clean
water
REPORT

TO

COHGRE//1975-76

U. S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D. C. 20460

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Dear Mr. President
Dear Mr. Speaker:

    I am pleased to transmit to the Congress, as required by section 516(a) of the Federal Water Pollu-
tion  Control  Act,  the third  of a series of annual reports  covering  measures taken to implement the
objectives of the Act. This is a consolidated report covering calendar year 1974 and 1975,
     Highlights of the report include:
    • By December 31, 1975, EPA had obligated over $8.2  billion dollars  for municipal wastewater
      treatment works construction. Estimated needs, however, greatly exceed these  amounts, and a
      strong Federal-State effort will be needed to accelerate obligations  of the remaining authorized
      funds.
    • The issuance of the first round of National  Pollutant Discharge Elimination System permits was
      virtually completed for  major sources—over 45,000 permits were issued by the end of December,
      1975. The major focus in the permits area must now shift to assuring compliance with the permit
      conditions, if the potential of the program is to be realized.
    • State  planning and management agencies have completed a majority  of the scheduled waste load
      analyses:  over 1700 segment analyses were  reported complete by June 30, 1975. In addition, the
      areawide waste treatment management planning program under  section 208 was initiated during
      the year.  Timely completion of  plans and the use of plan outputs for related program manage-
      ment actions must now  be emphasized.
    • The States have assumed increasing responsibilities in the national water quality  program. By the
      close of 1975, 27 States were participating in the National Pollutant Discharge Elimination Sys-
      tem, and the number continues to rise. The State role in construction grants administration was
      also expanded. Other important areas  of  Federal-State  cooperation include the  national compli-
      ance  monitoring system, water quality reporting, the State program under section  106, involve-
      ment in wastewater treatment operation and maintenance inspections and  evaluations, and atten-
      tion to the training and development of waste water treatment plant operation and maintenance
      personnel. Limitations on State resources will be a continuing restraint in this aspect of the pro-
      gram.
    • Water quality studies were continued,  addressing problems  such as  lake  eutrophication  and the
      potential impact of revised water quality criteria being prepared by the Agency. Work has  pro-
      ceeded on the Water Quality Inventory Report, to be completed in early 1976.
    • An approach to State and local management of nonpoint sources of  pollution was developed, to
      be carried out as  an important part of the State and areawide water quality management process,
      under EPA  guidance. Various problems are  foreseen, but these should not deter proceeding with
      a program in localities where it is needed.
    • Methods to reduce the  total  flow of sewage were reviewed, and several  promising devices and
      techniques were analysed.
    • Research studies investigated health effects,  ecological processes and effects, municipal, industri-
      al and nonpoint source  pollution control, and other areas of program or data management impor-
      tance.
    The water quality program under the 1972 Federal Act remains a relatively new  effort. Although
problems will continue to be encountered in many areas of the program, the significant accomplishments
to date are highly encouraging.

                                                        Sincerely,
                                                        RUSSELL E. TRAIN
                                                                                               iii

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                                                Introduction
  Clean water, the title of this Report, is the goal
of the national water quality program. More than
three years have passed  since the Federal Water
Pollution Control Act ("the Act") was  amended
on October 18,  1972, to add major new  programs
directed toward this purpose.  It has  been a time
for learning, deciding, and acting—learning more
about current  water quality  and  its protection;
deciding the basic questions inherent  in the devel-
opment  of major new programs; and  acting  to
carry out the important initiatives of the  Act.
  EPA has wrestled with countless problems dur-
ing this  time. Nor  is this a solitary  undertaking.
The Act reaches into every corner of the land. No
individual who uses water can fail to be affected,
directly or indirectly,  by the pervasive scope of
the 1972 law.

  This report  summarizes and highlights EPA's
actions during 1974 and 1975.  Progress in many
areas  is noted; where there are problems, these
are also  described. Together,  the  photographs,
charts, and narrative attempt to present a compre-
hensive overview of EPA's myriad activities per-
formed to implement the Act and move toward its
objective.
    Protecting existing high quality waters is an important policy in the Nation's water quality program. (Canoeing on the
                                        Wisconsin River.)

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                                                                          CHAPTER  ONE
                                              Water   Quality -
                                              Monitoring
                                              Standards   and
                                              Coals
  Knowledge of existing water quality is expand-
ing, although the informational base remains im-
perfect. Enough  is known to recognize that  a
great deal  of water quality improvement remains
to be accomplished.
  Water quality standards define  specific water
uses and criteria for individual waterways. They
are  an  important part of the Federal/State regula-
tory scheme for pollution abatement.
  A further  goal—restoration, preservation  and
maintenance  of water  quality—is  also  a major
component of the system. Its purpose is to assure
that existing  water quality will not deteriorate in
contravention of the Act.

WATER QUALITY MONITORING—
THE PRESENT PICTURE

  Collection and analysis of current water quality
data is  the first step in  developing  national water
quality  requirements, goals and expectations. Dur-
ing  1974 and 1975, EPA's attention was directed
both to reviewing water quality data and to devel-
oping new  information.

Reviewing Current Information

  Studies of water quality are  conducted through-
out  the country by EPA,  other Federal agencies,
and State and local organizations. During 1975 the
States for the first time  prepared and submitted to
EPA their  own  reports on water quality and relat-
ed programs. These reports, along with a national
summary and analysis by EPA, have been trans-
mitted  to  Congress as  called  for  under  Section
305(b).  In  total,  the report provides  the most
comprehensive nationwide review to date of:
  Current water quality and recent trends
  Current and projected uses of the water
  Costs of meeting water quality objectives
  Nonpoint source pollution problems
  The States generally confirm the findings of the
1974 National Water Quality Inventory report to
Congress that, despite recent improvements in the
levels of pollutants  which  had received wide-
spread control efforts, such as bacteria and oxy-
gen-demanding organic loads, significant problems
from these  pollutants still exist in many areas,
especially near population centers.
  Furthermore, several States reported worsening
trends for nitrogen and phosphorus, the nutrients
most often  blamed  for  eutrophication.  These
trends were also noted in the 1974 report. Signifi-
cant problems were  also  caused by  toxic sub-
stances such as dissolved metals, industrial chem-
icals, pesticides, and other harmful compounds.
  The 1975 305(b) report also contains two sec-
tions describing special analyses done by EPA:
  The National  Water  Quality Surveillance Sys-
  tem CNWQSS)-The NWQSS, established un-
  der Section 104(a), consists of 188  monitoring
  stations  located upstream  and downstream of
  selected areas across the country (Figure 1-1).
  The areas were chosen to reflect a cross-section
  of the different types of streams  and land use
  characteristics found in the United States. The
  analysis of the first year's data focused on de-
  termining the relationships  between water quali-
  ty parameters  and the  differing uses of  the
  land.  It was found that bacteria and  nutrient
  levels were strongly related  to  municipal/in-
  dustrial activity and, to a lesser degree, to agri-

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  cultural activity. Oxygen-demanding loads and
  total solids loads were not as strongly related to
  levels of land use activity.
    The  National Eutrophication Survey—EPA's
  reseach laboratories in Corvallis, Oregon and
  Las  Vegas, Nevada have been studying  lakes
  throughout the country to determine the extent
  of the  nation's eutrophication problem.  The
  survey found  that  phosphorus is the element
  which  usually needs to be  controlled  to  slow
  the rate of eutrophication.  Of the 298  lakes
  surveyed in 22 States east of the Mississippi, 73
  percent have  phosphorus  concentrations high
  enough that they would be  expected to exhibit
  eutrophication symptoms.

Developing New Information
  Additional water quality information is needed
for many aspects of the  national water quality
program. Data can indicate areas for future priori-
ty attention and reveal  the appearance  of  new
problems, as well as showing the consequences of
past efforts.

  Several programs are currently under way. The
National Eutrophication  Survey is completing  its
coverage of the nation's lakes and should  have  its
final results available by the  end of 1976. State
monitoring programs  are being improved to pro-
vide greater capability for studying all areas with-
in a State. For example:
    • In FY 76, the majority of states were oper-
      ating primary monitoring networks. This is
      a vast improvement over FY 75.
    • Intensive   surveys have  been  improved
      greatly  in FY 76. However,  many states
      still need  to expand and  intensify their
      efforts in  this area.
    • Approximately one half of the states oper-
      ate programs specifically designed to moni-
      tor lakes and reservoirs.
                                                 Figure 1-1.

                                NATIONAL WATER QUALITY SURVEILANCE SYSTEM

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    • Most of the states have NPDES authority
      and therefore operate compliance monitor-
      ing programs.
    • Quality  assurance  programs  have  shown
      much  improvement over FY 75. Most  of
      the  states have now  developed quality as-
      surance programs and are in the process of
      implementing these plans.

    • Approximately  one half of the  states are
      now operating  some  type  of  biological
      monitoring  program.

  For the 1976 National Water Quality Inventory
report, the States will be focussing on an analysis
of the projected effects of the Act's effluent limi-
tations  on water  quality and  water uses. The
NWQSS analysis  will  attempt to determine the
relative   magnitude  of pollutant  loadings  from
point  source  discharges  and  from   nonpoint
sources  for different types of pollutants.

  The  National Commission on  Water Quality.
formed under section 315 of the Act to "make a
full and  complete investigation and study of all of
the technological  aspects  of achieving,  and  all
aspects of the total economic, social, and environ-
mental effects of achieving  or  not achieving, the
effluent limitations and goals set  forth for  1983"
has completed its regional assessment studies and
its staff  draft report. The final  report is expected
early in  1976.
WATER QUALITY STANDARDS—
THE CURRENT RULE
  Water quality standards,  section 303, establish
and define water  quality requirements for specific
waters. Through  standards, all waters are classi-
fied in  terms of  their  uses, such  as  swimming,
aquatic life or drinking water  supply.  Standards
also set the specific criteria needed to protect the
uses.

  Standards are a two-pronged  weapon in the pol-
lution fight. They both mandate current abatement
activities and set goals  for longer-range  planning.
Regarding  abatement,  individual  sources  must
meet existing standards, even where this results in
tougher discharge limitations than those demand-
ed  by  the Act's  technology-based requirements.
As  to  planning,  standards  underlie the manage-
ment actions which define an overall control strat-
egy. For example, standards supply a baseline to
assess progress, identify problems, establish priori-
ties and allocate an  area's total acceptable  pollu-
tant load among  present  and future  point  and
nonpoint sources.

  Since the public has  an opportunity  to partici-
pate in standards  development, critical standards
decisions  can represent the people's views  and
enjoy their support.  EPA views this safeguard as
a key  element in  the  nation's clean water cam-
paign.

  Status.—During 1975, the initial standards re-
view requirements (section 303(a)(b)) were essen-
tially  completed.  (See Table 1-1). As of  Decem-
ber, 1975  EPA-approved standards  were effective
in 55  States and other jurisdictions. In 11 States,
Federal promulgation actions have been needed.

  The present standards define criteria necessary
to maintain various  beneficial uses  of the waters.
With few  exceptions, all waters are now classified
for protection of fish and wildlife and for recrea-
tional  activities on  the  water.  In addition,  all
States have  classified many of  their waters for
swimming.

  Water  quality   standards  have  been used in
some  segments  to  determine  individual  point
source controls. To  use standards  in setting per-
mit conditions, waste load analyses are  conducted
and total  allowable  loads are allocated to indivi-
dual sources and  reflected in the permits.  Initial
waste  load  analysis  has concentrated on oxygen
demanding materials in  order  to define pollutant
reductions needed to meet  dissolved oxygen cri-
teria, although various  other  critical parameters
have  also been included in  a number of the ana-
lyses.  Waste  load analyses  will  be expanded to
cover many additional parameters that affect wa-
ter quality.

  Standards Review.—During FY 76 and FY 77,
water  quality standards will be  reviewed  and if
necessary revised, as provided by  section  303(c).
The revised standards should  be adopted  by the
State and approved  by  EPA as the national water
quality  program  moves into the next round of
planning and  permitting and also implements an
expanded program of nonpoint  source control.

  Revised standards  will consist  primarily of  wa-
ter  use classifications and related criteria. A spe-
cific revisions policy will be  established  during
1976.

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                                                         TABLE 1
                                    WATER QUALITY STANDARDS STATUS REPORT

       State Adoption and EPA Approval Under 303 (a & b), and/or Promulgation Action Initiated and in the Federal Register
               State
                                      Date of EPA
                                       approval
        Promulgation
        F R. notice
                                                                                                     Comment
Alabama 	     1-29-74
                                    5-23-74


Alaska	     8-30-73
American Samoa	     10-4-73
Arizona*	     8-1-74 (Partial)
                                    12-30-75

Arkansas  	     10-24-73
California* 	     6-20-74 (Partial)
                                    Most basins ap-
                                    proved as of
                                    12-31-75
Colorado* 	     8-13-74

Connecticut	     12-19-73
Delaware  	     5-9-75
District of Columbia 	     8-28-73
Florida 	     12-20-74
Georgia 	     3-23-74
                                    6-12-74
                                    8-18-75
Guam  	     6-4-74


Hawaii 	     5-14-74
Idaho  	     8-28-73
                                    4-17-75
Illinois	     6-6-74

Indiana	     8-9-73
Iowa 	     3-26-74
Kansas 	     8-2-73
                                    5-29-74
Kentucky	     2-22-74


Louisiana	     9-17-73
Maine	     12-17-73
Maryland 	     7-2-73
Massachusetts 	     7-18-74
Michigan	     11-26-73
Minnesota	     11-6-73
Mississippi 	     3-6-75
Missouri 	     7-13-73



 Montana  	    9-23-74
 Nebraska 	    7-23-73
 Nevada*  	    6-7-74

 New Hampshire 	    12-11-73
 New Jersey 	    4-25-75
Proposed 7-17-74
Final  11-26-74
Nutrient Proposed 10-15-74
Salinity Proposed 6-13-74
Salinity Final 12-12-74
Promulgated Fish and Wildlife
  classification for all waters.
  State changed WQS after 1-29-74
  approval.
EPA will be publishing final
  nutrient standards in 1976.
Salinity Proposed 6-13-74    State has adopted and EPA has approved
Salinity Final 12-18-74
Salinity Proposed 6-13-74
Salinity Final 12-18-74
Proposed 6-11-74
Final 1-6-75
Proposed 11-28-73
Withdrawn 10-24-74
Proposed 9-26-74
Final 12-2-74
F. R. Notice 11-1-74
 Salinity Proposed 6-13-74
 Salinity Final 12-12-74

 Proposed 12-20-73
 Withdrawn 7-24-75
  interstate WQS. Intrastate WQS are
  being revised through basin planning
  process.
Promulgated aquatic life criteria
  for coastal waters and bioassay
  procedures for toxics.
State adopted EPA requests.
Definitions were adopted in the
  form of emergency regulations.
Promulgation action was required
  as original WQS submitted did not
  include all waters of the State.
F. R. notice was a clarification of
  previous approval. The "no discharge'
  provision on the Big Piney River was
  made exempt from consideration.
 State adopted EPA requests.

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                                                              TABLE 1
                                  WATER QUALITY STANDARDS STATUS REPORT—Continued

   State Adoption and EPA Approval Under 303 (a & b), and/or Promulgation Action Initiated and in the Federal Register—cont'd
               State
                                       Date of EPA
                                         approval
        Promulgation
        F R. notice
                                                                                                           Comment
New Mexico*  	     10-3-73

New York	     5-8-74
                                      2-23-75

North Carolina	     11-6-74
                                      8-26-75
North Dakota  	     3-12-74
Ohio  	     5-14-75

Oklahoma 	     10-24-73
Oregon 	     7-30-73 (Partial)

Pennsylvania 	     8-10-73
                                      6-28-74
                                      10-30-74
                                      6-23-75
Puerto Rico	     6-26-74
Rhode Island 	     12-18-73
South Carolina	     1-15-73
                                      3-7-73
South Dakota  	     7-18-74
Tennessee	     5-14-74
                                      9-2-75
Texas 	     10-25-73
                                      7-2-75
T.T. of Pacific 	     10-26-73
Utah*	     12-13-73

Vermont  	     1-18-74
Virginia 	     8-3-73
Washington  	     3-18-74
West Virginia  	     7-11-74

Wisconsin 	     4-15-74
Wyoming*	     8-23-73
                                      1-30-75
                                      6-25-75
Virgin Islands  	     11-15-73
Salinity Proposed 6-13-74
Salinity Final 12-12-74
Proposed 12-20-73
Withdrawn 7-24-75
Proposed 5-3-74
Withdrawn 8-7-75

Proposed 2-4-74
Withdrawn 12-10-74
Proposed 9-21-73
Withdrawn 7-24-75
Final approval excepted from
  consideration certain portions
  of the thermal WQS.
State adopted EPA requests.
F. R. notice on dissolved gas WQS
  withdrawal was signed  12-10-74
State adopted EPA requests.
Salinity Proposed 6-13-74
Salinity Final 12-15-74
Proposed 9-19-73
Withdrawn 12-27-74

Salinity Proposed 6-13-74
Salinity Final 12-18-74
State adopted EPA requests.
  *A salinity control policy and standards procedures was proposed jointly for these seven States. It was signed in final form on 12-18-74
Totals
1. Standards revisions completely approved or promulgation action initiated—55 states or jurisdictions
2. Complete approval or initiation of promulgation action pending—None
3. Total promulgation actions initiated to date—18$
  a. Promulgations final—10
  b Promulgations pending—1 (Arizona)
  c Promulgations withdrawn—7
$ 17 States have had promulgation action initiated. Arizona had 2 separate promulgation actions initiated, therefore 18 promulgation actions have been initiated.

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 Water quality standards should provide for many different
 uses of water. (Calumet Park beach, Chicago, Illinois, with
           power plant in the background.)

RESTORATION, PRESERVATION AND
MAINTENANCE OF WATER QUALITY
  The objective of the  Act  is "to  restore  and
maintain the  chemical,  physical,  and  biological
integrity of the Nation's waters." The State's an-
tidegradation policy, an integral part of  its water
quality standards, determines the extent  to which
this objective will be  achieved.  At a minimum,
each  State's antidegradation policy must assure
the following:
  • Water uses currently being achieved instream
    will be maintained and protected.
  • Waters  with water quality exceeding the min-
    imum level necessary to  support the FWPC
    Act's water quality goal  uses  will  be main-
    tained unless  the  State decides, after ade-
    quate  public  participation  and  intergovern-
    mental  coordination,  to  lower the  quality
    because the resulting  social and  economic
    development would be necessary and justifia-
    ble. In  no case, however, could the lowering
    of water quality impair any existing  beneficial
    water use.
  • Waters  considered  to  be  an outstanding na-
    tional resource will not be degraded.
Antidegradation policies have been  in effect since
before enactment of the 1972  amendments to the
FWPC act. The revised  water quality management
process (see Chapter VI)  will include  increased
emphasis on implementation. Techniques which a
State  may select to implement  its antidegradation
policy include:
  • Reducing the  discharge of  pollutants from
    existing sources and restricting any new  dis-
    charge  of pollutants  from new and existing
    sources.
  • Requiring  land  disposal for new  municipal
    projects.

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                                                                           CHAPTER  TWO
                                              The  Basis  for
                                              Water   Quality
                                              Controls
EFFLUENT LIMITATIONS

Introduction
  Effluent limitations for a point source discharg-
ing to navigable waters derive from two principal
FWPCA components:  technology-based  effluent
limitations   and  water  quality  standards.   An
NPDES permit, issued to the discharger, will es-
tablish its effluent reduction responsibilities. Nor-
mally,  technology-based  limitations in  keeping
with  EPA guidelines indicate a base level which
the source must meet regardless of receiving wa-
ter quality.  If a discharge  at that level would
nonetheless  violate  water  quality  standards,  the
source's limitations  will be made as stringent as
necessary to end the violation.
  This chapter focuses  on EPA's  progress  and
problems in developing technology-based effluent
limitations.  Water quality standards have been
discussed previously. (See Chapter 1.)
  In  addition, this chapter discusses another regu-
latory control requirement  which qualifies the ba-
sic format of national technology limits plus local
water quality concern: toxic pollutant discharge
standards. When toxic pollutant standards are set
by the Administrator,  every affected point source
must comply.
Municipal effluent limitations
  1977 Requirements.—The 1977/78 effluent limi-
tation required by  the Act  for  publicly  owned
treatment works (POTW's)  is  secondary treat-
ment. EPA's  definition  of secondary treatment
limits the discharge of  biochemical oxygen  de-
mand (BOD), suspended solids, and fecal  coli-
form bacteria and delimits an acceptable pH range
for the secondary effluent. EPA has proposed an
amendment to the definition of secondary treat-
ment (Federal Register August 15, 1975, v. 40 p.
34522) to exclude fecal coliform bacteria,  relying
on disinfection  requirements  incorporated  into
water quality standards.
  1983  Requirements.—By  1983, publicly  owned
treatment works must provide for the application
of "best practicable waste treatment technology"
(BPWTT). EPA's definition of BPWTT was pro-
posed during 1974 and promulgated October 25,
1975.
  Three alternative wastewater management tech-
niques are specified  in the regulation, addressed
to the three possible modes of wastewater  dispos-
al. The disposal options are:

   • Treatment and discharge into navigable wa-
    ters.
   • Land application techniques and land  utiliza-
    tion practices.
   • Reuse.

  POTW's providing treatment and discharge into
navigable waters must continue to achieve  a mini-
mum of secondary treatment in 1983. Where fac-
tors such as water quality standards  or availability
of cost-effective technology warrant, the munici-
pality must also provide additional treatment or
include the use of other waste management tech-
niques.
  A treatment works that employs land applica-
tion techniques or land utilization practices which
result in  a discharge to navigable waters must

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meet  the  same  criteria as works discharging di-
rectly into the water.  If a POTW land treatment
results in wastewater entering the ground water, it
must provide protection for any existing or poten-
tial drinking water supply use of the underground
source. Ground water criteria for any other uses
will be determined on a case-by-case basis, taking
into account the present  and potential use of the
ground water.
  In the case  of wastewater  reuse, BPWTT limits
the allowable  quantity of  any  pollutant in the
effluent from  the reuse project which  is directly
attributable to the effluent from the POTW.  The
attributable portion  of the project's effluent  may
not exceed the  amounts which would have been
allowed under the POTW's  other two alternative
disposal options.

Industrial Effluent Limitations
  EPA establishes technology-based effluent limi-
tations and standards by promulgating regulations
under  the  combined authorities of  sections  301,
304, 306,   and 307.  These regulations  define ef-
fluent limitations for industrial  sources. Although
clearly more binding than "guidelines" in the tra-
ditional sense of that word,  regulations are  gener-
ally referred  to as  effluent  limitation guidelines;
accordingly, that term is used here.
  Effluent limitation guidelines  are  developed for
categories  of  industries. For the sake of fairness
and to prevent unsound geographic variation  in
environmental safeguards, guidelines  for similar
sources should  establish similar requirements. At
the same   time, real differences among generally
similar sources must be recognized.  Distinguishing
factors recognized in the law include the age and
size of the  plant,  raw  materials,  manufacturing
processes, the products produced, available  treat-
ment  technology, energy requirements,  and cost.
In response to  these conflicting needs, EPA has
subcategorized industries.  The guidelines are uni-
form   for  subcategories,  but  sources  within  a
broad industrial category may  be subject to dis-
tinct requirements.  To date,  the agency has identi-
fied approximately  500 subcategories within  45
major industrial categories.
   EPA defines three levels of treatment technolo-
gy for each industrial category (or subcategory):
best   practicable   control   technology   currently
available  (BPT) for existing  sources to be applied
by 1977;   best available technology economically
achievable (BAT) for existing  sources  to be ap-
plied by 1983; and new source performance stand-
  Effluent regulations and guidelines define  permissible ef-
  fluents for classes and categories of industrial point sources.
                 (Kanawha River.)
ards (NSPS) to be applied by all new sources. In
addition, pretreatment requirements  are specified
for both new  and existing plants discharging into
municipal treatment  facilities.  As a result, five
essentially  different  treatment  levels must  be es-
tablished for  each  of the 500 subcategories that
EPA has identified. Thus,  EPA's  effluent  guide-
lines will in effect include some  2,500 complex,
technical regulations.
  Progress  in Guidelines Development.—In  ad-
dressing the  enormous  guidelines  development
job, EPA turned first to the 28 industrial catego-
ries which  the Act  expressly  requires to be  ad-
dressed. These categories,  known  as  Group I,
have  now  all  been subcategorized.  In addition,
EPA has identified  18 additional industrial catego-
ries  that need effluent  guidelines.  These  indus-
tries, not specifically mentioned in the Act, have
been designated Group II industries.
10

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  Guidelines development  for  Group I has been
conducted in two phases. Phase I industries repre-
sent those  subcategories the Agency felt  should
have been developed first.  Limited resources  and
the  significance  of  particular  subcategories in
terms of pollution loads  were prime factors in
choosing Phase I industries.  Effluent guidelines
for all Phase I industries were promulgated during
1974. By the end of calendar year  1975, guidelines
for eight Phase II categories were  promulgated,
ten Phase II categories were proposed as interim
final, two were proposed,  and two  were noticed
for proposed rulemaking. (See Table II-l).
  The  magnitude  and importance of the effluent
guidelines effort has  inevitably  retarded  EPA's
ability  to complete  all of  the needed guidelines
within  the time frame contemplated by  the  Act.
EPA has been sued over the delays and  is  now
subject  to a court-ordered  schedule for comple-
tion. Current activity is focussing  on the eight
categories still under court-ordered  deadlines  and
on  revisions  to guidelines which  have already
been published.

Problems
  The  concept of national  technology-based  limi-
tations covering all dischargers is a major innova-
tion of the  1972  amendments.  These limitations
are the foundation for safeguarding the nation's
waters from point source  pollution. They repre-
sent a critically important  aspect of the national
water quality program, and their economic  im-
pact, both on industrial sources and as a regional
or national  question,  can be  significant. Effluent
guidelines  development has  unavoidably  raised
some serious problems.
   Technical Problems.—The  sheer size  of  the
effluent guidelines development effort has strained
the limited resources within the Agency and in the
field of qualified technical consultants. Finding a
good technical  contractor  for the work is often
difficult. The contractor must  be familiar with the
field, technically  competent,  and free from  any
conflict  of  interest that  could affect  its effort.
Unfortunately,  familiarity  and competence often
go  hand in  hand with conflict, making the search
difficult. For  some categories, very few contrac-
tors have knowledge  of the field: in these cases
the choices  become even more limited.
   The  development   of the  effluent limitations
guidelines involves the following progressive tasks:
   • Categorize the industry.
                 TABLE II-l
EFFLUENT LIMITATIONS GUIDELINES REGULATIONS
                  GROUP I



Industry
Insulation fiberglass 	
Beet sugar 	
Feedlots 	
Glass 	
Cement 	
Phosphate 	
Rubber 	
Ferroalloys 	
Asbestos 	
Meat products 	
Poultry 	
Inorganic chemicals 	
Cane sugar regining 	
Grain mills 	
Fruits and vegetables 	
Electroplating 	
Plastics and synthetics 	
Non-ferrous 	
Fertilizer 	
Leather tanning 	
Soap and detergent 	
Timber products 	
Insulation bd. seg 	
Organic chemicals 	
Petroleum refining 	
Builders paper 	
Dairy 	
Pulpandpaper 	
Seafood 	
Ironand Steel 	
Foundries 	
Carbon and alloy 	
Textiles 	
Steam Electric 	
(

Industry
Paving and roofing 	
Paint and ink 	
Wood furniture 	
Oil and gas extraction ...
Mineral mining 	
Coal mining 	
Ore mining 	
Phase I
Date
prom in
Fed. Reg
... 1-22-74
... 1-31-74
... 2-14-74
... 2-14-74
... 2-20-74
... 2-20-74
... 2-21-74
... 2-22-74
... 2-26-74
... 2-28-74
... N/A
... 3-12-74
... 3-20-74
... 3-20-74
... 3-21-74
... 3-28-74
... 4-5-74
... 4-8-74
... 4-8-74
... 4-9-74
... 4-12-74
... 4-18-74
... N/A
... 4-25-74
... 5-9-74
... 5-9-74
... 5-28-74
... 5-29-74
... 6-26-74
... 6-28-74
... N/A
... N/A
... 7-5-74
... 10-8-74
3ROUP II
Proposed in
Federal Registe
1/10/75
2/26/75
... 11/14/74
8/15/75*
... 10/16/75*
10-17-75*
11/6/75*
Phase II
Date Date
prom in prom in
Fed Reg. Fed. Reg
N/A N/A
N/A N/A
N/A N/A
8-21-74 1-16-75
N/A N/A
1-27-75*
8-23-74 1-10-75
2-24-75*
8-29-74 1-09-75
8-28-74 1-03-75
4-24-75
5-22-75*
2-27-75*
9-17-74 1-03-75
10-21-75*
4-24-75*
9-20-74 1-23-75
2-27-75*
10-7-74 1-14-75
N/A N/A
N/A N/A
8-26-74 1-16-75
8-26-74
N/A
N/A N/A
N/A N/A
N/A N/A
N/A
1-30-75*

8-21-75**
8-21-75**
N/A N/A
N/A

Promulgated in
;r Federal Register


6/2/75




»interim final regulation.
"Advanced notice proposed rulemaking.

