TD423
.U53
OOOR791Q2
                                 STATEMENT OF

                                DOUGLAS COSTLE

                                ADMINISTRATOR

                        ENVIRONMENTAL PROTECTION AGENCY

                                  BEFORE THE

                      SUBCOMMITTEE ON OVERSIGHT AND REVIEW

                  COMMITTEE ON  PUBLIC WORKS AND TRANSPORTATION

                         U.S. HOUSE OF REPRESENTATIVES

                                JULY 18, 1979

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TESTIMONY FOR THE RECORD

HEARINGS BEFORE THE SUBCOMMITTEE ON OVERSIGHT AND REVIEW, HOUSE COMMITTEE
ON PUBLIC WORKS AND TRANSPORTATION, JULY 18, 1979


     This written testimony supplements the oral statement of Douglas
Costle, Administrator of the U.S. Environmental Protection Agency,
presented at the hearings on Section 208 and the Water Quality Management
Program.  The hearings focus on the significance of nonpoint sources in
water pollution and the role of the Water Quality Management program in
controlling them.

     This written statement contains a brief overview and background; a
detailed discussion of the nonpoint source problem; a discussion of
nonpoint source data deficiencies and needs; descriptions of practices
used to control nonpoint sources; progress of the 208 program and a
description of the WQM strategy for controlling nonpoint sources.

                      I.  OVERVIEW AND BACKGROUND

     The Section 208 effort under the Water Quality Management program
is essential to the quality of our Nation's waters.  It is the only EPA
program aimed directly at nonpoint source water pollution problems.

     A large body of research during the last decade has produced evidence
that nonpoint sources contribute a major share of many serious pollutants
to our lakes and streams.  Without controls, nonpoint source pollution
will prevent achievement in a portion of water in at least 37 States of
our 1983 goal of fishable and swimmable waters.

     There is little doubt that nonpoint sources have a direct, serious
impact on the uses Americans make of water.  Nonpoint source pollution
has appeared in community after community as a pathway for toxic and
hazardous pollutants with direct effects on human health.  We view with
increasing concern the frequent findings of heavy metals in urban and
mining runoff, and pesticides and herbicides in agricultural runoff.
In many urban areas, nonpoint pollution has significantly raised the
cost of providing safe domestic drinking supplies.

     In many rural areas, nonpoint sources have contaminated family
wells and livestock water supplies.  Saline pollution, which is also
nonpoint in nature, significantly impairs yields of many irrigated crops
in western States.

     There are many pollutants involved in nonpoint sources which can
degrade both surface and ground water quality.  Some of the major ones
are large amounts of silt; organic debris; heavy metals such as lead;
grease and oil; nutrients such as nitrogen and phosphorus; pesticides
such as Toxaphene and Sevin; toxic organic chemicals, nitrates; and
dissolved solids.

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     The country stands today at a crossroad in its progress  toward  the
1983 goalswhile we have taken giant steps to clean up point source
pollution, similar progress on nonpoint source control  is  lacking.   The
job of controlling nonpoint sources will  not be easy.   The political  and
economic problems to be solved in applying nonpoint controls  ("best
management practices" or "BMP's") are substantial.   Although  many State
and local governments have already led the way by enacting sediment
control, cost-sharing, forest practices,  or mine-drainage  laws on their
own initiative, many areas are not controlling the nonpoint problems.
In several of our nonpoint categories a better technical base on problem
and solutions is essential if we are to make an effective  case for
control.  In the past eight years, we have just begun  to fathom the  true
depths of our water problems.

     The Water Quality Management Program has completed the initial
planning phase, and has begun the job of carrying out  the  plans that the
225 agencies completed.  As of July 2, 1979, 107 of the 176 areawide
plans started in FY 74-76 have been certified by the States,  and 68  have
received EPA approval.  Of the Statewide plans, which  were started  in FY
76, 22 have been certified, and 7 have been approved.   We  expect all  the
remaining certifications and approvals by December, 1979.   Table I,
below, gives grant-by-grant information on the status  of certifications
and approvals.

