclosed basin, but it occurs at varying depths so that a

single contaminating well may pollute two or three aquifers.   It typically
flows at very slow rates of from 20cm/year to 2m/day.  This,  in combination
with the fact that it lacks many of the self-cleansing properties of surface
water, means that groundwater polluted with relatively persistent chemicals
may remain in this state indefinitely.

     3.  Marine Waters.

     Marine waters are indirectly polluted by wastes which are discharged
inland and carried to the sea by streams, and by atmospheric  fallout.  They
are also polluted directly by ocean disposal of wastes and dredged materials,
oil spills, and discharges from ocean outfalls.  Discharges from outfalls
are subject to EPA permit restrictions under section 402 of P.L. 92-500.
Permits for the disposal of dredged material are issued by the Corps of
Engineers under guidelines established by EPA .  Since April  1973, disposal
of other materials in the ocean has been regulated by the Marine Protection,
Research, and Sanctuaries Act (P.L. 92-532).  Preliminary data indicate
that only off the Mid-Atlantic and Gulf States are permits generally being
issued for ocean dumping; average monthly disposals are presently larger than
the estimated rates in 1968.  On the Pacific Coast only one permit has been
issued; industrial sources are expected to turn to other disposal methods.
There is no history of ocean dumping of sewage sludge in the  Pacific, although
it is discharged from outfalls.


     The basic elements of the Strategy for controlling water pollution
are set by the scope and emphasis of the Act itself.  Of all receiving
waters, the Act focuses (Federal) attention on navigable waters first.
Of all dischargers into these navigable waters, the Act assigns highest
priority to point sources for control.

     Accordingly, the initial sections of this part of the Water Strategy
concern programs for the control of stationary point sources, discharging
inland to streams, lakes, and rivers.  Later sections deal with sources
which are diffuse or intermittent, and with the pollution of oceans and

     The Act's primary mechanism for controlling point source discharges
into inland and coastal waters is the National Pollutant Discharge Elim-
ination System.  Under NPDES, permits are issued stating the limits of
allowable discharge in 1977 and 1983 (the general target dates of the Act)
and a schedule of interim dates and allowable discharges.  Section A
explains the basis for the final effluent limitations contained in these
NPDES permits.


      Every point source is subject to an effluent standard and a water
quality standard.  The effluent, or technology, standard states what is
economically achievable in pollutant reduction for that class and type of
discharger, nationally.  The water quality standard can be used to determine
what additional pollutant reduction is environmentally necessary to achieve,
if the particular stretch of water on which a discharger is located is to
be used for its designated purpose (drinking water supply, swimming).

      The effluent limitation which is contained in a discharger's
permit is calculated by comparing the technology standard for the source
category with the xvater quality standard for the receiving waters, and
adopting whichever implied level of control is more stringent.  This is
done on a constituent-by-constituent basis, so that a discharger in a
water quality limited segment may find that the level of discharge of two
of his pollutants is established by load allocations, for example, while
seven other pollutants are controlled by effluent guidelines.  In practice,
the technology standard is used as the base level for limitations.  Its
provisions are tightened where necessary to meet water quality standards.

      The concept of base-level limitations unrelated to local water
quality is one of the major innovations of the Act.  It represents a
departure from water pollution control practice prior to the 1972 Amend-
ments, when water quality standards alone were the basis for treatment

      The following discussion outlines EPA's strategy for setting
effluent standards and water quality standards.  It then treats three
areas where the described relationship between effluent standards and
water quality standards for calculating effluent limitations is not
entirely accurate.  These areas are toxic pollutants, where the effluent
standard is not based on technology; thermal discharges, where the efflu-
ent standard may not be the base level for limitations; and limitations
above 1983 effluent standards, where higher levels of removal to meet
water quality standards will not be automatically imposed.

A.I.  Effluent Standards

      Sections 304, 306, and 307 of the Act require EPA to develop
technology-based standards (or guidelines for effluent limitations) for
the following regulatory deadlines:

           Point Source

By 1977:
   publicly owned treatment works
   sources other than POTW's

By 1983:
   publicly owned treatment works
   sources other than POTW's
Following publication of proposed
   new sources other than POTW's
Within tnree years of promulgation:
   sources discharging into POTW's -
    Level of Control
secondary treatment

best practicable control technology
currently available (BPT)

best practicable waste treatment
technology (BPWTT)
best available control technology
economically achievable (BAT)
new source performance standards
pretreatment standards
      For each industrial category and for municipalities, prescribed
levels should represent efficient levels of removal of pollutants within
the Act's directive that all categories of sources proceed towards no
discharge of pollutants by 1985.

      Where possible, effluent standards for 1977 will incorporate tech-
nology that is compatible with the technology for meeting 1983 standards.
Guidelines will be written to minimize the cost of new controls for
industrial or municipal sources which do not take the preferred option
of installing BAT/BPWTT now.

      EPA will, in selected instances, subcategorize its effluent
guidelines to reconcile two somewhat competing goals of the Act.  The
Agency is required to promulgate uniform guidelines that may be applied
to individual permits and enforced in court without the necessity of
treating each discharger as a unique situation.  The Agency is also
required to give effect in these guidelines to factors which may result
in different limitations to different plants:  their age and size, raw
materials, manufacturing processes, products produced, available treat-
ment technology, energy requirements, and costs.  In the process of
accommodating the needs for both specificity and uniformity, EPA has
identified, among the initial 30 industrial categories of section 306,
approximately 180 industrial subcategories and 45 additional variances
as subjects for different standards.

      Standards will normally be expressed as single numbers rather
than as ranges of values.  All necessary economic considerations will
generally be taken into account in the derivation of a standard (by
adjusting the general prescribed removal level, or by subcategories),
and therefore will not reappear in its application.  This guidance is
based on the experience that the least stringent of a suggested range
of values frequently becomes the maximum requirement that can realis-
tically be enforced, so that a single value system results in any case.
A single numerical standard can be far easier to interpret and to
administer than a range of numbers.  Some standards will contain a
variance clause, however, to allow the reconsideration of limitations
on a case-by-case basis during the permit application process.

      a.  Industrial Standards:  Best Practicable and Best Available
          Technology and New Source Standards

          The methodology for industrial standards is substantially out-
lined in the legislative history to the Act.  Beyond this guidance few fixed
rules will apply from one source category to another.  Each guideline will
reflect informed opinion on the amount of effluent reduction attainable, for
1977, through good housekeeping and end-of-the-pipe controls, and for 1983,
through these and process changes.  As an indicator, legislative history
provides that the capability of the best present performers should be the
minimum acceptable level for BPT guidelines, and the single best performance
as the minimum acceptable level for BAT guidelines.

          While limitations for 1977 based on best practicable control
technology currently available will generally be less stringent than the
limitations for 1983 based on best available control technology economically
achievable, in some cases BPT may equal BAT.  This reflects the fact that
guidelines for limitations based on BPT can be set at relatively high levels
of removal, including some calling for "no discharge."  In other cases BAT
may reflect prototype technology not yet demonstrated to be practicable,
and thus may even exceed the currently promulgated standard for new sources.

          Detailed information on EPA's schedule for developing indus-
trial guidelines is contained in Appendix C.

      b.  Municipal Standards:  Secondary Treatment and Best Practicable
          Waste Treatment Technology

          Secondary treatment is a uniform standard based on the most
cost-effective level of removal of BOD, and in addition to BOD, will con-
trol suspended solids, fecal coliform, and pH.

          In contrast to secondary treatment,  where EPA is required to set
an effluent standard, under the Act,  criteria-setting for best practicable
waste treatment is discretionary.   Values for BPWTT will nevertheless be
set to provide a basis for planning,  funding,  and permitting of projects
for 1983.  The definition will reflect Congress' emphasis that other than


traditional methods of treatment be considered in the long-range planning
for POTW's.  EPA will set criteria for land application and wastewater reuse
as well as for treatment and discharge.  Cost-effectiveness regulations for
grant applications specify that these alternatives be considered before
a project decision is made.  Groundwater will be protected by the standards
on chemical and organic pollutants.  As the technological minimum, surface
water criteria will be set at a level equivalent to secondary treatment.

      c.  Pretreatment

          Pretreatment standards for new and existing sources have been
written to protect the operations of the treatment works into which user
industries discharge, and to prevent the pass-through of pollutants which
are inadequately treated.  Thus the pretreatment standard prohibits influent
into municipal works which could cause fire, explosion, process upsets, or
other damage to operations.  It also divides all constituents into compatible
and incompatible pollutants:  industries may take credit for compatible
pollutants which a municipal plant substantially removes, but they are
required to pretreat incompatible pollutants to BPT levels.  Pretreatment
thus imposes a sliding standard.  A pretreating industry is asked to comple-
ment the removal characteristics of the municipal plant it uses and to which
the plant is committed in its NPDES permit; as the treatment process
employed in the plant varies, so will the pretreatment limitation.

          Pretreatment will require abatement measures of a more restricted
number of dischargers within industrial categories than will the guidelines
for BPT/BAT.  The latter apply to all industries.  As a rule pretreatment
standards apply only to industries which discharge in excess of 50,000 gal-
lons per day, or which account for more than 5% of the influent to municipal
works, or which discharge toxic pollutants.  EPA has made these cut-offs so
that the pretreatment requirements will be administrable.

A. 2.  Water Quality Standards

      Prior to the 1972 Amendments, the Federal Water Pollution Control
Act required States to adopt, for Federal approval, and enforce water quality
standards for interstate waters.  Each of these standards consisted of a
designated use or uses to which a body of water would be put; criteria,
representing the acceptable limits of pollutants in receiving waters dedi-
cated to those uses; and schedules of implementation for sources discharging
into the body of water, whose achievement would result in the meeting of
the criteria.  Based on the latest scientific knowledge of the effects of
pollutants on human health, biological communities, recreation, and aesthetics,
EPA developed water quality criteria which it recommended to be included
in the water quality standards.

      Initial Promulgation and Review of Standards:  1973-1974

      Section 303 of the 1972 Amendments calls for an expansion of the
Federal/State standards system to all navigable waters, including intra-
state waters.  Accordingly, the first objective of the water quality

standards program has been to promulgate Federal/State intrastate standards,
and to bring up to date many of the established interstate standards.

      The earliest possible completion of the initial standards setting
and revision process is necessary to establish a firm water quality target
for 1977.  A definitive classification of segments depends equally upon
final water quality standards and final effluent guidelines.  In stream
segments classified as water quality limited segments, water quality standards
are the basis for determining the effluent limitations which must be assigned
to point sources.  Where a State's revision or promulgation has not been
satisfactory EPA acted to promulgate standards.  By June 1974, Federal/
State water quality standards should exist for all navigable waters of the
United States and its territories.

      In Phase I, the objective of the Act, "to restore and maintain the
chemical, physical, and biological integrity of the Nation's waters," has
been administratively interpreted as requiring, as general minimum, standards
which will protect indigenous aquatic life and secondary contact recreation
(limited body contact, such as boating and fishing).  These uses and assoc-
iated criteria will be incorporated into the standards unless an exception
for a lower use has been requested and assigned because:

      •  present technology cannot restore the water quality to
         these levels, or

      •  the cost of meeting these standards is economically
         prohibitive compared with the expected benefits, or

      t  the natural qualities of the water are less than the
         recommended minimum criteria.

Water quality which will support these aquatic life and secondary recreation
uses will be generally sufficient to protect others, such as raw public
water supply, agricultural and industrial use, and navigation.

      Subsequent Revisions of Standards:  1976-1978

      The aim of subsequent standards activity will be to establish use
designations and supporting criteria consistent with the Act's 1983 goal
of water quality, where attainable, that will protect aquatic life and
primary contact recreation (swimming); and to see that these uses and cri-
teria are in effect no later than 1978, thus providing a basis for imposing
needed point and non-point source controls to achieve that goal.  Lower
use designations should not be made initially unless the natural quality
of water is less than the recommended minimum criteria.  A further balancing
of socio-economic and environmental costs and benefits may take place in
hearings under section 302.

      In addition to the goals of the Act, these reviews for Phase II will
take into account any new Federal and State legislative requirements and
information.  States will have increasingly accurate knowledge of the causes
of any remaining low quality waters.  The Federal Government will continue
to review water quality standards and to revise and expand recommended cri-
teria.  Standards may also be modified to reflect the Act's provisions
regarding the discharge of heat and toxic materials.

      Revised standards under Phase II will consist only of designated
uses and criteria:  standards implementation will be conducted through con-
struction grants, second round permits, and other mechanisms of the law.

      States and EPA Regional Offices should coordinate these substantive
objectives with the law's procedural requirement that at least once every
three years each State hold public hearings to review and as appropriate
modify its water quality standards.  The first round of standards promul-
gation and revision discussed above is considered the States' initial
review.  States should use their continuing planning process to schedule
and carry out these reviews.

      Water Quality Criteria

      The Act required EPA to publish revised recommendations for water
quality criteria by October 1973.  The prime sources for these recommenda-
tions included the 1968 Report of the National Technical Advisory
Committee to the Secretary of the Interior ("Green Book") and a refined
and more comprehensive version of this report prepared under contract
to EPA by the National Academy of Sciences ("Blue Book").  The raw
scientific data have been condensed and simplified to facilitate their
use in subsequent reviews of water quality standards.

      The 1972 Amendments required the Administrator to publish additional
information on the higher water quality objectives of the Act.  A second
volume therefore provides information on sources of polluting constituents
(man-made or natural), mean levels in major river basins, techniques for
biological and physical measurements, methodology for bioassays, the
overall classification of water quality, and types of pollutants suitable
for maximum daily load measurements.

      Application of EPA's recommended criteria to a given waterway may
vary according to local conditions and socio-economic factors relating
to a water's use.  A case in point would be the known potential for some
pollutants (e.g., chlorine) to have a synergistic effect, which would
warrant the application of additional safety factors.  Information developed
in connection with a thermal discharge hearing under section 316 may also
subsequently bear upon the appropriateness of thermal criteria contained
in a water quality standards.

      Toxic water quality criteria will be coordinated with the establish-
ment of toxic effluent standards under section 307.  Criteria will supply
the base information from which the effluent standard methodology proceeds.

      Through its laboratories and contracts, EPA will conduct research to
refine and expand the scope of Federal water quality criteria.  Publication
of the next recommendations has been scheduled for October 1976 to coin-
cide with the States' 1977-1978 review of water quality standards.  Those
criteria will focus on the highest water use categories.  Priority will be
assigned to toxic and bioaccumulative substances that need updated criteria
for implementation of the 1983 goals.  Where areas of uncertainty persist,
criteria recommendations will err on the side of safety.

A.3.  Toxic Effluent Standards

      The major instruments for the control of discharges from point
sources, including discharges of toxic substances, are effluent guide-
lines and water quality standards.  Both are applied to individual
dischargers through NPDES permits, which are issued approximately once
every five years.  Water quality standards normally are revised once
every three years.