 . Characterize the wastes  resulting  from  dis-
   charges  within  the  industrial category  and
   each subcategory.
 • Select appropriate pollutant parameters.
                                             11

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   •  Identify the  range of control and treatment
     technology applicable to the discharges from
     each subcategory.
   •  Evaluate the available technology with regard
     to technical and economic factors.
   •  Select the three levels of technology required
     by the Act.
   •  Evaluate the non-water  quality environmental
     impacts including energy requirements.
   •  Based on the selected technology recommend
     effluent guidelines for BPT, BAT, NSPS and
     pretreatment.
Each of these steps is exceedingly complex. Diffi-
cult  engineering judgments  and  trade-offs are re-
quired to come up with sound guidelines.
   Litigation.—When a new  agency, working on a
new  program, promulgates regulations that  affect
millions of  persons in a direct  and costly way
(with civil and perhaps criminal penalties in the
background), an onslaught of lawsuits can well be
expected. To  date, suits have  been filed against
many of the industrial effluent guidelines. None of
these suits  by January,  1976,  had resulted in a
stay  of a final regulation. The  proceedings also
deflect technical expertise from the Agency's fur-
ther  guidelines development  work, thereby imped-
ing work on Phase II and Group II industries and
pretreatment. Thus, the litigation has further bur-
dened an already resource-stressed program.

Pretreatment Standards
   Many  industrial water  users do not discharge
directly to a stream but rather to a publicly owned
treatment works (POTW). Pretreatment standards,
sections 307(b) and (c) of the Act are designed to
prevent  the discharge into the POTW  of any
substances  which  could cause  fire,  explosion,
damage to  equipment, process  upsets, or which
could pass  through the plant untreated or inade-
quately treated.
   Under EPA's approach, pollutants are classified
as either  compatible or incompatible. Compatible
pollutants  are  those  which are  substantially re-
moved by the POTW treatment process; their dis-
charge into the POTW need  not be limited. In-
compatible  pollutants,  those   not  substantially
removed  by the POTW, will  be regulated both
through   general   pretreatment   standards  and
through pretreatment standards  developed for in-
dividual categories of dischargers.
   Regulations  promulgated  November  8,  1973
(effective December  10,  1973) announce general
pretreatment requirements. They define  compati-
ble pollutants and limit the discharge of incompat-
ible pollutants to levels prescribed by distinct pre-
treatment standards for specific industrial catego-
ries. As  an  exception to the  limitation on incom-
patible pollutants, if the POTW is committed in
its NPDES  permit to remove a specified percen-
tage of any incompatible pollutant, the  pretreat-
ment  standard applicable  to  users  of  such  treat-
ment  works will  be  correspondingly reduced for
that pollutant.
  Both the definition of compatible pollutant and
the exception to the  limitation in incompatible
pollutants have caused problems. Defining a com-
patible pollutant as  one substantially removed by
the POTW is clear  for certain pollutants but can
be  ambiguous for a pollutant  parameter  whose
removal  efficiency  many fluctuate widely  over
time  and from  subcategory  to  subcategory.  In
addition, the exception allowing credits for incom-
patible  pollutants can be   impractical  because
varying removal efficiencies  may result  in inade-
quate treatment at various times.
  EPA is planning to revise its pretreatment regu-
lations.  The concept of compatible  vs. incompati-
ble pollutant will be further refined.
  The industry which uses the POTW is not sub-
ject to NPDES requirements.  EPA has  authority
in sections 307(d) and  309 to enforce its pretreat-
ment standards directly against the  point sources,
but with no permit and with  often difficult techni-
cal problems of measurement  and  proof,  this
route is cumbersome.
  EPA will instead encourage enforcement of pre-
treatment standards  at  the municipal  level.  This
can be accomplished on a voluntary basis if the
municipality  passes  a  local  pretreatment ordi-
nance. An alternative,  which has been used spar-
ingly  to date and which may face  legal  obstacles
in the future, is to require in the municipal permit
that applicable pretreatment  standards be met. In
this fashion pretreatment standards could  be en-
forced  in conjunction with  municipal NPDES
permits.
  In order for a State to receive NPDES authori-
ty,  EPA must be assured that the  State has  au-
thority to enforce pretreatment standards in  con-
junction with issuing permits  to POTW's  pursuant
to section 402(b)(9). Thus,  States which  issue
NPDES permits will assume  authority to enforce
pretreatment standards  if municipalities  in  those
States fail to do so.
12

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TOXIC POLLUTANTS
CONTROL PROGRAM
   Virtually  all substances, including those occur-
ring naturally, are potentially toxic to humans and
other  organisms.  This toxicity  is dependent on
both the amount of the substance that the orga-
nism is exposed to and the length of time the or-
ganism is exposed.  In some cases,  toxic  effects
occur  only after exposure to large amounts of the
substance;  in other  cases,  exposure  to  almost
immeasurable amounts result in  serious,  and of-
ten, lethal effects. Regulation of  such  substances
requires a number of alternative control options.
   Some 30 Federal laws, under a number of sepa-
rate agencies, include regulation of  toxic  sub-
stances. Within the Federal Water Pollution Control
Act, toxic substance discharges may be controlled
in various ways. The program's  regulatory bases
include effluent limitations guidelines, water quali-
ty standards, 307(a) standards, 307(b) and (c) pre-
treatment authorities, and  control  of  hazardous
substances under section 311.
  Some  categories of effluent guidelines  already
contain limitations on substances with toxic prop-
erties. The electroplating guidelines, for example,
limit  heavy metals  and cyanide, and  the steam
electric power generating guidelines limit  metals,
chlorine, and  PCB's. During  Phase II, guidelines
for all industrial categories  will be reviewed, and
standards for  those industries  with  substantial
toxic  discharges  of  such substances will be  re-
vised  where  necessary to include limitations  on
those substances.

  Regulations  for   hazardous  substances  were
proposed under the  authority of  section  311  on
December 30,  1975. These regulations designate
hazardous substances  and  specify  removability,
harmful quantities, and penalty rates.

  In 1973, EPA promulgated an initial list of nine
substances to be regulated  by section 307(a) and
proposed  effluent standards for selected source
categories. In April and May of 1974, public hear-
      Dangerous toxic wastes can pose a threat to humans as well as to aquatic life. (Industry near Corpus Christ/, Texas.)
                                                                                                13

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ings  on those standards were  held. The lack of     By  integrating  the  regulatory  provisions  of
sufficient evidence  in  the  record  prevented pro-   effluent guidelines, toxic  pollutant effluent stand-
mulgation of those standards.  During 1975, sub-   ards in section 307(a),  and hazardous substances
stantial reworking of the standards occurred  and   in section 311, EPA expects to develop a coordi-
additional information was collected.  New stand-   nated, Federal toxics control  program  for  toxic
ards  are scheduled to be proposed in 1976.           water pollutants.
 14

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                                                                          CHAPTER  THREE
                                                The   Application
                                                of   Controls
PERMITS
  The national  pollutant  discharge  elimination
system (NPDES) under section 402 remains the
principal  vehicle for source by source control of
the discharge of pollutants into navigable waters.
In 1974,  this program, together with construction
grant awards,  held highest priority  among  EPA
water programs. Administrative responsibility for
the program was shared by States  and the  EPA
Regional  Offices; the role  of  EPA  Headquarters
was largely advisory.
  By law, permits are issued for  a  term of up to
five years.  They require point source dischargers
to comply with applicable FWPCA  provisions in-
cluding technology- or water quality  standards-
based effluent limitations,  new  source perform-
ance standards, toxic and pretreatment standards,
and ocean discharge criteria. They may also abso-
lutely prohibit the discharge of certain substances.
Finally, permits include conditions regarding mon-
itoring,   recordkeeping,  reporting,   entry  and
inspection.
  Program  Accomplishments During 1974-1975.—
The  Act  expected that all  permits were to have
been issued by the end of 1974. In all, about 28,-
000 permits were issued by the end of the calen-
dar year. However, a  substantial  number of per-
mits, mostly for minor dischargers,  had not been
issued by that  date.  Since  EPA  and the  States
lacked the  resources to process permits properly
for all of  these sources, activities  were prioritized
to maximize the program's effect.  Highest priority
was assigned to  issuing the  remaining major and
new source permits; lower emphasis was given to
minor dischargers causing less serious water qual-
ity problems.
  By the  end of  1975, permits had been issued to
95% of all major municipal dischargers; 91% of all
major non-municipals;  78%  of all minor munici-
pals; and  62% of all minor non-municipals. A total
  By December 31, 1974, most major point sources and many
  others had been issued discharge permits specifying effluent
  limitations for their discharges. (Chemical company along
                Kanawha River.)


of 45,865 permits had  been  issued by the  end  of
the year. (Table III-l—III-2). The small number  of
major permits left  unissued  are  tied up in  pro-
tracted administrative procedures, primarily at the
State level.
                                                                                          15

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                                            TABLE III - 1
                    MUNICIPAL & NON-MUNICIPAL PERMITS BY REGION (EPA & STATES)
                                          December 31, 1975

I

II

III

IV

V

VI

VII

VIII

IX

X

Total



Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Major
Minor
Total

Permits
Issued
372
288
476
632
389
1,437
1,258
745
543
4,330
356
1,532
377
1,880
226
807
223
250
155
569
4,375
12,470
16,845
Municipal
Identified
Dischargers
372
353
517
1,537
416
2,785
1,412
1,343
567
5,039
359
1,531
364
1,784
227
840
214
250
156
598
4,604
16,060
20,664

Percent
Issued
100%
82%
92%
41%
94%
52%
89%
55%
96%
86%
99%
100%
104%
105%
99%
96%
104%
100%
98%
95%
95%
78%
82%

Permits
Issued
436
1,129
508
710
392
1,610
1,110
4,206
663
5,334
384
1,975
215
3,275
166
1,384
228
1,561
111
1,561
4,213
22,745
26,958
Non-municipal
Identified
Dischargers
437
1,568
644
1,809
545
4,156
1,199
6004
748
6,699
370
7,350
215
3,807
166
1,622
217
1,608
114
2,176
4,655
36,799
41 ,454

Percent
Issued
99%
72%
79%
39%
72%
39%
93%
70%
89%
80%
104%
27%
100%
86%
100%
85%
105%
97%
97%
72%
91%
62%
65%
                  TABLE III - 2
            OVERALL STATUS REPORT
PERMITS ISSUED
December 31, 1975
TOTAL

Issued EPA and States**
Identified Dischargers** 	

Major*
8,814
9,485
Minor
37,051
54,695
Total •
45,865
64,180
Non-municipal
Issued EPA and States
Identified discharges

4,213
4,655
22,745
36,799
26,958
41,454
Municipal
Issued EPA and States
Identified discharges 	

4,375
4,604
12,470
16,060
16,845
20,664
  *Major count includes "significant minors"
 "Includes EPA-issued Federal facilities permits as follows:
 226 major; 1,836 minor; 2,062 total

  EPA has  continued to encourage  the  States to
assume  responsibility for  the  NPDES  program.
By the  end of 1975, 27 State NPDES  programs
had been approved. (Table III-3).
  Problems in the  Municipal Area.—The  scale
and public cost of the  national municipal permit
effort, coupled with the tight  requirements of  the
FWPCA,  have  led inevitably  to some  serious
problems  in connection  with  issuing municipal
permits.  First, many municipal facilities  will  not
reach  the  1977/78  secondary treatment  require-
ment by  the  statutory deadline.  It  is estimated
that  by 1977,  50 percent,  or  about 9,000,  of  the
municipal treatment plants will provide secondary
treatment or some  higher level required by water
quality. However, less than 40 percent of the 1977
population will be  served  at the secondary treat-
ment level or better, principally because the large
cities will  not have had  time  to  complete con-
struction.

  Failures to meet  requirements may be traced to
both  financial and  physical barriers, and the  re-
cently provided availability of the full  amount of
construction grant monies  called for by PL 92-500
will  not  wholly cure the problems. Due  to these
uncertainties,  many short-term permits were writ-
ten.  During 1975, EPA has reexamined its posture
regarding these  difficult cases. A significant effort
in modification  and reissuance of permits is  ex-
pected.
16

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                    TABLE m - 3
              NPDES PERMIT PROGRAM
                  December 31, 1975
                 States and Territories
                  (alphabetical listing)
      Approved
                               Not approved
  1. California
  2. Colorado
  3. Connecticut
  4. Delaware
  5. Georgia
  6. Hawaii
  7. Indiana
  8. Kansas
  9. Maryland
  10. Michigan
  11. Minnesota
  12. Mississippi
  13. Missouri
  14. Montana
  15. Nebraska
  16. Nevada
  17. New York
  18. North Carolina
  19. North Dakota
  20. Ohio
  21. Oregon
  22. South Carolina
  23. Vermont
  24. Virginia
  25. Washington
  26. Wisconsin
  27. Wyoming
 1. Alabama
 2. Alaska
 3. Arizona
 4. Arkansas
 5. District of Columbia
 6. Florida
 7. Guam and Trust Territories
 8. Idaho
 9. Illinois
10. Iowa
11. Kentucky
12. Louisiana
13. Maine
14. Massachusetts
15. New Hampshire
16. New Jersey
17. New Mexico
18. Oklahoma
19. Pennsylvania
20. Puerto Rico
21. Rhode Island
22. South Dakota
23. Tennessee
24. Texas
25. Utah
26. Virgin Islands
27. West Virginia
  An Opportunity for Public Involvement.—The
NPDES  provides  important opportunities for the
public to participate in permitting decisions.  Pub-
lic notices are issued  for  all permit applications,
and  if sufficient interest is shown public hearings
are held. Formal  adjudicatery hearings may also
be requested by the discharger or other parties.
  Adjudicatory requests may be denied under cer-
tain  circumstances. Issues may  be  untimely, not
subject  to  hearing or  not within the purview  of
the permit program. Also, the permitting agency
may find that the  request concerns matters that
have been or will be adequately addressed in pub-
lic hearings.
  By December 31, 1975, 1,880 adjudicatory hear-
ings  had  been requested. Of these, 458 cases were
settled prior to hearing, 52 requests  were denied,
one  was  settled  at the hearing and 1,069 requests
were still pending. Although there has been a de-
gree of  public interest, the extent  of public in-
volvement has often been disappointing.
  Current Objectives.—In  1975, NPDES priorities
were shifted, since most permits had been issued.
Compliance  monitoring and  enforcement  of the
issued permits have come to the fore as the logi-
cal successors to the past permit effort.
  In preparation for the next  round of permits,
the program  is again emphasizing increased  State
assumption of  program  responsibilities.  Federal
and  State  permit processing is continuing,  with
dischargers having the  most critical effect on wa-
ter quality receiving the  most  attention.  Permit
program areas which will  receive highest priority
in the near  future  are: reissuance  of  municipal
permits; issuance, reissuance and modification of
major and  new  source  permits, issuance of ocean
dumping permits, and preparation of environmen-
tal  impact statements  for new source permits.
Adjudicatory hearings on permits will also receive
major attention.
  Judicial  Decisions.—A recent judicial decision
calls for expansion of the EPA/State NPDES pro-
gram. This raises difficult program  and policy is-
sues which EPA, and possibly the Congress, may
have to reexamine. The District Court for the Dis-
trict of Columbia has  held  that EPA  incorrectly
exempted some  point  sources  from the NPDES
program. NRDC v.  Train, Civil Action  No.  1629-
73, 396 F.  Supp.  1393  (March 24,  1975).) Certain
feed lots, separate storm  sewer outfalls, agricul-
tural and silvicultural discharges are covered  by
the decision,  as defined in the new EPA regula-
tions. EPA is appealing this decision.
                            COMPLIANCE MONITORING
                            AND ENFORCEMENT
                              The  compliance monitoring and  enforcement
                            program  polices the EPA/State point  source con-
                            trol effort. This program assumes an  increasingly
                            central role as  source discharge requirements are
                            defined and we move into the period of implemen-
                            tation.
                              An Important State Role.—The national policy
                            favoring  increased State  program participation is
                            keenly  important in the  enforcement  area, where
                            appreciation of local circumstances may be partic-
                            ularly valuable. States with EPA-approved permit
                            programs have primary responsibility for monitor-
                            ing  and  enforcement  of the  permits they have
                            reissued  or issued  either  alone  or   jointly  with
                            EPA.  In addition,  some  States without  an EPA-
                            approved program have accepted partial  responsi-
                            bility for monitoring.  In all cases,  Federal and
                            State activity is coordinated, and EPA  maintains
                            backup enforcement authority.
                                                                                                  17

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     EPA or the States may initiate legal proceedings to abate excessive discharges. (Mining company plant on Lake Superior.)
  The National Compliance Monitoring System.—
EPA  and States have  developed and  are  imple-
menting  a national system  for compliance moni-
toring. The system integrates three agency activi-
ties:  review of  self-monitoring  reports,  facility
inspections, and maintenance of quality assurance
activities. Fair and accurate performance is essen-
tial throughout the system,  since these activities
may ultimately support enforcement proceedings.
  During  1974,  EPA/State  resource  limitations
prevented full review of all  sources. Scrutiny fo-
cussed on dischargers having the greatest poten-
tial impact on water quality.

  Mandatory self monitoring, comparable  to  the
national  income tax system in terms of individual-
ly generated reports, is established through permit
conditions.  All reports  are logged for receipt.  Fa-
cilities inspections may be prompted by violations
apparent on the face of a monitoring report or by
random  or preselected audits.  Inspections  may
include  examinations   of  production  processes,
equipment and facilities and the  taking of effluent
samples. Self monitoring report analysis is coordi-
nated with any inspection of the facility.
  Municipal facilities  inspections may also look
for areas where operations and maintenance activ-
ities  (O&M) can  be improved.  Information  gath-
ered from O&M inspections is  used to upgrade
performance.  Manpower  training  for municipal
personnel has  also  been  developed  to  improve
performance. (See Chapter IV).
  EPA  has been developing a data system to as-
sist EPA and the States in conducting and direct-
ing monitoring and  enforcement activities. Fur-
ther, a quality assurance program has been estab-
lished  to  assure  that  EPA/State and discharger-
related  laboratory and  field  activities are in con-
formance with EPA guidelines  and  regulations.
This should help assure that the data reports  are
both accurate and precise.
  Enforcement.—Enforcement  of  permits   pro-
ceeds under a variety of authorities.  Section  309
of the Act (Federal enforcement) is supplemented
by section 311  (oil and hazardous  substance spill
regulations),  307(a)  and  (b) (toxic and  pretreat-
ment effluent standards), and section 404 (dredge
and  fill requirements).  Also, the Agency is em-
powered  to take emergency action pursuant  to
section 504.
18

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  EPA and States with approved permit programs
are not the only parties with enforcement powers.
Interested citizens may  also  enforce  against the
Government  and  other  persons by commencing
civil actions  under conditions prescribed  in  sec-
tion 505.
  Enforcement action can also be initiated under
other laws.  Proceedings  begun before the enact-
ment of the  Act  and   retained  by   the  savings
clause have continued uninterrupted;  other laws,
including the  Federal Insecticide, Fungicide  and
Rodenticide Act, Safe Drinking Water Act, Ocean
Dumping Act, and Refuse Act have also entrusted
EPA and the States with enforcement  responsibil-
ities.
  In  1974 the  enforcement program  emphasized
assistance to the permit  issuance  effort, including
proceedings against sources  which failed  to file
permit applications. As permit conditions, includ-
ing construction schedules,  become fully effective
and enforceable,  EPA has  begun to  place more
emphasis on enforcing these provisions.
  In  conducting  enforcement  activities  primary
attention is directed  towards those  areas where
actions will have the  greatest beneficial impact on
water quality.  Priority  is  given to   proceeding
against the  chronic or recalcitrant violators  and
others who critically affect water quality.

DISCHARGE OF DREDGED
OR FILL MATERIALS
  The Army Corps of Engineers  is authorized  to
issue permits for the disposal of dredged or fill
materials in navigable waters and to  specify dis-
posal sites (section 404). EPA is required to de-
velop  guidelines in conjunction  with the Corps
defining procedures for site  specification and use.
  On March 27, 1975, the U.S. District Court for
the District of Columbia ruled that the responsi-
bility and authority of  the  Corps to  regulate the
discharge of dredged or fill  materials extends  to
"the waters of the United States." Therefore the
jurisdiction  of the Corp's dredge and fill  regula-
tions will be expanded in phases,  from traditional-
ly  "navigable" waters  to all waters  covered by
the FWPC Act.  The  Corps has published interim
final  regulations  with varying scopes  of  applica-
tion (Federal  Register,  July 25, 1975) for review
and public comment.
  EPA published its section 404 guidelines in  con-
junction with  the Corps,  also  in interim  final
form (Federal  Register,  September 5, 1975).  The
Legal proceedings against alleged polluters may be brought
by private complainants. (Dead and dying oysters collected
        as evidence, near New Orleans, La.)
                                                                                                 19

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                                              Figure III-l.

                               TOTAL ENFORCEMENT ACTIONS INITIATED IN 1974
        280
        240
        200
        160
        120
         80
         40
  REGION
                 I      II      III       IV      V     VI      VII      VIII      IX      X     HO
guidelines are designed to minimize or prevent the
harmful effects of the covered activities in waters
of the United  States,  including inland navigable
waters.
  A significant controversy surrounds coverage of
the inland wetlands.  Congressional  action  may
resolve  this issue.
  The proposed guidelines contain safeguards to
prevent irreversible damage to waters covered by
the guidelines. At the  same time undue restric-
tions  must not be imposed on dredge and fill oper-
ations needed  to maintain navigation, especially in
critical port and harbor areas.
  EPA  is committed to the development  and im-
plementation,  with the Corps  of Engineers  and
the States, of a realistic, manageable,  environ-
mentally-protective,  and  minimally  bureaucratic
program for  the  permitting of  the  discharge of
dredged or fill material. This will be a substantial,
ongoing program, to be carried  out largely at the
Regional and State level.
OIL AND HAZARDOUS MATERIALS
  Section 311  of the FWPCA regulates spills and
similar discharges of oil and  hazardous materials.
EPA's primary objectives  are to prevent such dis-
charges and, where they  do occur,  to minimize
their environmental and economic impact  through
containment and removal.

  EPA's spill  response, prevention  and enforce-
ment  programs further these objectives.  In  the
past year, program priority was given to response
to oil spills and development of remaining regula-
tions.  Almost all oil  regulations have  been pro-
mulgated. Four key hazardous substance  regula-
tions were proposed at the end of 1975.

  Response and Removal.—EPA shares responsi-
bility for the response and removal program with
the Coast Guard under the National  Contingency
Plan (40 CFR  1510). Activities under the Plan are
financed by a Federal Revolving Fund. Both the
Plan and the Revolving Fund provisions were re-
20

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                                            1974
                                          Figure III-2.

                    ADMINISTRATIVE ORDERS & NOTICES OF VIOLATIONS TO STATES
    150
    120
    90
    60
    30
     0
REGION
vised in  1974 to incorporate recent developments
in the spill program.

  Notwithstanding  the Revolving Fund,  dischar-
gers who spill are expected to take immediate ac-
tion themselves to  contain and remove the sub-
stance. If they fail  to do so or  need extra  assist-
ance, the plan is implemented. In either case they
are financially responsible for all removal  opera-
tions.

  EPA and  the Coast Guard provide Federal on-
scene coordinators  for  discharges to inland  and
coastal waters, respectively. Each year there are
about  13,000 oil spills,  600 spills of hazardous
substances  and  2000 spills  of  unknown  sub-
stances. The number of hazardous substances spills
is based on voluntary notification, as mandatory
reporting is not yet  required. Over the five years it
has  existed, the  Contingency Plan  has  been  in-
voked over  5,000 times,  primarily for oil spills.  A
total of $18  million  of the revolving fund has been
expended, part of  which  has  been  replenished
through  the  assessment of fines  and  reimburse-
ment from discharges for Federal clean-up activi-
ties.

  Prevention. Oil.—The major elements of the oil
spill prevention program have been implemented.
Regulations which became effective  in  January
1974 require potential sources to develop and im-
plement Oil Spill Prevention Control and Counter-
measure  (SPCC)  Plans (40 CFR  112). Regional
personnel inspect  facilities  to assure that the re-
quired plans  have been prepared  and implement-
ed. Also, if  a discharger has major or repeated
spills, its plans will be reviewed  and, if necessary,
revised.  Appropriate enforcement  action may be
taken against sources with or without plans.

  Hazardous  Substances.—Proposed  regulations
designating  hazardous substances,  determining
their removability, establishing harmful quantities
and  establishing  penalty  rates  were  published
                                                                                                21

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    Dredging operations must obtain a permit from the Corps of Engineers and meet the joint requirements of EPA and the
                                     Corps. (Lake Pontchartrain, La.)
December  30,  1975.  Final promulgation  of these
four regulations is anticipated before the  end of
CY  1977.  A supplement to  the  hazardous  sub-
stances regulations was issued  to  support  the
selection of  substances on  the designation list.
The proposed designation regulation contains  307
hazardous  substances which are subject to  regula-
tion under  section 311.
  Enforcement.—EPA's objective is to encourage
preventative  action, but  enforcement  measures
will be undertaken where necessary.  Both the fail-
ure to report spills of a harmful quantity and the
discharge  itself  are subject  to  penalties  under
Coast Guard  administrative  procedures. EPA
cites violators of the oil pollution  prevention regu-
lations. Violations  include failure  to prepare  and
implement the  required SPCC plans and failure to
revise plans as required by facilities which  contin-
ue  to  have spill problems. When non-removable
hazardous  substances are discharged in excess of
the harmful quantity, EPA may also  assess a civil
penalty.  Under  the  proposed  hazardous  sub-
stances regulations, such discharges of non-remova-
ble hazardous substances will be subject to either
of two penalty provisions. Under one, the penalty
could be potentially very high ($500,000 for fixed
facilities and $5 million for vessels). Alternatively,
a penalty of from  $500 to $5,000 per spill event
may be assessed.
   The choice of penalty options  is at the discre-
tion of the Administrator. The penalty rate regula-
tion proposes that  gross negligence on the part of
the discharger be used as the criterion for decid-
ing which penalty option should apply. Gross neg-
ligence in either causing the discharge or in dam-
age mitigation activities may result in the $500,000
or $5 million penalty assessment.  Where negli-
gence is not evident,  the  penalty will be assessed
in the range of $500 to $5,000.
   The  NPDES  and  section 311  programs both
apply to point  source dischargers.  Some  spills
may violate both  section 311  and an applicable
permit. In  other instances,  there  is the  potential
for a discharge from a fixed facility to exceed sec-
tion 311 limits for  spills but not be in violation of
permit limitations  for the substances.  EPA has
22

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               EPA's oil contingency plan regulations provide for quick response to oil spills. (New York harbor.)
proposed an exemption for hazardous substances
discharges under section 311 as long as they are
in accordance with an applicable NPDES permit.
MARINE POLLUTION
  The primary objective  of EPA's marine  pro-
gram  is to protect the quality of ocean waters by
regulating the disposal  of materials. Almost all
intentional ocean discharges, whether in the terri-
torial seas, the contigious zone or the ocean wa-
ters  beyond, are regulated  by section  402,  403,
and 404 of the  1972 Amendments of the FWPCA
(PL  92-500)  or  by the  Marine  Protection,  Re-
search  and  Sanctuaries  Act  ("Ocean  Dumping
Act") (PL  92-532 as  amended 93-254).  Sections
311 and 312 of PL 92-500 regulate the  discharge
of oil and hazardous materials and section 102 of
PL 92-532 regulates fish wastes.
  Thus, all ocean dumping is now subject to  per-
mit requirements.  Only those dumping activities
which meet environmentally protective criteria or
which  are part of  an implementation  schedule
leading  toward compliance with such criteria will
be permitted.