     It is clear that Congress gave the 208 program a  very broad charge
in the 1972 Clean Water Act Amendments.  A complete list of the require-
ments appears in section 208(b)(2).  It says that 208  plans will address
both point and nonpoint source controlsnot only sewage collection  and
treatment needs, plant siting, and construction priorities, but also the
control of runoff from urban areas, agriculture, silviculture, mining,
and construction, the prevention of saline intrusion,  and  the protection
of ground water in the disposal of wastes.

     Considering the breadth of problems the program addresses, and  the
large number of local, State and Federal  agencies who  must cooperate to
solve them, it is not surprising that the program has  not  accomplished
all the Congress expected of it.  Most of the initial  focus was on  point
sources, which is understandable as the primary emphasis of the Act  was
point sources.  The first 208 agencies designated were those  in metropolitan
areas where point source problems predominated.  Later, when  States
began 208 planning, nonpoint source problems received  more attention.

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                         TABLE   I
                             STATUS OF 208 PLANS -7/2^9
Real on/State/Areawide   Certified   Approved
II
 III
 IV
      Greater Portland
      Southern Maine
      Northern Maine
      Androscoggin
      Southern Kennebec
      Rhode Island
      Vermont
      Southeastern MA
      Old Colony
                  X
                  X
                  X
                  X
                  X
                  X Partial
                  X Partial
                  X
                  X
Martha's Vineyard X

Tri County NJ     X
Middlesex County  X
Nassau-Suffolk    X
Mercer County     X

New Castle County X
Baltimore         X
Roanoke           X
Rappahannock      X
Wash COG          X Partial

Central Midlands  X
X
X
X
X
Alabama X Partial
First TN-VA X
Charleston X
Tennessee X
Waccamaw SC X
West Alabama X
Orlando FL X
Yolusia County X
Tampa Bay X
Tallahassee X
Central Florida X
Georgia X
Southwest Florida X
Macon-Bibb County X
Chatham County X
At! anta X
Kentuckiana X
Raleigh NC X
Memphis X
Knoxville X
South Carolina X Partial
Mississippi X Partial
Mid Cumberland X
Chattanooga X
Appalachian X
Low Country X
Florida X
Brevard X
Palm Beach X
Pensacola X
B reward X
Dade County X
Detroit X
So Cen Michigan X
Fj int Michigan X
Jackson Michigan X
East Cen Michigan X
West MI Shoreline X
Grand Rapids X
Lansing X
Eastern Upp Penin X
Northwest MI X
Northeast X





X
X
X
X
X
X


X
X
X
X
X
X
X
X











X
X
X
X
X
X
X
X
X
X
X
                                      Partial
 Additions this reporting period
 States
TO**L CtKTIUcD: 129
TOTW. APPROVED: 7B
Reaion/State/Rreawide Certified
West Upp Penin X
Southwestern MI X
Central Eipp Penin X
Cincinnati X
Toledo X
Eastgate X
Miami Valley X
VI Oklahoma X
Central Texas X
New Mexico X
Indian Setions X
North Central TX X
Southeast Texas X
Houston X
Alamo Area X
Coastal Send X
Lower Sio .Grande X
Texas X
Arkansas X
Arkhoma X
VII Des Molnes X
Iowa X partial
Kansas X
Mid-America X
East-West Eateway X
VIII Pikes Pes* X
Pueblo C X
Denver X
Larimer-Wield X
South DafeDta X
Sixth Disa SO X
Southeastern SO X
Provo UT X
Salt Lake County X
Weber Riwasr X
Uintah Basin X
IX Pima AZ X
Central Arizona X
Dist 4, rsraa AZ X
Southeastern AZ X
* Ventura Qsunty X
"Monterey Say X
*.San Diecc- X
*San Fran Say X
*Washoe iW X
* Clark Coustrty NV X
* Northern Arizona X
*Nevada X
"Hawaii X
Sacraraert.lSD X
* CgHforria X
Phoeni x X
* Los Angeles X
* Tahoe X
 Carson River X
* Trust Terr X
* Guam X
X Oregon X
Portland X
Mid-Willamette X
Lane COG X
Rogue Valley X