      Any substance is toxic to aquatic life and to other organisms when
it is present in sufficient concentration for a sufficient period of time.
EPA will use section 307 to control only those harmful substances which
are dangerous even in very low concentration.  As a means of discriminating,
and to conform with the clear legislative intent that the toxic list remain
relatively short, the following selection rationale will be employed:
(1) data from laboratory or field studies indicate that a pollutant could
constitute a serious environmental threat if discharged into water (these
would include data on bioaccumulation, teratogenicity, mutagenicity,
carcinogenicity, and high acute toxicity), (2) the pollutant is discharged,
or has the potential of being discharged, from point sources, (3) data are
available to establish effluent standards meeting the requirements of the
Act, and (4) standards-setting under section 307(a) is appropriate because
the timing and effectiveness of abatement actions under other provisions
of the Act are not commensurate with the seriousness of the problems identi-
fied by the above criteria.

      Using these criteria,  EPA has promulgated the following initial list
of toxic pollutants:

            Aldrin-Dieldrin            Endrin
            Benzidine                  Mercury
            Cadmium                    Polychlorinated Biphenyls
            Cyanide                    Toxaphene
            DDT (ODD, DDE)

      Appearance of a substance on the toxic pollutant list is a signal
that water quality criteria for the pollutant will be incorporated in the

next revision of all water quality standards.  At the same time, guide-
lines for industries which have been identified as major dischargers of
the pollutant will be checked and if necessary retro-fitted for adequate

      The effect of toxic effluent standards will be to require the base
level of reduction that is necessary to meet toxic water quality standards.
This level of control incorporates a margin of safety, which will be
revised and refined to reflect local conditions after criteria for toxic
pollutants are incorporated into water quality standards.

      Toxic discharges which still result in acute environmental damage,
from sources proceeding to meet their 307(a) limitations, will be controlled
by EPA under the authorities of sections 311 and 504.  Section 311 (e) pro-
vides for injunctive relief against discharges of hazardous substances
(of which toxic pollutants are a subset) that threaten the public health
or welfare of the United States, including damage to fish, shellfish,
and wildlife.  Section 504 gives the Administrator emergency powers to
restrain discharges of any pollutants which present an imminent and sub-
stantial endangerment to the health or livelihood of persons.

A.4.  Thermal Limitations

      A discharge of heat is a pollutant under the Act and hence is subject
to applicable effluent guidelines and water quality standards.  However,
section 316 of the Act contains provisions, unique to thermal discharges,
which (1) allow thermal control requirements to be modified if the source
can demonstrate that they are excessively stringent for aquatic life pro-
tection; (2) require that effluent limitations minimize the potential
damage of cooling water intake structures and (3) provide assurances
that a source will not be required to make multiple modifications respecting
its thermal component within a short period of time.

      The interim water quality criteria published by the Administrator
pursuant to section 304(a) will, when final, supersede EPA's former water
temperature recommendations.  By specifiying seasonal average and maximum
temperatures for individual fish species, the new criteria can provide better
protection of aquatic life than is achieved by most of the existing State
water quality standards.  State standards will be revised as necessary to
integrate the new recommendations.  For each waterway, the State will
determine one or more species which should be protected.  The selected
species should be indicative of the overall local biologic situation, so
that the resulting criteria adequately protect the balanced, indigenous
aquatic population.  The site-specific temperature requirements will then
apply in all areas of the water body outside of defined, limited mixing

      Effluent limitations should be determined initially by reference to
any applicable effluent guidelines.  Controls more stringent than those
provided in guidelines may be imposed where necessary to achieve thermal
water quality standards.  Standards may be particularly relevant for indus-
trial categories subject to effluent guidelines which do not address the
thermal component of the discharge.

      Conversely, under section 316(a) any source may petition for relief
from thermal limitations, including limitations proposed in accordance
with effluent guidelines or water quality standards.  If the source can
demonstrate to the permitting agency that the proposed limitations are
more stringent than necessary for the protection and propagation of a
balanced, indigenous population of shellfish, fish, and wildlife, alterna-
tive limitations may be imposed, after opportunity for public hearing, which
afford that protection and propagation outside of any mixing zone.  An
existing source may make its 316(a) demonstration by showing that its prior
operation and discharge has caused no appreciable harm.  Any source may
attempt to satisfy the demonstration requirement by showing that the proposed
limitations are more stringent than necessary to protect particular indicator
species selected by the permitting agency.  In the absence of either of these
demonstrations, the 316(a) showing must involve production by the source of
comprehensive information regarding the water body and the discharge.

      Section 316(c) of the Act provides that if a point source commences
a modification of its thermal component after the date of enactment of
the 1972 Amendments and the modification is sufficient to achieve effluent
limitations pursuant to sections 301 and 303 and sufficient to assure
protection of a balanced indigenous aquatic population, the source may
not be subject to any more stringent thermal effluent limitations for ten
years after completion of the modification (or the period of its tax write-
off, if shorter).  It is important to observe that this subsection protects
only sources which are required to make some modification and whose modifi-
cations satisfy both sections 301/303 and the independent "balanced,
indigenous population" test.  A modification which achieves water quality
standards in effect when the modification was commenced may fail to immu-
nize the source from further near-term requirements, if the standards
themselves were deficient when measured against the Administrator's section
304(a) criteria recommendations.

A.5.  Limitations Above BAT and BPWTT

      The use  of higher  limitations than  technology base levels  to meet
water quality  standards  will operate  automatically up  to the 1983 level
of technology.   Above BAT for industries, limitations  imposed to achieve
water quality  standards  will be subject to special review procedures.  Such
limitations may be  established  only after the permitting agency  holds
public  hearings to  consider  the social and economic costs and benefits
and the availability of  technology to achieve the  proposed  limits,
and the possibility of alternative control strategies.   If  the permittee
can demonstrate that there  is not  a reasonable  relationship between
the costs  and  benefits to be obtained, the proposed limitation will
be adjusted.

      The  Act  establishes this  hearings procedure  in  section  302 for
 limitations  to be  achieved  by 1983.   No point  source  should be required
 in a Phase I permit to  install  facilities above 1983  standards,  without

the benefit of procedures guaranteed by the law for such a situation in
Phase II.  The provisions of 302 will therefore apply whenever the suf-
ficiency of BAT to meet water quality standards is in doubt.

      Where natural conditions prevent the attainment of the national
water quality standards goal, the preferred solution for both 1977 and
1983 is to have the standards reflect this.  Since water quality and not
particular levels of performance is the end goal, the development of
meaningful water quality standards is imperative.

      Where non-point source conditions prevent the attainment of the
water quality standards applicable in 1977, and a combined control
strategy for point and non-point sources will not achieve standards
by then, point source limitations should be set no higher than BAT and
secondary treatment.


B.I.  Permits

      The expeditious issuance of permits is a critical priority in the
conduct of the strategy.  As a general goal, EPA and State efforts should
be directed at getting permits issued to all dischargers in all segments
prior to December 31, 1974.  After this date, dischargers without permits
are no longer immune from either governmental or citizen legal actions.
However, since administrative or technical problems may preclude the full
accomplishment of this goal, permit issuance efforts should concentrate
on significant dischargers and on those for which a lengthy abatement
schedule is expected.

      State Program Coordination

      EPA Regional Offices and the States should cooperate to facilitate
the issuance of permits.  As an example, if a State possesses all the elements
for a permit program under the National Pollutant Discharge Elimination
System (NPDES) except the necessary legal authority, permits may be completely
processed by the State and issued by EPA.  EPA should also protect the integ-
rity of existing State permit programs by agreements to possibly issue
identical Federal and State permits,  or jointly issued permits.

      States will be encouraged to assume responsibility for issuing permits
under the NPDES program at the earliest possible time.   At the time permitting
devolves from the Region to a State,  care should be taken that the least
possible interruption occurs in the issuance of permits.  EPA Regional Offices
should make available for State use permit material in the pipeline at the time
of State NPDES assumption, and otherwise help in the final processing of these


      Guidelines for Issuance

      Permits should be issued in the order which will have the greatest
beneficial effect on national water quality.  Permit priorities are partic-
ularly important in cases where a Region or State may fail to complete writing
permits by the end of 1974.  Because permit issuance is often subject to the
availability of information such as effluent guidelines or water quality
analyses, a rigid priority system is presently unreasonable and would impede
permit issuance.  Rankings in permit issuance priority lists should reflect
the following kind of considerations, as appropriate:

     a.  dischargers which are covered by effluent limitations guidelines
         BEFORE dischargers which are not covered by guidelines (permits
         based on guidelines are easier to write, and more defensible);

     b.  dischargers in water quality limited segments where load allo-
         cations have been completed BEFORE dischargers in WQL segments
         without load allocations (permits in WQL segments yield greater
         reductions, and therefore water quality improvement, when they
         take into account local conditions as well as effluent guidelines);

     c.  "major" or "significant" dischargers BEFORE minor dischargers
         (by definition, major dischargers from any EPA or State list
         have a greater impact on water quality);

     d.  dischargers with long abatement schedules BEFORE dischargers
         with short abatement schedules (in the interest of having the
         maximum number of sources meeting their effluent limitation
         goals by 1977);

     e.  dischargers in areas of critical water quality BEFORE dischargers
         in other areas (this focuses abatement where the greatest ambient
         gains are needed, and can often be registered, or where pristine
         conditions need protection, according to the States' segment

     f.  dischargers in areas of large population BEFORE dischargers in
         areas of small population (concentration on populous areas dis-
         tributes the aesthetic and recreational benefits of the water
         pollution control program to the greatest number of persons);

     g.  dischargers in areas of national priority BEFORE dischargers in
         other areas (this coordinates all permits with the national com-
         mitment to clean up the Great Lakes, and to track ambient trends
         in certain basins);


     h.   publicly owned treatment works (POTW)  where operations  and
         maintenance can be improved BEFORE POTW's  which are presently
         good performers (improvements  in 0§M can bring about signifi-
         cant effluent reductions quickly and relatively inexpensively).

      Notwithstanding all other guidance, permits should be issued to:

         POTW's having significant construction needs which have
         received Federal assistance, or which can  reasonably expect
         to receive Federal assistance  from FY 1973-75 allotments,
         BEFORE POTW's which have significant construction needs
         but cannot expect to receive Federal funds through FY 1975.

      Bases for Permits

      Permit terms will be based on effluent guidelines, toxic effluent
standards (for certain classes of sources), and water quality standards.
Guidelines will provide the base-level  for limitations.  This will be
revised where necessary to meet applicable toxic standards and water
quality standards.

      It is recognized that a significant effort will be needed to revise
the initial issuance of some municipal  permits to incorporate pretreatment
requirements.  Regions and States should anticipate that this may be a major

      If, by the beginning of FY 1975,  analysis for load allocations has
not been performed in water quality limited segments, industrial permits
to dischargers in those segments should be written on the basis of effluent
guidelines.  If, by the same time, guidelines have  not been published for
a category of sources, and are not expected to issue in time for the
December 1974 deadline, permits to industrial dischargers should be written
on the basis of the best technical judgment of feasible control technology
for that category.

      In water quality segments where analysis indicates that the predominant
reason for not achieving presently established water quality standards is
non-point source pollution, and point source abatement would not achieve
standards, discharge limitations should be based on effluent guidelines unless
a non-point source control program is being implemented.  In this latter  case,
if a combination of non-point and point source control will achieve standards,
the point source permits should be based on the level of control necessary to
contribute to the achievement of water quality standards.

      Permits to municipal dischargers, where there are no funding problems,
should, in general, be written on the basis of secondary treatment except in
the case of advanced-treatment facilities which should, in general, receive
permits requiring them to perform at design capability.


      Permits for Municipal Facilities That Will Not Meet
      1977/78 Requirements

      In issuing NPDES permits to many publicly owned treatment works, EPA
is faced with the difficult problem of developing compliance schedules for
sources where meeting the 1977/78 deadlines required by law is not possible.
The latest State/EPA needs survey, indicating that construction of necessary
facilities would require the expenditure of 60 billion dollars, clearly pre-
sents financial, as well as physical, barriers to full POTW compliance by
1977/78.  For some facilities the financial barrier will exist irrespective
of the courts' resolution of the impoundment issue and of any level of
funding that might be expected in FY75 and FY76.  To resolve this dilemma,
the following policy has been adopted:  Five-year permits providing for
full compliance with 1977 requirements should be issued to all publicly
owned treatment works where no major construction is needed, where construc-
tion scheduled for completion by the 1977 deadline is presently under way
or where the source is sufficiently high on the State's priority list and
the proposed construction schedule is such that compliance with the 1977/78
requirements is possible.  Where it is clear that a municipal facility will
be unable to achieve full compliance with the 1977/78 deadline despite all
best efforts to do so, the facility should be issued a three-year permit
containing only the appropriate interim schedule milestones such as Step 1
and 2, and performance and other conditions which can realistically be
achieved during its term.

      For facilities which will be physically unable to complete construction
by the 1977/78 deadline, as for example a facility on which construction has
already begun but the size of the project results in a completion date after
1977, EPA will review the practicability of issuing a permit that reflects
realistic completion dates even though this may not result in compliance with
the 1977/78 deadline.

      Municipal Permits and Growth

      Selected municipal permits will also include special growth-related
conditions designed to ensure continued high performance by the facilities.
These facilities will be reminded that EPA or the State possesses the stat-
utory authority under the Act to obtain a court order banning or restricting
new sewer connections in the case of permit violations.

      For facilities where an overload appears imminent (e.g., operating in
excess of 85% of design flow or BOD load and experiencing annual population
growth in excess of 3%), specific planning and management actions will be
required on the part of the municipality including coordinating capacity
decisions with land use plans.  Such actions can be introduced in the facil-
ities planning or areawide planning processes, to be developed by local units
of government.

      For facilities presently overloaded (exceeding design flow or BOD
load), permits will specify increased removal efficiency through improved
0§M, adjustments in flow through changes in user fees, or provision of
additional capacity where this is consistent with water quality requirements.

B.2.  Compliance

      The achievement by dischargers of permit requirements, and by
potential spillers of oil or hazardous materials of uniform preventive
measures, will be assured by a four-pronged compliance program.

      The first element is the assistance provided by States and EPA
to municipalities to promote effective operations and maintenance efforts
at municipal facilities.  The second is the application of good self-
monitoring practices, as required by NPDES permits, which will enable a
discharger to respond quickly to changes in its discharge and take both
preventive and corrective actions.

      The third area is facility inspections and ambient and effluent
monitoring by EPA and the States to observe changes in water quality and
compliance with permit requirements.  This effort, when combined with the
self-monitoring data, will provide the information necessary to:

      a.  Detect significant waste sources that are not permitted.

      b.  Validate self-monitoring reports.

      c.  Assess compliance with permit conditions.

      d.  Develop the water quality effects of non-compliance.

      e.  Develop priorities for enforcement actions.

      The fourth area is enforcement under the authorities provided to
EPA by the Act, and to the States under State law.  EPA can proceed civilly
to order compliance with the terms and conditions of any permit, and can pro-
ceed criminally and civilly to punish violations of permit conditions.  This
enforcement authority is a keystone to accomplishing the goals and require-
ments of the Act, and EPA, as a regulatory agency, will continue to use it
fully.  EPA may also invoke emergency powers to restrain through court order
any discharge, not necessarily in violation of any permit condition, where
there is an immediate and substantial danger to public health or public live-
lihood, such as an inability to market shellfish.