  A comprehensive  report  on ocean dumping,
addressing the implementation of Title  I of the
Ocean  Dumping  Act, is  submitted to Congress
annually.

Marine  Sanitation Devices
  An estimated 573,000 U.S. vessels  and an un-
known  number of foreign-flag ships may be sub-
ject to  marine discharge  standards. On  June  23
1972, EPA promulgated  a  virtual  no-discharge
standard,  with certain incentive provisions appli-
cable to existing vessels. On January 30,  1975, the
Coast Guard promulgated a regulation addressing
the design,  construction,  installation  and opera-
tion of marine sanitation devices to meet the EPA
standard.  On October 10, 1975, EPA published a
proposed  regulation  that would modify  the 1972
standard,  and on  January 29, 1976, EPA expects
                                                                                               23

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to promulgate final marine sanitation device stand-
ards early in 1976.  Responsibility for  enforcing
the standards is vested in the Coast Guard.

  In addition, the FWPCA  allows States with the
Administrator's concurrence, or the Administrator
upon  request, to  establish  strict  no-discharge
zones to protect or enhance the quality of particu-
lar  State waters.

Clean Lakes
  The FWPC  Act  authorizes  EPA  to  provide
matching grant financial  assistance to  States  to
carry out  methods  and procedures to  control
sources  of  pollution and restore the quality  of
publicly owned freshwater lakes (section 314) and
also to enter contracts with  or make grants to var-
ious persons to develop and demonstrate lake pol-
lution control methods. (Section 104(h).)
  Grants approved under the lake restoration pro-
gram  are matched by equal  amounts from  State or
local  governments. Initial Federal appropriations
were  $4 million, about  10  percent of which  has
been  earmarked for use  by EPA to  evaluate the
results  achieved. An  additional $15  million  has
been appropriated for Fiscal Year 1976.
  EPA's program is directed toward restoring the
quality  of  publicly owned  freshwater lakes that
have  been degraded  by pollution  from urban or
stormwater run-off, chemicals leached from  septic
tank fields, or run-off from  farms and fields. Such
sources are contributing an ever greater percent-
age of  the Nation's total  water  pollution  load,
since  most industrial  plants and  sewage treatment
facilities have already started  cleaning up their
discharges under  the  other EPA water pollution
control  programs.
  The lake restoration program  includes such ac-
tivities  as  diverting  run-off from  storms,  farms
and  feedlots,  diking,  controlling  sedimentation,
street cleaning and sweeping to cut pollution from
urban run-off,  dredging to remove  major deposits
from  plant decay,  constructing sediment  traps,
and promoting the growth  of beneficial plants to
dispose of excess nutrients. Grant  funds may not
be used for activities having only temporary bene-
ficial  effects,  such as  weed  cutting  or chemical
treatment to limit the growth of algae.

  Note: A series of tables indexing enforcement actions taken
under  the Federal Water Pollution Control Act Amendments
of 1972 during 1974  and 1975 will be separately printed and
distributed.
 24

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                                                                             CHAPTER  FOUR
                                                Municipal
                                                Construction
  Publicly owned treatment facilities play  an  im-
portant role in determining the quality of the Na-
tion's waterways. They handle waste-water gener-
ated by 160 million persons—76 percent  of  our
population—plus the  effluents from many indus-
tries.  By  1990, plants are  expected  to provide
sewage treatment for at least 210 million  persons.
  Cities, towns, and special service districts sup-
ply waste treatment ranging from crude to sophis-
ticated for the sewered population. To assure that
every community has adequate  treatment—sec-
ondary treatment  plus more stringent treatment
where  necessary—as rapidly  as possible, EPA
provides funds for construction to municipalities,
supports  needed  manpower training,  and  pro-
motes good operation and maintenance  practices
for new and old plants alike.

MUNICIPAL CONSTRUCTION
  The  Federal  Water Pollution Control Act  of
1956 initiated the program  of Federal grants  to
communities for waste treatment works  construc-
tion. Since 1956, EPA and  its predecessor agen-
cies have  obligated over  $14 billion for  pollution
control projects. The  total cost of these  projects,
including State  and local shares, was about  $27
billion (See Table IV-1.)
  In addition to the $18 billion for new treatment
works construction, the 1972 "Act also authorized
$2.75  billion to reimburse  communities for  the
costs of some treatment works construction com-
pleted prior  to the  Act. Subsequent legislation
added $600 million to the reimbursement  fund. As
of June 30, 1975, $1.9 billion had been appropriat-
ed for reimbursement.
  A Major State Rote.—The construction  grants
program is included in EPA's high priority effort
to transfer major responsibility for program oper-
ation from EPA to the States. The sizeable man-
power requirements of the grants program, along
 Advanced waste treatment technology is often needed  to
 meet standards in the receiving waters. (Carbon adsorption
    system. EPA-supported facility at Pomona, Calif.)
with the program's  high  dollar value  and clear
local impacts,  underline the importance of this
transfer.
  EPA supports  an  amendment to  the  1972 Act
which would encourage delegation of grant func-
tions to capable  States by  allowing them to re-
serve up to two  percent of  their construction al-
lotments  to finance  administration  of the grants
program.
  EPA may delegate to States with  the necessary
authority, responsibility, and capability a substan-
tial portion of the construction grants program. At
a minimum, EPA must carry out the provisions of
the  National   Environmental  Protection  Act
                                                                                          25

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                                             TABLE IV-I
                                      MUNICIPAL CONSTRUCTION
                                          DECEMBER 31, 1975

                          Annual Authorizations, Allocations, Obligations & Expenditures
Fiscal
years
1957 	
1958 	
1959 	
1960 	
1961 	
1962 	
1963 	
1964 	
1965 	
1966 	
1967 	
1968 	
1969 	
1970 	
1971 	
1972 	
1973 	
1974 	
1975 	
1976 	
Transition 	
1977 	

Authorizations
	 $50,000,000
	 50,000,000
	 50,000,000
	 50,000,000
	 50,000,000
	 80,000,000
	 90,000,000
	 100,000,000
	 100,000,000
	 150,000,000
	 150,000,000
	 450,000,000
	 700,000,000
	 1,000,000,000
	 1,250,000,000
	 2,000,000,000
	 7,750,000,0001
	 6,000,000,000
	 7,600,000,0003
—
.... —
—
Actual
allocations
$50,000,000
45,657,000
46,816,000
46,101,000
45,645,260
80,000,000
90,000,000
90,000,000
90,000,000
121,000,000
150,000,000
203,000,000
214,000,000
800,000,000
1,000,000,000
2,000,000,000
3,900,000,0002
3,000,000,000
4,000,000,000
9,000,000,0004
—
—
Fiscal year
obligations
$50,000,000
45,657,000
46,816,000
46,101,000
45,645,260
80,000,000
90,000,000
89,642,425
88,225,123
120,946,373
150,000,000
203,000,000
214,000,000
437,635,609
1,167,505,913
872,462,638
2,926,230,179
2,669,119,938
4,149,461,347
4,500,000,000*
1,000,000,000*
6,400,000,000*
Actual
outlays
$844,000
16,844,000
36,429,000
40,295,000
44,085,000
42,103,000
51,738,000
66,432,000
69,755,000
81,479,000
84,476,000
122,109,000
134,530,000
176,377,000
478,366,000
413,407,888
684,400,479
1,553,421,169
1,937,574,981
2,350,000,000*
600,000,000*
3,770,000,000*
 'Includes $2.75 billion for reimbursement under section 206.
 Includes $1.9 billion appropriated for reimbursement.
 Includes $600 million for reimbursement (P.L. 93-207).
 "Release of $9.0 billion in FY73/74/75 authorizations.
 *Estimate.
(NEPA)  and  other mandatory  Federal  require-
ments, monitor  and audit grants, provide overall
management,  make formal  approvals of  grants,
and distribute funds. The states can assume some
or all other grant-related functions.
  The construction  grants program for treatment
plants and sanitary sewers has five objectives:

  • To manage  the  program  in an efficient man-
    ner with  sufficient resources to  ensure that
    the effluent limitations  and the water quality
    standards required under  the Act are achieved
    at the least  cost and in the minimum possible
    time.
  • To assure that planned facilities are environ-
    mentally sound.
  • To safeguard  the integrity of the  program by
    detecting and deterring fraud and other irreg-
    ularities  in  the  awarding of grants and con-
    struction of the facilities.
  • To maintain reliable  and efficient operation
    and maintenance at all plants.
  • To transfer from EPA to the States the basic
    responsibility for the operation  of  the pro-
    gram.
  Three-step  Program.—EPA uses  a  three-step
grants program  to provide adequate planning, de-
sign, and  construction. In  general, each step must
be completed and approved before a grant can be
made for  the  next step. Step 1,  Facility Planning,
governs the municipal facility investment  decision
at the  local level. Its goal  is selection of the most
cost-effective and  environmentally  sound  waste
management alternative for the planning area. An
environmental review, resulting in a negative dec-
laration or an  environmental  impact  statement,
must be completed before Step  2 begins. Step  2
consists of preparation of  detailed plans and spec-
ifications,  and Step 3 is actual construction of the
project.
26

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  Each construction  grant  represents  a lengthy
effort by the grant applicant and EPA. Comple-
tion of a Step 1 Facility Plan may take six months
to a  year or more, and preparation of plans and
specs under Step 2 can take another year. Both of
these steps  must  be  completed before  construc-
tion can begin.
  The Soaring  Needs.—Since 1969,  EPA  has
conducted  several surveys of  municipal facilities
to predict  the costs  of  needed treatment  works
construction in each State. The 1974 Needs Survey
was the first survey of projected needs associated
with the  1983 goals of the Act as well as the 19771
78 requirements—for  many treatment plants, sec-
ondary treatment  will  satisfy the  1983  goals, but
special factors including more  strict water quality
standards may toughen the  requirements in some
cases. (See Chapter I.) In addition, many  of  the
reporting constraints  on  the  1973  Needs  Survey
were  removed  in  1974, which   broadened  its
scope.
  The 1974 Survey, despite  certain corrections by
EPA, reported that meeting the 1983 goals  of  the
Act would cost the staggering sum of $342 billion.
In contrast, the  1973 Needs Survey, just one year
earlier, projected  total needs of only $60 billion.
A major reason for this dramatic leap is the inclu-
sion in the 1974  Survey of a new category of
needs—treatment  and/or  control of stormwater—
totalling  $235 billion. Also, for the 1974 Survey,
EPA accepted  estimates of  the  cost of meeting
the 1983 goals, whereas the  1973  Survey was  de-
signed to show  needs for meeting only the 1977
goals,  and such  needs were to be reported only if
they were documented.
  EPA does not consider the needs estimates for
the new  stormwater category to be useful either
as an accurate indicator of long-term requirements
or for allocating grants among the States. Differ-
ent States  used different  assumptions and  tech-
niques to  estimate  their  stormwater  abatement
needs. In some States, the estimate included not
only the  costs of  controlling existing stormwater
discharges, but also the  costs  of providing new
storm sewers and stormwater treatment  facilities
in certain areas currently lacking storm sewers.

  However, even when needs are limited  to the
so-called traditional eligibilities, treatment plants
and  interceptor  sewers, the totals are immense.
The  1974 Survey  for these components reported a
figure of $46 billion. This figure represents a $10
billion, or 28 percent,  increase over the preceding
year's estimate. The increase resulted partly from
a new awareness  that  future water quality stand-
ards may be more stringent than the standards on
which the  1973 Survey was based. The  presence
in the 1974 Survey of more needs for advanced
waste treatment  in  relation to simple secondary
treatment supports this explanation.

   Awarding  Grants  for  Priority Actions.—The
needs surveys are  conducted  to determine the
extent of  the  pollution  problem  and to  enable
Congress to  allocate  Federal  construction funds
among the States in proportion to the  size of their
municipal treatment problems.  Of the $18 billion
authorized for  new  treatment works construction
in the FWPCA of 1972, over $8.2 billion  had been
obligated by December,  1975. In  FY  1976, EPA
plans to award  about 4,000 grants for  planning,
design and construction,  totaling  about  $4.4 bil-
lion.
                                                                       TABLE IV-2
                                                                 SUMMARY OF CONTRACT
                                                           AUTHORITY GRANT ACTIVITY UNDER
                                                                       P.L. 92-500
  Disposal of sludge from municipal waste treatment plants is
  an increasing problem. (Chicago's sludge transported for
          experimental use on Illinois cornfields.)
Fiscal


1973 	
1974 	
1975 	
1976 	
Transition
1977 	
Authorization


5,000,000
6,000,000
7,600,000
—
—
—
Allotment

(THOUSANDS
2,000,000
3,000,000
4,000,000
9,000,000
—
—
Obligations

-$)
1,591,000
1,384,000
3,616,000*
4,400,000*
1,000,000*
6,000,000*
Expenditures


...
160,000
880,000
1,467,000*
490,000*
3,370,000*
  *Estimate
                                                                                                 27

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                 TABLE IV-3
 STATUS OF WWT CONSTRUCTION GRANT FUNDS
               UNDER PL 92-500
           AS OF DECEMBER 31, 1975
Region State
1 Conn.
Mass.
Maine
N.H.
R. I.
Vt.
Region totals
2 N.J.
N.Y.
P.R.
V.I.
Region totals
3 D.C.
Del.
Md.
Pa.
Va.
W. Va.
Region totals
4 Ala.
Fla.
Ga.
Ky.
Miss.
N.C.
S.C.
Tenn.
Region totals
5 111.
Ind.
Mich.
Minn.
Ohio
Wis.
Region totals
6 Ark.
La.
N. Mex.
Okla.
Tex.
Region totals
7 Iowa
Kans.
Mo.
Neb.
Region totals
8 Colo.
Mont.
N. Dak.
S. Dak.
Utah
Wyo.
Region totals
9 Ariz.
Calif.
Guam
Hawaii
Nev.
Trust
Territories
American
Samoa
Region totals
10 Alaska
Idaho
Ore.
Wash.
Region Totals
National Totals
Fiscal Year 1973, 1974,
Allotments
308,684,700
573,905,000
153,097,200
153,817,300
90,908,600
45,397,400
1,325,810,200
1,300,686,700
2,089,647,700
169,968,400
15,390,700
3,575,693,500
146,295,800
111,035,200
564,743,400
992,799,000
496,196,400
122,150,600
2,433,220,400
95,821,100
691,686,500
242,575,800
188,609,400
80,756,900
226,984,200
170,538,900
213,748,200
1,910,721,000
1,136,455,100
483,619,900
1,213,699,300
337,866,800
979,291,100
284,762,800
4,435,695,000
81,362,800
154,404,100
36,265,400
134,336,100
420,340,100
826,708,500
197,194,700
112,696,700
314,797,600
77,973,500
702,662,500
89,874,200
28,222,800
12,013,100
17,736,800
44,996,100
8,320,100
201,163,100
43,259,200
1,894,076,900
12,931,200
109,558,300
64,920,400

5,087,100

1,554,900
2,131,388,000
51,569,600
38,002,500
154,189,600
213,176,100
456,937,800
18,000,000,000
1975 and 1976
Obligations
119,768,607
248,037,826
123,786,074
75,683,301
53,461,612
15,265,585
636,003,005
662,087,945
773,747,685
57,685,014
5,024,250
1,498,544,894
112,449,640
46,723,995
247,757,280
409,982,341
271,382,613
41,320,532
1,129,616,401
51,418,104
426,027,809
74,896,286
86,112,818
39,971,008
91,719,127
61,748,223
81,777,569
913,670,944
484,895,773
190,574,247
537,640,712
170,894,947
458,605,770
141,318,507
1,983,929,956
40,288,711
71,096,954
16,004,763
41,370,200
225,929,191
394,689,819
92,282,799
34,999,109
174,553,477
38,834,142
340,669,527
56,026,536
18,321,755
7,736,871
8,130,107
29,849,895
4,507,152
124,572,316
33,394,146
761,012,076
9,883,352
93,148,350
55,958,345

2,957,555

240,000
956,593,824
32,588,274
22,135,371
93,309,072
118,711,350
266,744,067
8,245,034,753
Combined
Unobligated
188,916,093
325,867,174
29,311,126
78,133,999
37,446,988
30,131,815

638,598,755
1,315,900,015
112,283,386
10,366,450

33,846,160
64,311,205
316,986,120
582,816,659
224,813,787
80,830,068

44,402,996
265,658,691
167,679,514
102,496,582
40,785,892
135,265,073
108,790,677
131,970,631

651,559,327
293,045,653
676,058,588
166,971,853
520,685,330
143,444,293

41,074,089
83,307,146
20,260,637
92,965,900
194,410,909

104,911,901
77,697,591
140,244,123
39,139,358

33,847,664
9,901,045
4,276,229
9,606,693
15,146,205
3,812,948

9,865,054
1,133,064,824
3,047,848
16,409,950
8,962,055

2,129,545

1,314,900

18,931,326
15,867,129
60,880,528
94,464,750


  Appropriate project priorities  are  an important
part of  the program,  to  maximize the public ex-
penditure's impact on water  quality  and public
health hazards.  Each year, the States  develop
municipal project priority lists. Construction grant
awards go to identified priority needs,  where they
can  bring  about  direct  improvements in  water
quality.
  EPA  has  set  the goal of obligating the  entire
$18 billion authorization  by the  end of FY 1977,
to assure that these funds are promptly  used to
attack the problem of  municipal  pollution. To
achieve this goal,  the rate of obligation of availa-
ble grant funds will  have to be  accellerated to
about $450 million a month, and  vigorous, skillful,
and efficient grants management will be required.
The Administrator has established the principle of
having  a single EPA project manager for  each
grant during  the  entire three-step  process,  to
make sure that grants are processed  carefully and
smoothly. Major commitments of Federal and al-
ready strained  State resources will  be needed if
the  grant  objectives are  to  be  fully  realized.
Greater involvement of State personnel is particu-
larly important.
  The Agency recognizes  that  the  pressures to
accelerate the grants program could lead  to great
inefficiencies in  the way  the remaining $12 billion
is spent. However, by maintaining proper priori-
ties, by promoting better grants  management, and
by  delegating authority to  the States, EPA is in-
suring against  both financial  waste and  environ-
mental degradation.

TRAINING FOR
ASSOCIATED PERSONNEL
   The rapidly-increasing rate of wastewater treat-
ment  plant  construction will seriously  magnify
current  shortages  of  adequately-trained  operation
and maintenance  personnel. A well-planned and
executed manpower  planning,  development and
training program is therefore a key factor in insur-
ing effective use  of  the billions of dollars  being
invested in treatment works.
   Estimates  vary on the demand for and  supply
of persons to operate  and  maintain wastewater
treatment works.  Proposed studies should provide
much more accurate information on  which to base
employment and training needs projections.
   One  limited  survey conducted by EPA in  1974
and based on recommended staffing levels by size
and type  of plant indicated that approximately
85,000 persons were needed for optimal operation
28

-------
and  maintenance of then-existing facilities. This
estimated need was somewhat  higher  than posi-
tions actually budgeted by local governments, and
more than  25 percent  above the estimated  67,000
full  and part-time workers  engaged  in  operation
and  maintenance activities  for  municipal plants.
This numerical  shortage is complicated by the fact
that  a number of inadequately-trained and inexpe-
rienced personnel appear to  be filling positions.
  In an effort to  alleviate this problem and assist
the States  to achieve  self-sufficiency,  EPA con-
ducted eight instructor development courses dur-
ing 1975. A total of 117  persons, from 24 States,
were trained as instructors in these intensive, one-
week programs. Over three-fourths of those were
trained  in the area  of  wastewater treatment.  The
remainder  received instruction  in other  environ-
mental  fields,   such  as pesticides.   Additional
courses are scheduled through 1976.

Programs to Meet Needs
  A  number of programs, not all under the Envi-
ronmental  Protection  Agency,  are  intended to
help meet these needs.
  Sections  109-112.—The activities  of EPA under
sections 109-112 of  the Act  are  keyed to  develop-
ment of undergraduate training  programs and the
construction of state training  facilities. EPA pro-
vides curriculum development program guidance
and support for States  and educational institutions
desiring to  offer  undergraduate courses  in treat-
ment plant operations and maintenance.  Since
Fiscal year 1973, EPA has awarded under section
109(a)  approximately $331,000 annually  to assist
7-10 institutions per year. These grants have sup-
ported curriculum and  pilot program development,
faculty  training,  student support  and  part-time
student employment within treatment  facilities.
  Under section 109(b), as  of December 1975
EPA had  made  three grant awards  of  $250,000
each for the construction of State  training facili-
ties to  train operation and maintenance  personnel.
Other States have indicated  interest in developing
a State  training center. These training centers are
funded  out of the  construction grant funds allo-
cated to a  State  under section 205.
  EPA  has made no  grants  under  section  111,
award of scholarships for undergraduate study.
  Section 104(g)(l).—EPA activities under section
104  of  the Act  represent the  major portion of
EPA's  investment in attempting to assist  States
and local  governments  meet their needs  for ade-
quately-trained operations and  maintenance per-
sonnel.

  In FY 75, EPA awarded $1.1 million in grants
to the States  and training institutions  under sec-
tion 104  (g)(l)  to  support operator training.  In
addition, States  receiving grants under section  106
in FY 75 budgeted  approximately $3  million  for
training purposes, including training for treatment
works operations and maintenance.

  Section   104(g)(3).—During  FY  75,   section
104(g)(3)(A) training grants awarded to  universi-
ties in support of post graduate training amounted
to $1.8 million.  This program supported  640 pro-
fessional trainees at 52  universities. Over the past
four years, slightly  more than one-third of stu-
dents supported by  this program  initially  became
employees of Federal,  State, and  local  govern-
ments. (See Tables  IV-4, IV-5.) State  and Local
Fellowships awarded  under  section  104(g)(3)(B)
amounted to $344,000 in FY 75 and supported  74
fellowships for undergraduate and graduate  train-
ing.  The  same  amount will  be awarded in  FY
1976, to assist  about  55-60  trainees.  No awards
are planned under this section after FY 76.
                  TABLE IV-4
      SUPPORT FOR POSTGRADUATE TRAINING

              (Section 104(g)(3) Program)
Fiscal
year
1962
1963 	
1964
1965 	
1966 . ..
1967 	
1968
1969 . ...
1970
1971
1972 .. .
1973 	
1974 	
1975
1976 	
1977 	

104(g)(3)(A)
Training Training
appropriation awards
(thousands) to universities
$700
1,100
2,000
2,000
2,500
2,910
3,365
3,300
3,800
4,565
4,650**
2,800
2,770
2,105
1,200
None*
23
35
54
57
65
71
84
79
88
91
103
87
73
52
33
None*
Trainees
supported
83
177
291
364
391
509
633
792
1,243
1,295
962
845
640
425
None
104(g)(3)(B)
Fellowships
appropriation Fellowship
(thousands) awardees
$100
300
474
617
710
650
633
600
600
600
600
250
344*
344*
7
25
45
75
101
113
103
113
91
105
108
105
51
29*
53*
7
 *Change from Research Fellows to State and Local Fellowships
 **$! ,200 of FY 72 funds supplied in early FY 1973
 Source: EPA Records
                                                                                                29

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                   TABLE IV-5
    INITIAL EMPLOYER OF PERSONS SUPPORTED BY
            TRAINING APPROPRIATIONS
                  (104(g)(3)(A))

                   In percent
     Employer
                      1972
  1975
(estimated)
Government 	
Federal 	 	

Consultant firms
Industries

unknown
43.8
25.3
18 5
32 0
9 2
14 9

33.0
11.9
21 1
39 0
11 0
17 0

38 1
14.3
23 8
36 8
9 5
15 6

360
10.7
25 3
34 8
90
20 2

  Source: EPA sample of universities receiving grants
  Other Federal Agencies' Programs.—EPA  has
also  attempted to impact  other  Federal  human
resource  development  programs which could  be
directed to help meet the needs for qualified per-
sonnel in  the  Water Pollution Control  Programs.
Primary among these are the public employment
and training programs  under the Comprehensive
Employment and Training  Act of 1973 (CETA),
and the Vocational Technical Training Programs
under  the Federal/State  Vocational  Education
System.

  CETA provides primarily for  entry-level train-
ing of unemployed persons and for upgrade train-
ing. Information currently available to  EPA indi-
cates that over $81  million  has already been allo-
cated by Prime Sponsors for CETA employment
and training in environmental occupations. A sub-
stantial percentage of this investment was direct-
ed toward the employment and  training of 2,187
persons in the water and wastewater fields.

  In addition,  EPA has worked with the Office of
Education (HEW)  in  an  effort  to  develop  and
strengthen relationships between State pollution
control  agencies  and State vocational education
systems.  These systems,  if  adequately  financed
and  staffed, can  provide the needed training  for
operations and maintenance personnel, and repre-
sent one element of a  long-term solution to train-
ing needs. An  EPA-OE  interagency  agreement
will  formalize the Federal agencies' roles in  en-
couraging mutual cooperation in the State agen-
cies.
The State Manpower Planning Response
  Adequate  manpower  planning  capability  in
State and local water pollution control agencies is
an important part of  the establishment of  State
and local  self-sufficiency in water  quality pro-
grams, and a major EPA goal.  Although there is
wide variation among States,  on the average pres-
ent manpower planning capability appears to  be
only about 30 percent  of the needed, or optimal,
level.  EPA has encouraged the  use of section  106
grants  to  State water  pollution control agencies
for manpower planning  positions. During Fiscal
Year 1974, EPA trained  more than  100  State and
local government  personnel in manpower planning
for waste treatment works.
  A recent Memorandum of Agreement between
the U.S. Department of Labor and  EPA recom-
mended that  if a State or local pollution control
agency did not  possess the manpower  planning
function, CETA Prime Sponsors should give con-
sideration to  the establishment  of an environmen-
tal manpower planning function within the Prime
Sponsor staff.
  As  manpower  planning becomes  better estab-
lished  within  State and local water pollution con-
trol agencies, these agencies  should encourage
and support  local efforts to provide for  optimal
treatment  plant   staffing  and appropriate  salary
scales  for persons engaged in waste treatment.