Approved
X
X
X
X
X
X



X
X






X


X
X



X
X
X
X



X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X



X
X




X
X
X
X
Washington X Partial
Clark Ccwmty X
Metro Seattle X
^nnhrtrrn^in V
X
X
If

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     Given two to three years to complete a plan requiring not only
technical, but political, institutional,  and budget decisions, it  soon
became evident that only a few of the major problems could be addressed.
In many instances, sufficient cause and effect water quality data  has
been lacking.  Efforts in the 208 program were originally directed
toward solving the obvious problems.

     There have also been other problems  which have reduced the program
effectiveness.  One problem was the large number of problem areas  to be
covered in such a short time frame.  Another was the large number  of
Federal, State, areawide, and local agencies involved in the program and
the coordination and conflict resolution  required.   Funding levels
fluctuated from year to year, disrupting  the program's continuity  and
causing high staff turnover in the field.  The previous Administration
attached a low priority to section 208 in relation  to the permit and
construction grants programs, and EPA was late to issue necessary  WQM
regulations and guidance, which contributed to the  loss (to the program)
of $137 million in appropriated funds.

     However, given the broad charge of section 208(b)(2) and the  many
constraints placed on the program, the State and areawide agencies
accomplished a great deal in FY 73-77.  The list of WQM program successes
and implementation projects spinning off  of WQM plans grows every  day  as
more of the WQM plans receive certification and approval and enter the
implementation phase.  Many examples of implementation projects for  the
nonpoint source problem areasagriculture, silviculture, urban runoff,
construction, mining, and ground water contaminationare described
within the testimony.

     Since 1973, Congress has authorized  750 million dollars for the 208
grant program.  A total of 469 million dollars has  been appropriated
since FY 73, and less than half of that amount has  been expended--$220
million.  Current obligations of 85 million dollars with an additional
obligation of 14 million dollars by August are funding the continuing
program.  Table II presents a funding summary for the 208 grant program
to date.

     In fact, as the figures in Table III illustrate, the program  has
actually saved the taxpayers over twice what they have invested in the
program, just by finding more cost-effective treatment processes for
municipal point sources.  Table III cites 23 examples with a total
capital cost-savings of approximately $500 million  which are more  specifically
described later in the testimony.

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                    II.  THE NONPOINT SOURCE PROBLEM

     Nonpoint source loadings are causing significant problems which
afect every region of our nation.  There is a substantial array of
evidence, much of it provided by 208 State and areawide agencies, which
indicates water quality standards in many streams and lakes will not be
reached even though treatment will be provided to municipal and industrial
point sources.  The majority of States have indicated at least some of
the river basins within their borders will not attain the Clean Water
Act's 1983 goal of "fishable/swimmable" waters because nonpoint pollution
sources will not be treated at that time.  We will provide later in this
testimony a number of case studies taken from 208 plans which show that
water uses are presently impaired for domestic, industrial, and agricultural
water supply; for recreation; and for fish and wildlife use.

     The following two tables (Tables IV and V) indicate the extent and
effect of nonpoint source problems.  While these figures suggest that
the magnitude of nonpoint loadings is significant on a national scale,
we also have evidence that they are causing real problems in a high
proportion of States and watersheds.  Consider the following:

    109 of the first 149 areawide agencies designated under section 208
     identified agricultural, construction and urban stormwater runoff
     (which does not include combined sewer overflows) as principal
     contributors to their water quality problems.

    At least 37 States have reported that they will be unable to meet
     1983 goals in at least part of their waters because of nonpoint
     pollution.

t    Although toxic metal loadings are difficult to estimate on a national
     scale, studies of individual cities have shown concentrations of
     certain toxic metals in urban stormwater runoff to be many times
     greater than concentrations in municipal sewage.

t    By 1981, BOD loadings from untreated urban runoff will equal those
     from treated municipal effluent and combined sewer overflows.