      As a prerequisite to a State's assumption of the permit program, EPA
has  specified with a few exceptions that the State must have comparable
penalty provisions under State law to those provided the Federal Government.
Civil penalties for the violation of a permit condition or any order issued
by the Administrator may be up to $10,000 per day of violation; criminal
penalties may be as much as a $25,000 fine per day of violation and a year's
imprisonment, with these penalties doubling after a first conviction.  EPA
considers the magnitude of the fines that it intends applying as a major
economic lever to assure compliance.  Frequently in the past, it was cheaper
to pay a small fine than to install and operate control equipment.

      Compliance Monitoring

      EPA in conjunction with the States will develop a system for conducting
compliance monitoring.  Elements include:

      a.  Integration of self-monitoring report analysis, and facility
inspections.  Self-monitoring reports will involve validation of data,
followed initially by manual screening and subsequently computer screening
of violations.  Facility inspections will be generally precipitated by
self-monitoring reports or programmed to provide a random or pre-selected
audit.  Where appropriate, water quality effects of the discharge will be
identified through sampling.

      b.  Incorporation of permit and compliance monitoring data into the
computer based General Point Source File System.  This will assist in the
identification and determination of the extent of non-compliance,  and the
tracking of significant permit events.   Regions and States will participate
in the system, the States either inputting directly,  or by providing data
in a computer-compatible format.   A major task will be to introduce pro-
cedures for quality control over data input, with the Regions conducting
spot-check screening for this.   Effluent monitoring forms have been developed
and will be sent to permittees for their use.

      c.  A quality assurance effort involving sample collection and handling,
laboratory and field quality control, and a validation of testing activities
with performance checks on a selected percentage of samples.

      In the case of municipal facilities, the compliance program will include
a review of monitoring data to identify areas of assistance with operations
and maintenance, manpower training or other corrective programs to improve
facility performance before civil or criminal enforcement is initiated.   States
will be encouraged to provide such assistance jointly with EPA and eventually
assume the burden for as much of the assistance as possible.

      At the discharge site, compliance monitoring can involve grab or comp-
osite sampling of the discharger effluent, process verification of major
industrial dischargers, or composite sampling for toxic substances.  Supporting
this effort will be data developed from intensive stream surveys which
(although perhaps conducted for other objectives) can be used to relate source
pollution to water quality and to detect non-permitted sources, non-compliance,
and to identify enforcement priorities.


      State Enforcement Role

      The primary enforcement responsibility under the Act resides in the
States.  Emphasis will be placed on shared responsibility with the States
for enforcement.  Where States cannot maintain an adequate enforcement
level, the Federal Government will ensure enforcement.  The Federal role
is a back-up role.  It is to be recognized that States retain authority
to enforce against dischargers using State laws, and State efforts in
this regard are encouraged.  States having an approved NPDES program are
required to conduct periodic compliance monitoring of dischargers.  States
lacking this approval but having similar legal authorities to those given
EPA can be delegated authority to conduct facility inspections to determine
compliance with NPDES permits.  For other States, the State may be desig-
nated as an agent of EPA and conduct the inspections.

      Federal Efforts

      During the past year, surveillance personnel have been developing
the monitoring data necessary for the preparation of permits in those
segments where permit conditions will be established by water quality
requirements rather than by effluent standards.  Other S§A personnel have
been used in the technical drafting of permits.

      As an adjunct to efforts against permittees, other various enforce-
ment proceedings continue or are being completed.  These include proceedings
initiated before the enactment of the new law and which are retained by the
savings provision, and proceedings where appropriate under either the Refuse
Act or section 311 to control oil and hazardous material spills.  The Coast
Guard will be generally responsible for compliance monitoring of ocean dump-
ing, and for enforcing against violations in connection with marine sanitation
devices and spills of oil and hazardous substances on ocean waters (EPA has
responsibility for inland waters).

      Until permit conditions and implementation schedules come into general
effect, the Federal enforcement program will concentrate on assisting in the
issuance of permits, and on initiating proceedings against dischargers who
fail to apply for a NPDES permit.  During the next year, the principal permit
compliance focus will be on schedule compliance rather than discharge param-
eter compliance, as most facilities will be in the stage of construction or
modification to achieve the 1977 requirements.  Initial enforcement efforts
will generally concentrate on the chronic or recalcitrant violator, or those
whose violations are having a critical effect on water quality.

      EPA and States will coordinate enforcement efforts.  EPA will not
initiate enforcement against State issued permits without alerting the
State.  Scheduling of inspections should be complementary, and States and
EPA may jointly inspect.


      EPA, using the authorities provided under §508, will ensure that
Federal contracts, grants, or loans will not be awarded to. applicants
utilizing facilities in violation of the basic water quality requirements
of the Act.  Finally, EPA will retain responsibility for issuing permits
to Federal facilities, and will conduct the compliance monitoring effort
against such facilities.


C.I.  Treatment Works

      The first objective in chis area is to manage funding of the cost of
"construction" of eligible "municipal treatment works," as defined in the
Act, so that those works will meet the effluent and ambient requirements
set by the Act for 1977 and 1983.  The second objective is to establish
the principle that municipal works should meet the requirements of the Act
with a cost-effective design.  The third objective is to operate and main-
tain efficiently the plants that are not constructed.

      The establishment of appropriate priorities is critically important
in maximizing the program's impact on water quality and alleviating dangers
to public health.  States will develop the priorities for construction through
a State Municipal Projects Priority List, subject to EPA review.

      EPA will coordinate, process, award, and oversee municipal construc-
tion grants to ensure nationwide uniformity.  It will also participate with the
States in overseeing the construction of treatment works, with particular
emphasis on pre-application and design conferences and on the consideration of
cost-effectiveness and environmental impact.  Assistance to communities will
also be especially needed in successfully integrating industrial pretreatment
requirements into the design plan for the municipal facility.  The States,
wherever possible, shall be responsible for the detailed review and certifi-
cation of engineering reports, studies, construction plans and specifications
and 0§M manuals.  EPA will maintain final approval authority for any action
required of the Agency by statute, such as contractual obligations.

      EPA will also introduce a grants management system which will ensure
that construction grant processing and monitoring is directed on an essentially
uniform basis across the nation.  The management system developed will cover
a project from pre-application conferences through the operation and maintenance
of the facility.  It will also form the major basis for assessing yearly
funding requirements to liquidate obligations.


      Priorities for Construction

      In contrast to total projected needs, Federal funds that can be
applied to meet these needs are limited.  For this reason, and to assure
that funded projects, nationwide, will most directly bring about improve-
ments in water quality, States should develop the State Municipal Projects
Priority List, which is part of the annual State program submission,
according to the guidelines set forth below, which are stated in order
of importance.  The list should be used in accordance with the following
general rules:

      •  The ranking of importance does not mean that all projects in
class (a) must be funded before intiating projects in class (b), and so
forth; nor does it mean that projects must be funded in sequential order.

      •  Projects can be segmented to apply separate priorities to construction
of integral sections.  An example of this is a secondary plant addition
to a primary plant, or improving secondary treatment to advanced treatment.
Attention should be given in the review of candidate projects, especially
projects against which a uniform national standard such as secondary treat-
ment is not being applied, to giving priority to projects which will result
in the greatest number of days in compliance with the critical parameters
in water quality standards by 1977 or 1983.  As an example, a community
may decide to give priority to correction of combined and storm sewer dis-
charges before installing treatment above secondary if this will result in
the greatest improvement in water quality.

      Priorities for Municipal Construction

      (a)  Projects which are required in order to meet existing water
quality standards or otherwise comply with the enforceable provisions of the
law--i.e., treatment works that provide secondary treatment or any higher
level of treatment dictated by standards.  Included in this category are
ancillary improvements which must be done in conjunction with an award, such
as a cost-effective solution to certified excessive infiltration into sewers.

      (b)  Projects which are not required to meet water quality standards
but which must be installed to comply with the enforceable provisions of the
law--i.e., treatment works that provide secondary treatment.  This would in-
clude ancillary improvements as described in Step  (a) above.

      (c)  Projects against which the enforceable provisions of the law,
best practicable treatment, will not be applied until 1983; or against which
many water quality standards will not be applicable until 1983--storm
and combined sewers.  Storm and combined sewer projects will be subject only
to the treatment requirements necessary to meet water quality standards.
At the request of a State, projects to correct combined/storm sewers if
necessary to achieve existing water quality standards, where this is cost
effective and practical by the 1977 date for achievement of standards, can
be given a higher priority in the FY 1975 list.

      (d)  Projects which are not discharges--e.g.,  collection sewers or
recycled water supply facilities are to receive lowest priority.   Collection
sewers can be given higher priority where there is  an existing problem of
groundwater contamination, or where they are an integral part of a waste
treatment system (which includes a treatment plant)  for a community which
previously was without such a system.

      Appropriate recognition in developing priority lists should also
be given to Step 1 and 2 projects so they can sufficiently anticipate future
year construction, and they need not conform to near-term construction
priorities classified in (a) through (d) above.


      A continuing series of need surveys will be conducted on a biennial
basis to provide the Congress with estimates of the amount and the distribu-
tion of funds by municipalities to meet the objectives of the Act.  The
needs survey, to be conducted during the spring-simmer of 1974, will not
be confined to projects required for the 1977 time frame of the Act, but will
also address the 1983 requirements.

      Facilities Planning

      Selection of the most cost effective and environmentally effective
waste management alternative for a proposed construction project is a major
goal of facilities planning.  This planning governs the municipal facilities
investment decision in the locality.  It constitutes Step 1 of an integrated
construction grants process and should generally be completed before Step 2
or 3 grants  (construction plans and specifications and actual construction)
are awarded.

      Facilities plans define the waste treatment management area to be
covered by the project; analyze environmental factors; and adopt a solution.
Essential components of the plan depend on the magnitude of the problem.

      EPA in conjunction with the States has made the facility planning
requirements more flexible, especially over the near term.  Where facility
planning and preparation of plans and specs for a project have been under
way, they should be phased into the system.  Content of the facilities plan,
other than any statutory requirement, can be determined by the Regional
Administrator, who can make adjustments as to content depending on the size,
nature, and  location of the project.  Step 2, preparation of plans and specs,
will gradually be transitioned into a non-reimbursable status so that Federal
funding will be available only after prior grant award.

      A sewer system evaluation to determine whether the collection system
is subject to excessive infiltration/inflow is a prinicipal element in the
facilities plan and is, generally, a prerequisite requirement to be met
before the award of a Step 2 or 3 grant.   It is recognized that this has
and may continue to delay the award of some Step 2 and 3 grants.  Correction
of inflow-infiltration conditions need not occur simultaneously with treat-
ment plan construction but EPA will withhold payment of the final 20% of a
grant until a community has an approved sewer use ordinance, and/or is
complying with the sewer system evaluation and rehabilitation schedule.
The ordinance would prohibit new connections into the sanitary system from
inflow sources such as drainspouts and yard and area drains.  If an excessive
infiltration/inflow condition is determined, the community will complete
a survey of the sewer system to decide on the most cost-effective solution
to this situation.  This could be rehabilitation of the sewer system or
providing for extra capacity at the treatment plant, or most probably a mix
of the two.

       Cost effectiveness is a- second principal element in facilities plan-
ning.  Projects which are proposed for award of municipal construction grants
will be scrutinized for cost-effectiveness in terms of the projected total
lifetime cost.  Such measures are essential to any achievement of the national
need at a relatively economical cost.  Cost-effectiveness analysis seeks
the most economical way to meet the designated effluent standard, e.g.,
secondary treatment or more stringent water quality standards where the base
level effluent standard will prove inadequate.  For secondary treatment,
emphasis will be placed on the evaluation of ways to combine waste systems
to realize economies of scale; to reuse or market wastewater to reduce opera-
ting expenses; to reduce total waste flow (including the correction of excess
infiltration) instead of increasing plant capacity; and to improve operations
and maintenance instead of expanding facilities.  For cost-effectiveness in
meeting a water quality standard, emphasis will be placed on the evaluation
of the relative costs of controls on such publicly-owned sources as treatment
plants, combined sewer overflows, and storm sewers; and of the relative costs
of controls on these point sources as opposed to controls on non-point
sources, including urban runoff.

      A third principal feature of the facilities plans will be an assessment
of the expected environmental impact.  In reviewing environmental assessments
to determine the significance of a proposed project's or plan's impacts,
EPA will give particular attention to long-term impacts, projects whose
individual impact is small but which set a precedent or set in motion a string
of events whose cumulative impact is large; and the potential stimulus to
changes in land use resulting from the choice of treatment plant capacity
and location, and interceptor sewer pathways.  In cases in which the probable
impacts conflict with the terms of proposed or approved Federal, State, and
land-use plans, the environmental impact statement must justify the choice
to proceed, despite the conflict.

      Cost Recovery and User Charges

      The Act and accompanying regulations introduce several fundamental
changes to the concept and structure of the Federal grant.  These changes
involve:  (1) cost recovery from industrial users; (2) user charges for
operations and maintenance; and (3) establishment of sewer use ordinances--
conditions which affect the award of any Step 2 or Step 3 grant or the sub-
sequent payment schedule.

      Capital cost recovery requires that the community collect from the
industrial users that portion of the Federally funded capital cost of
construction proportional to the strength, volume, and flow characteristics
of the wastes received from the industrial user.  Fifty percent of the
amount collected will be retained by the community.  At least 80% of the
community's funds must be set aside for future reconstruction and expansion
of the treatment works.  Generally, Federal agencies are expected to contribute
individually to the capital cost of construction to reflect the services
provided to them.

      Each community is to establish a system of user charges to assure that
each recipient (whether industrial, commercial, or residential) will pay
its proportionate share of the costs of operating and maintaining the
treatment works.

      To phase in these prerequisite conditions, communities may receive
Federal funding for Steps 2 or 3, if they provide, at the time of grant award,
a plan and schedule for implementation of a system of user charges and letters
of intent from significant industrial users to pay their capital cost portion.
The final 20% Federal payment will be withheld unless at that time the
community has an approved user charge and cost recovery system.

      Operations and Maintenance

      Operations and maintenance activities related to construction grants
should be integrated into the framework of the present construction grant
procedures and included as part of the responsibility of the engineer who
handles the technical review for each grant project.  0§M aspects should be
carefully considered at the pre-design stage, and when reviewing plans
and specifications.  Plant staffing requirements and potential training
needs should be assessed, and 0§M manuals reviewed.  Regions will work with
the States to help develop cooperative programs so that each can complement
the 0§M activities of the other, but the principal 0§M role is to be played
by the States.

      Near term Federal operations and maintenance inspections should
be conducted to assist the establishment of permit conditions and improve
the operational efficiency of major plants and smaller plants in critical
areas of water pollution.  Intensive technical assistance to selected
problem plants should be provided to demonstrate the improvement possible
from good 0§M.  Regions will work closely with the States in these efforts
to develop the State 0§M programs as rapidly as possible.