SLUDGE DISPOSAL
  One of the most perplexing problems in waste-
water  treatment concerns disposal of the resultant
sludges. Approximately  5  million  dry tons of
sludge  are generated   annually  from  municipal
treatment  works, and  the  amount  continues to
increase. Further complicating disposal will be the
change in  sludge composition.  As more stringent
treatment techniques  are increasingly employed,
sludges will  contain a wider range  of types  and
greater concentrations  of toxic  substances such as
heavy metals.
   Most popular  disposal methods—ocean dump-
ing, incineration,  land disposal—all have uncertain
or negative environmental impacts associated with
them.  Ocean dumping has  been constrained by
recent legislation  (see   Chapter III),  and  the
amount of sludge dumped in oceans is expected
to decline. Incineration  consumes a considerable
amount of energy and  may contribute to air pollu-
tion in some areas.  Land disposal  is inhibited in
some  locations by citizens'  attitudes or legal re-
strictions.
30

-------
  EPA Actions.—The Agency currently is prepar-
ing a technical  bulletin to  assist in evaluating
sludge-disposal  related  aspects   of  wastewater
treatment works grant applications, and  has pub-
lished a contemporary review of  sludge process-
ing technology. In addition, the Agency has estab-
lished a  Residual  Sludge Working Group whose
mission is to  coordinate Agency  policy develop-
ment, program planning, and implementation for
residual sludges  which include municipal, industri-
al,  and pollution control sludges.  The major out-
put of this group will be a strategy document for
the short  and long term management  of residual
sludges. The strategy will suggest Agency policy,
identify ongoing  programs, and  define gaps  and
needs for  future research.
  As  standards and regulations  published  under
recent environmental legislation begin to close off
water as a disposal medium, municipal sludge dis-
posers can  be expected  to  turn increasingly to
land disposal  as  a means  of solving their sludge
problems. The need for technical information and
regulations for land disposal will become increas-
ingly more acute.
                                                                                                31

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                                                                            CHAPTER  FIVE
                                                Efficiency  of
                                                Treatment
                                                Works
  EPA and the States conduct periodic operation
and maintenance (O&M) inspections  and evalua-
tions of existing wastewater  treatment facilities.
These inspections are conducted primarily to as-
sure compliance with permit and grant conditions
on facilities constructed with Federal grant funds.
The resulting data are  used to  develop perform-
ance  summaries and  technical  documentation.
Evaluations  of publicly owned treatment works
(POTW) performance, compared with their design
efficiencies, and other related data serve  the fol-
lowing purposes:
  • They provide information to agencies respon-
    sible for the  POTWs.
  • They assist planning agencies to make  deci-
    sions  on treatment works  construction  or
    upgrading.
  • They help Federal  and  State program person-
    nel  to  formulate monitoring  and assistance
    programs.
  This survey, required by  Section 210 of the
Act, is derived from  O&M inspection reports dur-
ing 1973-1974.  It  summarizes  the  operational
status as of the end of 1974 of facilities construct-
ed with Federal assistance. Preliminary results for
1975 are  reported at the end of  this chapter. A
more complete report for  1975  will  be  published
during 1976.

SAMPLE DESCRIPTION
AND METHODOLOGY
  The results of 960  inspections conducted during
calendar years 1973  and 1974 were received and
stored in the same way  as in previous years, 1 but
  'Clean Water: Report to Congress-1974, p. 55

32
the analysis of the data has been improved in this
year's  report in several  ways. More complete
sample statistics for removal efficiencies were cal-
culated, performance levels and distributions were
plotted, and indices  of design versus  actual  per-
formance were used to allow more direct compar-
isons among all plant types.

  The  inspection reports  in the final  survey are
divided into the following groups (Tables  V-l and
V-2):
                                       No. of
                                        Plants
Group A—Records with enough design and operational
   data to allow comparisons	 386
Group B—records without operational performance
   data 	484
       Records disqualified for lack of design
   data 	 84
       Total 	954

  The  plants in Group A represent waste treat-
ment processes of all sizes and  types.  The sample
contains records from 38 States, with as  few  as
one coming from one State  and as many as  78
from another; the median  is 15 records per State.
  The  plants in Group  B also represent a full
range of treatment process sizes and  types.  This
group  contains records from  40 States, with just
one coming from each of three States and a  total
of 52 from one State at  the other extreme. The
median is ten records per  State.
  The  largest number of plants in Group B (no
operating data)  were  lagoons or   stabilization
ponds, usually smaller than 1 mgd. Lagoons tend-
ed to fall into Group B because (1) the States of-
ten require no testing at lagoons; (2)  lagoons are
seldom heavily staffed and staff personnel are of-
ten untrained;  and (3)  lagoons often  have  no
effluent, so that no testing is needed.

-------
                   TABLE V-l
NUMBER OF MUNICIPAL TREATMENT PLANTS IN SUR-
                  VEY GROUP A

Type of process

Lagoons 	
Trickling filters

Total
Percent

"Million gallons per da
Class
1
(15 +
mgd')
.. 7

. 6
8
21
5.4

y
Class
2
(5-15
mgd)
10

6
20
36
9.3


Class
3
(1-5
mgd)
10
1
60
61
132
34.2


Class
4
(0-1
mgd)
12
16
53
107
188
48.6


Class
5
(un-
knowi
_
5
1
4
10
7 5



i) Total
39
22
126
199
386
100.0



Percent
10.1
5.7
32.6
51.6
100.0
100.0


                   TABLE V-2
NUMBER  OF MUNICIPAL TREATMENT PLANTS WITH
     INSUFFICIENT OPERATIONAL DATA-GROUP B
Class Class Class
1 2 3
(15+ (5-15 (1-5
Type of process
Primary 	
Lagoons 	
Trickling filters 	
Activated sludge . .
Total
Percent

mgd*) mgd)
1


.. —
]
2

6
1
2
2
11
2.3
mgd)
17
12
23
17
69
14.3
Class
4
(0-1
Class 5
mgd) (unknown) Total
28
165
44
119
356
73.5
3
29
4
11
47
9.7
55
207
73
149
484
100.1
Percent
11 3
42 8
15 1
30.8
100 0
100.0
                                                    •Million gallons per day
GROUP A PLANT PERFORMANCE
  As in previous years, plant operational daja col-
lected during inspections were analyzed for 5-day
biochemical oxygen  demand (BODs)  and total
suspended  solids (TSS)  removals.  The  perform-
ance of Group A plants with respect to these  pa-
rameters  is reflected in two  measures:  (1) devia-
tions from design parameters  for BODs and TSS
removal;  and (2)  comparison of actual effluent
quality with the current secondary treatment defi-
nition.  Additional information  on removal  BODs
and TSS efficiencies by size and type of treatment
plant is  also presented.
  In the analysis, it  was found useful to classify
the plants based upon  their performance record.
    Good Plant performance requires constant attention to all aspects of plant operation, from highly complex operational con-
                         trol procedures to routine equipment cleaning and maintenance.
                                                                                               33

-------
Throughout this  section, the following classifica-
tions are used:
  S—Satisfactory
  U—Unsatisfactory but marginal.
  P—Poor.

Deviation from Design
  Section 210  specifically requires a comparison
of actual  performance of plants with their design
specifications.  For  this  reason,  TSS  and  BODs
removals  have been converted from straight  per-
centages to indices  of deviation from  design  per-
formance. This method  makes it  possible to com-
pare the performance of plants over a wide range
of design criteria to  arrive at more direct compari-
sons among the  various types and sizes of treat-
ment  facilities. Table V-3  presents results from
the analysis of performance for  plants  in Group
A.
  Within  Group  A, roughly  half  of  the  plants
were operating at or above  their  design specifica-
tions. Only  about 20% of the plants fell more than
ten percentage points  below  design  levels  for
BOD and/or TSS. In terms of achieving  design
efficiencies,  activated   sludge  plants  performed
best in BODs removal, with 73% performing well
and only  10%  performing poorly,  as against 60%
and 19%  for all of Group A.  For TSS, activated
sludge plant performance closely paralleled over-
all Group A performance. Primary plants exhibit-
ed the  best TSS performance, 60% performing
well and 31% performing poorly.
  Discounting  lagoons,  of which there were only
28, trickling filter  plants had the poorest perform-
ance  record. Only 45% and 46% operated  within
design specifications for BOD5 and  TSS  respec-
tively. Here again, however, unsatisfactory plants
were  as  often  marginal  as poor, indicating that a
substantial percentage could be brought to accept-
able levels by increased attention to  operation and
maintenance activities.  In general,  all types  of
plants appeared to  have more trouble with TSS
removal than with BOD5 removal.
  While  the number of  large plants (over 5 mgd)
included  in the  survey  sample  was  relatively
                                             TABLE V-3

                    DISTRIBUTION OF GROUP A PLANTS BY TYPE, SIZE, AND PERFORMANCE
                Primary
                                        Lagoons
                                                            Trickling filter
                                                                                 Activated sludge
                                                                                                  Total
         Class Class Class Class Class    Class Class Class Class Class     Class Class Class Class  Class      Class Class Class Class  Class
           12345      12345       12345        12345
           15  (5-15  (1-5 (o-l  (un-    (15+ (5-15 (1-5 (o-l (un-     (15+ (5-15 (1-5  (0-1  (un-      (15+ 5-15 (1-5  (o-l  (un-
         mgd* mgd) mgd) mgd) known) All mgd*) mgd)* mgd) mgd) known) All  mgd) mgd) mgd) mgd) known) All  mgd*) mgd) mgd) mgd) known) All


8
£
1
£
1





1
i
o
t
£
c/1
£

Sat.
(S)

Unsat.
(U)

Poor
(P)
Sat.
(S)
Unsat.
(s)
Poor
(P)


No.
Data
Total

4757


1131


3223

5467

- 3 1 4

322-



1 1
8 10 10 11

- 23 - - - 9 1 10 3 2 25 27 - 57 2 9 41 88 1 141 231


- 6 - - 1 6 3 10 3 2 17 11 1 34 1 7 9 14 1 32 82


- 10 - - 1 5 2 8 - 2 17 16 - 35 4 4 6 5 1 20 73

- 22 - - - 1 1 2 3 1 21. 22 - 47 1 7 27 49 1 85 156

- 8 - - - 2 - 2 2 1 14 9 - 26 1 4 13 18 - 36 72

- 7 - - - 1 - 1 - 3 15 12 - 30 5 7 10 15 2 39 77



2 - - 2 16 5 23 1 1 9 11 1 23 - 2 6 25 - 33 81
39 - 2 20 6 28 6 6 59 54 1 126 7 20 56 107 3 193 386
Million gallons per day
34

-------
small,  there  does seem to  be a pattern  of  poorer
performance by  these  larger plants.  Among acti-
vated sludge and trickling filter plants, only slight-
ly over 40% of  the large  facilities exhibited ac-
ceptable BODs removals as against 64%  of the
smaller plants. Only in the case of primary facili-
ties did large plants perform as well as the  sample
population in general.  As with  the smaller facili-
ties, large plants generally  were less  successful in
meeting TSS design criteria. By this latter  meas-
ure, activated sludge plants operated  most poorly,
with only 32% of plants over 5 mgd operating sat-
isfactorily.
  Federal law, through NPDES permits, requires high quality
  effluent. This can only be achieved  through cooperation
  among Federal, State, and local agencies  concerned with
             improving plant performance.
Removal Efficiencies Summary
  Basic  removal  efficiency,  presented as  a per-
centage  reduction of pollutants  coming  into the
plant,  shows  the  plant's performance in absolute
terms, independent of its design efficiency.  On the
average all Group A plants had  a BODs removal
efficiency of 80% and a TSS efficiency of 79%.  A
summary of sample statistics on  removal efficien-
cies is shown in Table  V-4. Figures V-l and V-2
show the distribution of plant  performance in re-
lation to the measures presented  in the table.
                    TABLE V-4
STATISTICAL  SUMMARY OF BOD AND TSS REMOVAL
                  EFFICIENCIES
                                                                              Percent removal
                                                                  Type
                                                                  plant
                                            Number
                                    Standard   of plants
                             Mean    deviation   m sample


BOD

Efficiency




Suspended
Solids

Efficiency





Primary
Lagoons
Trickling
filter
Activated
sludge
All
plants
Primary
Lagoons
Trickling
filter
Activated
sludge
All
plants


35 39
— 81

84 81

92 89

80
56 55
	 Insufficient cases
82 79

89 83

79
1974
Figurr V-l
18.0
9.2

14.2

10.2

19.7
18.1

14.7

18.0

19.1


39
28

126

193

386
42
8
108

163

321


                                                          100
                                                     CUMULA- 80
                                                     TIVE FRE
                                                     QUENCY
                                                     (PO
                                                      E F
                                                      RP
                                                      C L
                                                      E A
                                                      N N
                                                      TT
                                                           70
                                                           50
                     BOD5 REMOVAL EFFICIENCY
                     (IN PERCENT REMOVAL)
                                                                                                    35

-------
                            1974
                          Figure V-2.
CUMULA-
TIVE FRE.
QUENCY
IP O
E f
R L
C A
E N
N T
T S)
               20
                                         90   100
                    TSS REMOVAL EFFICIENCY
                    (IN PERCENT REMOVAL)
  Compliance With
  Secondary Treatment Requirements
    Comparing the efficiency of plants to their own
  design  standards is an effective measure  for de-
  sign efficiency, but it does not indicate compliance
  or noncompliance  with Federal secondary  treat-
  ment requirements. Currently, these requirements
  for BOD5 and TSS are as follows:

    • Not  more than 30 mg/1 for either parameter
      where   influent  concentrations are  greater
      than 200 mg/1  or;
    • Not  less than 85% removal for plants  with
      influent concentrations less than 200 mg/1.
    This  section reviews compliance with  the sec-
  ondary treatment requirement for those  trickling
  filter and  activated  sludge  plants where   both
  BODs and TSS data were  available. As in  previous
  sections,  a  satisfactory classification of "S" was
  assigned  only if both BODs and TSS  removals
  were within the  relevant limitations. If either or
  both measures fell  between 30 and 40 mg/1 or 75%
  and 85%  removal a "U" (unsatisfactory but  mar-
  ginal) classification was assigned. All others were
  classified "p" (poor).  Under this definition,  some
  42% of the  plants  were satisfactory; the  remain-
  der were unsatisfactory with the greater  number
  falling  in the poor performance category. (Table
  V-5.)
                   TABLE V-S
POTW  COMPLIANCE WITH SECONDARY STANDARDS
                FOR BOD AND TSS
                                                              Trickling
                                                               filter
                   Activated
                    sludge
                                                                                       Both
        Number       Number       Number
         plants Percent  plants  Percent  plants   Percent
S
U
p
Total
27
28
53
108
25
26
49
100
88
31
44
163
54
19
27
100
115
59
97
271
42
22
36
100
OPERATIONAL DEFICIENCIES
GROUPS A AND B
  Satisfactory  operation  and maintenance  of  a
publicly owned treatment works is critical to the
plant's overall performance.  General data on op-
eration and maintenance  problems and deficien-
cies  for plants in Groups A and B  is shown in
Table V-6. Major  problems  include inadequate
laboratory  testing, deficient management practices
and  the incidence of  substantial  deficiencies re-
quiring follow-up action.  While differences  were
not statistically  significant, the  data  trend shows
generally  that  the  satisfactory  Group A plants
have  lower incidence of  operation  and mainte-
nance problems than the  unsatisfactory Group A
plants and  the Group B plants.

  Laboratory testing, records keeping, and report-
ing are  major problems,  particularly in Group B
plants. From the plant size and type distribution
for Group  B (Table V-2), it is  apparent that the
laboratory  testing and reporting  failure  remains
predominantly a characteristic of the small plants,
especially  primary treatment plants and  lagoons.
Many of these plants  do  not have the equipment
or trained personnel  to  conduct the necessary
laboratory  analyses, and in many  cases they have
not been required to report test results.

  Only  29%  of the  Group B plants showed any
laboratory  analysis at  all. Where lab analysis was
indicated,  most  showed  only  dissolved  oxygen,
chlorine residual, or settleable solids testing.

  Laboratory deficiencies of Group B plants were
further  summarized, based on  available  informa-
tion. This summary  omits  stabilization  ponds
(which often have no effluent, so that no testing is
needed), other plants  where  no testing is needed,
and  those plants where  reasons for laboratory
  36

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                     TABLE V-6
    OPERATION AND MAINTENANCE PROBLEMS AND
                   DEFICIENCIES
   Problems and deficiencies
                            Frequency of occurrence (%)
                           Group A     Group A   Group B
                           (Meeting   (Not meeting
                          design criteria)  design criteria)
Have inadequate laboratory           20     22       71'
  facilities and/or inadequate
  laboratory testing programs.
Have no O&M manuals designed       40     51       48
  specifically for them.
Inadequate spare parts               21     26       27
  inventories.

Inadequate records of                11     17       34
  maintenance repairs and
  replacement.
Inadequate routine maintenance        11     13       18
  schedules.
Need follow-up actions to            36     37       83
  correct operational, mechanical,
  or manpower deficiencies.
Operations and other plant            16     14       36
  personnel do not routinely
  attend short courses, school,
  or other training.
Infiltration/inflow, major or           75     74       55
  minor.
Hydraulically overloaded.            18     25       182

  'Most of these facilities are primary treatment plants and lagoons, smaller than 1
mgd
  ^Based on only Group B plants having both design and average daily flow rates

deficiencies were  unknown. The reasons  for inad-
equate laboratory  testing are  as follows:

  • 69% (126  plants) have no  testing program es-
     tablished  or  infrequent  current  testing,  or
     need additional tests.
  • 24%  (43 plants) have no  lab equipment,  no
     lab facility, or insufficient  testing equipment
  • 7%  (12 plants) have inadequate  manpower
     and training for lab testing.

  O&M  management, as reflected by the percent-
age  of plants  that  have  inadequate  spare  parts
inventories, maintenance  records,  and  mainte-
nance  schedules,  is  better  in  the  satisfactory
Group  A   facilities  than in  the  unsatisfactory
Group A and the  Group B plants. Group B plants
had the worst  record for these  three  items.
  The next most  important  item is  the  need for
follow-up  action.  While the  percentage  of Group
B plants requiring follow-up was more than dou-
ble that  for either segment of Group  A, the  per-
centages  were quite high for  the entire  sample.
Data available for this survey were inadequate to
provide a detailed analysis of the types and extent
of follow-up needs, but  it  is apparent  that  this
area should  receive  more  emphasis.
  The  unavailability  of  O&M  manuals  was  a
problem for a high  percentage of all  plants in the
survey. Here again, more plants in the unsatisfac-
tory category of Group A, and in Group B, lacked
specially  prepared manuals.  In  addition, infiltra-
tion/inflow was present in a majority  of all plants;
this  appears to be  a problem regardless of per-
formance.  Finally,  overloading also  presents  a
problem in about 20% of the cases.
  The elements of treatment  plant operation most
often cited for  deficiencies in operation and main-
tenance of Group B are as follows:
 1. Laboratory controls  	268 cases
 2. Flow meter and recorder	 193
 3. Records 	 90
 4. Condition and appearance of grounds	 71
 5. Safety features 	 51
 6. Pump station	 47
 7. Effluent chlorine  	 39
 8. Chlorine contact tank 	 26
 9. Chlorinators	 25
10. Sludge drying beds	 24
  Deficiencies in laboratory facilities and analysis continue to
  be a major problem in improving treatment plant perform-
                        ance.
                                                                                                         37

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SUMMARY OF EFFICIENCY
IMPROVEMENT ACTIVITIES
  The  implementation of the  comprehensive  mu-
nicipal operations strategy, discussed last  year,2
accelerated in 1974. The NPDES permit  system is
now being more closely linked with the improve-
ment of  the  operational efficiency  of plants.  The
technical assistance program, an essential element
of the  strategy, has seen some success and is re-
ceiving increasing emphasis.
  The  technical  assistance activity is  directed to
helping municipalities identify and solve  operation
and maintenance  problems which cause inefficient
plant performance, and to training State  and local
personnel in procedures to improve plant  per-
formance. Each project provides on-the-job train-
ing of the facility's operating technicians, enabling
the community  to maintain  consistently higher
pollutant removals. Depending  on the  situations
of  individual plants, operations  personnel  are
taught  how to respond to changes in  hydraulic
and  organic loadings, how to identify and elimi-
nate or reduce the effects of industrial discharges
into municipal systems, and how to improve their
laboratory testing programs.
  In many  cases,  pollutant removals   increase
dramatically. For example, EPA Region IV  pro-
vided  assistance  at  a  7.0 mgd  activated  sludge
plant,  increasing  the  BODs removal  efficiency
from 38 to 91 percent. The TSS removal efficien-
cy  increased  from 20  to 77 percent.  These in-
creases, as well as internal plant process improve-
ments, brought the plant from poor to satisfacto-
ry.
   Of particular importance in the development of
the technical assistance program is the  increasing
involvement of State water pollution control agen-
cies. Several States  have begun to develop inde-
pendent  ability to provide operational  assistance
to their  municipal treatment facilities. This trend
must be encouraged. The U.S. EPA cannot pro-
vide all necessary technical  assistance and there-
fore intends  to guide and help the States in devel-
oping their own programs.
   In addition to  technical assistance,  EPA  has
undertaken a variety of other efforts to aid those
concerned with proper  plant operation. The fol-
lowing are the most significant activities:
   • Through the use  of contracts, a  series  of
     technical documents on  O&M is being  pub-
   lished,  to increase the amount of established
   knowledge  easily  available to  plant  opera-
   tions personnel.
   A  "mini-documentary"  (two-minute  public
   information  film) on O&M released to  100
   selected television stations in late 1975.
   A series of seminars for consulting engineers
   and State and Federal personnel on the prep-
   aration and review of O&M manuals for indi-
   vidual plants has been conducted throughout
   the country.
   A  continuing series  of  technical workshops
   has been instituted to improve the  capability
   of  EPA Regional  personnel in  dealing  with
   treatment plant  operational problems.
   Training  courses  are being developed  and
   presented  for treatment  plant  inspectors  and
   performance evaluators  and troubleshooters.
  2Clean Water: Report to Congress-1974, pp. 60-61
Technical assistance to municipalities will help them im-
prove plant operations to meet permit conditions and reduce
        the pollution load on receiving waters.
38

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CONCLUSIONS, 1974
  The data collected for this report are consistent
with data collected  for  the two  earlier reports
(Clean  Water:  Report to  Congress-1973, 1974),
and are distributed by size and type much as is
the national  population of plants. Therefore, from
the prior performance data review, it may be in-
ferred that significant improvement in operational
efficiency could be achieved by means of:
  • Improved techniques,  procedures, and guid-
    ance  for suspended  solids removal  (which
    appears to be  a problem for all types and siz-
    es of plants);
  • Improved inspection, evaluation, and techni-
    cal assistance for larger  plants, particularly
    trickling filter  and activated  sludge  plants,
    and for  marginal  plants  of all kinds where
    only  a  few   points  of improvement could
    bring performance to satisfactory levels;
  • Increased attention to  the  problems  of trick-
    ling filter  plants,  with special attention  to
    identifying problems  sensitive  to  improve-
    ment through better O&M.
  The  above items are based  on operational per-
formance.  Several additional  needs, based on
analysis of plant problems,  have been identified.
  • Inadequate laboratory  testing is  still  the most
    prevalent problem and presents a major diffi-
    culty in assessing the operational  efficiency
    of plants.
  • Special  attention to means for  encouraging
    States  and municipalities  to improve labora-
    tory controls and reporting is needed.

  There  is a consistent  pattern reflecting higher
incidence of  certain  types of problems  among
Group A plants  not meeting requirements  and
among Group  B  plants. For   this  reason,  other
problems which merit special attention are:
  • Substantial improvement  is needed  in O&M
    management, particularly  maintenance record
    and supply inventory management.
  • New and improved training delivery systems
    must be provided; and State and  municipal
    agencies must be  encouraged to ensure that
    more personnel are given  training opportuni-
    ties. (See Chapter IV).
  • Special  attention must be  given to inspection
    follow-up activities,  to determine more  pre-
    cisely  what the impact of such actions has
    been, and  to identify  more precisely the na-
    ture of deficiencies and of needed assistance.
   • More  concentrated effort is needed to ensure
     the availability of well-written and  specially
     prepared operation and  maintenance manuals
     at  all plants.
   • A special effort is needed to increase the lev-
     el  of  public awareness  of, and support for,
     improved municipal treatment plant  perform-
     ance  to protect  the  public's investment  in
     these  facilities.

 Preliminary Results on the  Efficiency of Treatment

 PRELIMINARY RESULTS ON THE
 EFFICIENCY OF TREATMENT PLANT
 OPERATIONS—1975
   The  preliminary  results for 1259 inspections
 conducted during the period January 1974 to May
 1975 are reported below. These  results provide
 the design efficiency data required by Section 210
 of the Act. More detailed  analyses which parallel
 and extend the  1974  results reported above are
 being performed and will be published separately.
   As in previous years,  the 1975 survey,  to be
 reported during 1976, is divided into the following
 groups: (Tables V-7 and V-8).

                    Table V-7
 NUMBER OF MUNICIPAL TREATMENT PLANTS IN SUR-
                  VEY GROUP A

Tofe
Process
Primary 	
Lagoons 	
Trickling Filter
Activated
Sludge 	
TOTAL
PERCENT 	
Class
1
(15 +
MOD')
8
1
11

25
45
5.6
Class
2
(5-15
MOD)
11
2
36

67
116
14.5
Class
3
(1-5
MDG)
33
9
125

152
319
39.7
Class
4
(0-1
MOD)
12
60
65

178
315
39.2
Class
5
(Un-
known)
1
0
2

5
g
1.0


Total
65
72
239

427
803
100.0


Percent
8 1
90
29.8

53.2
100

  *Million Gallons per day.
                    Table V-8
NUMBER OF MUNICIPAL  TREATMENT PLANTS WITH
    INSUFFICIENT OPERATIONAL DATA - GROUP B
Class
Type 1
of (15+
Class
2
(5-
Process MGD*) 15 MOD)
Primary 	
Lagoons 	
Trickling Filter
Activated
Sludge
TOTAL
PERCENT 	
0
0
2

1
3
0.7
3
4
4

3
14
3.1
Class
3
(1-5
MGD)
19
16
39

32
106
23.3
Class
4
(0-1
MGD)
18
134
56

95
303
66.5
Class
5
(Un-

known) Total
2
22
4

2
30
6.6
42
176
105

133
456
100.0

Percent
9 2
38 6
23.0

29 2
100 0

                                                   *Million gallons per day
                                                                                               39

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Group A—Records with enough design and operational
        data to allow comparisons  	803
Group B—Records without operational performance
        data 	456
                                TOTAL       1259
  Group A contains  records from 47 States, with
as few as  1 coming from two  States and as many
as 96 from one State; the median is 14 records per
State.
  Group B contains  records from 41 States, with
just one coming from each of seven States and a
total of 52 from one State at the other extreme.
The median is eight records per State.
  In the 1975 survey sample inspection emphasis
(as indicated by sample distribution) has shifted to
a greater proportion of large  plants than  in pre-
vious years.
  Changes  in grant funding and secondary treat-
ment requirements is evidenced by  decreases in
primary and trickling filter plants this year versus
increases in activated sludge and lagoons.

Performance vs. Design Intent—Group A
  The  operational performance data for treatment
facilities in Group A were scanned  to determine
plant performance compliance with original design
objectives.  The main results  of  this  preliminary
analysis  indicate that 66% of  all  plants are meet-
ing  their BOD5 design  criteria.   Also,  59%  are
meeting  their design  criteria for  total suspended
solids. The results by plant type  are summarized
in Table V-9.
   This  year's  data is consistent  with results  of
previous surveys.
                     Table V-9

SUMMARY OF OPERATIONAL EFFICIENCY FACILITIES
          MEETING DESIGN CRITERIA 1976
Type Of Process
BOD,
                                             TSS
  Primary

  Lagoons

  Trickling Filters

  Activated Sludge

  All Plants
 78%

 59%

 52%

 74%

 66%
72%

50%

48%

64%

59%
 40

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                                                                           CHAPTER  SIX
                                              Program
                                              Planning  and
                                              Management
A COMMITMENT
TO INTEGRATED PLANNING

  From the earliest version of the legislation that
resulted in P.L. 92-500, Congress recognized that
achieving desired  water quality may require more
effluent control than  is attainable  through base
level technology,  and that incoherent and uncoor-
dinated planning  and management is perhaps the
principal cause of inefficiency and poor perform-
ance in waste management, particularly in  metro-
politan regions.  EPA shares  those beliefs.  The
Agency, working  with State and local authorities
and the  public,  has made major progress since
enactment of the 1972 Amendments toward the
formulation of an integrated national water  quality
planning and management system.

  Three tiers of government—Federal,  State and
local—share the responsibility  for carrying  out an
adequate and efficient water quality control pro-
gram. Efforts at each level are being coordinated
to achieve meaningful and reasonable results.

  Duties and opportunities under the FWPCA cut
across individual  sections of the Act. For  exam-
ple, State water quality management is based on
the  State's planning process .called for by section
303(e), but the process merges various  statutory
requirements. The State's process should satisfy,
at the least, requirements of  areawide  planning
(section 208), waste load analysis (303(d)) and water
quality reporting (305(b)).

  For each type of planning, programs are  devel-
oped in accordance with stated objectives. Manage-
ment actions must provide for:

  • Assessing the problem.
  • Defining priorities.
   •  Setting targets.
   •  Developing output commitments.
   •  Insuring that adequate management and regu-
     latory actions are provided to carry out the
     program.
   •  Tracking major milestone achievements  and
     water quality changes.