     The following information shows the magnitude of nonpoint source
loadings.  It indicates that when point source treatment goals are
reached, significant nonpoint source problems will still exist.

t    Sediment loads from man-made nonpoint sources are estimated to be
     360 times higher than those from municipal and industrial point
     sources after treatment, and three times higher than those from
     natural background.

t    Biochemical oxygen demand from nonpoint sources is estimated to be
     five times higher than either treated point sources or natural
     background.

t    Total nitrogen from nonpoint sources is estimated to be four times
     higher than that from treated point sources and three times higher
     than natural background.  Total phosphorus from nonpoint sources is

-------



































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     slightly higher than from point sources and twice as high as natural
     background.

    Loadings of fecal coliform bacteria from nonpoint sources will  be
     at least 50 times higher than from point sources, once secondary
     treatment with disinfection is achieved for all  municipal sources.

     While every region of the country is impacted significantly by  some
type of nonpoint pollution, the types of problems vary dramatically  from
region to region, according to the topography, climate and types of  land
use which prevail.  One implication of this is that the solution of
nonpoint source problems will require a flexible approach which takes
these variations into account.

     State and areawide plans completed during the past six months are
providing much more specific information on nonpoint source problems
than we have had previously.  Since agriculture and urban runoff have
been identified as the major nonpoint sources, it is not surprising  that
we have more data on these problems than on others.

A.   Agricultural Nonpoint Source Problems

     Agricultural activities are the most widespread cause of nonpoint
source problems, affecting over two-thirds of the river basins in the
Nation.  The regions most affected by agricultural nonpoint source
pollution are the North Central, South Central, Southwest, and Island
regions.  Agricultural pollution can come either from runoff or irrigation
return flows.  Runoff is the major problem in the North Central region,
primarily from spring snow melt, and in the Islands,  from heavy rains.
Irrigation return flows are the major problems in the Southwest, South
Central, and North Central regions.  These regions report many more
problems with dissolved solids (salinity) than the rest of the country.

     In the area of non-irrigated agriculture:

    Over 50 percent of the total man-made sediment load of the Nation
     is from agriculture.

    Only 31 States have average annual erosion rates that meet the
     generally-accepted standard of five tons or less per acre.

t    Since 1935, 100 million acres have been damaged  so badly they
     cannot be cultivated; on another 100 million acres, more than half
     the topsoil has been lost to erosion.  It has been estimated that
     the U.S. loses one billion dollars worth of topsoil annually.

     With respect to irrigated agriculture:

    Of the 195 million acre-feet of irrigation water Federal  projects
     supply to the western States, about 42 million acre-feet are lost
     through seepage in the canals, and 24 million acre-feet are lost
     to non-agricultural  weeds.  Each acre-foot of water lost results in
     less water available in the stream to maintain flow with a resultant
     decrease in water quality.
                                     11

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    Saline soils reduce crop production 25 percent on the irrigated
     lands in the West; 50 percent of irrigated acreage is threatened by
     increased salinity; and over a third of the soils in the five
     Western States are highly saline.

     Another aspect of the agricultural  nonpoint source problem is
     animal feedlots:

    In a USDA survey convering 90 percent of the Nation's feedlots for
     beef, dairy, and swine, 29 percent  had water quality problems.

    50 percent of the smaller feedlots  (under 1000 animals) contribute
     high nutrient loads to water bodies.

    20 States have 98 percent of the feedlots and 95 percent of the
     feedlots associated with water quality problems.

     Following are specific examples of  agricultural  nonpoint source
problems identified in 208 plans.  These examples show how various
aspects of agricultural pollution disrupt recreation, water supplies,
and fisheries with a variety of pollutants ranging from sediment to
synthetic organic chemicals:

Maine:  Has identified 9 lakes and portions of 3 rivers (Aroostook, St.
Johns, Prestile) as having significant water quality problems (coliform,
DO, nutrients, sediment) attributable to agricultural nonpoint sources.
Specific water quality standards violations have been documented on some
lakes for coliform and DO.