      Manpower Training

      The number of trained operator personnel needs to be increased and
their skills improved if the permit requirements are to be met.  To help
in developing a supply of these personnel, EPA will assist local areas
in assessing their manpower needs and will compile a nationwide forecast.
EPA has developed model training curricula and will assist the States in
adjusting them to their own needs.  State training programs will be further
assisted by EPA grants intended to train entry-level personnel and to upgrade
present employees' skills.  Under the Act, EPA can provide each State a 100%
grant of up to $250,000 to construct a training facility in the State for
the training of operators and maintenance personnel.

C.2.  Combined Sewer Overflows and Stormwater Discharges

      As a class of point source discharges, the overflows from a municipal
waste collection and treatment system and discharges from sewers which col-
lect stormwater can be shown to have a major impact on water quality.   However
control of these sources faces the following problems.  While legislative
history to the Act contains frequent references to the need for control, neither
the history nor the Act itself indicates definitively whether these sources must
be subject to an effluent standard in addition to water quality standards;
and if the former, what kind of effluent standards should be applied--those
for publicly owned treatment works,  or those for sources other than publicly
owned treatment works.  Again, the effects of overflows and stormwater dis-
charges have historically received little study.  Little monitoring is per-
formed during storm conditions, either on loadings or effects.  This was most
recently demonstrated by the Needs Survey, in which some States presented
partial data on the control of overflows, but others had none at all.
Finally, overflows and stormwater discharges exhibit a characteristically
uneven pollutant load as between the first hour or two of discharge, subse-
quent flows, and the final tapering load.  This, plus the fact that the ratio
between dry and wet weather flow frequency varies radically between basins
and regions, presents difficulties in the establishment of' an effluent standard.
Unlike secondary treatment for treatment plants, there is not a generally
recognized acceptable level of treatment for overflows and stormwater
discharges.   The following strategy flows from the above considerations.

      Overflows and storm sewers will not be considered publicly owned treat-
ment works for the purpose of complying with the effluent standards of
secondary treatment for 1977 (Titles III and IV); nor will a separate uniform
effluent standard be promulgated for them.  Correction of overflow problems
will be defined in terms of meeting the applicable water quality standards
of 1977 and the fishable/swimmable standards of 1983.  "Meeting water quality
standards" is itself a concept which will be further defined in guidance by

      It would generally be expected that the degree and extent of treatment
of wet weather flows would correspond only to what is required to achieve
standards.  In this case, not all overflow or stormwater pipes in a geographic
area need receive treatment, and the treatment levels on those that do could

      Overflows will be precisely defined to distinguish between storm-caused
overflows and overflows resulting from structural defects in the municipal
waste system, e.g., inadequate treatment capacity or excessive infiltration.
Dry weather overflows which result from such conditions will be subject to
the full requirements of secondary treatment.

      BPWTT is assigned as the 1983 effluent standard for a municipal treat-
ment plant, as distinct from a treatment system.  This standard is presently
defined as secondary treatment for direct dischargers.  Satisfaction of the
1983 water quality requirements may dictate that a community introduce
advanced treatment of its discharge, or begin using land disposal or a reuse
system.  An alternative to this may result from an examination of the entire
system as opposed to just the treatment plant.  Provision can be made for
controls on overflows in place of added or optimum treatment at the plant
where this would make more sense in terms o£ local water quality conditions
 (a coliform vs. a dissolved oxygen problem for example).  This flexibility
clause is the present device for incorporating overflows and stormwater
within the 1983 permit effluent goals.  EPA will hold in abeyance the alter-
native of setting a separate, uniform effluent standard for overflows.

      An additional consideration in examining the need for correction of
wet weather flows results from correlating the water use to be protected
 (as an example, swimming) with the season and frequency that rainfall occurs.
 If swimming activities only occur during a season when there is little or
no rainfall, correction of wet weather flows may be unwarranted.

     Where overflow conditions have been studied and overflow needs are
presently known, treatment of overflows can be given comparable eligi-
bility with treatment plant construction in terms of access to Federal
 funding under Title II.  States are thus at liberty to handle acute
 overflow problems on a case-by-case basis, but will not be required to
provide correction of all problems by 1977.  Consistent with this strategy,
 overflow needs, which have been only fragmentarily reported in the Needs

Survey, were not used as a basis for apportionment of Federal construction
grant funds among States for FY75.  However, the Needs Survey to be conducted
in 1974 will more fully examine needs in this area.

      Where wet weather conditions have not been studied and needs have not
been assessed, the NPDES permit program will become the vehicle to produce
such analysis.  Permits will require municipalities to monitor overflows,
and, within 1-2 years, develop a plan for their correction to meet water
quality standards.  All overflows from municipal waste systems will thus be
permitted, and, where the requisite planning has been done, become eligible
for inclusion on State project lists.  It is expected that facilities plans
(Step 1 grants) and areawide plans under §208 will be used to prepare correc-
tive solutions for combined and storm sewer flows.


D.I.  Planning and Program Management

      Effective water quality management involves an assessment of the
situation; developing a plan for control of existing or potential problems;
an orderly implementation of the plan; followed by a system for review
and reporting.  Under the Act, the States and areawide agencies at their
level are responsible for the development of management programs integrating
and carrying out these components.  EPA contributes guidance, technical
assistance and financial support.

      The management program is oriented toward two phases:  Phase I aimed
at achieving the Act's 1977 objectives and Phase II for the 1983 goals.

      To achieve the Act's 1977 objectives, the initial management effort
must focus on point source controls, such as permits and construction grant
awards.  To support these activities, planning must prepare waste load
analyses in water quality segments, and provide the management information
to assist in coordinating and directing various program efforts.

      Longer range management, Phase II, will address additional and
often more complex problems, including non-point source control.  It will
be supported by more extensive water quality and technical information and
will employ a more sophisticated planning structure, including evaluation
of past efforts, to produce more comprehensive State strategies and pro-
grams.  Areawide waste treatment management will be introduced.

      The principal statutory water quality management mechanisms are:

      •  Basin management.  The State prepares a segment-based, water
         quality oriented analysis and plan for an overall basin.  The
         annual State program will be developed largely from these

       •  Areawide management.  Areawide organizations will conduct a
         more detailed planning effort in specifically designated areas,
         followed by a management structure to operationally implement
         the institutional, regulatory, and facility construction
         aspects of the plans.

1977 Requirements

       The State Program

       State water quality management is formed through the annual State
program.  The program, consisting of a State strategy, output commitments,
reporting and evaluation, is sequenced year-round process.  It begins
with a State submitting its strategy, followed by an annual program plan.
A semiannual evaluation and reporting of accomplishments completes the
cycle.  The program's contents are developed in accordance with:  the annual
national strategy and other guidance, including funding guidance; the State
strategy, and available basin planning and other information.  Elements of a
State  program include:  permitting; planning; enforcement; monitoring; municipal
facilities management; NFS control; administration; training; and public

       The regulations for a continuing planning process under §303(e)
require the States to develop an annual State strategy setting forth
the program direction for the coming year.  The State strategy takes its
lead from the national strategy document.  It is emphasized that the State
strategy should not be a mirror image of the national strategy, but should
reflect individual pollution problems and program initiatives within the
State.  Much of the State strategy will represent an aggregation of infor-
mation developed from basin plans.  Additionally, beginning with the April
1975 submission, the State strategy will incorporate the elements required
of the State under 305(b)--the annual assessment and projection of water

      The output commitments are a key feature of the State program.
Specific quantitative target outputs are set for prescribed categories
such as municipal facilities construction, permits, planning,  and monitoring.
Coordination of State and Regional target outputs is necessary.  As  an
example, a Region's anticipated delegation of the permit program to  a
State must be reflected in the State program's target for permits to  be
processed.   Biannual reporting and State/Regional evaluation of accomp-
lishments is another aspect of the State program.

       A substantial portion of the annual State program grant  is keyed
to assisting States in conducting critical tasks such as permits, basin
plans, and construction grant plans review.  Additionally, there is a
requirement under the Act that* a State conduct an approved monitoring
effort to receive any of the annual grant.  Funds under the incentive
portion of the grant should reflect changing program emphasis, but also
will be adjusted gradually over time to allow for reasonable rephasing
of program efforts.  An extensive examination into the future dimensions

                                        STATE/FEDERAL:  STRATEGY  AND  PROGRAM  PLAN
  303 Plans
Inventory of Dischargers
Ranking of Significant
Compliance Schedules or
 target abatement dates
Total Max. Daily Loads
Control Targets and
Non-Point Sources
 and Control
                                                   ANNUAL  EPA  STRATEGY
                                                     National  Objectives
                                                     National  Priorities
                                                     Program & Resource
                                                       T       JT
                                                 303 Planning Process
                                                   "Stato Strategy" .
(reported in the State
program submittal but
developed here)

.  problem assessment
.  geographical
  discharger  priorities
   program schedules
.  needs assessment
.  process for assigning
   outputs in 106
.  basis for program
.  303 basin  planning
   requirements & schedule
          STATE  PROGRAM (106)
                                                                                             Available Information
                                                                                             on ongoing State
                                                                                             activity not covered
                                                                                             by' 303 plans.
                                               Program Submittal  (Annual)
                                               . Problem Identification
                                                    . Segment classification
                                                    . Major sources identification
                                                 Task Identification  and  Scheduling
                                                 for Pcogram  Modules
                                                   — Expected Outputs
                                                   - Priority Lists
                                                   - Needs  (biennial)
                                               .  Identification  of Resources  Required
                                                 to Obtain  Outputs
                                                   - Adjustment  to Resource Constraints
                                               State Evaluation  &  Report
                                        rf 0!
                                        H rfi
                                        Qi ftj1
                                        rf <-r
                                        a »
                                                   - Compliance  and  program milestones
                                                      achieved  (semi-annual)
                                                   - Reducations achieved      >
                                                   - Water Quality Improvement j

and use of the annual State program grant will be conducted during the
spring and summer of 1974, keyed to the FY76 Federal budget cycle.

      The municipal facilities construction grant priority is a key element
in the State program plan.  Delays in approving the annual State program
or States adjusting to new priority requirements have been identified as
impeding grant awards.  To overcome this, EPA now provides that a State
priority list once approved is effective until the next approval, and the
priority requirements have been made more flexible.

      Each State should prepare an annual State program pursuant to the
following schedule:

      April 15    -- The State submits its strategy, preliminary estimate
                     of outputs, resource needs and annual discharger lists.
                     The strategy contains an assessment of the State's
                     water quality problems and a means for developing con-
                     trol strategies and assessing results.

      June 30     -- The State submits the State program and grant appli-
                     cations for the next year.  Contents of the program
                     are developed in accordance with the national and
                     State strategies and other guidance including funding
                     guidance.  An evaluation and review of State program
                     performance for the past year is also conducted at
                     this time.

      July 30     -- EPA approval of the State program.   Grant assistance
                     for approved programs pursuant to national allocation
                     formula and incentive amounts for priority activities
                     are awarded.

      December 30 -- State and Regional personnel conduct mid-year evalu-
                     ation of State programs.

      January 31  -- Regional Administrator reports to the Administrator
                     on his evaluation of State accomplishments in the first
                     six months of the fiscal year.

      Basin Planning under 303

      Information on the basic water quality and source problems for the
State is developed from basin planning performed under section 303(e) of
the Act.  The information, as incorporated within the State strategy, pro-
vides assurance that State program grants will contribute to an effective
State effort focusing on priority program needs.

      The basin plan forms the basic framework for planning under the Act.
Facilities plans, areawide plans, and Level B plans under §209 are folded
into the basin plan as they are completed.


      Each State has established segment classifications and prepared
the required planning process.  The first basin planning effort is being
devoted to water quality segment analyses to develop load allocations for
permits.  Less detailed management information is being prepared for efflu-
ent limited segments.  Segment analyses will be aggregated to form completed
basin plans.  The plans provide inputs to the State strategy and program;
generate data for the national, information system and contribute to the
determination of municipal and industrial priorities.  Development of a
complete basin plan is expected to be phased over time, as various
elements are developed and incorporated.

      Each State should complete its basin plans, pursuant to the schedule
in its basin planning process.  Segment analyses are first conducted, con-
centrating initially on water quality segments with sufficient data to develop
load allocations.  Analyses of all segments in the basin are aggregated into
complete basin plans.  Initial plans are to be completed by July 1, 1975,
although the Regional Administrator may extend this one year.

      Interstate agencies (river basin commissions) have a fundamental
role to play in coordinating the development of basin plans on interstate
boundary waters.

      The content of a basin plan at various times is as follows:

      •  Generally by July 1974 (for waste load allocations to assist
         in permit issuance)--Identification of segment boundaries;
         identification of water quality standards; water quality
         analysis; waste load allocation against 1977 standards.

      •  July 1975--The above plus:  identification of basin bound-
         aries; classification of segments within the basin against
         1977 requirements; identification of point source discharges;
         identification of facilities planning areas under 201;
         ranking of segments within basin; identification of water
         quality standards revisions; identification of schedules of
         compliance or target dates of abatement; assessment of municipal
         needs; and establishment of program to monitor in-stream
         standards, including the conduct of monitoring surveys.

      •  July 1978--The above plus:  identification of control pro-
         cedures over residual waste; coordination with subplans,
         facilities plans, and areawide plans; establishment of anti-
         degradation program; analysis of maximum daily loads for all
         segments 303(d); waste load allocations against 1983 standards
         (replaces allocating against 1977 standards);  inventory of


         significant dischargers and priority for their permit issuance;
         identification of, evaluation of, and program plan for control
         of non-point sources; description of the application of land
         use decisions to water quality; compilation of data from
         monitoring and in-stream surveys; assessment of eutrophic
         status of lakes within basin; reclassification of segments
         against 1983 requirements (replaces segment classification
         against 1977 requirements).

      Areawide Management

      A central element in developing controls over source pollution
in metropolitan areas is the designation of areawide planning and manage-
ment agencies.  The authorities assigned such agencies, including site
location over new sources or activities, non-point source control, set-
ting discharger permit conditions, and conducting facilities planning
over a wide area, enable the development of a comprehensive management
scheme to integrate the various areas of pollution.

      Because of the time phasing assigned to the development of 208 plans,
they will focus on the 1983 water quality requirements of the Act, and for
municipal facilities, would examine treatment requirements above secondary,
including abatement of combined and storm sewer problems.

      Areawide designations need not  be confined to urban-industrial areas,
but locations confronted with acute growth demands over the next several
decades which may threaten a high level of water quality, or which have a
substantial groundwater aquifer problem, can also receive designations.

      The Act emphasizes that approved plans developed under the areawide
planning process are to be implemented, with EPA and the States required
to take cognizance of them before issuing permits or awarding construction
grants.  This requires a degree of commitment on the part of the communities
to integrally participate in the development of the plan and to carry out
its implementation.

      Present expectations are that approximately 125 designations will
be made by June 1975, although designation of additional areas meeting
the prerequisite criteria can be made up to the authorized funding level.

      Pursuant to EPA guidelines, Governors will designate areawide waste
treatment management areas and planning organizations; they may also
expressly non-designate areas that are not interstate in nature.  Where
Governors are silent, local officials may make designations.