  Preparation of  complete  and  comprehensive
programs for all sources  and concerns in a plan-
ning area may outrun the management agency's
resources. Hence, EPA  and  the  other agencies
have  prioritized objectives,  to tackle  the most
important needs first. Past objectives have empha-
sized completion of basic water quality standards,
development of  initial basin plans, designation of
areawide planning  areas and agencies, and initial
structuring of the management program. The com-
ing period will  focus  on revising  water quality
standards during FY 1976 to reflect the Act's 1983
national water quality goal as specified in section
101(a)(2); conducting water quality planning to es-
tablish targets for Phase II permits where base-level
BAT will be inadequate to reach that goal; and  im-
plementing areawide waste treatment management
planning by designated agencies and the States, in-
cluding coverage of nonpoint sources of pollutants.
THE COMPONENTS OF THE SYSTEM

  From  a broad perspective, the water quality
planning and management system includes  three
major aspects. These are:  the national strategy
and program guidance; individual State strategies
and program plans; and specific State or areawide
planning and management. Other  associated plan-
ning has to date played only a minor role in the
overall effort.
                                                                                        41

-------
  Careful planning and management is needed to protect eco-
  logically valuable salt marshes from excessive developm-
  ent. (EPA biologist studying marsh conditions near Pensa-
                   cola, Florida.)
Federal and State Strategies;
Federal Program Guidance
  Each year EPA prepares two important docu-
ments:
  •  The Water Quality Strategy Paper, to provide
     an overview of program  objectives and indi-
     cate developing national policies.
  •  The  Management  by  Objectives Operating
     Guidance,  to  describe  individual program
     priorities, outputs, narrative descriptions and
     reporting requirements.
Each  State  prepares  an  individual State water
quality strategy that corresponds to  the  Federal
strategy  and operating guidance. The State strate-
gy lists problems and geographical priorities, out-
lines the  State's approach and establishes priori-
ties  and  schedules for  specific actions. The State
strategy, updated annually,  becomes an  integral
part of the State program.
The State Program
  Section 106 of the Act authorizes  EPA to  make
annual allotments  to  the States and  interstate
agencies  based  on  the  extent of  the  pollution
problem in the several States. EPA grants supple-
ment State funding and strengthen the capacity of
State agencies to achieve the goals established by
the Act.
  Federal expenditures have grown  from $10 mil-
lion in FY 1968 to $48.5 million in FY 1975. At
the same time State expenditures have shown an
even greater  increase, from $19 million in  FY
1968 to $80  million in FY  1975.
  A Growing State  Effort.—One  of the major
directives of  the Act is the delegation for adminis-
tration of programs by the States.  As of  the end
of FY  1975,  24 States had been delegated permit
authority  (NPDES); 35  States  O&M manual re-
view authority; and 29 States POTW construction
plans and specification review authority.
  The  States provide, in their  annual State pro-
grams, output commitments to be achieved for the
forthcoming  year. These serve as  milestones for
accomplishing the major water quality goals.
  Output estimates and  accomplishments for FY
1975 are presented in Table VI-I.  Resources ap-
plied by the States  to  achieve the outputs  are
shown in Figure VI-I. Table VI-2 shows  the Fed-
eral share  and total amount of planned FY 1975
State program expenditures by State.
  In addition to the Table VI-1 activities, during
1975 States were active  in certification and  draft-
ing of permits; monitoring water quality; enforce-
ment; and training programs. Planned and/or ac-
tual outputs  were dependent  in  some  cases on
EPA actions (e.g., certification of permits  based
on  EPA  issuance); therefore,  no comparable na-
tional achievement rate was measured.  In  other
cases where  no  achievement  rate  is given,  the
States  were  not  asked  for  commitments due to
difficulty  in  establishing  valid output  measures
and/or validly projecting a "planned" figure.
  Moving  to the New  System,—Several factors
affected  the  level of achievement of the  planned
outputs for FY75: guidelines from EPA were still
being finalized well into the year; States in many
case directed their limited resources to high prior-
ity areas which  in turn reduced  staff  of  lower
priority programs (e.g., basin planning);  vacancy
rates were high in some States, particularly  in the
municipal facilities area, due partly to low  salary
42

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                     TABLE VI-1
              FISCAL YEAR 1975 OUTPUTS*
Program area
NPDES delegation
O&M manual
delegation
P&S review
delegation
WQL segment
analyses
Basin plans
completed
Major industrial
permits
issued
by States
Minor industrial
permits
issued by States
Major municipal
permits
issued by States
Minor municipal
permits
issued
by States
Construction grant
awards (Sbillion)
Planned FY 75
States 35
States 40

States 38

Analyses 2170

Basins 390

820



11892


875


6169



6.5

Percent
Actual FY 75 achieved
States 24
States 35

States 29

Analyses 1712

Basins 115

778



10804


782


5097



3.6

69
88

76

79

29

95



91


89


83



55

                     Figure VI-1.

            FEDERAL-STATE EXPENDITURES
               AND CONSTANT DOLLARS
 *Figures obtained through EPA's Federal Planning and Reporting System and
 Grants Activity Report
scales, and some areas lacked  a clear-cut defini-
tion of EPA vs. State responsibilities (e.g., munic-
ipal facilities).
   1975 did  prove to be a productive year for the
water program at the State level, relative  to 1974.
As it was the first  full year of activity following
passage of PL 92-500, 1974  was basically a transi-
tion year for the States as they  became  familiar
with the  new  Federal/State program.  1975, how-
ever, showed expanded State  activity and respon-
sibility  in carrying  out the short-term  goals  and
objectives  of the  program.   Given  limited   re-
sources   and   significant  staffing  problems,  the
States did a creditable job meeting output targets
and working  in partnership with EPA  in several
program areas.
  State production  increased  significantly during
FY75, and it was apparent that both EPA and the
States has  made  most  of the major  adjustments
required by P.L.  92-500 and  the new  regulations
issued pursuant to the Act. Prospects for 1976 are
generally  good,  except in  the  area  of funding,
where inflation and  fiscal constraints on both EPA
and the States threaten the  attainment of  the  ma-
jor milestones in the Act as  well  as  the States'
capability to play the role envisioned  from them
in  the Act.
                                                           1970
                                                                          1972    1973    1974    1975

                                                                          FISCAL YEARS
The nation's environmental and energy needs must both be
 met.  (Barges transport coal to Ohio River power plant.)
                                                                                                     43

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                                            TABLE VI-2
                               PLANNED FY 1975 FEDERAL-STATE TOTAL
                               COMPARED TO FEDERAL CONTRIBUTION
State/Region
Region I
Conn 	
Maine 	
Mass 	
N.H 	
R.I 	
Vt 	
Region II
N.J
N.Y 	
P.R 	
V.I 	
Region III
Del
D C
Md.
Pa
Va
W Va

Region IV
Ala
Fla
C,n
Kv

Nc
s c
Tenn

Region V
111 	
Ind
Mich
Minn
Ohio
Wis

Total ($)
	 1912348
	 1383827
.... 1961126
	 1848800
	 570300
	 854656
3508925
9072416
	 1080548
	 446461
1324256
432622
3060057
6204233
5125140
870760

1077128
4651323
?ft^1478
1 S177SQ
11^7^78
78317S3
IQA'lf.^T,
1 867072

	 7415518
2439903
5049700
2072614
5199489
3371516

Federal
contribution ($)
710298
146900
951600
271800
342300
198900
1137035
2203382
651056
293155
705213
270029
674616
1790134
1006112
430940

931408
1030718
1246499
588288
595097
1468797
795947
795367

1499380
1303143
1933987
749367
1531484
1085316

Federal
share (%)
37
11
49
15
60
23
32
24
60
66
53
62
22
29
20
49

86
22
61
39
51
52
41
43

20
53
38
36
29
32

State/Region
Region VI
Ariz
La
N M
Okla
Tex

Region VII
Iowa
Kans
Mo 	
Nebr .
Region VIII
Colo 	
Mont 	
N. Dak 	
S. Dak 	
Wyo 	
Utah

Region IX
Ariz 	
Calif 	
Guam 	
Hawaii 	
Nev 	
American Samoa ..
Trust Territories ...

Region X
Alas 	
Idaho 	
Oreg 	
Wash 	

Total($)
987289
1155812
525604
694626
6372210

834851
1033211
1169406
898367

... 1153892
	 537120
.... 275800
	 231700
	 345730
542665


	 631976
.. 11025400
	 339899
	 649001
	 309782
	 151329
183040


	 260378
	 741618
... 1609218
... 1787286

Federal
contributions ($)
593675
686710
26293 1
442600
1477400

661682
421822
755190
502900

375242
317398
171530
173015
127830
246034


325900
2355848
248868
283263
139923
62228
134887


131039
347522
667700
872500

Federal
share (%)
60
59
50
64
23

79
41
65
56

33
59
62
75
37
45


52
21
73
44
45
41
74


50
47
41
49

   National Total = $112,574,919
   Federal contribution = $40,123,905
   Federal share = 36%
Statewide Planning and Management
  EPA,  together  with the States  and numerous
advisors, have  labored  to flesh out  the  specific
planning mandates of  the Act to form a meaning-
ful State management tool. The goal has  been to
translate preexisting State efforts into a workable
new program in  keeping  with  the 1972  Amend-
ments.  The continuing planning process  (section
303(e)) is the vehicle which integrates the various
related elements of the Act—Statewide, areawide,
local and facilities oriented activities—and acts as
the State's central management tool for  adminis-
tering water  quality  programs. As  of December
31, 1975,  all 56  States  and  territories had  an
EPA-approved continuing planning process. These
will be  revised  during 1976  in  accordance  with
revised  regulations (40 CFR  130)  promulgated
November 28, 1975.
44

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   A  Two-phased  Program.—Statewide  planning
 involves  essentially two  phases. The first phase,
 basin planning, accomplishes the transition from
 pre-amendment planning into  the  more  sophisti-
 cated effort contemplated by the  new Act. This
 phase, scheduled for completion by  July  1, 1976,
 encompasses the following requirements:
    1. Inventory and  ranking  of  significant dis-
 chargers.
    2. Schedule of compliance or target dates.
    3. Assessment of municipal needs.
    4. Determination  of  total   maximum  daily
 loads.
    5. Established or targeted load allocations and
 effluent limitations.
    6. Assessment of  nonpoint  sources of pollu-
 tion.
    7. Residual waste controls.
    8. Recommended water quality  standards revi-
 sions.
    9. Planning relationships.
   10. Appropriate   monitoring  and  surveillance
 programs.
   11. Interstate/intergovernmental cooperation.
   Phase II, termed  State Water Quality Manage-
 ment Planning, will fold the State's more complex
 areawide  planning  efforts (see  section 208) into
 the completed Phase I basin plans. Essential man-
 agement activities—establishing priorities, sched-
 uling actions and assisting  the  direction of re-
 source expenditures—operate in both phases.
  The major change in Phase II  will  be the addi-
 tion of nonpoint source control programs. Phase I
 has provided preliminary qualitative evaluation of
 the nature and  extent of nonpoint source loading,
 but Phase II plans should present a far more de-
 tailed  evaluation of these loadings and  identify
 control measures, regulatory  programs and imple-
 menting agencies. The Phase II process will also
 produce  information on  urban  stormwater sys-
 tems, industrial waste treatment needs,  and resid-
ual waste controls.  A Federal district  court has
ruled  that Phase II  plans, including  section 208
requirements, must  be completed  no later  than
November 1978.
  The Early Results.—Although transition from
Phase I to Phase II is now  in progress,  specific
priority items are already completed  and in use.
Significantly, a majority of  total maximum daily
load determinations and wasteload allocations are
now available for use in setting the effluent limits in
NPDES permits.
   According  to  EPA's formal reporting  system,
 1,712 water quality  segment  analyses, out  of  a
 total 2,362 such  segments, had been completed as
 of June 30, 1975. Figure VI-2 shows the progress
 toward completing the  analyses for  all water qual-
 ity segments. Of those that do not  yet have com-
 pleted  water  quality segment analyses,  most in-
 clude significant  nonpoint source control problem
 areas (which  will  be further  developed under
 Phase II planning) or  extremely complex urban/
 industrial areas which demand more detailed anal-
 ysis.


                        Figure VI-2.
        NUMBER OF WATER QUALITY SEGMENT ANALYSES
        2000  -
    o
    o
    o
    cr
    uj
    00
        1600  -
        1200  -
         800  -
         400  -
              1973        1974         1975

                     CALENDAR YEARS
  Overall, the Statewide planning programs appear
to be functioning at a passable level. As could be
expected, there have  been many  growing pains
associated with the developmental  stages of the
program.  Recent indications  are,  however,  that
the program is functioning as  a  necessary  and
viable part of the effort to clean our nation's wa-
ters.

Areawide  Planning and Management
  The Act  provides local  areas  with a  unique
opportunity to  plan and manage a comprehensive
waste treatment  control  program  for municipal
and  industrial  wastewater;  storm  and combined
sewer runoff, nonpoint source pollutants and land
use as it  relates to  water quality.  This areawide
planning and  management program concentrates
on  metropolitan  areas  that  have  water  quality
                                                                                               45

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problems  requiring treatment levels beyond sec-
ondary for municipal wastes and best practicable
control technology for  industrial wastes. It may
also involve areas that wish to preserve high qual-
ity waters or that have  been or will be subject to
extensive  energy development.
  Beginning the Effort.—Initiation of  the program
lagged somewhat  because  of  the attention  de-
manded  by  the  permit program,  construction
grants and Statewide planning. During 1974, how-
ever,  this program  was  launched.  Regulations
published September 14,  1973, and revised Nov-
ember 28,  1975, set forth specific criteria for area
and planning agency designation. They include:
  • Areas—a preference for areas  with  urban-
    industrial concentrations or  with substantial
    surface  and/or  ground  water quality  prob-
    lems; and
  • Agencies—an insistance that agencies possess
    a coordinated waste treatment  management
    system or that  the local governments intend
    to plan and implement areawide  waste treat-
    ment management.
  Generally, the State  Governor  designates  the
areas as well as the agencies that will conduct the
work. He is responsible for  assuring that the work
is completed  and is consistent with  the  overall
State  effort. In areas  which are  not designated
pursuant to section 208, the State's water  quality
management plans and individual facility plans
will provide programs addressing the  needs  of the
area.
  Most of the agencies  approved are  general pur-
pose  regional planning  agencies  representing ur-
ban-industrial areas.  Some  agencies,  in  contrast,
will work in areas with substantial ground water
pollution problems, such  as  Nassau-Suffolk, New
York, other  agencies will work in areas that are
subject to extensive energy development, such as
the Yellowstone-Tongue area of  Wyoming,  or
areas seeking  to  preserve  existing  high  quality
waters,  such as  Jackson Hole,  Wyoming.  The
average 208 area contains 2,490 square miles and
has a population of 610,000.
  Implementing the Plan—The areawide planning
agencies will develop comprehensive  plans  cover-
ing both point and nonpoint sources  of pollution.
An essential ingredient of any plan is a manage-
ment system to insure plan implementation.
  The primary importance of the agencies will be
realized  when plans  are  carried out  during  1977-
83—Phase II of the national water quality control
effort. At that time, permits in areawide planning
areas  should  begin to reflect  plan  targets  and
directives.
  However, planners must also show an ability to
produce usable interim outputs. These can be sig-
nificant early achievements of the plan and  can
contribute to near-term State areawide discussion
and coordination as well as to specific manage-
ment actions.

Progress to Date
  A  few  agency designations were  made in FY
74,  with fourteen area and  agency  designations
and eleven grant awards, totalling approximately
$13.5 million. However, FY 75  has  marked the
real growth of the  program, with the additon of
138 grants at $150 million bringing the total to 149
grants  amounting to $163.5 million, (see Table VI-
3.)
  By early June, 1975, applications nationwide for
grants  totalled over $176 million. However,  EPA
was  only  authorized to obligate  $150 million for
Fiscal  Year 1975. This resulted in 23  designations
submitted by Governors but not approved due to
lack of funds. The system for awarding 208 grants
was  modified  at the beginning of April  1975  by
means of funding allocations to each of EPA's ten
regions. From that point it was carried on a national
first-come, first-served basis.

ASSOCIATED PLANNING
  Other planning  efforts  are authorized  by the
Act. These include comprehensive   planning for
water  pollution  control (Section 102) and Water
Resources Council basin  planning  of  water  re-
sources (section 209).
  The 102(c) program  was designed  essentially as
a continuation  of  the 3(c)  program established
under  prior water  quality legislation. Since pas-
sage of the  1972  Amendments to  the law there
have been no new  funding allocations authorized
in either the 3(c) program or the 102(c) program.
  This year's  budget  request submitted  by the
President  included, for the first time, a proposal
for  a Level B Water Resources Study to be fund-
ed under  the authority of section 209 of the Act.
Previous Level B efforts have been funded under
other authorities.
46

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               TABLE VI-3
               SECTION 208
DESIGNATIONS APPROVED BY ADMINISTRATOR
               BY STATE
          DECEMBER 31, 1975
               Designation
Region
IV

IX

IX

VIII


III 	
Ill 	
IV 	


XI 	

X .
'V

V


State
Alabama



California




Delaware
District of
Columbia
Florida


Guam

Idaho
Illinois




Area
Birmingham
Tuscaloosa
Mobile


Lake Tahoe (In-
terstate.)
Ventura Co.
San Diego
Monterey
San Francisco
Pueblo County
Colorado Springs
Rifle (Rio Blan-
co)
Northwest
Larimer-Weld
New Castle County
Sussex County
Washington-
Metro Area
Palm Beach
Orlando
Volusia Co.
Brevard Co.
Bay Co.
Pensacola
Sarasota/Ft. Myers
Broward Co.
Tampa Bay '
Dade Co.
Tallahassee
Polk Co



Pocatello
Panhandle
East St. Louis
Southern
Lake & Porter
Co.
South Bend
Madison-Muncie
Indianapolis
Terre Haute
Date
3-25-75
3-25-75
5-22-75
6-06-75

8-05-74

6-13-75
6-18-75
6-18-75
6-18-75
10-08-74
9-18-74
6-26-74
4-24-75
5-14-74
5-14-75
6-12-74
1-30-75
3-28-75
1-10-75
3-28-75
4-22-75
4-24-75
4-30-75
5-14-75
5-16-75
5-23-75
5-27-75
5-30-75
5-30-75
6-06-75
6-18-75

4-02-75
3-25-75
5-27-75
5-30-75
5-20-75
6-23-75
5-20-75
5-23-75
5-27-75
5-30-75
6-06-75
Region State
VII Iowa
VII 	 Kansas

IV 	 Kentucky



III Maryland
I .. .. Massachusetts




VII Missouri

VIII 	 Montana


IX 	 Nevada

I . New Hampshire

Area
Des Moines
Centerville
Kansas City

Louisville

Portland
Southern Maine
Northern Maine
Lewiston-Au-
burn
Augusta-Cob-
Baltimore
Pittsfield (Berk-
shire)
Lowell
Cape Cod
Martha's Vine-
yard
Brockton
Worcester
Fitchburg
Boston
Southeast
Detroit
Kalamazoo
Jackson
Flint
Tri County
Muskegon
Grand Rapids
Bay City
St. Louis
Joplin
Middle Yellow-

stone
Yellowstone
Tongue
Flathead
Gallatm
Carson River
Reno
Clark Co.
Salem
Lakes Region
Date
6-10-74
5-23-75
6-13-75

4-02-75

6-25-74
7-26-74
8-05-74
12-19-74
12-19-74
6-06-75

2-18-75
3-04-75
2-27-75
2-27-75
3-06-75
4-11-75
4-17-75
4-18-75
5-20-75
5-20-75
5-27-75
5-27-75
5-27-75
6-06-75
6-06-75
6-06-75
6-06-75
5-23-75
6-06-75


4-02-75
4-08-75
4-02-75
6-05-75
6-03-75
6-06-75
6-13-75
4-01-75
6-03-75
                                                                  47

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                                           TABLE VI-3
                                          SECTION 208
                        DESIGNATIONS APPROVED BY  ADMINISTRATOR
                                           BY STATE
                                       DECEMBER 31, 1975
                                           (Continued)
Region
II 	

II 	

IV 	
VIII 	
v
VI

X

III
I

IV


State
New Jersey
New Jersey
New York

North Carolina
N Dakota
Ohio
Oklahoma

Oregon

Pennsylvania


South Carolina


Area
Mercer
Middlesex
Camden
Ocean Co.
Nassau-Suffolk
Westchester
Erie-Niagara
So. Tier Cen.
(Corning)
New York City
Central NY
(Syracuse)
Raleigh-Durham
Asheville
Lewis & Clark

Toledo
Youngstown
Dayton
Cleveland
Akron
Tulsa
Oklahoma City
Portland
Salem
Eugene-Spring-
field
Medford
Philadelphia
Pittsburgh

Columbia
Greenville
Beaufort
Waccamaw
Date
5-12-75
5-14-75
5-14-75
6-03-75
4-24-75
6-03-75
6-03-75
6-05-75
6-05-75
6-05-75
3-08-74
6-23-75
5-22-75
6-12-74
6-25-74
6-28-75
6-25-74
5-27-75
5-23-75
9-18-74
10-25-74
11-18-74
11-18-74
11-18-74
6-03-75
6-18-75
6-23-75
6-23-75
4-17-75
3-25-75
5-09-75
6-03-75
6 06-75
6-06-75
Region State Area
VIII S Dakota Sioux Falls
Black Hills
IV . Tennessee Memphis
Knoxville
Chattanooga
Nashville
Kingsport-Bris-
tol
VI . Texas Dallas
Beaumont
Houston
San Antonio
Corpus Christi
Lower Rio
Grande
Texarkana
VIII 	 Utah Provo
Uintah Basin
Salt Lake Coun-
ty
Ogden (Weber-
Davis Cos.)
Southeastern
Five Counties
III Virginia Hampton Roads
Richmond
Roanoke
Fredericksburg
Southwest Va.
X 	 .Washington Clark County
Seattle
Snohomish
III 	 West Virginia Charleston
V 	 Wisconsin Southeastern
Area
Dane County
Green Bay
Green River
Jackson Hole
Date
5-23-75
5-16-75
6-25-75
6-28-74
10-10-74
11-11-75
6-05-75
4-17-75
4-18-75
4-22-75
5-10-75
6-06-75
6-06-75
6-23-75
1-21-75
1-10-75
3-06-75
4-02-75
4-17-75
5-14-75
6-25 74
6-25-74
6-25-74
1-07-75
1-30-75
4 09-75
4-20-75
6-03-75
6-06-75
12-26-74
5-22-75
6-06-75
4-04-75
5-14-75
6-04-75
48

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                                                                           CHAPTER SEVEN
                                                Nonpoint
                                                Source
                                                Program
The Evolving
Nonpoint Source Strategy
  The legal mandate to protect water quality from
nonpoint source impacts  is  far  more  tenuous
than the Act's  point source  control provisions.
Perplexing  technical problems confront  this,  as
any,  area  of  pollution  control.  Furthermore,
sound regulatory moves to abate nonpoint source
problems may raise the red flag of  Federal land
use control. Nonetheless,  as Congress recognized
in passing section 208, the national water quality
effort can  never succeed  by addressing point
sources  alone.
  Until  1974, EPA  did not emphasize nonpoint
sources  management, but rather concentrated lim-
ited  Federal  and other  resources  on  initiating
point source controls. Now that the first round of
NPDES permits is virtually complete, the Agency
as a part of its  long term program plan is urging
the States and planning agencies designated under
section 208  to begin problem assessment and plan-
ning nonpoint  source  management. Under  the
Act, designated 208 planning agencies  and,  in
their absence, the States are expressly responsible
for assessing nonpoint  source control needs and
designing   programs  for  pollution  abatement.
These efforts will be integral parts of the areawide
planning and State water  quality  management
processes. (See  Chapter VI.)
  Some States  are not  only  far along in the as-
sessment and planning  stages of their programs,
but have passed legislation and are in the process
of implementing regulatory programs  to  control
certain categories of nonpoint sources. Whether a
program has been initiated or not, EPA is encour-
aging each  State and local designated 208 agency
to move forward as rapidly as resources allow.
  EPA  issued regulations for State programs in
nondesignated areas in November, 1975 and is in
the process of developing guidelines, which  will
be published during 1976. In addition, the Agency
will assist States and 208 agencies by  providing
technical guidance manuals dealing with specific
nonpoint sources and the activities  which cause
them. The States and local agencies will be en-
couraged to  incorporate  EPA's  approach  into
their programs.
  EPA is also working closely with Federal agen-
cies that manage lands or impact land  managing
activities. The goal  is to  achieve a  coordinated
Federal/State/local approach to nonpoint source
problems.
  Best Management  Practices.—Severe technical
difficulties impede precise identification and meas-
urement of individual nonpoint  source impacts.
EPA believes that sound land management prac-
tices,  rather  than after-the-fact  treatment,  may
best abate this type of pollution.  EPA's guidance
therefore concentrates on describing preventative
measures,  termed  Best  Management  Practices
("BMPs").
  The term "Best Management Practice"  refers
to a practice  or  combination of practices that  is
determined  by a State after problem  assessment,
examination of alternatives, and appropriate pub-
lic participation to be practicable  and most effec-
tive in preventing or  reducing the amount of  pol-
lution generated by  diffuse  sources to a  level
compatible with water quality goals.
   Best Management  Practices  will  be designated
to prevent or mitigate pollution normally associat-
ed with such land-disturbing activities as  agricul-
ture,  silviculture, and  construction.  Each  BMP
will be tailored to the type of  activity as well  as
the prevailing physical factors at the  source  such
as  slope,  soil, rainfall,  climate and vegetative
cover. These variables will to a great extent deter-
mine which control methods pertain in any area.
                                                                                            49

-------
  New  and existing sources may be handled dif-
ferently within a State or area.  For a new land-
disturbing  activity  there  are  often  more  options
for highly  effective management measures. These
more stringent  practices  will  be  considered  in
State selection of BMP's for new sources.

UNRESOLVED ISSUES
AND PROBLEM AREAS

  Administrative Obstacles.—A  variety of  admin-
istrative obstacles confront the  fledgling national
nonpoint source program.  First,  a Federal  district
court has  recently  maintained that EPA may  no
longer  exclude  any  point  sources  from  the
NPDES permit program. Under this ruling, permit
program regulatory responsibilities are being rede-
fined in new regulations relating to feedlots, storm
sewers, irrigation return flows, and silviculture. In
the past, EPA claimed authority to exempt these
categories  of sources from the permit program
and to deal with them as if they  were all nonpoint
sources.

   In the past, Federal financial  support for State-
wide 208  planning has not been available. A  re-
cent Federal district  court decision has  ordered
that  section 208 designated area funds be made
available  for State  planning.  Funds  have  been
made available for States in FY76.

   Technological Problems.—Across the country,
the state of the  art in  respect to  prediction  and as-
sessment  of  nonpoint sources  lags considerably
behind our understanding of the magnitude of  the
problems and the need for prevention or control.
The  best  management  practices  approach  has
been determined to be the most practical means
of assigning control responsibilities, but the BMP/
resulting-effects equation  is  at  times  uncertain.
For a number of land management  practices, pre-
dictive techniques allow estimates of the expected
reduction  of particular pollutants. However, non-
point source managers  are  often  denied  assur-
ance, usually available  in point  source  effluent
control technology, that the result  will match  the
expectation.

   Difficult as it is to  predict  the pollutant  loading
that  might result from  a  single nonpoint source
activity, it is more difficult to succeed in tracing
instream pollutants back  to specific sites. Where
a large number of nonpoint  sources operate  side
by side, the problem is compounded.
Acid mine drainage degrades streams once depended upon
for sport fishing and municipal drinking waters.  (Mine near
                  Rico, Colo.)
 Significant nonpoint sources will be required to employ best
 management practices to  minimize their pollution eff-
        ects. (Holding pond near Uravan, Colo.)
 50

-------
  An efficient nonpoint source program should be
limited to control of significant sources. However,
technically, and ultimately  administratively,  it is
difficult to determine  a  uniform cut-off  point  at
which a  substance will begin  to cause  in-stream
damage and should be cited as significant.