Connecticut:  Agricultural erosion statewide was determined to be over
12 tons/acre/year (acceptable value generally 3-5 tons/acre/year).
Problems are especially noticeable in Lake Waramug and the Housatonic
River.  Recreation and water supply uses are being impaired.

Massachusetts:  Rural nonpoint source problems (agricultural runoff and
erosion, livestock, and rural septic systems) are causing eutrophication
problems in several lakes and reservoirs in Berkshire County, which are
critical because of water supply and recreation demands of tourist
industry.  Some 60-90 percent of nutrient loadings to these lakes are
from nonpoint sources.  Water quality standards violations have been
documented for nutrients, coliform, and  dissolved oxygen.

Delaware:  Rural nonpoint source (agriculture, animal wastes, and rural
septic systems) are causing coliform and nitrate problems in ground
water drinking supplies in Sussex County.  Water quality standards
violations have been documented (60-100  mg/1 nitrates; standard is 10
mg/1).

Virginia:  Agricultural and urban runoff are contributing to eutrophication
threatening Occoquan Reservoir (drinking supply for 700,000) and may
negate benefits of a very expensive AWT  plant.
                                     12

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Maryland:  Animal wastes and other agricultural runoff are resulting in
coliform water quality standards violations in several rivers (Northeast
Maryland, Carrol County, Frederick County, and Howard County) and two
reservoirs (Lock Raven and Liberty) which supply drinking water to
Baltimore.

North Carolina:  Average total nitrogen levels of 7 mg/1 were found in
Union County on a creek tributary to Lane Creek where fish kills and 0
mg/1 DO were observed.  Animal operations are believed the cause.
Herbicide related fish kills are found in Richardson Creek and Twelve
Mile Creek.  Erosion rates of 20-60 tons/acre/year have been observed in
areas of the State.  On the upper Neuse River, DO concentrations fell
to about 1 mg/1 during certain storm conditions.  During all storm
events measured, high concentrations for suspended solids were observed
in both the small streams and larger rivers.  The Chowan River has
experienced severe algal blooms which have affected the fishery resources
in the estuary, ruined recreation beaches, and resulted in objectionable
odors and deposits of decaying algae.  About 85 percent of the nitrogen
input is from nonpoint sources, with agricultural areas accounting for
50 percent of the total.

Tennessee:  High total phosphorus and total nitrogen loadings from agri-
cultural land use have resulted in the Chickamauga and Nicajack Reservoir
being classified eutrophic.  Algal bloom preclude recreation in certain
areas.

Illinois:  Eighteen public water supplies in Illinois periodically
exceed the nitrate level recommended to prevent methemoglobinemia in
infants (similar in effect to the "blue baby" syndrome).  A majority of
Illinois surface waters violate phosphorous and heavy metal standards at
intervals throughout the year.

Arkansas:  In one basin intensively studied:  2 million tons of sediment
are delivered each year; out of 60 streams in this basin, 47 are not
suitable for swimming and 37 not suitable for fishing because of agricultural
nonpoint sources; streams in eastern Arkansas violate criteria for
pesticide Toxaphene.

Louisiana:  Lake Providence (Quanchita Basin) and Round Lake have deteri-
orated due to high sediment and pesticide residues from agricultural
nonpoint sources; private and commercial  fishing has been banned by the
State in Lake Providence because Toxaphene levels in fish violate standards.

New Mexico:  The State projects problems  for present and future use of
San Juan and Rio Grande Rivers for irrigation due to sediment and salinity.

Oklahoma:  Little Washita watershed has a major water quality problem
resulting from sediment; 12 other segments (out of 59) have been identified
as having major nonpoint source problems.