      The Administrator will act on designations as received.   EPA Regional
Offices will assist States and local communities in getting agreement by
the affected municipalities to join together to develop and implement a
plan which will result in a coordinated waste treatment management system
for the area.  Each approved planning organization will develop and operate
an areawide planning process.  The Administrator will provide financial
support and policy, technical and planning guidance.

      In non-designated areas, States will undertake many elements of the
areawide planning process and incorporate them into basin plans.

1983 Requirements.

      Phase II involves program planning and implementation directed toward
achievement of the Act's 1983 goals.  It will see a significant advance in
the use of orderly management techniques, growing out of the Phase I ground-
work, to achieve required water quality.

      Program management will be further decentralized and will involve
not only States but areawide management agencies.  Expanded monitoring will
result in a more extensive understanding of water quality data and trends.
Basin plan revisions will cover additional areas, and will be periodically
reviewed and updated.

      The State program will generally continue as developed under Phase I.
However, the program sequence, as far as timing, and the funding mechanism
may be adjusted as a result of the review to be conducted this year.  The
annual State program should identify the State and local activities that
satisfy needed 208 elements in non-designated areas.  By the latter half
of the decade, the 208 system will be the basic structure for most Phase II
implementation within covered areas and may become the keystone of national
water quality abatement efforts.

      Major elements of areawide waste treatment, section 208, will be
effected in all areas of the State.  Where specific areas and agencies are
not designated, generally areas involving less complex waste treatment needs,
the State will act.  The initial designated planning organizations should
complete their plans by 1978.  Areawide planning should focus particularly
on those pollution problems which affect the achievement of the 1983 goals.

      The difficult problems remaining in Phase II will require careful
analysis of cost/benefit relationships and the total environmental impact
of alternative solutions.  Intensive areawide planning will be an important
analytical tool.  Land use and land management programs may become essen-
tial as abatement measures.  Non-point source pollution and urban runoff
will be primary targets for abatement.

       Finally,  as  higher  levels of water quality are achieved, preservation
 of existing  high water quality must be given detailed attention.

       Water  quality  standards, through the basin planning process, will
 be revised to conform to  the Act's July 1983 fish/swim goal, in consonance
 with the water  quality criteria being published pursuant to section 304(a).

 D.2.   Monitoring and Evaluation

       The monitoring and  evaluation objectives are to provide the effort
 required to:

       (a)  Identify and assess quantitatively the magnitude of
           existing and potential water pollution problems not
           presently fully considered.

       (b)  Measure the effectiveness of the permit and construction
           grants programs in terms of abatement efforts and the water
           quality improvement that results; this combined with (a)
           should provide a data base from which ongoing and future
           planning efforts can focus control programs and strategies.

       (c)  Prepare assessments of present and future water quality.

       (d)  Continue conducting stream analyses in preparation for
           the second round of permits.   Most of the stream analysis
           work to prepare load allocations for the first round of
           water quality limited permits has been completed;  however,
           a more comprehensive series of analyses needs to be con-
           ducted under 303(d) of the Act and should be integrated
           into the final 303(e)  plans to be completed by July 1978.

      Progress toward reaching these objectives will involve (1)  the
establishment of data collection programs,  (2)  the establishment and
maintenance of complete and accurate files of ambient water quality data,
point source data and other water program related data,  and (3) the use
of broad based and technically sound evaluation techniques and analyses.

      A strong emphasis will be placed on developing full coordination
between Regional and State monitoring efforts.

      National Water Quality Surveillance System (NWQSS):

      A fundamental contributor to the data base will be the National
Water Quality Surveillance System.  The NWQSS consists primarily of a
number of selected segments located in municipal/industrial and agricul-
tural/rural areas monitored for a consistent set of parameters at a
uniform frequency.

      The NWQSS will incorporate data from the following principal sources:
 (1) paired station monitoring conducted by EPA, States, and other Federal
agencies, mainly USGS;  (2) State primary monitoring network stations;
 (3) EPA intensive surveys; and (4) monitoring by other groups and agencies.
The NWQSS and the States' monitoring programs are complementary with the
main difference between the two being that NWQSS data analysis will be con-
ducted from a national perspective while the States will perform their
analyses with a local and more detailed orientation.

      The NWQSS will be implemented in two steps.  The first will involve
the establishment of a national network of fixed stations which bracket
major land use areas, such as municipal/industrial and agricultural/rural.
The EPA Regional Offices will select the paired station locations.  These
station data will be analyzed for baselines and trends in water quality in
the different types of land areas.  Intensive surveys by the States and
EPA will be conducted in selected areas to determine cause and effect rela-
tionships between point and non-point sources of pollution and water quality.
A plan for the expansion and operation of the NWQSS will be prepared to
cover:  (1) expansion of the system to include groundwater, the oceans,
estuaries, and the territorial sea; (2) a review procedure for evaluating
the NWQSS with respect to its objectives; (3) delineation of Headquarters,
Regional, and State relationships in the operations of the NWQSS.  State
data will be used to the greatest possible extent.  Regional monitoring
would supplement State efforts to provide data from a national perspective,
such as on certain pollutants which are not an apparent problem in the

      The second step will result in the full-scale operation of the NWQSS
plan.  Some specific outputs of the NWQSS will be:  (1) annual data reports
on the water quality in the ten Regions as part of the section 305(b) report;
(2) a continuing assessment of water quality with respect to the implementa-
tion of the Act.  The NWQSS will be a continuing program that will evolve
as additional understanding of the Nation's water quality is obtained and
more methods for evaluating the water quality are developed.  It will also serve
the States in developing program focuses in the State strategy.

      Reporting on Water Quality:

      The basic reporting elements under the monitoring program are three:
(1) an annual report by EPA on the state of water quality in the surface and
groundwaters and the oceans; (2) a one-time report by EPA in February 1974
describing the present state of water quality, and a projection of water
quality in 1977, 1983, and post-1983;  and (3) annual reports by the States
beginning in 1975.  These State reports will describe:  the present state
of water quality; project water quality to 1983; analyze the extent to which
"no discharge" technology is being employed or will be needed; provide an
economic and environmental cost/benefit assessment of Statewide pollution
control activities; and give a description of non-point source pollution
along with a recommended control strategy.


      Much of the data for these reports will be developed from activities
conducted in support of NWQSS, and from analyses that States perform during
the course of developing 303(e) basin plans.  The State reports will be
incorporated into the annual State program plan and strategy.

      Reflecting the development of a data base, the initial reports will
become, over time, more refined and more extensive in their coverage.

      State Monitoring Programs Under Section 106:

      The fundamental objectives of the State monitoring programs are to:

      •  Develop and maintain a knowledge of the State's water quality,
         including a basic knowledge of the quality of the groundwater
         in the State;

      •  Obtain an understanding of the cause and effect relationships
         of the State's water quality;

      •  Assess the effectiveness of water pollution control programs,
         including the determination of compliance or non-compliance
         with legal requirements, such as permit conditions.

      A model State program description incorporating these objectives is
being developed.  The model State program description will become part of
the criteria upon which the issuance of State program grants is based.  As
each State has individual monitoring problems or focuses, the model State
program will serve primarily as a baseline against which actual State pro-
grams can be adjusted.

      A priority area for FY 75 will be the development of State quality
assurance programs.  This will receive emphasis so that accurate and con-
sistent baseline data will be introduced into the system.  To achieve this,
all laboratories and sampling agencies should develop, maintain, and operate
quality assurance programs as an integral part of their monitoring program.
The program should cover all aspects of data generation--from sample col-
lection and preservation to laboratory analysis and data handling.

      The EPA Regional Offices will assist the States in developing their
quality assurance programs.  EPA Headquarters and the National Environmental
Research Centers (NERC) will provide technical guidance and technical sup-
port as requested by the Regional Offices and States.

      State monitoring efforts over the next several years will form the
basic framework for setting any water-quality based requirements in the
second round of permits.  Initial planning and preparation for this task
should be undertaken in FY 75.

      Continuing evaluation of the State monitoring programs will be made
by reviews of the annual State strategies, mid-year evaluations and the
Region-State quality assurance activities.  Secondary evaluations will be
made by analyses of the data submitted for input into the Federal data files

      The many elements of a State monitoring program argue for a ranking
of effort over the next few years.  These rankings will differ from State
to State depending on, among other things, the level of progress of the State
towards assumption of the NPDES program.  Priorities of monitoring efforts
will naturally be consistent with the priorities of the overall State pollu-
tion control program as set down in the State strategy.

      The management of monitoring activities is done through a monitoring
strategy which recognizes and fulfills the monitoring requirements of the
State pollution control agency components (e.g., planning, permitting,
enforcement, management).

      The monitoring requirements should be expressed without regard to
existing monitoring resources.  The purpose of the monitoring strategy is to
determine how the existing resources can best be utilized to meet the total
monitoring requirements and, where resources are not adequate, to determine
the size and scope of any necessary increases.  The monitoring strategy
should then set down the schedule to be followed in building toward those
additional capabilities that may be required.

      The following ranking df effort is intended as a guide for FY 75:

      1.  Achievement of an effective level of field and laboratory
          support which includes a valid quality assurance component.

      2.  Establishment of an efficient data handling, storage and
          reporting capability which includes an effective data quality
          control component.

      3.  Monitoring required for the development of permit conditions
          and for the issuance of permits.

      4.  Monitoring and facilities inspections required for the assess-
          ment of discharge compliance with permits (including implementation

      5.  Beginning the five year cycle of basin, or segment, management
          unit status surveys.

      6.  Establishing the primary network stations.

      7.  Design and begin establishing the groundwater monitoring

      Data Systems for Updating and Program Management and Evaluation:

      Two STORE! files, the General Point Source File (GPSF)  and the Water
Quality File, will be the main data storage and retrieval systems for point
source and ambient data.  States which are not now presently using the STORET
System will be encouraged to do so.  Those which do not wish to use STORET
will provide EPA needed data in a compatible form.  Data to be stored in
the systems will be screened for errors prior to storage.  Inputs from mult-
iple sources to the GPSF will be made in a "preferred-source" basis and all
inputs will be screened to avoid duplication or conflict among entries.
Total contents of the system will be coordinated with all users, and support,
advice, and assistance will be furnished in the entry and retrieval of data
upon users' requests.

      Output programs, including formatting and statistical analyses, have
been and are being developed for the Water Quality File of STORET.  These
programs will assist in preparing the annual reports to Congress that are
required by the Act.

      Data Evaluation and Analyses:

      The information gained from the various monitoring activities will
be combined with economic, demographic, and other water program related
data to provide a basis for evaluative judgments to be conducted partly
by the States but principally by EPA.

      These analyses will include:

       (a)  An assessment of non-point pollution problems and the
           benefits in terms of water quality that might be achieved
           by their control.

       (b)  An examination of the water quality benefits of zero
           discharge in comparison with the social, environmental,
           and economic costs that would be incurred.

       (c)  An examination of the relative emphasis placed on the
           water program elements and the effects of different
           alternatives in funding for construction and enforcement

       (d)  An assessment of the likelihood of changes in trophic
           status in the Nation's waters as discharges are reduced.

       In the evaluation and analysis activities particular emphasis will be
on the development of alternative policies or amending legislation.

D.3.  Preservation and Maintenance of Water Quality.

      The Act provides EPA and the States with a renewed charter and
responsibility to assure that high levels of water quality, once achieved,
are not appreciably degraded over time by new or added discharges.  Sup-
plementing this responsibility are provisions for States or areawide
management agencies to affect non-point source activities.

      Presently, all water quality standards feature an antidegradation
clause, but for many States, the clause is difficult to apply because
it is imprecise.

      Recognizing that economic and social growth predicate that additional
use be made of the Nation's waters, the problem becomes one of accommodating
additional sources and discharges while still maintaining the high levels
of water quality that the Act has set out as national policy.

      Among the existing mechanisms of the Act which compensate for growth,
and therefore contribute to the maintenance of water quality, are:

      •  The increased removal efficiencies as source technology
         standards progress from BPT and secondary treatment to BAT
         and BPWTT.

      •  Revisions in effluent standards as new technology is
         demonstrated, especially for new sources.

      •  Environmental assessments and impact statements for new
         source permits, and for any construction of publicly owned
         treatment works with Federal funds.

      •  Comprehensive areawide waste management authority under
         section 208, including the authority to control land use.

      •  The assurance of adequate opportunity for public comment
         and hearings on actions involving possible degradation.

These measures protect water quality from deteriorating below designated
use levels; they should generally protect water quality from deteriora-
ting below the 1983 criteria for fishing and swimming.  They may not
protect waters which are currently above these criteria from being
degraded to those levels.

      The key elements of an antidegradation policy are a baseline for
water quality, a definition of significant degradation to be applied against
that baseline, and a control strategy to insure compliance with the defini-
tion.  EPA considers that the latter steps will be most successful if they
are taken by the States themselves in their continuing planning processes.

This recognizes not only that the economic and social implications of the
antidegradation concept are immense, with immediate consequences for growth,
siting, and land use within each State, but also that the States possess
the more complete set of authorities to deal with degradation, particularly
from non-point sources.

      The near-term strategic priority for FY 1975 is the establishment
of baseline measurements in relatively clean waters that are likely to be
affected by growth in the next decade.  A baseline for water quality
previously established in connection with water quality standards may be
used.  In the absence of recent data, best estimates should be made and
the State or Regional monitoring program should take into account this

      EPA believes that it will be necessary to establish national guide-
lines on degradation to assist the States in their definitions and control
strategies, and to standardize the criteria for degradation.  These guide-
lines would take into account the various ways in which some States already
approach the problem.  These include:

      •  a zoning of waters which permits no discharge or no additional
         discharge (either point and/or non-point) in certain waters;
         this is, in effect, a land use measure--it may occur under the
         Wild Rivers Act or as part of a State program to protect waters
         of high scenic, recreational, or ecological value.

      •  the allowance of additional discharges, provided that the
         effluent of each is at least equal in quality to that of the
         receiving waters.

      •  the provision for growth up to, and within, an established
         maximum stream loading; the allowable load, in turn, may
         be calculated against existing high water quality, or against
         a percentage deterioration of water quality.  However, in no
         instance would the degradation result in a use less than that
         specified for 1983 under the Act.

      EPA is contemplating other steps to protect high quality waters from
being degraded.  These include a policy on permits to dischargers in effluent
limited segments who currently perform better than national guidelines, and
a policy specifying that permit applications and impact statements precede
the siting of new sources.

      In another example of a protective concept, EPA, in the thermal
criteria regulations, is requiring that States identify indicator fish
or shellfish species for the purpose of assessing the thermal tolerance
of the aquatic ecosystem.  As the indicator species may be relatively
tolerant to heat, each State is also required to set aside a significant
portion of its waters to protect the most sensitive and intolerant species.


      Preparation for situations involving antidegradation requires at a
local or State level:  (1) the regulatory ability to impose restrictions
on growth, siting, or land use; (2) an understanding of the physical,
chemical, and biological characteristics of the receiving water and its
assimilative capacity; and (3) a comprehension of the alternative steps
that could be taken to maintain the assimilative capacity and preserve
the water quality, and possessing the ability to select and apply an alter-
native step.  This preparation effort will be a major program emphasis
over the next several years.