  In applying solutions such as Best Management
Practices  to  nonpoint  source  pollution,  water
quality management officials  must often rely on
insufficient information.  Gaps  may result from a
lack of  necessary research,  from  the  inherent
complexities  of the pollution  problem,  or—most
likely—from  both. For example, control of  acid
mine drainage from abandoned mines is extremely
difficult, as it is too late for preventative manage-
ment practices. While perhaps  one half of  the
drainage problems could be  corrected with suffi-
cient funds,  the  solutions  to  the  remainder  are
unknown.

  For other complex nonpoint sources, technolog-
ical  solutions  may be perceived but not proved.
Full scale use  of  promising techniques cannot be
advocated until after adequate  testing.

  Administrative Problems at the  State  Level.—
Even given technical  answers  to  a  State's  non-
point source  pollution problems,  existing  laws,
traditions, and State  and local politics will  often
prove serious obstacles to their implementation. It
is not clear how these problems can be overcome,
particularly in the absence of adequate sanctions.

  Finally,  the  nonpoint source program bluntly
faces the  Act's  ever present deadline problem.
Success should be achieved by  1983—but before
that, a number of  sequential efforts are necessary.
In many States, legislation must be passed; insti-
tutions must be established or redirected; regula-
tory measures  must be defined and  applied; and
individual nonpoint source managers must imple-
ment their responsibilities.  For some  States  to
accept and carry  out  these  comprehensive  tasks
may take  many years. In such States, it is unlike-
ly that the 1983 goals  can be  achieved for all wa-
ters.
                                                     Excessive pulping wastes interfere with aquatic life by de-
                                                     pleting the water's oxygen and adding excessive nutrients
                                                     and, in some cases, toxic chemicals. (Foamy pulping waste,
                                                                   Port Angeles,  Wash.)
                                                                                                 51

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                                                                          CHAPTER  EIGHT
                                                Research
                                                and
                                                Development
INTRODUCTION
  A strong scientific and technical base is crucial
to EPA's  success  in formulating  policy, setting
standards, implementing programs  and  pursuing
necessary enforcement.  The Agency is conducting
a research, development, and  demonstration pro-
gram  focussed  on  developing  new or improved
pollution control technology, improving monitor-
ing instrumentation and methods, increasing un-
derstanding of  pollution processes  and  their ef-
fects  on public health and aquatic  ecosytems,
developing more effective methods  to utilize sci-
entific,  technical,  and  socio-economic  data for
environmental  decision-making. Together, these
interrelated programs  provide technical support to
EPA and other agencies responsible for improving
the Nation's waters.
  This chapter outlines  the  actions  taken and re-
sults achieved during 1974 and 1975 in EPA's re-
search,  development,  and  demonstration  pro-
grams.

HEALTH EFFECTS PROGRAM
  The health effects program concentrates on two
major  activities: assessing  the  effects  of water
pollutants on health,  and developing  criteria and
standards to ensure safe supplies of drinking wa-
ter.
  Health Effects.—The water  quality health ef-
fects  research and  development program embod-
ies: (1) health  effects research dealing with the
development of  valid criteria for  the safe treat-
ment  and disposal of  wastewaters and  sludges and
(2) the development  of health-related  criteria for
fresh  and  marine recreational and shellfish grow-
ing waters.
  Studies  are being conducted on  the health ef-
fects  of  land  application  of wastewaters  and
sludges and on the transport of toxic substances
and pathogens (especially virus) from wastewater
and sludge to man's food chain and  drinking wa-
ter. Such studies require extensive monitoring of
waste components and waste breakdown products
in water, food, and air.
  At present, under the fresh  recreational water
program,  the etiology of amoebic meningoence-
phalitis is being investigated. Broad  epidemiolog-
ic-microbiological studies will be initiated to refine
fresh recreational  water quality criteria based  on
scientific health effects data.
  The  marine recreational  water program deals
with epidemiological studies of  marine beaches in
temperate climates. It may be extended to tropical
climates as well during FY 1977. Epidemiologic-
microbiological  studies are  being conducted  in
recreational waters to relate health effects  to var-
ious quantitative indices of pollution. Moreover,
modest research programs will  be initiated to im-
prove microbial water quality guidelines for ma-
rine shellfish-growing waters.
  Recent accomplishments include the following:
  • Studies have been initiated  to determine aero-
    sol transport  from  conventional wastewater
    treatment plants. In addition, the transport of
    microbiological contaminants  and  chemical
    compounds from spray  irrigation of wastewa-
    ter and sludge application to land will be de-
    termined. Pathogen transport through sludge
    application to land will be investigated.
  • Statistically significant differences were iden-
    tified between the illness rates at two  marine
    beaches—one  of  barely  acceptable   water
    quality, the other  relatively unpolluted. An
    additional pair of beaches  in the vicinity of
    New York City will be investigated  during
    the 1976  swimming season.
52

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  • Attempts are being made  to  determine the
    frequency, distribution and cause of amoebic
    meningoencephalitis. This  almost  invariably
    fatal  disease is believed to strike following
    swimmming in fresh or brackish waters.

  Water Supply Research.—Funding for the Wa-
ter  Supply Research Program  is provided under
the  Safe Drinking Water Act of 1974. Since these
activities are related to those of the FWPC  Act,
they are included here for the sake of  complete-
ness.
  The  objective  of  the  Water Supply Research
Program is  to provide the  scientific knowledge
necessary to refine standards for organic, inorgan-
ic, and microbiological contaminants of drinking
water.  These standards will then be incorporated
into primary  drinking water regulations  under the
Safe Drinking Water Act of 1974. Treatment proc-
esses for the removal  and/or inactivation of  con-
taminants are  being developed, as  are  control
techniques to protect water supplies at the source
and in  the distribution system.

  Major research activities include:
  •  Nationwide  surveys  to determine the  extent
    of contamination of water supplies by virus-
    es, organic and inorganic chemicals—espe-
    cially those suspected of having carcinogenic
    properties.
  •  The isolation and identification of  organic
    compounds   present  in   drinking   water.
    Toxicological studies are being  carried  out on
    organic residues isolated  from tap water by
    reverse osmosis techniques.  Results of  toxi-
    cological  studies will assist in  the  design  of
    corroborative epidemiological studies.
  • Studies  to establish  criteria based  on health
    effects for  the  inorganic  chemical  contami-
    nants of  drinking water.
  • Investigation of occurrence of  water-borne
    diseases.  The objective is  to determine what
    diseases  are or may be transmitted by drink-
    ing water, and  the conditions that  allow this
    to occur. This  knowledge will indicate  what
    improvements  in  technology  or  operating
    practices  are needed by the water-works in-
    dustry.
  • Development and  evaluation of  various wa-
    ter-treatment processes  for  the removal  of
    trace organics and taste- and odor-  producing
    substances. Current work involves the use of
    activated carbon and oxidants  such as ozone
    for the removal process.
  • Evaluation and improvement of methods for
    the inactivation of microorganisms  in drink-
    ing water. Studies are being conducted on the
    interference of turbidity with the disinfection
    process  and  on  the  chlorine-resistance  of
    naturally occuring viruses.
  • Evaluation of water-treatment  processes for
    the removal of a variety of inorganic contam-
    inants (arsenic, asbestos, barium,  cadmium,
    chromium, lead,  mercury, selenium, radium).
    Studies of the chemical and bacteriological
    water-quality  deterioration  that  can  occur
    during storage and distribution  of drinking
    water. Methods are being developed to moni-
    tor the quality  of water in the distribution
    system and to minimize  any such deteriora-
    tion in quality.
  • Determination  of the  amounts of  asbestos
    and vinyl chloride leached respectively from
    asbestos-cement and PVC pipes.

Recent accomplishments include the following:

  • A review was made of the incidence during
    the last  decade of water-borne disease out-
    breaks. Causes of outbreaks were investigat-
    ed  so that  the  deficiences  in  water-supply
    systems  and  operation  practices can be cor-
    rected, thus  preventing  the  recurrence  of
    such outbreaks.
  • The first  phase  of the nationwide drinking
    water survey has been completed.
  • A breakthrough in virus quantification.
  • A new sampling  device, the "mini-sampler,"
    has been devised for capture of total organics
    on activated carbon.
  • A water quality monitor has been  developed,
    through contract, to measure physical proper-
    ties as well  as to detect trace  metals  at low
    concentrations.  Measurements include  cop-
    per, cadmium, lead,  flouride,  nitrate, chlo-
    ride,  residual  chlorine,  turbidity,  tempera-
    ture,  dissolved   oxygen, pH,  conductivity,
    hardness, alkalinity, and  corrosion potential.
    Arsenic  has  been  shown to be  removable
    from  water supplies by coagulation  with fer-
    ric  sulfate. Removals  in excess of 95 percent
    can be achieved.
  • Reverse osmosis  has been analyzed as a po-
    tential mechanism  for  the  concentration  of
    organics from drinking water and  appears to
    be promising.
  • The use of cell cultures as test organisms has
    been  demonstrated to  be a  valuable rapid
                                                                                               53

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    technique to determine the  toxicity of inor-
    ganics and organics found in drinking water.

ECOLOGICAL PROCESSES
AND EFFECTS PROGRAMS
  Ecological studies are directed primarily toward
development of criteria to be used in setting water
quality standards.  Two major study areas are  es-
tuaries and the Great Lakes.

  Marine and  Estuarine Research.—The objec-
tives of  the marine and  estuarine research pro-
gram include developing (1) scientifically  and  le-
gally defensible water quality criteria; (2) informa-
tion for assessment  of damage to marine ecosys-
tems from acute and chronic exposures to pollu-
tants; (3) criteria for ocean disposal of pollutants
on marine ecosystems.
  The following studies  were initiated  or contin-
ued in 1974 in response to section 104:
  • Description of pollution stress in  arctic and
    sub-arctic estuarine ecosystems.
  • Ecological  impact of  petroleum substances,
    heavy  metals,  and  synthetic  organic com-
    pounds on coastal ecosystems.
  • Ecological requirements essential for the pro-
    tection  of estuarine ecosystems.
  • Development  of biological  response  models
    indicating the  reaction of  estuarine ecosys-
    tems to pollutional stress.
  • Ecological impact of ocean waste outfalls and
    ocean dumping activities.
  • Ecological  impact of  chlorinated effluents
    from sewage treatment plants and chlorinated
    power plant cooling waters.
  Freshwater Ecological Research.—EPA's fresh-
water ecological research  program at  present  is
focused on five principal areas:  (1) effects of pol-
lutants or  other  stresses  on aquatic organisms,
including  the determination of environmental  re-
quirements  and limits; (2) the  source, transport,
transformation, ultimate fate, and ecosystem-level
effects of pollutants  in  freshwater  ecosystems
generally and in the Great  Lakes specifically,  in-
cluding the impact of water quality control meas-
ures; (3) the eutrophication of lakes,  methods  for
evaluating  the  trophic status of  natural  waters,
and methods for  reversing  or redirecting the un-
desirable  effects  of cultural  eutrophication;  (4)
the effects of man-induced stresses on arctic eco-
systems  as  screening  tools for toxic substances
and as standardized systems for indicating poten-
tial ecosystem-level effects. All of these activities
have either evolved in response to Agency needs
for a data base upon which to develop water qual-
ity criteria and standards, or have been initiated
in direct response to section 104.
   Recent  accomplishments  in freshwater ecologi-
cal research include the following:

   • Developed freshwater aquatic life criteria for
    chlorine and chlorination products  produced
    by the use of chlorine in the  sterilization of
    sewage  effluents  and  as an  antifoulant in
    condenser cleaning for power generating sta-
    tions. These  data have helped identify poten-
    tial  problems   regarding   disinfection   of
    wastes.
   • Developed the test procedures and protocol
    for biologically testing freshwater organisms
    for toxicity of new chemicals. These proce-
    dures are being incorporated  into registration
    requirements  for pesticide  and  other toxic
    substances.
   • Developed data used by the Agency to estab-
    lish  criteria  for  many elements  and com-
    pounds including PCB's, heavy metals, pesti-
    cides, ammonia,  hydrogen cyanide, hydrogen
    sulfide,  temperature,  oxygen  requirements
    and  many other  organic  and/or  inorganic
    chemicals.
   • Assisted various local, State,  Federal, and in-
    ternational agencies  in the development and
    review of proposed  regulations relating to
    water quality and effluent standards.
   • Developed  fluid dynamic plume  models of
    thermal discharge. These models have been
     used by EPA throughout the  nation in court
     actions  involving  application of  the provi-
     sions of S. 316(a) of  P.L. 92-500.
   • Demonstrated   applicability   of   advanced
     waste treatment as  a lake  restoration tech-
     nique. This finding substantiates Agency .poli-
     cy that  eutrophication may  be controlled on
     an individual case basis and that nationwide
     curatives, such as banning phosphates from
     detergents, are not required.
   Great Lakes Research.—EPA's  research  pro-
 gram on the Great Lakes provides a scientific ba-
 sis for assessing the  source, fate, effects,  and
 importance of pollutants  in large lakes in general,
 with particular emphasis  on the Great Lakes. As
 an integral part of this program, predictive mathe-
 matical models for lake water quality management
 are being developed and improved.
 54

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 EPA's research program includes studies of ecological pro-
 cesses and effects. (Dead carp floating in algae, Wiscon-
                      sin.)

  Among the  specific pollution  problems  being
addressed are:
  • Eutrophication  (or  nutrient enrichment)  and
    its effects.
  • Thermal pollution and  related problems asso-
    ciated with power production.
  • Hazardous materials  source,  fate,  and  ef-
    fects.
  • Disposal  of dredging  spoils,  and  ecological
    effects on wetlands of  shoreline construction,
    canal digging, road  construction, and hydro-
    logic modifications.
  As  an  outgrowth of the International Field Year
for the Great  Lakes (IFYGL) program,  a working
mathematical  model of Lake Ontario is  now oper-
ational and is being tested.  Work is under way to
develop  similar  mathematical  models  of Lakes
Erie and Huron so that within  approximately  one
year  there  will be  available  a 3-lake  system of
predictive  models capable  of simulating not only
eutrophication effects within each  lake, but  also
interactions between lakes.
  In support of the above predictive development
and of the International Joint  Commission (IJC)
Upper Great  Lakes  Reference  Study, field  re-
search  continued in Saginaw  Bay  and  southern
Lake Huron.

MUNICIPAL  POLLUTION CONTROL
   Sludge  Program.—With  improvement  of  the
quality of wastewater  treatment,  sludge process-
ing, utilization,  and disposal has become a greater
problem. Utilization of  sludges for beneficial pur-
poses has also received new emphasis, due to the
potential value of the material as a soil condition-
er, low-grade fertilizer and as an alternative ener-
gy source.
   As  more  municipalities  upgrade  facilities  to
improve  effluent  quality, the quantity  of  sludge
will continue  to increase. Table  VIII-1  compares
sludge production in 1972 with the estimated pro-
duction  in 1985. The amount of secondary sludge
will be almost doubled, and chemical sludges will
be produced  in far greater  quantities.  Processing
costs will increase  more than proportionally  be-
cause the biological secondary sludges and several
types of chemical sludges are unusually difficult to
de water.

                   TABLE VIII-1
TRENDS IN PRODUCTION AND DISPOSAL OF MUNICIPAL
          WASTEWATER SLUDGE IN THE U.S.
Sludge type
                            1972

                        Popul. Dry tons**
                        (mill.) per year
    1985

Popul   Dry tons
(mill )   per year
Primary (0.12 lb/cap-day)* 	  145 3,170,000   170 3,720,000
Secondary (0.08 Ib/cap-day) ...  101 1,480,000   170 2,480,000
Chemical (0.05 lb/cap-day)	   10    91,000    50   455,000
Disposal methods
Landfill 	
Utilized on land 	
Incineration 	
Ocean (Dumping and outfalls)

Percent
40
20
25
15

Percent
40
25
35
0

  *  Ib x 0 454 = kg
  ** ton x 0 908 = metric ton
  Reference  "Overview of Sludge Handling and Disposal", J. B. Parrel!, National
 Conference on Municipal Sludge Management, June, 1974

  One  of the  primary objectives of the municipal
pollution  control  research,  development,  and
demonstration program is to advance the technol-
ogy for processing, utilization and disposal  of the
sludges resulting from wastewater treatment and
to improve the cost factors associated with appli-
cation  of the technology.
  The  early thrust of the research program  exam-
ined the  physical  problems and costs of dewater-
ing  sludges, since dewatering capability  is critical
                                                                                                   55

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to final disposition. Moisture content, for exam-
ple,  must be  minimized for sludges destined  for
incineration in order to keep energy requirements
and costs as low as possible.
  Direction of  the  program  is  now  toward  the
application of technologies which offer  new  po-
tential for formulating and applying sludge man-
agement systems  in a cost/effective manner,  in-
cluding full  consideration  of  environmental  ac-
ceptability.
  Beginning in 1974 and for the immediate future,
the program is focusing on the development and
demonstration  of  pyrolysis, co-incineration with
municipal solid waste, and wet-oxidation. These
methods will  require  little  or  no  supplemental
fuel;  will  produce usable fuel  gas and char; and
will eliminate the  microbiological problems asso-
ciated with municipal  sludge, such as  bacteria,
virus,  and intestinal parasites.  Certain methods,
such as wet-oxidation, offer the potential  of recla-
mation of trace metals, and all offer the  potential
for utilization  of waste heat for a  variety  of bene-
ficial purposes.
  A major effort is also being conducted to obtain
the necessary data for the development of guide-
lines  for the application of sludge  to  land. With
the increase  in the cost  of fertilizer the  use of
sludge as a soil conditioner/fertilizer is receiving
renewed interest.  Municipalities  are interested in
more  cost-effective  methods  of  final  disposal of
the wastewater sludges. However, potential health
hazards related to the microbiological  and heavy
metal constituents in sludge have been identified.
Consequently, present efforts  are being  directed
to the collection of information from existing sys-
tems, evaluation of new full-scale facilities utiliz-
ing the newest technology,  and basic  research
studies.
   Wastewater Disposal.—A second area  within
the Municipal Pollution Control program receiving
increased attention is  the land application  of mu-
nicipal wastewater.
  The disposal of municipal wastewater  to  the
land has been practiced around the world for cen-
turies. In the  United States, the practice  began in
about the late nineteenth  century.  The objective
of most  such systems, until  recent  years,  was
simply to dispose of  a community's wastewater.
Little  consideration was given  to treatment effi-
ciency,  environmental  consequences,  or  reuse
potentials.
  The past few years have witnessed  a  renewed
interest in land treatment of wastewaters. Factors
accounting for the trend include concern for reuse
of water and nutrients  and for more ecologically
compatible waste management, emphasis on ener-
gy and  resources  conservation, and a  search  for
more cost-effective waste treatment systems.
  The 1972 Amendments to the FWPC  Act recog-
nized land treatment of municipal wastewaters as
a viable  alternative  for  best  practicable waste
treatment. A major portion of the municipal pollu-
tion  control research and development effort  has
therefore  been  devoted  to  developing the data
base required for the design and successful opera-
tion  of  land treatment systems  to help attain  our
national  goal  of  protecting  our   environment
through effective wastewater management.

  To achieve these objectives, present efforts  are
directed to:

  •  Collecting information from existing  systems
     to help predict long-term effects.
  •  Conducting full-scale evaluation  projects to
     establish system operation and cost data.
  •  Conducting research  to develop the technolo-
     gy  of the three  basic modes of  land treat-
     ment.
  •  Conducting basic studies to ascertain the  im-
     plications  of land treatment related  to  un-
     known factors such as  health  effects, long-
     term effects on the  soil, and  other environ-
     mental consequences.
  Some major land treatment demonstration  and
development projects currently  funded  by the  Soil
Treatment Systems Program are listed  in Table
VIII-2.
                   TABLE VIII-2
         MAJOR SOIL TREATMENT SYSTEMS
              EVALUATION PROJECTS
Location

Belding Mich
Tallahassee Fla

Lake George N Y
Pauls Valley Okla
El Paso Tex

Barnstable County,
Mass

Type of system
Irrigation
Irrigation
Irrigation
Infiltration-
Percolation
Infiltration-
Percolation
Overland-Flow
Overland-Flow
Irrigation
	 Infiltration-
Percolation
and Irrigation
Expected
completion
12/31/77
04/01/77
12/12/75
08/31/77
10/31/76
06/15/76
06/31/75
04/30/80
06/10/76

56

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INDUSTRIAL POLLUTION CONTROL
  Point source discharges of water pollutants are
primarily from the manufacturing industry. Based
on water use  and pollution loads,  U.S. industry
accounts for up to 60% of the use of the nation's
water and also discharges a like percentage of the
man-made pollution load to our streams. In addi-
tion to volume and  discharge loads,  the industrial
water problem is complicated by the physical and
chemical complexity of the wastes discharged, the
extremely  diverse  characteristics   of  industrial
classification,  and a  growth rate  of about  four
times that of the population.

  The Research and Development program,  con-
tinuing in 1974, is primarily oriented toward estab-
lishing a technical basis  for best available technol-
ogy (BAT) regulations for industry. By law-; the
requirements are based on  economic achievabili-
ty. (See Chapter II.)
  EPA's industrial  research,  development  and
demonstration program is directed toward innova-
tive, efficient, and economical methods  to control
the pollution  from  industrial  sources.  This  pro-
gram  provides:
  • Demonstration  technologies  to verify  the
    achievability of BAT for industrial wastewa-
    ter treatment.
  • An expanding data  base for establishment of
    technically and economically feasible effluent
    guidelines.
  • Definition  of  pretreatment  parameters  for
    discharge of industrial  wastes  to  sewer sys-
    tems.
  • Alternative methods for control  of pollutants,
    including process modification  or reuse  of
    water, waste heat, and residual materials.
  In 1974,  alleged inconsistencies  and questiona-
ble  technical-economic  achievability of  some  of
the new standards came under judicial review. As
these  problems are ironed out and the standards
become established, the Agency will have utilized
all the  current storehouse of technology  upon
which the regulations  must be based. EPA's R&D
efforts in this  area must therefore proceed  with
the development of new technologies.  This effort
will be a continuing development process to refine
existing technology  as well as  seeking completely
new solutions.
  The EPA  industrial  R&D program  results  to
date,  in combination  with on-the-shelf practiced
technology, have provided the primary basis for
all the  promulgated regulations. Current projec-
tions indicate a strong EPA R&D technology role
will be a necessity to move the regulations toward
the objective identified by P.L. 92-500.
  Environmental  controls were coupled  with in-
dustrial manufacturing facilities in a cost-effective
manner in 1974.  This was  accomplished by  the
development of pollutant recovery and reuse sys-
tems as well as by  optimization of  manufacturing
process changes  in  lieu of  end-of-the-pipe  treat-
ment technology. As a result, economic benefits
were realized  in  the form of  reduced  treatment
costs, savings in  energy, raw material purchases,
and overall reduced costs of  manufacturing.  In
addition,  significant reduction or elimination  of
toxic  wastes using new  treatment technologies
which  have industry-wide applicability  achieved
indirect cost-effectiveness.
  Examples  are  macroreticular ion  exchange/
spent organic solvent regenerations  and reductive
degradation as applied to  toxic materials such  as
endrin,  heptachlor,  chlordane, toxaphene, PCB's,
DDT, aldrin/dieldrin, etc.
  It  was  determined in  1973  and  confirmed  in
1974 that  treatment technology state-of-the-art,  as
reflected  by EPA's  best  practical technology
(BPT) standards,  falls substantially  short of  elimi-
nating  the discharge of pollutants to the aquatic
environment.  Serious  issues have been raised
concerning  the  economics  of  controlling  toxic
materials  as well as proper disposal of  residuals
wastes. In  1974, efforts addressed  some of  the
most environmentally  critical areas  which would
have a significant economic impact on U.S. indus-
try. The areas of highest environmental-economic
impact are:

  • The economic  achievability of  the  proposed
     1983  BAT guidelines.
  • Adequate technology  for pretreatment and
    areawide waste treatment management.
  • The control of  toxic discharges by industry.
  • Marked  reduction/elimination   of   residuals
    from pollution  control systems.
  • Establishing  cost  effectiveness  of total envi-
    ronmental  control systems wherein  multi-
    media pollution processes are made  compati-
    ble with each other.

  Table VIII-3 indicates the diversity of industrial
pollution  control programs  completed  by  1974.
The cost-sharing  information is representative for
this program area.
                                                                                               57

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EXAMPLES  OF  CURRENT  AND PAST COST-EFFECTIVE DEVELOPMENT AND
                            SORED BY THE INDUSTRIAL POLLUTION CONTROL
                                                        DEMONSTRATION ACTIVITIES  SPON-
                                                        PROGRAM
       Grantee
                          EPA Cost/Total cost
                                                       Objective
                                                                                                  Results
City of Buffalo—N.Y	60K/250K
Onondaga County—N.Y	350/510K
Volco Brass and Copper
  Co.—N.J	
Diamond Shamrock
  Corp. —Ohio 	
    124K/178K
    . 35*K/35K
(USDA Analytical
 Support)  	
     10*K/10K
 American Enka Co. —N.C. .. 283K/980K
 Farmers Chemical Co.—Tenn.l54K/220K
 Del Monte Corp. —Calif.
. Dev. 18K/20K
Demo 50K/71K
 GoldKist, Inc. —Ind	  198K/283K
 Institute of Paper
   Chemistry — Wis. .
    . 40K/150K
 Pacific Egg & Poulty
   Assoc. — Calif	
    . 99K/151K
                 Establish methodology for most cost-ef-
                   fective manner to achieve compliance
                   with EPA regulations for municipalities
                   handling industrial wastes.

                 Establish baseline criteria for post-con-
                   struction evaluation of environmental
                   benefits resulting from an area-wide
                   wastewater management program.
Development and Demonstration of man-
  ufacturing process change, and end-of-
  pipe treatment for recovery of product
  and reuse of water.

Evaluation and assessment of exhaustive
  chlorination as cost effective resource
  recovery and reuse technique through
  chemical alteration/conversion of po-
  tentially toxic/hazardous chlorinated
  still bottom residues from organic chem-
  ical manufacturing.
                 Dev.and Demo, on effective and econom-
                   ically achievable technique to control
                   the discharge of zinc from viscose rayon
                   manufacture. Technique involved zinc
                   recovery.

                 Dev. and Demo, of recycle technology for
                   nitrogenous fertilizer plants. Previously
                   no technology was available for suitable
                   control of NH3 wastes.
Demo, of process modification to mini-
  mize waste generation resulting from
  fruit peeling operations.

Optimization of water and waste manage-
  ment by in-plant controls in poultry
  processing.

Developmental assessment of steam strip-
  ping and activated carbon process to
  reduce BOD from sulfite pulp liquor
  evaporation condensates with accompa-
  nying by-product recovery.

Pilot scale recycle of chiller wastewater to
  reduce BOD output, water use and re-
  frigeration requirements.
                                        On-going project will set a precedent as to
                                          the validity and workability of pre-
                                          treatment standards.
1.  Criteria established.
2.  Control implementation is under con-
   struction.
3.  Results show economic advantage for
   industry and municipality to join in
   effective control within a basin.

1.  Criteria established.
2.  Annual savings of the pollution abate-
   ment effort: $2.61 per ton of finished
   wire.

Conversion of USAF Herbicide OR-
  ANGE, via chlorinolysis, to carbon te-
  trachloride, carbonyl chloride, and hy-
  drogen chloride marketable products
  shown to be feasible. Teratogen "diox-
  in" destroyed/converted to below de-
  tectable limits (10 ppt). Toxicology of
  product CC14 negative. German process
  variant can also process at semi-works
  scale.

For a 2500-ton production plant the proc-
  ess demonstrated cost savings ranging
  from $116,000 to $465,000 depending
  upon the ratio of zinc used.
 Demo, shows that NH4NO3 recovery and
   water reuse can be achieved with mod-
   est cost at 80% closed-cycle. Future
   efforts will be aimed at reducing net cost
   to zero. Currently recover 6,000 tons/yr
   NH4NO-, at $40-60/ton.