Texas:  33 out of 297 segments have existing or potential water quality
problems related to nonpoint sources.
                                      13

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Missouri:  Sediment and agricultural  chemicals cause turbidity and
pesticide parameters to be violated in the northern 38 percent of the
State, in the Salt, Fox, Wyaconda and Upper Middle Fabius River.   In
the Salt River, 21 percent of basin (363,000 acreas) has erosion  of over
30 tons/acre/year.

Nebraska:  Eastern and central parts  of the state are impacted by sediment,
animal wastes, and agricultural chemicals, causing violation of standards
for nitrates, turbidity, fecal coliform and IDS.   Over 1.5 million acres
have been identified as sources.

Kansas:  Six areas have nutrient and  salt problems from agricultural
chemicals and irrigation return flows (Stranger Creek, Upper Nemaba,
Upper Wakarusa, Wolf River, Washington State Lake, and Soldier Creek).
These cover a total of 627,000 acres.

North Dakota:  In the Souris River agricultural activities have resulted
in nutrient, IDS and suspended solids violations.  These parameters are
violated 80 percent of the time and nonpoint sources account for  90
percent of the load.  The area recently experienced a major duck  kill.
The State has identified 10,000 acres as a high priority for treatment.

South Dakota:  The James River is impacted by agriculture activities
that affect fishery and drinking waters.  Parameters violated are suspended
solids, TDS and nutrients.  The State has identified 17,000 acres needing
treatment.  Lake Herman suffers from  sedimentation and nutrients.
Parameters are violated 100 percent of the time with 90 percent of load
coming from nonpoint sources.

Wyoming:  The Green River is impacted by irrigation returns, overgrazing
and septic tanks, which threaten agriculture, recreation and drinking
water uses.  Public lands contribute  8.9 million tons/year of sediment
and 145,000 tons/year of salt.  About 78 percent of the phosphorus
loadings are contributed from nonpoint sources and they are causing
eutrophication in the Flaming Gorge Reservoir.  The Wind/Big Horn River
is similarly impacted.  Nonpoint sources contribute 99 percent of the
total phosphorus load to Yellowtail Reservoir.  Sources of phosphorus
are agricultural fertilizer, septic tanks, feedlots and erosion.   Eleven
of the 20 problem stream segments will fail to meet water quality standards
in 1983 due to nonpoint sources.

Colorado and Utah;  The Colorado River is impacted by agriculture and
hydrologic modification, causing salinity parameters to be violated.
About 42 percent of the salinity in the upper basin is caused by  irriga-
tion.

Montana:  The Missouri, Yellowstone and the Big Horn Rivers have  approxi-
mately 4000 stream miles degraded by  nonpoint source pollution (13
percent of State's streams).  Sediment causes 2500 miles to be degraded
and salinity affects 1400 miles.  Parameters violated are salinity,
bacteria, nutrients and suspended solids.
                                      14

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Idaho:  Severe water quality problems have been identified in 5 stream
reaches in irrigated areas involving 350,000 acres, and 18 reaches in
nonirrigated areas involving 1,300,000 acres.  In these cases, fisheries
and recreation uses are impacted because of turbidity, sediment, algae,
reduced oxygen, bacteria, salinity, temperature, and reduced flows.

Washington:  Priority water quality problems have been identified in 27
stream segments involving 1700 dairies, 1,000,000 irrigated acres, and
5,200,000 nonirrigated acres.  Fisheries and recreation uses are impacted
because of turbidity, sediment, algae, reduced oxygen, temperature,
bacteria, salinity, and reduced flows.

B.   Urban Runoff Problems

     Urban runoff is a problem of increasing severity.  Urbanization
changes hydrologic cycles and expands impervious areas.  Runoff flowing
through the urban environment flushes atmospheric fallout, traffic-
related deposits, litter, and construction debris into receiving waters.