E.I.  Non-Point Sources Pollution Control Program

      Non-point caused water quality degradation will increasingly emerge
as the major barrier to achievement of the Act's 1983 water quality goals,
as substantial control of point source pollution is realized during Phase I.
The Act provides new authorities for a cooperative Federal/State/areawide
effort to abate non-point source ("NPS") pollution.*  Two major EPA efforts
toward solving the problem are:

      •  A water quality effort to identify, monitor, assess and
         predict the nature and extent of NPS pollution, particularly
         in water quality segments, and to lay the environmental and
         administrative groundwork for comprehensive NPS management.
         Institutional arrangements will be developed to handle
         new regional concepts through the 208 and 303 planning
         management process.

      •  A technological/engineering effort to develop, demonstrate
         and apply feasible control technologies, through Federal,
         State and local mechanisms, providing the technical base
         for the management programs.  Existing governmental insti-
         tutions will be encouraged to install effective control
         technologies.  Where existing mechanisms are inadequate,
         new ones will have to be developed.
*Non-point pollution is pollution from diffuse sources, such as agri-
 culture, silviculture, mining, construction, subsurface excavations,
 salt water intrusion, and hydrologic modification.

      Unlike point sources, there is no time requirement or level of control
specified under the Act for abatement of non-point sources.  The magnitude
of the problem, especially within certain areas, indicates that where con-
trol practices or technologies can presently be applied under existing
State program authorities, they should be.  Where this is not currently
feasible, the NFS program to be undertaken by the States would develop
the legal, institutional, and resource framework for its implementation.
An important near-term objective is to seek non-structural solutions to
non-point source problems, minimizing reliance on Federally supported
capital intensive remedies.  Various fiscal mechanisms to fund programs
will be explored, where the solution of the problem requires substantial
public funding.

      NFS control is a cooperative, intergovernmental responsibility, with
authorities divided among EPA, other Federal agencies, and State and local
units.  Principal authority for a full control program is vested, under the
Act, in the States and areawide management agencies.  Additionally, numerous
Federal agencies have power to include NFS measures as an aspect of various
programs.  Finally, EPA is charged with conducting research and demonstra-
tions, developing guidance and supplying support, to further NFS awareness
and abatement at all levels of government and in the private sector.  In
this regard, EPA published information on control methods and procedures
in October 1973 for seven NFS categories.  Additional information will be
prepared, focusing particularly on land use and management controls coupled
with institutional considerations.

      Water quality effort.

      EPA and the States will monitor, identify and assess the magnitude
and character of individual non-point sources and overall NFS problems.
Specific pollution conditions, and the water quality segment where the
problems occur, will be defined.  The definition will include control
recommendations, priorities, and cost estimates, which will be addressed
to meeting the Act's 1983 ambient water quality goals.  This will support
the State strategy and 305(b) water quality assessment and protection
report, first due in 1975, and annually thereafter.  EPA's Office of
Research and Development will report on available NFS data and will con-
duct modeling, supported by selected monitoring, in a few basins in FY74
and 75.  Further, it will provide essential water quality information for
expanding State/areawide NFS management under sections 208 and 106/303(e)
by identifying areas where initiation of limited programs can be undertaken
quickly and providing the basis for the broader activities to follow.

      EPA will develop techniques for State NFS problem identification
and water quality prediction, including NFS waste load methodologies.
Complementing the States' monitoring actions, EPA will commence intensive
modeling and monitoring during 1974-1975 in selected basins.  These efforts
will develop and validate models to describe pollutant loads; develop data

collection procedures to calibrate loading models, and link the loading
models and monitoring procedures to various available receiving water
models.  In turn, these procedures will be used to develop waste load
allocations for the State/areawide programs.

      Concurrently, EPA will develop planning and management guidance.
This will direct the State's efforts in assessing the water quality
problem, promote the consideration of alternative source controls to the
extent that they are economically feasible, and develop management con-
trol programs that are capable of meeting the regulatory requirements
for solving the water quality problem.

      Technical/engineer ing effort.

      This approach seeks abatement of currently controllable non-point
source pollution through existing, tested control methods and techniques.
In addition, methods and technologies will be developed, published and
applied toward the abatement of NPS problems for which current controls
are inadequate or economically unfeasible.

      Initially, these measures will be introduced through the existing
Federal/State/local institutional mechanisms.  Subsequent analysis will
identify any need to modify existing mechanisms and/or develop new ones.

      EPA will continue to identify sources for which point-source type
regulatory techniques, particularly a form of permitting, might be applied
by Federal, State or local authorities.  These would be "use" type permits.
To expand use of Federal, State and local "use" permits, EPA will develop
technical guides.  Initial targets are mining and dredging controls, fol-
lowed by earth disturbing construction activities and certain agricultural

      EPA will issue NPS policy statements and technical information and
guidelines, augmenting existing policy statements such as wet lands pres-
ervation and subsurface emplacement of fluids, and other current guidance.
Additional manuals will address alternative control means, including land
use and land management.  The information will be designed to provide for
environmentally and cost effective applications of technology.

      Pursuant to the Act and E.G. 11752, EPA is required to issue
guidance to Federal agencies for their pollution control programs.   As
one-third of the nation's land area is managed by Federal agencies,
and their programs influence further activities nationwide, EPA's
responsibility for encouraging water quality concern in other agencies
is highly significant.  Land management practices can serve, for example,
to reduce pollution caused by forest harvesting, road construction and
mining on Federal lands.  NPS considerations must also be incorporated
into Federal financial assistance and regulatory activities.  To this

end, EPA's consultations with other Federal agencies will be expanded
to include review of timber sales contracts and public lands mine
operation and access regulations (USDA and USDOI);  technical assistance,
guidance and practice requirements (USDA); reservoir management (DoD
and USDOI);  mine water control (USDOI and TVA); facilities construction
plan requirements (EPA, HUD, VA, HEW, and GSA); and regionally, with
Federal Regional Councils.  This will include inter-agency agreements
and assistance in developing internal regulations and practices to imp-
lement NPS controls, and continued assessment of NPS abatement requirements.

      EPA will employ various actions to help States assume their primary
responsibility for non-point pollution control.  In addition to the water
quality assessments and technical development, the agency will continue its
communication and consultation with State and local governmental organiza-
tions and public interest groups to assist in the development and adoption
of pertinent State laws and local government ordinances.  EPA will also
continue co-sponsorship of State and Regional institutes such as the sedi-
ment control institutes.

      Pilot control projects will site-test potential NPS abatement measures
in specific settings.  In this, public and private institutions will be
urged to apply suggested technical measures to significant NPS problems.
Pilot programs can provide the initial impetus for regional NPS control
actions.  These pilot control projects are under way in four Regions:
groundwater waste control methods, Region IX; mining activities, Region
III; salinity from irrigated agriculture, Region VIII; silviculture con-
trol, Region X.  Six projects will commence in FY75:  Region I - individual
domestic systems; Region II - urban runoff; Region IV - salt water intrusion;
Region V - agriculture, lake eutrophication; Region VI - oil field and
natural brines; Region VII - agriculture, mono-culture.

      Comprehensive State/Areawide Programs.

      States and areawide agencies should conduct a program to develop
comprehensive feasible NPS management by 1976.  These programs will employ
water quality data and demonstrated technical information applicable to
the particular area and problem type in developing remedial measures to the
extent feasible.

      The programs will be developed and operated through the  106/303(e)
 (Statewide) and 208  (areawide) mechanisms.  NPS management will thereby
be based on careful planning conducted pursuant to statutory planning
processes.  This will assure,  for example,  that 208 program determinations
will follow environmental and  cost/benefit  analyses of alternative strat-
egies and will include, as a prerequisite for Federal support, a detailed
identification of the management structure  capable of implementing planned

      EPA's preparation for State/areawide NFS management will include,
nationally, planning and control techniques (including model laws and
permit regulations) and, regionally, working with States and areawide
agencies to develop and implement appropriate authorities and programs.

      Finally, areawide agencies and the States will develop and, where
practicable, implement comprehensive water quality programs.  Specifically,
State program submittals during the 1975-77 period should provide NFS
analysis and feasible controls suggestions, including land management.
The FY76 State program submittal should include, as a part of the initial
submittal, a quantitative analysis of the types of NFS pollution in the
State, the relative contribution from each, the geographical distribution,
and the areas of major impact.  As part of the final submittal, the program
should provide for the implementation of an NFS prevention, control, and
enforcement effort in identified areas.

      States with existing NFS control and enforcement programs should
continue them.  Existing conservation programs should be reassessed and
if necessary redirected to include water quality considerations.  By the
end of FY76, enough data and a planning foundation should be available
to implement comprehensive programs.  All basins should be covered by
1983 or earlier.

      EPA will review and support State and areawide programs and planning
processes.  States and agencies are also responsible for continuing assess-
ment of their own programs.

      Continuing assessments of water quality and development of technical
and other NFS remedies will provide a constantly expanding, usable informa-
tion base for the management effort.

      The annual NFS national water quality assessment will be prepared
as follows:

      •  EPA guidance.  EPA will prepare a handbook on loading
         factors and guidelines for the initial State strategy/
         305(b) report.  For subsequent reports, EPA will provide
         States with models for waste load determinations.

      •  State assessment.  States through the 106/208/303(e)
         process will develop a stream monitoring system and pro-
         gram to characterize and evaluate their NFS problems and
         to recommend controls.

      •  EPA analysis.  EPA will analyze the State 305(b) reports
         in its report to Congress.


      The need for further legislative initiatives will be considered during
Calendar Years 1975 and 1976.  The initial State strategy 305(b)  reports will
contribute to this question.  Legislative changes, if warranted,  will be rec-
ommended during 1976-1977.

E.2.  Spills of Oil and Hazardous Materials

      Spills and other unique discharges of oil and hazardous substances
present problems for water quality and of control that make them different
from continuous or scheduled discharges.  The latter are amenable to a system
of permits based on established effluent and ambient standards.   Spills, in
contrast, cannot be foreseen, are not covered by the permit and regularly
exceed normally permittible amounts.   The primary objective of the oil and
hazardous substance program is to protect water quality through the prevention
of spills and minimizing the impact of spills on the environment, and the
dimensions of the program cannot be correlated with permit activities.

      Section 311 of the Act specifies a three-fold approach to the con-
trol of spills.  This involves spill response, prevention and enforcement.
The response program is shared with the U. S. Coast Guard and jurisdictional
lines between the agencies are drawn geographically between inland and coastal
(including the Great Lakes) waters.  It is EPA's expectation that the dis-
charger should take actions to remove the spilled material; however, if the
violator fails to do so, cleanup will be undertaken by EPA and the discharger
charged for the cost of removal.  Oil removal regulations will be promulgated
by mid-1974 with full implementation to shortly follow.  This action will
complete all major tasks for implementing the oil spill program.   To provide
efficient and coordinated response actions, national and regional contingency
plans are required which delineate procedures, techniques (chemical uses) and
responsibilities of the various Federal, State, and local agencies.

      The national and regional contingency plans were revised to reflect
the new provision of Section 311, which includes State access to the spill
removal fund and removal of hazardous substances.  The contingency plans will
need further revision after completion of regulations.  The development of
technical documents and draft regulations for designation of hazardous sub-
stances, penalty provisions, and harmful quantities will be initiated.  Final
promulgation of these key hazardous substance regulations will be completed
by the end of 1974.

      Following this, procedures will be developed for implementation
of hazardous substances control at the Regional level.  This will include
personnel safety and hazard assessment, spill investigation techniques and
enforcement, and spill response techniques and technical assistance activities.
By the first part of 1975, technical documentation and draft regulations

for hazardous substance removal, prevention and small facility liabilities
will be developed.  Promulgation of the regulations and implementation will
be completed in 1976.

      With the promulgation of the oil prevention regulations for ves-
sels, oil terminals, and non-transportation related facilities, the
major emphasis of the oil program is being placed on implementing these
prevention regulations through a series of seminars to be completed by
mid-1974.  The prevention program is divided between EPA and the Coast
Guard, with EPA having the responsibility for non-transportation related
operations.  Initially, the EPA program is being directed at the repeat
violators and major dischargers with an anticipated 50 percent reduction
of spills within two years after the effective date of the oil prevention

      The enforcement aspect of the program serves as a deterrent to
dischargers through the assessment of the penalty provisions.  For hazardous
substances the enforcement program will have greater significance since
severe penalties can be assessed for discharge of non-removable hazardous
substances.  Also, more aggressive field investigations will be required
because hazardous substances are more likely to go undetected than oil.

      By January 1975 all potential dischargers of oil will be required
to be in compliance with the oil prevention regulation.  In the latter half
of 1974, EPA will complete internal procedures for fully implementing the
oil spill prevention program and in early 1975, initiate the compliance phase.
Emphasis will be placed on spill prevention plan review, facility inspections
and enforcement.  External coordination with State agencies and Coast Guard
will be finalized in this period, and will complete the development of the
hazardous substance response capabilities in the Regional Offices; establish-
ment of personnel safety and hazard assessment program; and improvement of
special support activities such as emergency communications and the Technical
Assistance Data System.

      During 1974 and 1975 the oil and hazardous substances program may
be significantly impacted by external activities such as the energy crisis,
increased offshore drilling, trans-Alaskan pipeline, and international agree-
ments; therefore, special efforts will be required to evaluate the environ-
mental impact created by these activities.

      A coordinated research effort will continue between EPA and Coast
Guard on prevention, control and removal of oil and hazardous substances,
with greater emphasis being placed on hazardous substances.



F.I.  Ocean Dumping

      The disposal of materials in the ocean is regulated by EPA under
P.L.  92-500 and P.L. 92-532 in a manner consistent with the provisions of
the 1973 International Convention on the Prevention of Marine Pollution.
Since the goal of the program is to preserve the quality of ocean water,
disposal of harmful substances is prohibited, but that of innocuous
substances is not.  Implementation takes the form of requiring those who
wish  to dispose of or discharge material into the ocean to obtain permits
from  EPA or the Corps of Engineers under EPA review.  No permits will
be  issued for the disposal of radiological, chemical, or biological warfare
agents or high level radioactive wastes.  A crucial element of the program
is  the development of an' effective monitoring system by which data on the
present state of the oceans and the effects of ocean dumping may be gathered
to  detect trends and indicate actions to prevent degradation.

      EPA developed and published final regulations governing ocean disposal
on  15 October 1973, governing the conduct of an ocean dumping permit program.
All permits must conform to criteria established by EPA to preserve water
quality; these criteria are developed after evaluation of the effects of the
pollutant on human health, marine life, and amenities; the permanence and
persistence of those effects; and other possible disposal methods and places.
Permits specify the type of material to be disposed, the amount, the location
of  disposal, the expiration date of the permit, and any special conditions.
All permits are reviewed periodically.