 For a 20T/hr dry caustic peeling unit, a net
   saving of $7.82/hr was realized.
                                                          Achieved up to $21,600/month reduction
                                                            of sewer charges.
 Economic feasibility established. Value of
   recovered products and savings in treat-
   ment costs exceed wastewater treat-
   ment cost by just under 6%.
 Preliminary reports on this pilot effort in-
   dicate an expected reduction (approxi-
   mately 60%) in chill water usage, about
   30% savings in energy requirements for
   refrigeration, and about 6% reduction in
   fresh water.
 58

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NONPOINT SOURCE
POLLUTION CONTROL
  The  research and  development program for
nonpoint source pollution focuses  on  the  genera-
tion of management tools and source control tech-
nology for activities such as agriculture, construc-
tion, mining, and spills.
  Evaluation of the status of knowledge  relative
to the  magnitude and impact of land-originating,
diffuse pollutants has indicated certain deficien-
cies. Studies are now under way to answer these
questions. Specific projects include:
  • Development  of mathematical  expressions
    to permit estimates to be made of the  relative
    pollutant  contributions  to  surface   waters
    from various  land  use  activities in  water-
    sheds.
  • Utilization  of these  expressions  to make a
    nationwide  assessment  of  the  severity of
    nonpoint pollution.
  • Further development of management tools to
    evaluate the quantities of agricultural  chemi-
    cals polluting surface waters as influenced by
    changes in climatic,  edaphic,  and land man-
    agement factors.
  • Evaluation of the pollution potential  attend-
    ant with increased land application of  animal
    wastes  and with runoff from  pasture and
    rangeland.
  These  studies are aimed at providing tools to
the decision makers,  such as areawide planning
agencies or  State pollution control agencies. The
information  should help them to evaluate the rela-
tive importance of nonpoint pollution  within their
jurisdictions and  to establish reasonable  control
programs where necessary.
  A  second phase of activity on the nonpoint
problem  is the  development of the techniques to
be applied to  those  areas  where control  will be
required. Evaluations  of  the  effectiveness  of var-
ious  agricultural practices, such as cropping and
soil disturbing  methods,  and animal  waste man-
agement, to conserve soil and avoid water pollu-
tion are being made.
  For further information on the nonpoint  source
control program, see Chapter VI.

EQUIPMENT AND TECHNIQUES
PROGRAM
  Research efforts have been directed to develop-
ing test  procedures  required under various sec-
tions of  the  Act.  New and  improved  analytical
methods  for determining chemical,  and microbio-
logical pollutants have been  or are being devel-
oped for  use both in the field  and laboratory.
Specific   developments   and  major  activities
through 1974-1975 include:

  • Revision of the Methods  for Chemical Analy-
    sis of Water and Wastes  manual.
  • Revision of the biological methods manual.
  • Development of  a microbiological  methods
    manual.
  • Completion  of a  demonstration project  on
    computer automation  of  laboratory instru-
    ments to provide high  efficiency  analytical
    systems for water quality evaluation.
  • Development  of   improved  techniques for
    identification and  quantification of indicator
    microbiological organisms.
  • Development of  improved  fluorescent anti-
    body techniques for the  identification of mi-
    croorganisms.
  • Development  of  improved  analytical  tech-
    niques for the  determination  of  pesticides
    and  other  organic  and radiochemical pollu-
    tants.
  • Improvement of the mass spectroscopic pro-
    cedure for the identification of 25,000 poten-
    tial water pollutants.
  • Completion of evaluation of  a  hydrogen sul-
    fide  sensor  for application to  water quality
    measurements.

QUALITY ASSURANCE PROGRAM
  An Agency-wide  quality assurance program  is
being implemented to  improve environmental data
used by  EPA to  ensure the  validity of the data.
Key elements of the program are  laboratory  quali-
ty control and methods standardization.
  Achievements and major research activities ini-
tiated through 1974-1975 include:
  • Full implementation of the regulation for test
    procedures for the analysis  of pollutants  in
     wastewater  discharges,   implementing  sec-
    tion 304(g) of the Act.
  • Proposed revisions for the regulation for test
    procedures for the analysis of pollutants (40
    CFR Part 136).
  • Ongoing  development  and  distribution   of
    standard reference samples for demand anal-
    ysis, nutrients,  minerals, and  trace  metal
    analyses for internal quality control.
                                                                                               59

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  • Continuing methods  validation  studies  for
    minerals,  nutrients, oxygen demand analysis,
    trace metals, cyanide, and petroleum hydro-
    carbons.
  • Completed evaluation of all  EPA Regional
    laboratory and field  monitoring  support ef-
    forts  and  initiated similar  evaluation studies
    of State laboratories  involved  in wastewater
    and water quality analyses.
  • Completed a formal EPA laboratory certifica-
    tion  feasibility  study  and initiated guidelines
    development for  laboratory  certification, in-
    ter-laboratory comparisons, on-site laborato-
    ry inspections, and laboratory survey proto-
    cols.
  • Initiated development of guidelines for  sam-
    pling and  sample preservation and  for data
    handling systems.
 A Federal-State quality assurance program helps ensure the
 validity of environmental data used by EPA. (EPA biolo-
        gist prepares pesticide sediment sample.)
DATA AND INFORMATION
RESEARCH PROGRAM
  Remote  Sensing.—Efforts have  been  directed
toward demonstration of environmental  applica-
tions of existing remote sensing technology.
  Significant achievements over the past  year in-
clude:
  • Providing technical support to  the Agency in
    the remote  sensing of oil spills and the cata-
    loguing of environmental conditions and land
    uses.
  • Development of a demonstration program for
    application of aerial multi-spectral techniques
    in surveys of waterbodies.
  • Demonstration of  operational   aerial photo-
    graphic and isothermal infrared  capabilities
    for Regional outfall detection.
  • Development  of  an  environmental  photo-
    graphic interpretation system.
  Lake    Eutrophication.—The    eutrophication
threat to selected fresh water lakes  and reservoirs
in the  United  States is being assessed in  conjunc-
tion  with State  water pollution control  agencies
and the National Guard. The Survey is aimed at
developing lake  water quality criteria and infor-
mation concerning point and nonpoint sources of
lake  eutrophication and identifying  possible resto-
ration  measures.
  Major accomplishments   during  the  past year
include:
  • Completion  of all field  work  in the  eastern
    U.S.
  • Reporting of  significant study  findings for
    north central to northeastern U.S.
  • Initiation  of lake  watershed sampling/analy-
    ses in  mid-to-far-western States.

ENVIRONMENTAL MANAGEMENT
RESEARCH PROGRAM
  Engineering, economics, and the  physical,  bio-
logical, and social  sciences, in conjunction with
systems analysis techniques, are brought  together
in an interdisciplinary  effort to develop improved
environmental quality  management methods.  The
program's goal is to provide decision-makers with
data and techniques to improve  the cost-effec-
tiveness  of local, regional,  and national pollution
control programs. Research areas include  environ-
mental quality forecasting and analysis,  compre-
hensive  planning,  procedures  to set  and  imple-
ment  standards, cost  and  benefit   analysis,  and
60

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envionmental impact  analysis procedures. While
the program  focuses on  managing  the  environ-
ment considered as a whole, it also provides man-
agement assistance directly  applicable to water
problems. Recent accomplishments include:
  • A  series  of projects investigating alternative
    concepts for financing the various provisions
    of the Act.
  • Development of procedures  for States to use
    in designing a cost-effective  permit  compli-
    ance monitoring system.
  • Demonstration of comprehensive metropoli-
    tan water quality planning.
  • Analysis  of the comprehensive management
    of phosphorus water pollution.
  • Report on  the use of environmental analysis
    of wastewater facilities by local government.
  • Demonstration of a State water quality man-
    agement  information system.
  • Demonstration of an assessment methodology
    for the  environmental  impact of water  re-
    source projects.
  • Preparation of  a bibliography  of  water pollu-
    tion control benefits and  costs.
  • Development of procedures  for meeting relia-
    bility and  maintainability  goals in  ambient
    water quality monitoring networks.
  • A   cost-effectiveness  analysis   of   control
    methods for agricultural nonpoint sources  of
    pollution.
  Other water  quality management projects ini-
tiated or continued include:
  • Preparation of a comprehensive Report to the
    Congress on the costs of  implementing the
    Act (section 516(b)).
  • Techniques for  minimizing  the  intermedia
    impact of industrial residuals through reuse.
  • Analysis of a wide range of  standards options
    for control of groundwater quality.
  • Analysis of the secondary impact of transpor-
    tation and  wastewater treatment investments.
  • Development  of a handbook  to  assist States
    in implementing optimal compliance monitor-
    ing procedures.
  • Handbook to  assist  State and local  planners
    in the selection of water quality models.
   •  Economic evaluation of implementation strat-
     egies  for control of  agricultural  nonpoint
     sources of water pollution.
   •  An evaluation of current  and potential eco-
     nomic incentives for land use control.
   •  Systems for wastewater reuse in metropolitan
     areas together with a methodology for alloca-
     tion of limited water resources.
   •  Handbook to assist State and local planners
     in evaluating  secondary impacts of wastewa-
     ter systems.

TECHNOLOGY TRANSFER
   Technology Transfer bridges  the  gap between
research and full-scale operational use  by evaluat-
ing newly  developed successful technologies  and
transferring this  knowledge to  consulting engi-
neering firms; municipal, industrial,  and State de-
sign engineers; city  managers; directors of public
works; industrial managers; laboratory directors,
conservation groups; and others  concerned  with
design,  construction, operations,  and  monitoring
of pollution control facilities.

  This program has completed  additional  design
manuals  and  handbooks  in the  on-going series
which  now includes design manuals  for carbon
adsorption,  upgrading existing wastewater  treat-
ment plants, phosphorus removal, suspended  sol-
ids removal, sulfide  control, nitrogen control,  and
sludge  treatment and disposal, and handbooks for
analytical  quality  control,  monitoring industrial
wastewater, and  chemical  methods of analysis.
These  major  comprehensive   publications  have
been widely distributed and  used and are having a
significant effect on environmental pollution  con-
trol  facilities. Additional manuals are currently
under preparation  for both the  industrial and mu-
nicipal areas.

  The wastewater treatment seminar  series  con-
tinued  in  1974 with the total  cumulative attend-
ance at the sessions now totaling over 10,000 engi-
neers and plant managers.  Eighteen publications
evolving  from the seminar  series  are  now being
distributed on a national basis to those unable to
attend the seminar.
                                                                                               61

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                                                                                 CHAPTER NINE
                                                   Waste   Flow
                                                   Reduction
  The  high cost  of  treating wastewater, and  the
environmental impact  of treated wastewaters on
the receiving waters, are major concerns of EPA.
These, in addition to the needs of providing  new
water  supplies  and curtailing  energy  demands,
make water conservation and sewage  flow reduc-
tion measures an important consideration in water
supply and wastewater treatment planning.
  The  Act calls for  EPA to conduct research on
devices and policies for  reducing water  consump-
tion and the total flow  of sewage. (Section  104
(o).) EPA's first  investigations (reported in June,
1974) found potentials  for reduction in water  con-
sumption and sewage flow in the home, in indus-
try, and through infiltration/inflow control.   Re-
search has continued in all three of these areas.

THE CURRENT QUANTITY OF FLOW
  Current  withdrawals from  the  nation's waters
exceed 370 billion gallons per day (bgd). Of  this
total, direct industrial withdrawals constitute 47
bgd and public water supply is 27 bgd. This report
focuses on means for reducing this 74  bgd volume
of  water.  Withdrawals  for irrigation  (130  bgd),
livestock and rural uses  (4.5 bgd) and steam-elec-
tric power  plant cooling (170 bgd) are excluded
from  the discussion.  While these categories  are
major  ones (see Table IX- 1), they do  not involve

                    Table IX- 1
 TOTAL WATER WITHDRAWALS BY PURPOSE, 1970 (bgd)

Public water utilities .................................................. 27
  Industrial and commercial .................................. 9
  Domestic, municipal & losses ............................. 18
Industrial and miscellaneous ....................................... 47
Rural, domestic &Hvestock ....................................... 4.5
Irrigation [[[ 130
Steam-electric utilities ............................................... 170
public water supplies  or  require municipal or in-
dustrial wastewater treatment.
  Industrial and commercial water  supplies  are
primarily  withdrawn directly (47  bgd);  a smaller
portion is obtained from  public water supplies (9
bgd). Similarly, most  industrial and business dis-
charges go directly to the receiving  waters, with
only  a small  portion  discharged to sewers  (7.3
bgd.) (Table IX-2.)
  Domestic users obtain about 18 bgd from public
water  supplies. Deducting  the  portions  going  to
septic tanks, outdoor sprinkling, and  other losses,
domestic and  municipal  flows to sewers are esti-
mated to  be 10.6 bgd. Total municipal  treatment
plant flows are estimated to  be 24.0 bgd. Deduct-
ing the above  estimates of domestic and industrial

                   TABLE IX-2

ALLOCATION OF PUBLIC WATER SUPPLIES AND
     AMOUNTS DISCHARGED TO SEWERS, 1970 (bgd)


Industrial — large users 	
— small users 	
Commercial 	
Domestic municipal and losses
Losses (10%)' 	
Municipal (10%)2 ....
Residential with septic tank (10%)3
Sprinkling (25%)4 	
Domestic (in-house) use and sewage

Water 1
supply
9 0
4 5*
	 1 3***
.... 3 2**
18 0
	 1 8
1 6
	 1 5
	 3 3
	 98

teaching
sewers
7 3
28*
1.3
3.2
10 6

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discharges, the residual infiltration and storm flow
is estimated at 6.1 bgd.
                  TABLE IX-3
  BREAKDOWN OF MUNICIPAL WASTEWATER FLOW


Total flow in wastewater facilities
Industrial and commercial
Domestic
Residual: infiltration and storm flows
Flow
(bgd)
24.0*
7.3
10.6
6.1

Percent
100
30
44
26
 * Flow from municipally owned wastewater facilities in 1974 is estimated at 27 bdg
 (Municipal Waste Facilities Directory, 7/9/74, total of 24 7 bgd, adjusted for plants
 with no flow data) Three percent annual growth rate is assumed to estimate 1970
 flows
    In an  effort to  reduce the total  quantity of
wastewater generated and the demand for treated
public water supplies, EPA is conducting research
in the  areas of sewer infiltration/inflow and  in-
dustrial and home water conservation.

INFILTRATION AND INFLOW
  Infiltration and inflow refer to water which  gets
into  the  sanitary sewer  system through  leaks in
sewer  lines,  or from  drains on  buildings being
connected  to  sanitary sewer systems. It  is esti-
mated  above that infiltration/inflow accounts for
up to  25%  of  total  treatment  plant flows; other
estimates have been  up to 30%.
  The  Act  requires  all new  applicants for treat-
ment works grants to demonstrate that each sewer
system discharging  into the proposed treatment
works  is not subject to excessive  infiltration/in-
flow  (I/I). EPA's construction grant  regulation (40
CFR 35.927) and supplemental Guidance for Sew-
er System Evaluation (March 1974) implement the
Act's mandate.  The publications recognize that
some infiltration/inflow costs more to correct that
it does to treat. For these cases they insure that
the I/I flows are reduced to  the extent it is cost-
effective  to do so.
  Basically, the grant regulations  call  for the  fol-
lowing:
  • I/I analysis: An in-depth  study of the past
    records, rainfall and other pertinent informa-
    tion  relative to  the sewer system,  to  deter-
    mine whether excessive I/I may exist.
  • Evaluation  Survey:  When excessive  I/I  ex-
    ists, a physical  survey of the  sewer  system
    followed by detailed cost-effectiveness  analy-
    sis.
  • Rehabilitation: Physical  correction of  all  I/I
    sources that are previously determined to be
    cost-effective to repair.
  Of  the 640 projects currently under I/I  study,
only  27%  have  excessive  I/I.  These  projects,
ranging in size from .04 to 200 million gallons per
day flow, are presently  under evaluation survey
(task  2). Techniques for I/I  study  and correction
are relatively new and  complex. Therefore EPA is
preparing a new technical bulletin  describing I/I
methodology for  use as a guide by  designers and
municipalities. In addition, the National Environ-
mental  Research Center  in  Cincinnati, Ohio,  is
directing several projects  on analytical methods
and technologies  relating to infiltration and  inflow
control, as follows:
Analysis of Practices for Preparing An Economic
Analysis and Determining Infiltration
  The American Public Works  Association has
received a  grant to report on and prepare a man-
ual of practice on the practices used to determine
infiltration  and inflow in sanitary  and combined
sewers, and  develop  a framework  for economic
analysis to determine  whether or  not  infiltration
should be  reduced or pipe/plant size  increased.
The economic analysis will develop a  manual of
practice for unit  costs of repair, replacement, or
corrective action required to  minimize infiltration
and for the unit  costs of the affected  wastewater
treatment facility.
Demonstration and Evaluation  of The  Use of
Impregnated Concrete Pipe and other Methods of
Infiltration  Control
  The Texas Water Quality Board  has received a
research grant from EPA to perform a demonstra-
tion and evaluation of  impregnated concrete pipe.
Corrosion of concrete sewer pipe is  a major cause
of leakage  and failure in sewer pipes which  re-
sults  in infiltration. A  method of impregnation to
increase the  corrosion/erosion  resistance,  im-
permeability  and strength of concrete  pipe has
been developed under another EPA-funded  study.
This study will further evaluate  the performance
of the new method.
Trenchless Sewer Construction And Sewer Design
Innovations
  EPA has funded  a research project in the town
of Bethany Beach, Delaware, to evaluate trench-
less sewer  construction.  The project will demon-
strate a new sewer construction  method  which
promises to  be  less costly and  more rapid than
conventional construction and will  overcome the
problems of high water table, unstable soil,  asso-
ciated infiltration and  expensive  manhole  con-
struction. A  thorough  two year post-construction
evaluation is to be included.
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HOME WATER CONSERVATION
  Public water supply, the major source of the
homeowner's water, is responsible for only about
7% of  total U.S.  withdrawals. At  first  glance,
therefore, home  water use does not seem very
significant. However, water for public supplies is
costly to provide. Often it must be conveyed for
long distances. Before use, it  must be treated  to
potable quality, and after use  it must be treated
again before being returned to the environment.
Thus, public water supplies and  municipal treat-
ment are  important both economically and  envi-
ronmentally. Individual households account for  an
estimated 60% of delivered water and generated
sewage.
  Interest in home water conservation is growing.
Particularly where public water  supplies are  di-
minished to critical levels or where sewage treat-
ment capacity is  limited, public  discussions and
other  activities  are  increasing.  Because water
supplies and  sewage  treatment capacity remain
readily available and inexpensive in many areas of
the country, however, this interest is not univer-
sal.
  The major ways to reduce household water use
and  sewage  flows  are  through water saving de-
vices and user charge policies.

Water Saving Devices
  A considerable amount of  research  has been
and  is being conducted  on water-saving devices.
From  individual  inventors  to  major  plumbing
manufacturers, industry  is responding to the flow
reduction objective.
  A number of devices have been developed that
can be retrofitted to existing plumbing fixtures and
appliances.  Tests  show that many of the  devices
perform acceptably,  are  simple to install,  and
save  enough water  to  make  them worthwhile.
Many  of these home  water  saving devices  are
commercially available.
  Other research, conducted for the  most part  by
manufacturers, has concentrated on  the  develop-
ment  of  completely  redesigned water  saving
plumbing fixtures and appliances. These  fixtures
generally perform better than  conventional retro-
fitted fixtures, but their  higher cost makes them
practical  principally  for  new  installations or  re-
placement of  non-working  units. A number  of
water-saving plumbing codes, such  as that insti-
tuted by  the Washington (B.C.) Suburban Sani-
                    Figure IX-1.
  Damming devices, which hold back some of the water in a
  toilet tank, reduce the amount used in flushing and thus
                    save water.

tary Commission,  require the use of water-saving
fixtures for new or replacement installations.
  Much of  the credit  for  the rising interest  in
home water  conservation  goes to the efforts  of
concerned public utilities. The Washington  Subur-
ban Sanitary Commission, for example, has been
extremely active in promoting conservation by  its
customers. Beginning in 1970, the  WSSC has run
public  education  programs,  tested  and demon-
strated  water saving devices, revised its plumbing
code, distributed  displacement bottles  for toilet
tanks and shower flow-restricters to its customers,
and more recently  has begun an extensive  educa-
tion program in the elementary schools. This pro-
gram has served as a model; other utilities, such
as the Marin County (California) Municipal Water
District have instituted  a program  similar  to  the
WSSC's.  The adoption of these devices depends
to a large extent on whether or not the savings in
water and wastewater bills,  generally rather low,
provide an incentive for the homeowner to incur
the cost of capital outlay for aquisition and instal-
lation. Some data on water  savings and costs  of
such devices have been specified in previous pub-
lications of  EPA,  and further guidance is being
prepared.*

  *Federal Water  Quality Administration, A Study  of Flow
Reduction and  Treatment of Waste Water from Households.
James R. Bailey,et. al, Washington, D.C. 1969 NTIS PB 197-
599.
  U.S. Environmental  Protection Agency, Demonstration of
Waste Flow Reduction from Households, Report No. EPA-
670/2-74-071. National  Environmental Research Center,  Cin-
cinnati, Ohio. 1974. NTIS PB 236-904/AS.
64

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                                SAVING WATER IN THE HOME
       The most promising areas for inside the
     house water saving with devices appear to
     be the toilet and the shower. Toilet flushing
     and bathing account for approximately 39%
     and 34% respectively of inside water use. A
     number  of  workable  methods  have  been
     developed to reduce  the  amount  of water
     used in toilet flushing. The simplest  devices
     are displacement or damming devices which
     hold back some of the water in a conven-
     tional toilet tank and thus reduce the  amount
     of water used in a flush. Slightly more com-
     plicated  are dual  or regulated flush  devices
     which allow the user  to select a small flush
     for liquid  waste and  a larger  one for solid
     waste. Another alternative  is  a completely
     redesigned toilet which uses less water for a
     flush. Toilets which  use  water more effi-
     ciently are now readily available to consum-
     ers and are  in fact required in some places
     for new  installations or replacements. Other
     toilets have been designed  which use  little or
     no water at all. These include vacuum toi-
     lets, chemical toilets, incinerator toilets and
     composting toilets. The expense, complexity
     and  in  some  cases  the  inconvenience  of
     these units make them practical  primarily in
     extremely water  short areas or  in  areas
which do not have public water supplies and
sewers.
  Second to the toilet, the largest controlla-
ble in-house water use is the shower.  Con-
ventional  shower  heads use  between 5  and
15 gallons per minute. In a leisurely shower,
the high flow can  use large amounts of  wa-
ter, all of which goes into the sewer. Rede-
signed  shower heads  can  reduce  flows to
three gallons per minute or less and provide
even  a sybarite with a pleasurable  shower.
These shower heads  are usually not expen-
sive and  can pay  for  themselves  in water
savings to the consumer (when the consumer
pays for water on the basis of use). Other
devices,  which are more  expensive,  allow
the user to  shut off the shower flow at the
shower head while soaping up then turn it
back  on without disturbing  the  temperature
adjustment.  A simple, cheap and easily  in-
stalled device, designed  by Virginia  Poly-
technic Institute, consists of a plastic insert
which, when installed in a showerhead, re-
duces  the flow to 3.5 gallons  per  minute.
These devices were distributed by the WSSC
to all  of its customers who wanted them and
they appear to be  performing acceptably. A
similar device has  been developed to reduce
flow in other types of household faucets.
Pricing Policy and Rate Structure
  The Flow Reduction  Potential.—Basic  to  the
efficient use of resources is the idea that consum-
ers  should pay a price that reflects the cost of the
good or service being provided. Pricing policy and
rate structure  for  water and sewage  service can
help in achieving a cost-efficient  level of conser-
vation.
  EPA  is directly  involved  in the  question  of
municipal pricing policies. In order to qualify for
a construction  grant  under the 1972 Act, grant
applicants must agree to  adopt a policy  of  user
charges for sewage service. The main  purposes  of
such user charges,  according to EPA guidelines,
are  (1)  to  distribute  the cost  of operation and
maintenance of publicly owned treatment works
to the pollutant source,  (2)  to  achieve  self-suffi-
ciency of treatment works with respect to opera-
tion and maintenance  costs, and (3) to provide for
recovery of capital costs for the portion of capac-
ity funded by the Federal government and utilized
by industry.
  A  fourth  purpose  which  a  user  charge  system
can fulfill is that of encouraging the conservation
of water and   reduction  of  wastewater  flows.
However, the Act does not require that this func-
tion be served by the user charge  system institut-
ed by grant applicants. Rather,  it is designated in
section 104(o) as a matter to be studied. Whether
or not the fourth purpose is  achieved  hinges  on
two questions:  are  charges based  on flows, and
are charges  set to reflect incremental costs?
  Metering  and  Billing—To encourage  conserva-
tion through the  user  charge  system, users must
                                                                                               65

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be metered and the user charge system  must in-
clude a cost component based on individual flows.
For  example, a  "flat-rate" monthly charge per
dwelling  unit might serve the purpose of allocat-
ing treatment costs among users, but it would not
reward a householder  for producing less wastewa-
ter—or penalize  him  for producing  more—than
the average. If his water and sewage use rises, he
essentially  pays a  zero  price  for the  added
amount:  he has no incentive to conserve.
   In some situations, it  may  not be worth at-
tempting to  achieve   conservation  through  the
price system: the savings in terms of water and
wastewater costs may be less  than the required
expenditures  in terms of  other  resources—e.g.,
the cost  of  metering  and billing.  However, de-
mand elasticities suggest that pricing is a  generally
promising approach (see "The  response  to incre-
mental costs," below).
   Analysis of  pricing requires consideration  of
both water and sewage,  for two  reasons.  First,
although the  outdoor (sprinkling)  use  of water
does  not affect wastewater flow,  the  in-house
(domestic) use of water  and sewage  are, in  eco-
nomic terms,  complementary services—consumer
use depends  on the prices of both. Secondly, the
two  are  related  in terms  of  measurement  tech-
nique. Meters to measure sewage flow directly are
expensive and seldom used, but such flows can be
estimated from  the metered use of water. Where
sprinkling use  of water is substantial, for exam-
ple,  water use during winter  months has  been
used to provide an estimate of domestic water use
(and hence sewage flow). Thus, the availability of
water meters permits  sewage charges also  to  be
based on flow.
   Metering and billing for water  supply is wide-
spread.  Perhaps 75-80% of the public water sup-
ply through-put in the U.S. is metered. A  large
part of the unmetered use occurs  in several  large
cities—New  York, Chicago,  St.  Louis, Denver
(now undergoing metering) and  Portland,  Ore-
gon—where large commercial and industrial  users
tend to be metered, but single family residences,
and  sometimes apartment houses, are not.
   Where water meters are used, sewage bills are
frequently based on flows, either through a charge
directly related to flow or through calculating the
sewage bill as a fraction of the water bill. A sur-
vey  taken for  EPA indicates  that  either form of
sewage flow  charge is used by about 67% of the
agencies for  residences and even more frequently
for  multifamily  dwellings  (72%),  commercial
(85%) and industrial (87%) users.
  In general, it  seems that water bills are higher
than sewage bills.  Though there is considerable
variation with city size, etc., for  water the typical
monthly residential bill indicated in 1970 data is
over $4, for sewage about half as much. The typi-
cal flow charge  for water  for that date is on the
order of 400 per thousand gallons in the last  price
block; for sewage charges data is not available.
  Improving the Techniques.—The figures  indi-
cate that, in a majority of municipalities, billing
gives some  incentive for water  conservation and
waste flow reduction. However,  most utilities are
required to set their rates in terms of average, his-
torical costs. In contrast, to promote the efficient
use of  water  and sewer services,  prices at the
margin  (the  last  block rate) would be equal to the
incremental  cost of providing the  service.
  The implications of this approach for water and
sewer pricing  are far from thoroughly developed,
but would frequently imply that prices at the mar-
gin should be higher than at present. For exam-
ple, in many areas, incremental unit costs of new
water supplies are greater than average historical
costs.
  For many waste treatment plants unit costs de-
cline as capacity increases, because of economies
of scale.  Here, the incremental costs might be
less  than average costs. However, as  many as
half  of  all treatment plants are  located on water
quality  limited streams, where an increase in sew-
age flows requires  progressively higher  levels of
treatment—and, very likely, increasing unit costs.
Therefore, unit sewage charges greater than  aver-
age costs  may frequently be appropriate. In  these
cases, where incremental unit costs are increasing
(in constant dollar terms), the policies  generally
followed by utilities fail to discourage excess use
of water and sewage.
  As a dramatic example, Southern California is
an extremely arid area with large water demands.
New water  supplies  have to be brought great dis-
tances  at great  cost, yet  unit charges for water
appear  to be  no greater than in the rest of the
country. Because a large part of  the cost of water
supply  is  covered by a property tax, water  rates
do not  even cover average costs, let alone incre-
mental  cost.
  Response to Incremental Costs.—The feasibility
of flow reduction  through metering and  pricing
depends to  a large extent, of course, on  the re-
sponsiveness of users to increased charges — the
 66