     Urban runoff is a primary cause of water quality degradation in
populated areas.  Many pollutants are found in urban runoff, with severe
effects generally coming from suspended solids and toxics, particularly
heavy metals.  Urban runoff also frequently includes bacteria, oxygen-
demanding material, nutrients, oil, and grease.

     Nationwide, over 50 percent of the river basins are affected by
urban runoff.  The percentage is highest (70 percent) in the Northeast
and lowest (23 percent) in the Southwest and Northwest.

     The two figures which follow illustrate the magnitude of pollution
from urban runoff.  This information was prepared as part of the Agency's
1978 Needs Survey.  Stormwater discharge data was analyzed for 15 cities
across the nation. Figures I and II provide data at four of those
locations.

     As point source controls on industrial and municipal dischargers
take effect, urban runoff, if uncontrolled, increases because of the
growth of urban areas.  The 1978 Needs Survey estimates that in the  year
2000, more than 130 million persons will occupy 32,244,000 acres in
urbanized areas served by separate storm sewers.

     To further support this data, we have provided 23 examples from
completed 208 plans which underline the extent of pollution from urban
runoff and its effect on urban water quality.  All the evidence, taken
together, suggests that point source controls alone will  not achieve the
goals of the Act in many populated areas because of urban runoff.
                                      15

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Figure 1
Pollutant Loading
Durham Site Study
Summary*
(Third Fork Creek Basin
)
Average Pollutant Loads
Source
Upstream flow
WWTP effluent
Combined sewer
overflow
Urban stormwater
runoff
Total
BOD TKN
0 0
165,245 82,623
NA NA
328,769 17,159 32,
494,014 99,782 32,
SS

462,
NA
251,
414,

(lb/yr)
Pb
0 0
687 165
NA
331 12,119
018 12,284
*EPA 1978 Needs Survey.
Figure 1
Pollutant Loading Summary
Ann Arbor Site Study (Huron
Source
Upstream flow
WWTP effluent
Combined sewer
overflow
Urban stormwater
runoff
Total
Average
BOD
2.57
1.20

NA

0.82
4.59
River Basin)
Pollutant
TKN
0.71
1.11

NA

0.10
1.92
Loads
SS
5.46
1.20

NA

13.51
20.17
(106 lb/yr)
Pb
0.003
0.000006

NA

0.017
0.200
                               16

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     Figure 2*
     Pollutant Loading Summary
     Tulsa Site Study (Bird Creek Basin)

                        	Average Pollutant  Loads (Ib/yrj	
          Source           BOD         TKN          SS         Pb
     Upstream flow       6,387,391  1,424,783   115,886,398   82,117

     WWTP effluent       1,382,722    306,845     1,620,527    3,196

     Combined sewer
     overflow                    00             00

     Urban stormwater
     runoff              2,572,809    183,072   155,884,748  387,949

     Total              10,342,922  1,914,700   273,391,623  473,262


     *EPA Needs Survey.
Figure 2
Pollutant Loading Summary
Des Moines Site Study (Des Moines River
Source
Upstream flow
WWTP effluent
Combined sewer
overflow*
Urban stormwater
runoff*
Total
Average
BOD
38.99
3.71
0.70
4.72
48.12
Pollutant
TKN
11.99
1.35
0.09
0.32
13.75
Basin)
Loads (106
SS
3,504.24
3.71
3.03
39.65
3,550.63

lb/yr)
Pb
0.03
0.005
0.02
0.12
0.175
*Watershed area: combined sewer - 4,018 acres and stormwater runof - 45,000 acres,
                                 17

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Assessment of Urban Runoff and Its Effects on Beneficial  Uses

Roanoke, Virginia:  Wet weather flows cause considerable degradation in
water quality as measured on three streams leading to the Roanoke River.
Total solids and BOD concentrations increased two and one-half times.
Wastewater treatment was upgraded from 86 percent to 93 percent BOD
removal, yet there was no dramatic reduction in BOD load (3.3 million
pounds before upgrading; 3.1 million pounds after).