      In reviewing permit applications for the disposal of dredged spoil,
the Corps of Engineers considers the probable effects on navigation and the
area's economy should the permit be denied.  If a hardship would result
and no other disposal method is feasible, the Corps may request an exemption
from  EPA environmental criteria.

      Permits issued by EPA for disposal of other materials must also con-
form  to Agency criteria designed to prevent degradation and the provisions
of  the Convention.

      Satisfying §403 of the Act (P.L. 92-500), permits for discharges from
outfalls are subject to the criteria established under the ocean dumping
program, as well as to the technological requirements under the Act  (secon-
dary  treatment for municipal treatment plants, BPT for industrial).

      At present, interim permits are being issued which allow dumping or
discharging of substances exceeding the criteria because there is no feasible
alternative means of disposal.  Permit applicants are required to prepare and
implement a plan to develop methods which comply with the criteria.

       A joint monitoring program is being developed under the guidance of
 the Interagency Coordination Committee for Ocean Dumping.  EPA, NQAA, the
 Corps of Engineers, the Coast Guard, and other Federal and State agencies will
 monitor baseline data and the impact of disposed materials.  Highest priority
 is assigned to surveillance of interim dumping sites.

       Applying the criteria for determining degradation adopted by the Agency,
 EPA or the Corps of Engineers (for disposal of dredged spoil) has and will
 select dumping sites using the best data available, including baseline sur-
 veys and full environmental assessments.  No site is designated for permanent
 use; should the continuous review of the effect of dumping reveal degradation,
 the site is closed either permanently or until the area recovers.  No dumping
 is permitted at areas other than designated areas.

       In cooperation with such other agencies as NOAA, the Corps of Engi-
 neers and the Coast Guard, EPA is developing a research program which will
 provide the technical basis:   for the establishment of criteria and implemen-
 tation of the permit programs; for the evaluation of disposal sites; for the
 analysis of data and the effectiveness of the program; and for the development
 of procedures for handling, transporting, and dumping of wastes.  This pro-
 gram will also analyze alternative means of disposing of these wastes and the
 effects of extraneous pollutants, such as atmospheric pollution, relative to
 ocean dumping.

 F.2.  Groundwater

      At the same time that the Act may cause major shifts to land and
subsurface waste disposal, it gives EPA only limited authority to regu-
late the pollution of groundwater.  The basic provisions for standards-
setting and enforcement in Titles III and IV apply to discharges into
navigable water, as distinguished from groundwater.  To protect ground-
water, EPA will use regulatory powers incidental to its control of surface
discharges; establish groundwater criteria for treatment works it funds;
and structure its permit and planning regulations and research activities
to encourage States in establishing full groundwater protection programs
of their own.  Groundwater monitoring capabilities will be built up

      Dischargers who (1) contemplate a change from direct discharge
to land disposal or (2) employ a combination of discharge and land dis-
posal, as part of a program to comply with the effluent limitations
an NPDES permit, could be given permits containing conditions  to minimize
the damage to underground and surface water resources.  Permitting agencies
should take steps under section 514 to coordinate the requirements of
the Act with those of appropriate public health agencies.   Permits, especially
those issued by a State applying State law, may prescribe control practices
and procedures to be followed by the permittee.

      Parallel conditions could be set for pretreating industries.
Municipal permits could require municipal regulatory controls to protect
groundwater from facilities presently connected into a municipal sewer
system but which, because of pretreatment, user charge, or cost recovery
requirements, change to a land disposal technique.

      Grants for the construction of publicly owned treatment works employing
land disposal or aquifer recharge will be contingent on the design of the
project to meet specific groundwater quality standards in the zone of satur-
ation for heavy metals, dissolved salts, nitrates, and organic pollutants.
These criteria are contained in the definition of best practicable waste
treatment technology (BPWTT).

      The Act requires any areawide planning process set up under section
208 to include a process to control the disposition of all residual waste
generated in the area, including through surface or subsurface disposal,
to protect groundwater quality.  States have the option of applying this
control to all parts of a State if the Governor determines that consistency
with a Statewide regulatory program under section 303 requires it.   EPA's
planning regulations for section 303(e) do, in fact, require all plans
produced under the State continuing planning process to provide for ground-
water protection.

      Permit program regulations under section 402(b) also encourage States
to control discharges into groundwater.  To maintain Federal approval of
its NPDES program a State must either prohibit the disposal of pollutants
into wells (a major source of groundwater contamination), or control such
disposal so as to prevent pollution of ground and surface water resources
and to protect the public health and welfare.

      EPA will conduct research on point and non-point pathways of ground-
water contamination.  This research will be analogous to the information
the Agency is now publishing under section 304 (e) of the Act for surface
water (guidelines for identifying and controlling the pollution from agri-
culture and silviculture, mining, construction, well disposal, salt water
intrusion, and hydrographic modification), and will be of use to State
groundwater protection programs.  Additional research will be needed on
the rates of degradation and movement of organic pollutants and pollutants
affected by absorption.

      Under section 305(b) States submit annual reports to EPA on
sources of pollution--their nature, extent, recommendations for control,
and the cost of these controls.  As they become more sophisticated these
reports should cover groundwater effects from these sources of pollution.
EPA may request States to designate principal aquifers, locate ground-
water pollution sources, and provide an inventory of wells which can be
used to determine groundwater quality within their jurisdiction.

      EPA submits an annual report to Congress on the state of navigable
and groundwater nationally under sections 104(a) and 516(a).  The ground-
water portions of this will be based on the State groundwater reports and

on information made available to EPA by the U. S. Geological Survey from
its earth science and resource programs.

      The general ability of States and EPA to report on groundwater lags
behind their ability to report on surface water.  EPA is moreover assigning
first emphasis to surface water in the further development of monitoring
systems.  The Agency will, however, begin to emphasize groundwater monitor-
ing in areas where there is high use of groundwater.


      Strategic Guidance

      Among the criteria elements in government's accomplishment of the
objectives of the Act are two that will result from the efforts undertaken
in the area of research and development.

      The first involves developing the basis for a thorough understanding
of the complex and variable biological systems that are the measure of the
1983 ambient water quality goal.  The second involves having technologically
available, for application by industry, commerce, agriculture, and local
governments, practical and economical systems that will discharge treated
wastewater of the high quality necessary to support- attainment of the 1983
water quality requirements.

      The additional areas, which will become increasingly important,
will be to develop technical procedures for use in controlling non-point
sources of pollution and to develop methods for quantifying the benefits
attributable to clean water and to relate those to the standards, especially
with regard to economics.

      Research and development projects must focus on future objectives
and on efforts capable of producing significant advances over the existing
state of knowledge.  The strategy underlying this program is to prepare for
the achievement of the 1983 Water quality requirements, recognizing that
in many areas, the achievment of the 1977 requirements is constrained by
present technology and existing knowledge.  The efforts should be phased so
that technical and scientific data are available by the 1978-79 time period,
thus allowing a three to five year schedule for its application.  This timing
recognizes that.  The normal process for developing new technology and carrying
it into practical application is lengthy.

      Future research emphasis, particularly in development of control
technologies, is dependent upon analysis of current information relating
water quality to pollutant sources and abatement costs.  Until such time
that this information is accurately developed, no major changes will occur
to the present R§D balance.  However, under the presumption that the benefits
to be achieved by implementing non-point source control procedures will
outweigh the benefit of achieving zero discharge of point sources, a limited
shift in emphasis to increase the development of non-point source technology
will be undertaken.


      A fuller exposition of this research strategy is available in a
research strategy prepared in November 1973 by the Office of Research
and Development.

G.I.  Municipal Technology Research, Development and Demonstration Program

      The program is oriented toward the development of advanced technology
to assist municipalities in meeting water quality requirements where such
requirements indicate that conventional treatment technologies will be insuf-
ficient .

      The principal areas of emphasis will be developing technology for:
improving existing wastewater treatment plant operating efficiency, economy,
and reliability; processing, and utilization of wastewater sludges; effective
and economical control and treatment of combined sewer overflows; and conserva-
tion of plant capacity and water resources through wastewater flow reduction
and reuse.  A special stress will be placed on examining ways to decrease the
energy demands of a municipal treatment.

      Additionally, the development of technology to remove toxic pollutants
will be advanced (to the maximum extent possible consistent with resources)
to provide the availability of treatment techniques for those sensitive ecological
regimes, such as, estuaries which may require advanced treatment, and to impact
both industrial pretreatment and water reuse requirements.

      Many processes for removal of gross organics, nutrients, suspended and
colloidal solids, and bacteria have been developed.  Work will continue on
these processes to increase their reliability and reduce costs.  Emphasis will
be on demonstrations of alternate chemical disinfectants, including ozone,
ultraviolet, bromine chloride and chlorination/dechlorination; evaluations
of pilot plant pure oxygen nitrification; evaluation of full scale fixed media
nitrification; denitrification with other carbon sources then methanol;
engineering studies to improve clarifier design, engineering and cost studies
of organics removal with powdered carbon, granular carbon, ozone and advanced
biological treatment systems  (fluidized bed contactors, rotating bed contactors).
These activities will impact both the technology required for point source
control on water quality limited segments and the decision on the degree to
which "no pollutant discharge" can economically proceed.

      AWT processes for removal of virus, heavy metals, toxic and hazardous
materials, dissolved salts, primarily required for reuse and "no pollutant
discharge" systems will be pursued through pilot scale investigations and
possible demonstrations.  Pilot scale investigations will be used in improving
and developing new technology municipal treatment as no new full-scale demonstra-
tions are planned.

      Sludge processing and utilization will concentrate on more cost effective
dewatering supernatant treatment; pasteurization and disinfection technology;
stabilization and volume reduction technology such as composting, phyrolysis,
wet oxidation and incineration; byproduct and energy recovery processes and


evaluation of new or existing land disposal techniques.  Total sludge management
will be emphasized.

      Programs aimed at advancing reuse systems will rely on technology developed
in other areas.  The water quality goals for these systems will be provided
by environmental and health programs.  Design and performance criteria will be
generated for facilities capable of producing water equivalent to drinking water
quality.  Extensive demonstrations will be deferred until technological require-
ments are defined and water quality goals are set.  Emphasis over the long
term will be on technology to provide a fail safe potable reuse system.

      Upgrading the performance of present treatment plants will concentrate on
improved operation maintenance and application of automated systems for process
control.  In particular, the instrumentation and automation program will
demonstrate by 1977 fully automated municipal wastewater treatment systems to
serve as a model for determining costs, reliability and performance.

      Technology efforts in the area of abating overflow and storm flow dis-
charges, and on reducing wastewater flow into the treatment plant will be
continued.  Correction of infiltration/inflow will concentrate on development of
assessment techniques, and on abatement technology including new materials
and construction technology.  Combined sewer overflow and storm water discharge
projects will continue efforts to develop methods for predicting, controlling,
and treating urban runoff pollution loads.

      Finally the systematic evaluation of the treatment capability and capacity
of soil of various types and classes will be expanded in order to impact   ^
engineering design of land treatment systems for BPWTT, reuse and no discharge

G.2.  Non-Point Sources

      An increased understanding of the dimensions of pollution from non-
point sources such as agriculture, mining, construction activities, and from
intermittent sources such as spills of oil and hazardous materials, needs
to be developed.  This is done through a quantitative assessment of the
nature, magnitude, and controllability of these sources.  The most
immediate focus will be in developing information for use in guidelines
to assist in:

      a.  Characterizing and assessing pollution loading from specific
          non-point sources.

      b.  Assessing the applicability of demonstrated control options
          for their conditions.

      c.  Predicting load reductions which should result from applying
          specifying control procedures.


Associated efforts will involve development of improved models to predict the
impact of NFS pollution and its control within a river basin;  developing
quantitative tools for measuring and correlating land use activities with NFS
pollution; and developing and testing improved monitoring techniques.

      For problems for which available controls are clearly inadequate,
effective and economical control methods and devices will be developed
and demonstrated.  These control methods will focus on introducing changes
in the methods of operations and management of activities resulting in
this pollution.  Therefore, development of source control techniques is
of a high priority.  Initial attention will focus on coal mining; on agri-
cultural activities (point and non-point, such as irrigation return flows;
runoff from agricultural land; and animal feedlot pollution, primarily
from land disposal of manure); and on sedimentation and erosion control
procedures in the construction sector.  Second generation control methods
will be initiated as a more precise definition of abatement requirements
is defined and will be more comprehensive in coverage in contrast to the
present limited effort.

G.3.  Equipment and Techniques

      The focus of activity will be on the development, test and evaluation
of methods and instruments to identify and measure toxic and hazardous chemical
pollutants and microbiological pollutants for both fresh and marine waters,
as well as sludges and sediments of all types.  The stress will be placed on
sensor rather than from wet chemical methods development.

      Associated with this focus will be the development of NFS measurement
techniques, and of automated laboratory techniques and systems and platforms
for rapid collection and analysis of samples.  Development of the latter will
be initiated in FY 76.

      Predicated on the development of other compliance monitoring pro-
cedures, development of point source measurement techniques will be phased
down as best available and closed cycle technology become available, reducing
the demand for this type of measurement.  Some additional effort, as
resources allow, will be placed on marine monitoring methods development
in conjunction with NOAA, Coast Guard, and U.S. Coast and Geodetic Survey,
partly in support of ocean dumping.

G.4.  Environmental Processes and Effects Area

      Additional support to Agency efforts in setting water quality criteria,
toxic/hazardous  substances criteria, ocean dumping criteria, and other pro-
grams is needed.  Controversies in establishing some criteria and standards
have demonstrated that significant information gaps exist, and must be addressed
quickly from a research standpoint.  Particularly significant is the fact that
little data on fate of pollutants is  included in revised criteria and many

 significant  criteria are omitted.  Additionally,  information  is needed on
 eutrophication,  lake restoration and ocean disposal.  Because of  limited
 resources, future  efforts may be concentrated on  studying a more  restrictive
 number  of organisms and pollutants in fewer ecosystems and geographical areas.

      Research approach will be transformed by FY 76 to investigations
 of  total ecosystems, rather than species specific approach.   The  emphasis
 would be on  determining the range of allowable stress while still maintaining
 the function and structure of aquatic ecosystems.

      Investigations leading to establishment of  basic water  quality require-
 ments for aquatic  life  (temperature, D.O., salinity) will be  completed by
 FY  77 in the freshwater effects program and by FY 78 in the marine effects

      Criteria-like documents will be developed for those pollutants which,
 after screening  of existing information give evidence of environmental signi-
 ficance.  In addition, the scientific basis will  be prepared  for  a revised water
 quality criteria document in 1977-78, so that a revised set of water quality
 standards developed from those parameters can be  tied to the  second round of
 permits.  Scientific information for use in establishing and  revising water
 quality criteria,  toxic/hazardous pollutant list,  standards,  and  other criteria
 documents will be  developed in a manner compatible with cost/benefit research.

      Efforts aimed at understanding the effects  of more common pollutants will
 continue while increased emphasis will be given to:  effects  and  processes
 of  toxic/hazardous pollutants; basin models for non-point sources; and the
 areas of ocean dumping, groundwater and eutrophication.  Groundwater problems
 throughout the U.S. will be assessed and information on the processes and
 effects of groundwater pollution will be developed.