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elasticity of demand. In the most thorough analy-
sis  of  this question to date, the elasticity of de-
mand  for  water  used for  sprinkling  was  fairly
large; for domestic (in-house) use, the elasticity of
demand was smaller, though still significant.
  The elasticity estimates are:
   • Sprinkling use in dry western areas: .7% use
     decrease per 1% price rise
   • Sprinkling use in humid  areas:  1.6% use de-
     crease per 1% price rise
   • Domestic users  overall:   .23%  use decrease
     per 1% price rise
These  elasticity  estimates  apply  to small  price
changes. For  larger  changes,  of the  magnitude
often  called  for,  the effect  must be  calculated
from the demand equations.  Illustrative cases  of
doubling the flow charge from 200  per 1000 gal-
lons to 400 per 1000 gallons might result in a 40%
reduction in sprinkling use in the west and  a 10%
reduction in domestic use. Hence, the elasticity  of
demand for water appears  sufficient  to warrant
careful attention to pricing policy.
   Summary.—Legislation and  regulation of user
charges is directed primarily  toward an equitable
allocation  of costs, and  toward self-sufficiency  of
wastewater  agencies.  For example,  the Agency
has proposed  that ad valorem charges be  permit-
ted to continue where these goals can be met (Ap-
pendix C). However,  EPA is also studying user
charge policies  designed to  encourage the eco-
nomic use of water supply and wastewater services.
 INDUSTRIAL WASTE FLOW REDUCTION
   Industry  is, of  course,  one  of the  primary
 sources of  water pollution, directly withdrawing
 and  discharging  massive  amounts  of  water,  as
 well  as being a significant  user of public facilities.
 (Tables IX-1, IX-2,  and  IX-4) Because  of this
 importance, EPA maintains a broad program  to
 develop  industrial  pollution control technology.
 Many  of  the  projects are specifically  related  to
 internal recycling, a primary technique in reducing
 industrial waste  flow. For  many  industries,  the
 high  cost of end-of-pipe treatment, the  economies
 of treating  more concentrated waste,  and  rising
 water supply costs  have made recycling and other
 methods of  improved  water  management econom-
 ically attractive.
   The latest census of water use in manufacturing
 indicates that recycling has increased  rapidly  in
 recent  years. The extent of  recycling is indicated
                    TABLE IX-4
     WATER USE IN MANUFACTURING, 1973 (BCD)*
                                 Fresh
                                     Brackish
                                      & salt
                                              Total
Intake by source
  Public water systems ....
  Company water systems
4.5
4.5
Surface . . 	
Ground 	
Tidewater 	
Total 	

Discharge by type
Public utility sewer 	
Streams and rivers 	


Ocean 	 	
Ground 	

Total 	

Purpose of intake
Process 	
Steam electric power generation ...
Air conditioning 	
Other cooling and condensing 	
Sanitary service 	

Total 	

23.8 1 2
42 04
1.0 6.1
33.4 7.7
Flow
(bgd)
2.8
24.9
3.3
6.2
0.5
0.6
0.5
38.8
Flow
(bgd)

10.8
7.5
0.8
19.8
0.6
1 8
41.2

25 0
4 5
7.1
41.2
Percent
7.3
64.2
8.6
16.1
1.2
1.5
1.2
100.0
Percent

26.3
18.1
1.8
48.1
1.4
4.3
100.0

  *Water Use in Manufacturing, 1972 Census of Manufactures, Bureau of the Cen-
sus Data cover establishments using over 20 million gallons per year, estimated to
account for 97% of water use Details in some cases do not add to totals because
of rounding The water withdrawals given here are less than those in Table IX-1,
because mining is excluded here and perhaps because of other differences in the
method of estimation. Power generation here refers to that in industrial plants
                    TABLE IX-5
WATER INTAKE AND RECYCLING IN MANUFACTURING*

1954 ..
1959 	
1964
1968 	
1973

Water
intake
(bgd)
31 7
33 2
38 3
42 3
41 2

Gross Water
use
(bgd)
57 6
71 9
81 6
97 5
128 7

Ratio
gross use/
intake
1 O-J

-JIT
7 7. 1


Change in
ratio



-1.4%

35.5%
 •Water Use in Manufacturing, 1973, p SR4-7
by the ratio of gross water use (intake plus recy-
cled water) to water intake. This ratio was 2.31 in
1968 and 3.13 in  1973—indicating a 35% increase
in water use per  gallon of intake over the 5-year
period. This increase is greater than that in earlier
inter-census periods and may account for  the fact
                                                                                                    67

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that in the  1973 census, for  the first time,  water
intake in manufacturing declined (Table IX-5).
  A number of research projects related to  water
conservation  and  waste flow  reduction  were dis-
cussed in the last Report to Congress. Those dis-
cussed here are those which  are  presently  under
way, or were completed in 1975.
   Research being conducted in the food and kin-
 dred products  industry is of particular  interest in
 terms of  wastewater flow reduction. It is estimat-
 ed that over 21% of  the total  national  manufac-
 turing pollution load  is  contributed by this  group
 of  industries. More importantly from  a waste flow
 reduction standpoint, in  1973, 30% of  the wastes
 of  this  industrial group was discharged  to munici-
 pal sewer  systems.  Thus, while other  industrial
 groups  use  more water,  this group  discharges
 more wastewater to  municipal systems. Clearly,
 the studies  done in the food  and kindred products
 industry  offer  significant potential  for lowering
 industrial wastewater flows  to municipal systems.
 These  studies,  which  illustrate the  type  of re-
 search being carried out in the industrial area, are
 the following:

 Tomato Cleaning and Water Recycle
 National Canners Association
 Washington, D.C.
  This study will demonstrate low water use cleaning of toma-
 toes and recycling of the  tomato transport water. Water use
 for cleaning should be reduced from the present 700 gal/ton to
 6 gal/ton. In  combination  with the recycle system the water
 use for receiving and  cleaning should be reduced  from 930 ga/
 ton to 120 gal/ton.
 Reuse of Treated  Fruit Processing  Wastewater Within a Can-
  nery
 Snokist Growers
 Yakima, Washington
  This study will evaluate the feasibility of reclaiming end-of-
 pipe  process  wastewater  for  reuse within  a fruit  cannery.
 Reuse of the reclaimed water will be evaluated for a variety of
 different uses within the plant including cleaning, cooking and
 cooling.
 Integrated  IOB Vibratory Blanch  Cooler for  Reducing Pollu-
  tion Caused by Blanching of Vegetables
 American Frozen Food Institute
 Washington, D.C.
  This study will evaluate on a proto-type scale, a new type of
 system  in  which  the steam condensate from the vegetable
 blancher (IOB) will be utilized for spray cooling of the product
 prior to freezing.  Significant reductions in liquid effluent vol-
 ume (90%), and in the organic (70%) contained therein should
 be  demonstrated when  compared to current industrial prac-
 tices.
 Poultry Processing Wastewater Reuse Effects on Product and
  Water Safety
 Maryland State  Dept. of Health
 Baltimore,  Maryland
  This project is to evaluate the safety for human consump-
tion of poultry processed in a plant utilizing reclaimed  waste-
water in a closed loop water system. The poultry plant will
recycle about 50% of their own processing wastewater.  Safety
will be determined by relative amounts of contaminants  before
and after recycling begins.
Egg Breaking and Processing Wastes
Cornell University
N.Y. State College of Agriculture and Life Sciences
Ithaca, New York
  This project intends to  determine the magnitude  of the shell
egg and egg breaking and processing waste problem  and to
explore  waste  management  methods  that are  applicable to
these wastes. One of  the major objectives  of  this project  is
identify  opportunities for in-plant waste reduction and water
reuse.
Ecostatic Cane Processing System
C. Brewer and Co., Lmt
Hilo Coast Processing Co.
Pepeekeo, Hawaii
  This  project  involves  a full-scale demonstration  of sugar
cane harvesting and processing with water reuse and solid
waste recovery which will result in major reductions in  wastes
discharged.
Characterization and Reduction  of Specific  Wastewaters from
  In-Plant Hog Processing Units of the Meat Industry
University of Wisconsin
Madison, Wisconsin
  This project will characterize  wastewater from  critical unit
operations in hog slaughtering and associated cleaning process-
es, and  will develop and  demonstrate  methods  and equipment
for reduction of the flow  and waste load from these unit oper-
ations.
Minimization of Water  Use in Leafy Vegetable  Washers
Dulaney Foods Inc.
Eymore, Virginia
  This  project  involves the installation of a full-scale  experi-
mental leafy green vegetable  washer on a commercial process-
ing line. Performance of the experimental, water  saving unit
will  be  monitored and compared with that of conventional
vegetable washers.
Shrimp  Cannery Wastewater Treatment Demonstration  Project
American Shrimp Canners Association
New Orleans, Louisiana
  An in-plant water conservation and  management program
will be instituted along  with several possible process  modifica-
tions. The resulting effluent will be treated (plant scale) by
screening and dissolved-air  flotation  with chemical  addition.
Screening and sludge will be processed for ultimate disposal.


   Other industrial  groups  where studies  are  being
conducted in the  water  conservation and  waste
flow reduction area  are the chemicals and  allied
products  industry;  the pulp,  paper,  paperboard,
lumber and   wood products industry; the  textile
mill products industry; and the  metal and  metal
products  industry.  Most  of the  studies in  these
industries that relate to waste  flow  reduction con-
centrate on recycling the  water used in the  plant.
68

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For  each  of   the  industrial  groups   mentioned
above one representative study will be discussed.


Treatment of Petrochemical Wastewater for Reuse
Union  Carbide Corporation
New York, New York
  This project will  develop feasibility, design,  and economic
data on petro-chemical wastewater upgrading and  subsequent
reuse by  testing a pilot-scale  system comprising an integrated
sequence of the most promising treatment steps for upgrading
bio-treated  petrochemical effluents for  use in pilot-scale  heat
transfer systems.
Aircraft Factory Waste Water Recycling, Pilot-Scale Demon-
  stration
Boeing Commercial Airplane Co.
Seattle, Washington
  The  objective of this program is a pilot-scale demonstration
of treatment and  recycle  of  four dilute wastewater streams
resulting  from  aircraft  manufacture.  Both recurring and  non-
recurring costs of a full-scale  recycling plant  will be deter-
mined.
Pollution Controf Facilities, Textile Mill
J.P. Stevens & Co. Inc.
Greensboro, North Carolina
  One objective of this project is to produce an effluent from
a synthetic fabric finishing plant which will have a  5-day BOD
and suspended solids of 5 mg/1 or less and minimum dissolved
oxygen of 5 mg/1 using multi-media filtration. A second objec-
tive of the project is to determine the feasibility of  wastewater
reuse in the manufacturing process.
Water Reuse in a Paper Reprocessing Plant
Big Chief Roofing Company
Ardmore, Oklahoma
  This project is concerned with the treatment of paper repro-
cessing wastewater in a facility designed for water reuse. The
economic feasibility of wastewater  recycle and various treat-
ment  alternatives will be determined from lab  and full-scale
tests.
                                                                                                                     69

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                                                                          CHAPTER TEN
                                              Public
                                              Participation
                                              and   Advisory
                                              Groups
PUBLIC PARTICIPATION—
"THE SINGLE MOST IMPORTANT
INGREDIENT"
  EPA is unique among Federal  agencies in the
scope of its public participation  responsibilities.
No Agency has received a broader Congressional
mandate  to encourage public  involvement in  a
program than did  EPA in section 101(e)  of the
1972  FWPC Act amendments.  The Act requires
that the Agency encourage, assist and provide for
public  participation in virtually every  significant
aspect of the water program.

  This commitment to public involvement, which
EPA Administrator Russell E. Train has called
"the single most important ingredient in the envi-
ronmental management process," requires  much
more  than traditional forms  of  public involve-
ment. Imaginative new programs which  actively
promote public activism are essential.  If reaching
the public by tape cassette— a creative, success-
ful approach developed in EPA Region V—  is
more effective  than the printed word, then tapes
should be used. Furthermore, more innovative pro-
grams should be attempted. Unfortunately, while
several  new programs have been created, much
remains to be done.

   Continuing  Programs.—Some  agency  public
involvement activities, though traditional, are still
essential to a sound public participation program.
Through its Public Affairs Offices, the Agency dis-
tributes more than fifteen booklets and pamphlets
explaining the water program  and informing citi-
zens about means for involvement. The  Agency
and the States have conducted numerous public
hearings, as required by law or requested by citi-
zens, dealing with all major programs in the Act.
During 1974, public meetings included:
  • State Program Plans (in seventeen States).
  • The Construction Grants Program (all States).
  • The State Basin Plans (sixty meetings across
    the nation).
  • The Areawide Waste Treatment  Plans (twen-
    ty-seven hearings).
  • Industrial Permits  (approximately one hun-
    dred hearings).
  EPA also utilizes  a  wide  range  of  advisory
committees to promote  continuing  consultation
between its program officials and public or private
interests affected by the water program. Among
the most active of these is the Committee of Ten,
formed in  1972  to  bring  together  State water
planning  officials with Regional  Administrators,
Deputy Regional Administrators and senior EPA
Headquarters  staff for  discussion of water pollu-
tion programs. Committee members,  each repre-
senting an EPA  Region and selected by constitu-
ent States in each Region, consult with State offi-
cials before and after Committee  delibe'rations.
The Committee, working also through numerous
subcommittees dealing  with each major program
in the Act,  assures  continuing communication
between EPA  officials at all levels and local inter-
ests affected by Agency activities.
  A  New Direction.—Publications,  public hear-
ings and  advisory committees, however, are  not
enough  to  satisfy the  requirements of section
101(e). In an effort to communicate  directly with
the public and activate its  interest  in water pro-
grams, several more innovative public participa-
tion activities  in addition to the tape  cassette pro-
gram were planned and implemented during 1974.
70

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Among the most successful was a  three-phase
public  involvement program begun in 1974 with
"Water Quality Training Institutes" conducted in
each  Region  by  the  Conservation  Foundation
under an EPA grant. The  Institutes, attended by
863 individuals  representing a  variety of  public
and private groups, informed  participants about
the goals and  procedures of the water program in
great detail and with particular attention to meth-
ods of  citizen influence. To intensify the  Insti-
tutes' impact, follow-up "Workshops", organized
by Institute participants, were held in each State;
more  than 8,000 individuals attended 105  Work-
shops. The final phase,  an Awareness/Information
Program, will  bring the  activity to local communi-
ties.
  During  1975,  forty-six program leaders  and  36
groups will work to stimulate local interest in  the
Act. This program is aimed  especially at non-en-
vironmental  groups—those  commonly  least  at-
tuned to water pollution control activities. Lead-
ers in the Awareness/Involvement Program  accept
a responsibility to speak formally to at least twen-
ty such organizations  within their area of geo-
graphical responsibility.
  Despite  such  useful  programs,  much  more
should be done. The public is vitally affected by
the program  but  often  cannot readily understand
its  complexities.  In particular, "translating"  the
program into layman's  terms and  involving  the
public in  the early planning stages of policy—as
the Act requires—involve sustained,  face-to-face
contact between the public and program officials.
   More  Must be  Done.—What  more  could  be
done? Special participation activities  tailored to
specific programs could  be organized as such pro-
grams  assume  particular  national  importance.
Within the next two years, for example, extensive
planning for areawide  waste treatment programs
will be conducted  across the  United States,  and
public  participation  will  be  a  major  program
objective.
   EPA is  currently  encouraging designated  208
agencies to seek out actively the publics affected
by their program and to explain its implications in
terms  readily understandable  to laymen.  About
7.5% of the $163 million granted to these agencies
for areawide waste treatment  planning will be al-
located for public involvement activities—a poten-
tially important source  of funding for such a pro-
    A concerned public is essential to the nation's clean water goal. (Fly fishing in salmon stream below paper plant east of
                                           Bangor, Maine.)
                                                                                                 71

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gram.  The innovative programs  so far accom-
plished  suggest  the  constructive possibilities in
public   participation   as  envisioned by section
101(e). The challenge is  to  bring these activities
closer to the  objectives of the Act in quality and
variety.

ADVISORY COMMITTEES

ES +WQIAC
  The  Effluent Standards and Water Quality In-
formation Advisory Committee (ES  -I- WQIAC) is
a statutory committee created under section 515
of the FWPCA and rechartered under section 9(c)
of the Federal Advisory Committee Act.
  The  legislative mandate of the Committee was
to provide and  evaluate scientific  and technical
information on industrial point source  discharges
and toxic effluents, and to transmit this informa-
tion to  the Administrator for his use in fulfilling
the obligations of sections 304(b), 306,  and  317(a)
of the FWPCA.
  During the  fiscal year the committee has:
  • Continued an ongoing review of effluent limi-
    tations for possible review and updating.
  • Conducted a series  of  meetings with  public
    interest groups on the economic implications
    and environmental impact of FWPCA.
  • Made  recommendations  to  the   Assistant
    Administrator for Research and Development
    on ways to improve  agency  capability to
    meet the requirements of FWPCA.
  • Published special reports on  toxic substances,
    information utilization by EPA, and a  report
    to the House Committee on  Public Works on
    ES + WQIAC's first year activities.
  • Made available  to EPA, Federal  agencies,
    individuals, law  firms,  and public interest
    groups information developed by  the  above
    activities and other committee research, hear-
    ings, conferences, and seminars.

Water Pollution Control
Advisory Board
  The  Water  Pollution Control Advisory  Board
was created by section 503  of  the FWPCA.  The
Act mandates  that the Board advise the Adminis-
trator on policy issues arising under the FWPCA.

  The Board held  its final meeting from July  16-
19, 1974,  in Seattle.  Based on the meeting  and
presentations by interested persons and represent-
atives of private industry, trade associations  and
public interest groups, the Board made the follow-
ing recommendations:

   • That EPA adopt  more flexible effluent guide-
    lines:  the Board  concurred  with  ES   +
    WQIAC's recommendation that a  matrix  ap-
    proach be adopted.
   • That EPA speed up  processing of construc-
    tion grant applications, thus reducing con-
    struction  cost increases  pending  grant  ap-
    proval.
   • That EPA make a special effort to increase
    the efficiency  of information transfer to  pri-
    vate industry.
   • That EPA transfer enforcement of FWPCA
    to the States as soon  as possible.
   • The Board opposed adoption of any Federal
    land use plan amounting to a Federal zoning
    law.
   The Water  Pollution Control Advisory Board
was  not rechartered under  the Federal Advisory
Committee Act. The Board terminated as of Janu-
ary 1975.
72

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                                                                          APPENDIX A
                                             Compliance
                                             Through
                                             Federal
                                             Procurement
                                             Activities
INTRODUCTION

  Section 508 of the Federal Water Pollution Con-
trol Act,  "Federal  Procurement,"  is designed to
utilize the contract, grant and loan authorities of
all agencies of the Federal government as a means
of encouraging private citizen compliance with the
Act. The  section  requires the President  to submit
an annual report to the Congress  on  measures
taken in compliance with the purpose and intent
of this section. This Appendix is  submitted in
response to that directive.

LEGAL AUTHORITY

  Section 508 provides  two distinct  mechanisms
for promoting compliance by private citizens with
the provisions of the FWPC Act. First, section
508(a) prohibits any Federal agency from entering
into any  procurement contract with any person
who has  been convicted  of a  criminal  offense
under section 309 of the Act, if the contract is to
be performed at any facility at which the violation
giving rise to the conviction-occurred and if the
person owned, leased or  supervised the facility.

  In addition, section 508(c) directs the  President
to issue an Executive Order requiring each Feder-
al agency to utilize its  contract, grant and loan
processes to  effectuate the purposes of the  Act
and to set forth procedures, sanctions, penalties
and such other provisions as the President deter-
mines necessary  to carry out  the  section. The
President  is empowered (section 508(d) to exempt
any contract, loan or grant from the provisions of
the section  on  the basis  of paramount national
interest.
  Section 508 is comparable to the  language of
section 306 of the Clean Air Act, as amended (40
U.S.C. 1857 et seq.).

EXECUTIVE ORDER 11738
AND IMPLEMENTING REGULATIONS
  The President issued Order 11738, mandated by
section 508(c), on September 10, 1973. This order
supersedes E.G.  11602, issued under the  Air Act.
It uses the same language as the prior Order but
is applicable to both the Air and Water Acts.
  Section 5 of Executive Order 11738 requires the
Administrator to  issue  implementing rules  and
regulations.  Regulations  implementing the air  re-
quirements were  promulgated in the Federal Reg-
ister on December 27, 1973 (40 C.F.R. part 1538,
F.R. 35310). On April 16, 1975, EPA promulgated
regulations to revise the previously promulgated
air regulations and incorporate appropriate provi-
sions of section 508 and Executive Order  11738.
These regulations essentially repeat  the require-
ments of  the December 27, 1973, air regulations
but make them  applicable to both the  Air  and
Water Acts. The  regulations provide for the  es-
tablishment of a  List of Violating Facilities. This
list will identify  any  facilities  that are ineligible
for use in a Federal contract, grant, or  loan for
reasons associated with the Clean Air Act or the
FWPC act.
  The regulations' bases  for listing a facility are
not limited to Federal criminal convictions. (See
                                                                                    73

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Description of  Program, below.)  EPA  believes
that both section 508(c) of the Act and sections  1,
5, and 7 of the executive Order call for expansion
of  the bases  for  listing  beyond  that  narrow
ground.
   First, section 508(c),  which calls for the execu-
tive order, is independent of section 508(a): it re-
fers  to both contracting and  assistance activities
and  vests  the  President with broad  authority  to
carry out  the purposes of the  section. In contrast,
section 508(a) refers only to one, non-discretionary
basis for listing i.e., a Federal criminal conviction,
and it pertains only to contracts.
   The Executive Order is also consistent with the
wider approach. Section I defines the purposes  of
section 508 broadly as "to assure that each Feder-
al agency  . .  .  shall undertake procurement  and
assistance activities in a manner that will result  in
effective  enforcement  of  the Water  and  Air
Acts." Section 5 directs the  Administrator to is-
sue rules  and regulations as he deems necessary
and appropriate to carry out  the purposes of the
order, and section 7 further authorizes the Admin-
istrator to take appropriate  action  in  cases  of
noncompliance.
   Thus, both  section 508(c) of  the Act and  var-
ious sections of the executive order authorize the
Administrator to go beyond  the  one mandatory
basis  of  listing facilities  which violate the  Act.
The Administrator's regulations reflect the broad-
er reach of the program.


PROGRAM DESCRIPTION
   EPA is required  by its regulations to publish  in
the Federal Register and  periodically  revise the
List  of Violating  Facilities. The  program estab-
lished in  the  regulations published on  April  16,
1975, was made effective  to  contract, grant and
loan activities of all Federal agencies  as  of July  1.
The listing  relates  strictly to the facility, not  to
the entire company. Only the specific  facilities
listed by  EPA will be  ineligible for Federal  con-
tracts, grants and loans.
   Facilities will be listed upon a determination by
EPA  of continuing or  recurring noncompliance
with  clean water (or air) standards.  Any facility
giving rise to  a Federal criminal conviction  must
be listed, in keeping with  section 508(a) of the
Act.  Facilities may also be listed  as a result  of
State  or  local  criminal  conviction  or  Federal,
State or local civil adjudication or administrative
finding.
  The  program  applies to any contract, subcon-
tract, grant,  subgrant, or subloan  in  excess of
$100,000  as  well  as  any  contract  of a  lesser
amount involving a facility listed on the basis of a
Federal criminal conviction.
  When Federal criminal conviction is  the  basis
for listing, removal  will not occur  until the Ad-
ministrator certifies that the condition which gave
rise  to  the conviction  has  been completely  cor-
rected.  For State and  local criminal convictions
and Federal,  State and local civil adjudications or
administrative findings, removal  will  not  occur
until EPA enters into an approved plan  of compli-
ance which will ensure the condition which gave
rise to the listing has been corrected.
  In order to insure  due process,  no facility will
be  listed until its representatives  have been af-
forded an opportunity for a Listing Proceeding, at
which  time the  representatives may confer  with
and present  information to the Director of  the
Office  of Federal Activities, EPA.  If a request to
de-list  is denied, representatives  of the  facility
will be afforded a hearing before an EPA hearing
officer, with a fair opportunity to present evidence
and cross-examine witnesses.
  It must be emphasized that this program is  an
additional arm of the EPA enforcement effort. It
is  primarily  designed  to  encourage   voluntary
compliance, not to penalize a facility.

IMPLEMENTATION WITHIN THE
FEDERAL ESTABLISHMENT
   Each  Agency of the Executive  Branch is  obli-
gated under  section 4  of the Executive Order to
implement the  listing  program through its  con-
tract,  grant  and loan activities.  Implementation
involves amending the Federal Procurement Regu-
lations  (FPR), the Armed  Services  Procurement
Regulations  (ASPR),  and  any  supplemental  or
comparable  regulations,  as well  as maintaining
close coordination with  EPA to insure that re-
quirements of the program are fully carried out.
  The  FPR  (which  guides   civilian   agencies),
ASPR and NASA and ERDA procurement regula-
tions have now been  amended.  Various agency
grant and loan provisions have also been amended
to carry out the requirements of the program.
  Contact points within each Federal agency have
been identified to receive EPA's List of Violating
Facilities. The list will be distributed periodically
and, to insure prompt implementation,  every time
a new facility is added to the list.
74

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  Under the FPR and ASPR contract provisions
each bidder must  certify when bidding on a par-
ticular contract  that he is  not on EPA's List of
Violating Facilities and that he will promptly noti-
fy the contracting officer  of the receipt of  any
communication that he is under consideration for
listing. If a particular basis for  listing has  been
identified against a facility  but the facility is not
on the  EPA list, the Director of the Office of
Federal  activities, EPA,  may request  that  an
award  of a particular contract be withheld for a
period not  exceeding fifteen days pending comple-
tion of an investigation.
  The  contract  provisions  also require that con-
tractual provisions be inserted in  every  non-ex-
empt Federal contract. The contractor must agree
that no portion of the work will be performed at a
facility on  the EPA list;  that he will comply with
the clean water (and air) standards issued prior to
the contract award as  well as with  the record-
keeping and inspections requirements under the
Air and Water Acts; that he will use  his  best ef-
forts to comply  with  clean water (and air) stand-
ards where the facility has not been listed prior to
award; and that  the  contractor will  insert these
same requirements in  any  non-exempt  subcon-
tract. This last provision illustrates the reach of
the program to cover all subcontractors.
  These same requirements have been inserted in
various agency regulations  covering  grants  and
loans.
  It is  emphasized that the awarding agency must
determine  whether the  solicitation and  contract
provisions are being followed, and that each agen-
cy  of  the  Federal  government  can assist  in the
effectiveness of the program by encouraging con-
tractors to  comply with clean water and air stand-
ards. Also  the head of each agency has a respon-
sibility to ensure that  all  officers and employees of
his agency  involved in the contract, grant, or loan
process be familiar with  the regulations. To fur-
ther assist EPA  in implementation, the  head of
each agency has a responsibility to report prompt-
ly to EPA  any conditions in a facility which may
involve noncompliance with water or air  stand-
ards.
                                                            •ft U S GOVERNMENT PRINTING OFFICE-1977 O—593-021  75

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