 G.5.  Environmental Management Research Program

      The major program focus will be on improvement of benefit and cost
 functions;  effectiveness criteria;  ambient and effluent standards setting
methods; analysis of alternative control program  (including non-treatment
 control);  and methods for assessing the overall environmental impact of water
quality management strategies.   In addition,  several alternative methods for
financing and post-1976 program will be investigated.

      Within the near-term,  the task will be to develop standards to quantita-
tively measure benefits for recreational and aesthetic values.  A report to
Congress on cost-benefit tools  and techniques was made in January 1974.
Emphasis will be altered with time toward determining  the benefits of specific
standards  and regulations.


      Development of management methods will be continued with emphasis on
non-point agricultural sources as related to pesticides management.  Inves-
tigations into urban runoff and groundwater management methods would be
initiated in FY 76.  Analysis of options for setting groundwater standards
will be completed.

      The need to establish costs, risks, and benefits of pollution control,
alternate management approaches, and long-range analysis of environmental
problems remains high.  The program will emphasize development of more applied
tools for use by program offices, Regions, and States.  These will include:
(1) the development and evaluation of new cost allocation and financing; (2)
development of systems evaluation techniques for controlling point and non-point
sources; (3) development of methods for assessing the comprehensive environmental
impact of P.L. 92-500 including preparation of environmental indices and methods
to evaluate secondary effects of programs that achieve goals of P.L. 92-500;
and (4) the development of methods for integrating areawide waste treatment
management with land use and other functional elements of comprehensive planning.

G.6.  Industrial Technology Research Development and Demonstration

      The time schedule for the second round of permits indicates that to have
an effect,  development and demonstration of "best available" technology for
industrial sources must occur by 1977-78.

      The focus of technology development will be for industries for which
"best available" technology is not likely to be satisfactory, either in terms
of meeting water quality requirements or by being economically feasible,
or by resulting in other significant environmental effects.   Emphasis will be
given to those industries contributing most significant pollution loads, and
those which can demonstrate low cost to maximum benefit for pollution control.

      Additionally, technology development would be emphasized for those frag-
mented, small industries with primitive control technology which are unable
or unlikely to produce necessary technology.  Systems which minimize multi-
media effects and have low-energy demands will receive developmental attention.

      The legislative requirements to influence the development of advanced
industrial technology are strong and matched by the significance of the problem.
In terms of BOD, industrial wastes account for more than twice the BOD loads
from the entire U.S. population and are growing at three to four times that
rate.   However, no legislative incentives exist to stimulate industry to
develop advanced technology.  Technical risk, while initially small, will
increase in later years as the program tackles more difficult problems.  A
shift in emphasis toward application of developed technology to other industries
will occur in later years.

       It  is estimated that, if advanced technology approaching zero polluting
discharge could be demonstrated in approximately 65-70 industrial subcategories
out of a  total of 165 industrial subcategories, 801 of the discharge from
major  industrial pollutants could be abated.  Federal expenditures of approxi-
mately between 1/2 to II of capital costs would be required, but would stimulate
technology and significantly impact second generation permits.  Specific steps
include the development of BAT technology in 1974 for 9 of 165 technology
subcategories.  A similar number will be developed in 1975.  The number of areas
covered is limited by available resources.  In other areas, the program will
continue  to rely heavily on industry to advance technology through pilot stages.
Preparations  for development of advanced technology treatment for the remaining
key subcategories in future years will be made.

G.7.   Health  Effects Area

      The important focus is to develop the scientific information necessary
to revise criteria affecting health for water quality, for reuse of industrial
and municipal wastewaters,  and public water supply standards.   This latter
area relates to drinking water contamination from discharges of pollutants,
especially where the contamination cannot be treated before use.   The technology
needed to economically attain the drinking water standards needs to be developed.
Other important areas include determining the long-term,  chronic health effects
of microbiological and persistent toxic pollutants and the effects on health,
from contact recreation, that can result from discharge from municipal waste-
water treatment facilities.   (Other research activities relate to drinking
water supplies and are not covered in this paper.)

      Maximum emphasis,  including an increased use of epidemiological studies
will be provided on determining the human health effects  of microbiological
pollutants in particular, viruses and other organic pollutants.

      An increased emphasis will be placed on technology for water supply
systems taking advantage of advances in the municipal technology program.
Beginnning in 1975,  efforts aimed at determining the health threat from waste-
water treatment processes and facilities,  in particular,  spray irrigation
facilities,  land disposal of sludges and municipal treatment facilities will
be expanded.

G.8.   Quality Assurance Program

       The general need for EPA and the States to measure progress in improving
water  quality cannot be neglected and will affect decisions on programs and
permits.  With major responsibilities being given to the States for monitoring,
EPA should provide overall coordination, and assure that monitoring quality
control is maintained and data are properly developed and utilized.


      The following areas of focus are identified:

      (a)  The development, evaluation, and selection of standard reference
methods for sampling and analysis of water, sludges and sediments.  Programs
to develop standardized methods and quality control procedures will be continued
with some accelerated effort in the area of quality control programs, and on
verifying standard reference methods for marine waters.

      (b)  The development of quality control procedures to improve data
accuracy and provide data verification.  Continued planning will be conducted
toward defining data management requirements, with implementation delayed
until 1976.

      (c)  The development of guides for the design and operation of optimal
water quality monitoring programs.

      (d)  The development, through the Lake Survey Program, of information
on lakes threatened by eutrophication by high nutrient sources.  The Lake
Eutrophication Survey will be terminated in FY 76.  Before that time, EPA will
investigate and develop plans for continued use of this capability beyond FY 76
to support other objectives including non-point source monitoring activities.

      (e)  The development of systems to correlate aircraft or satellite sur-
veillance data with land based stations to permit development of gross area

G.9.  Great Lakes Research Program

      The program is conducted to develop the scientific information needed
to assess and evaluate the effectiveness of implemented programs to improve
the Great Lakes water quality, and to develop the scientific information
needed to support the Canadian/U.S.  Agreement for the Great Lakes.  Emphasis
will be altered from studies directed toward development of information and
methodologies for Lake Ontario to Lake Erie and Upper Great Lakes in FY 74
and beyond.


H.I.   Preparation of Environmental Impact Statements

      The following actions of EPA are subject to the requirements of the
National Environmental Policy Act that their environmental impacts be evaluated
before they are approved:   areawide plans under section 208;  construction
grant awards for municipal treatment plants,  for which only one assessment

 or  statement  need  be prepared  to  cover all  steps, unless  there  is  an  inter-
 vening  change in project nature and  scope;  and discharge  permits for  selected
 new sources under  section  402.

      It  is EPA policy  to  assure  proper consideration of  the  environmental
 impacts of these actions while avoiding unnecessary delay in  the disbursement
 of  construction grant funds and issuance of permits.  In  order  for both these
 goals to  be realized, it is imperative that applicants prepare  complete
 environmental assessments  as integral parts of their plans or applications
 for grants.   Assessments for treatment works would be done as a part  of the
 facilities plans and should include  a description of the  environment  without
 the project,  dealing with  both water and non-water quality related aspects
 both in the present and in the future; an analysis of all alternatives and
 the reasons for preferring that one  chosen; and factors in the  decision on
 siting, capacity,  and degree of regionalization.  Environmental assessments
 are as  a  part of the 208 plans should include, in addition, an  analysis of
 non-structural alternatives such  as  land use controls, non-point source
 controls, and institutional changes.  The Regional Administrator may  require
 additional information  from the applicant.  Prompt and complete preparation
 of  the  environmental assessment by the applicant allows it to conduct more
 thorough  reviews of these  assessments and to prepare more complete environ-
 mental  impact statements in cases where they are warranted.

      Other procedures may be  followed to reduce the burden of  preparing
 environmental impact statements while assuring that the impacts themselves are
 given adequate consideration.  If warranted, environmental impact  statements
 should  be prepared on 201  or 201  facility plans; then any construction
 grant awards  under those plans can be made without additional impact  state-
 ments unless  there is a significant  change  in the projects from the one con-
 tained  in the original plan.   Impact statements should also be  prepared
 on  groups of  individually minor but  similar actions whose cumulative  impact
 is  large or sets a precedent.  It is expected that municipal plants with
 eligible costs  of  $20 million or more will be considered to have a signifi-
 cant impact which must be  evaluated  in an environmental impact  statement.
 (This requirement may be waived by the Office of Federal Activities, on
 request of the Regional Administrator, if the grant is to upgrade or reno-
 vate an existing plant and will not add signficant new capacity.)  Finally,
 environmental  impact statements should be prepared for municipal plants of
 smaller size which have major effects on public parks or historic sites,
 are located on wetlands or the habitat of an endangered species, induce growth
 affecting non-water quality aspects of the environment,  or divert water from
 the basin with resulting adverse effects on water quality or quantity.

      The Agency has not yet decided whether ?n< ironmental assessments pre-
pared by new source applicants should include consideration of non-water
 quality related impacts.

H.2.  International Agreements

      Great Lakes with Canada

      The Agreement between Canada and the United States on Great Lakes
Water Quality of March 1972 requires the U.S. to give priority in all pro-
grams to reducing pollution on the border lakes and their tributaries.
P.L. 93-243 revoked an established EPA requirement that States give high
priority to projects on the Lakes and their tributaries within their con-
struction grant lists.  While no longer a requirement, EPA will encourage
the States to retain this project priority in light of the unique resource
which the Lakes represent and the treaty commitment.  Additionally, EPA
will support the goals of this Agreement in issuing permits to industrial
dischargers and carrying out research into non-point source pollution of
the Lakes.  EPA will participate in a Corps of Engineers study of Lake
Erie which is to produce a model of the Lake.

      Lower Colorado with Mexico

      The Minute of the International Boundary and Water Commission of
the United States and Mexico pledges the U.S., subject to Congressional
authorization, to adopt measures to achieve certain annual average salinity
levels on the Colorado River.  Extension of the Wellton-Mohawk bypass drain
is specifically identified.  Other actions by EPA also impact on this issue.
Salinity standards are being developed with which all NPDES permits will be
required to comply.  It is expected that these standards will maintain salinity
levels at or below those present in the lower main stem of the Colorado
in April, 1972.  EPA is conducting research into methods to reduce demand for
irrigation water, volume of return flows, and leaching of salts; changes
in land use and agricultural practices are among the techniques which are
to be examined.  The Agency will also study desalting techniques in an
effort to develop methods which demand less energy than those currently in

      International Conventions

      International Conventions on Pollution of the Sea by Oil  (1954 and
revised in 1962, 1969, and 1971) and on the Prevention of Marine Pollution
by Dumping of Wastes and Other Matter (1973) have been and are being incor-
porated into the regulatory requirements of this country.  The latter has
not yet to come into force but its provisions have been anticipated in the
preparation of ocean dumping regulations and guidelines.  Some additional
environmental specifications may emerge from the Law of the Sea Conference
to be held in 1974.

      Mich of the pollution of the sea comes from discharges into rivers or
 from coastal sites that flow into the ocean; or from airborne emissions.
 Control of these land-based sources represents the next major initiative.
 Several Baltic Nations, France, and the Netherlands have prepared initial
 proposals.  During 1974, the United States will be developing proposals for
 such a Convention which would incorporate many of the features of the Act,
 stressing control over toxic and hazardous substances and introducing rela-
 tively equivalent levels of pollutant control among nations.  Sections 7
 and 101(c) of the Act charter activities in this regard.  In an associative
 effort, section 6 of the Act requires the Department of Commerce to report
 annually on the effects on international trade resulting from this and other
 countries' introduction of pollution control technologies and to recommend
 any compensating action (such as surcharges) where an imbalance exists.

 H.3.  Small Business Loan Assistance

       The Act requires EPA to review applications from small businesses
 for loan assistance from the Small Business Administration in the con-
 struction or modification of facilities to comply with permit or other
 requirements under the Act.  EPA's review is confined to a determination
 o± the necessity and adequacy of the proposed construction or modification,
 with SBA conducting the review of financial eligibility.  The program is
 phased so that much of the workload is expected to come some time after
 the initial surge of permit issuance.

       EPA will establish agreements with SBA on cooperative handling of
 the program and provide guidance to Regional offices,  and will encourage
 States to assume or participate in program responsibilities.

       In  several years,  as completion  of the initial  series of areawide and
 basin planning nears,  EPA will  review  whether to include non-point  sources
 within the categories  eligible  for loan assistance.

 H.4.  Multi-Media Impacts

       The  environment  is a closed  system and  its parts are closely inter-
 related.   Pollutants originally found  in one medium (air, water or land) can
migrate into another where they may be more difficult to remove or may
 cause  greater damage.  Particulate air pollution, including toxic heavy metals,
pesticides, and radioactive substances, can be washed into bodies of water
by precipitation.  These same pollutants, present on the land either naturally
or as a result of man's activities, can enter the water by leaching or erosion.
Wastewater treatment processes such as land treatment, or disposal of sludges
on land, in water, or by incineration, can result in the migration of
pollutants such as toxic heavy metals, organic matter and bacteria to other
media.  Therefore, the impacts of a proposed wastewater treatment project on
all media must be considered before the project is approved.

      Recognition of other impacts also plays a part in establishing stan-
dards.  Requests to allow primary treatment as a sufficient standard for
municipalities discharging into the ocean, if agreed to, could then encourage
similar requests for waivers on the basis of ambient conditions by industrial
dischargers and industries subject to pretreatment.  This could aggravate the
the developmental pressure along our coasts.

      Consideration must also be given to the secondary impacts of a municipal
project on all media.  Construction of a waste treatment plant often induces
economic growth, so the plant's capacity and site must be determined after
evaluation of the impact such growth will have on air and water quality, open
space, wildlife habitat, and other parameters.  The relative energy demands
of different treatment methods must also be considered, since supplying that
energy involves air and thermal pollution, changes in land values from strip
mining and power lines, water pollution from mine drainage, and disruption
of streams by construction of dams.

      EPA has adopted two specific procedures to assure that impacts of pro-
posed pollution abatement measures on all media are considered.  Since
December 31, 1973 all major standards, regulations, and guidelines have been
subject to an environmental evaluation which addresses effects on air quality,
solid waste disposal, demand for energy and other resources, and land use;
pertinent non-environmental factors, including social, economic, political,
and legal ones; viable options; and the rationale for choosing the proposed
regulation or standard.  Second, review of environmental assessments and
Environmental Impact Statements prepared for facility and areawide plans and
municipal treatment works will provide another opportunity to evaluate the
impacts of water quality related programs on other media.  Regulations under
individual programs also deal with this issue; for example, producers of
pesticides are required to report on their products' tendency to migrate and
their characteristics in each medium.  Certain studies under EPA auspices,
including those on the health effects of pesticides in water and the health
effects of radiation in water and the ways in which radioactive substances
enter the water, will be used to develop additional regulations.

      EPA will encourage the States to expand their consideration of multi-
media impacts in their water planning decisions, especially with regard to
land use planning under the 208 program.
                                                  *U.S GOVERNMENT PRINTING OFFICE: 1974 546-317/316 1-3