Durham, North Carolina:  If Durham provided 100 percent removal of
organics and suspended solids from the raw municipal waste on an annual
basis, the total reduction of pollutants discharged to the receiving
water would only be 59 percent of the ultimate BOD, and 5 percent of the
suspended solids.

Long Island, New York:  Stormwater runoff, the predominant source of
coliform bacteria, is responsible for many of the shellfish area closures
on Long Island and also threatens many bathing beaches.  The area is
also concerned over the suspected organic contamination of drinking
water supplies from runoff.

Denver, Colorado:  The Colorado Department of Health concluded that the
major receiving waters in the Denver region are heavily impacted by
nonpoint sources of pollution.  Bacterial, nutrients and heavy metal
pollution problems have all been attributed in part to nonpoint sources.
These receiving waters have been described by the Health Department as
being unsuitable for beneficial uses such as recreation, agriculture and
water supply.

Southern California:  Shell fishing and contact recreation are prohibited
in Upper Newport Bay because of bacterial pollution.  At the mouth of
the Los Angeles River, biological conditions are poorer than anywere
else in the Los Angeles-Long Beach Harbor complex.  The Colorado Lagoon
in Long Beach has been closed to shellfishing due to excessive lead
concentrations, the result of urban runoff and weak flushing patterns.
Studies of Outer Bolsa Bay show a decrease in primary production of
epidiatoms primarily due to lead build-up from urban runoff.  Bacteria
densities in the surf zone, which persist for several days, greatly
exceed shellfish and contact recreation standards, are the result of
surface-runoff discharges.

Mystic River Basin, Massachusetts:  Urban stormwater runoff is a substan-
tial part of the water quality problems.  Coliforms and nutrients are
commonly the cause of water quality standards violations.  The recreational
use  of the Upper  and Lower Mystic Lakes is precluded because of stormwater
pollution.
                                     18

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Lake Quinsigamond, Massachusetts:  Deteriorating water quality threatens
the major recreational lake serving the Worcester metropolitan area in
central Massachusetts.  Water quality studies show that urban runoff is
the major contributor to the lake's accelerated rate of eutrophication.
Urban stormwater contributes half the phosphorus and one-sixth of the
inorganic nitrogen to the lake.  Sediments carried by urban runoff cause
turbidity and create sandbars.  Bacteria in urban runoff degrade the
quality of the lake.

Brockton, Massachusetts:  Ellis Brett Pond has been closed to swimming
since the mid-1960's because of high coliform bacteria counts and heavy
sediment loads from urban runoff.  Nitrate, phosphorus, and chloride
levels exceed standards because of urban runoff.

Durham, New Hampshire:  Stormwater runoff from urbanizing coastal areas
produces high levels of coliform bacteria, biochemical oxygen demand,
nutrients, and possibly toxicants which degrade water supplies, estuarine
shellfish, and recreational opportunities.

Myrtle Beach, South Carolina:  Serious problems with fecal coliform and
pathogen contamination from urban runoff exist in the beach and surf
zone.  Forty-two percent of the dry weather discharge samples had fecal
coliform counts greater than swimming standard of 200 colonies/100
milliliters.  Wet weather samples had counts ranging up to 240,000
colonies/100 milliliters.  Storm runoff discharges to the beach through
289 separate pipes ranging from 2 to 48 inches diameter.  Because the
population grows from 20,000 in winter to 200,000 during the beach
season, closing the beach has an extremely heavy impact on the local
economy.

Northeastern Illinois (Chicago Metro Area):  Urban stormwater runoff
causes violation of standards for dissolved oxygen, ammonia, fecal
coliform, copper, total iron, lead, manganese, zinc, cyanide, and boron.
Pesticides and polychlorinated biphenyls (PCB) have been linked to urban
storm drainage.  The biological quality of most urbanized streams is
poor, with low fish diversity and widespread bluegreen algae.  In some
streams not even algae can survive because of high turbidity.  Sediment
washed into urban streams is a major factor limiting fishability.
Sediments form bottom deposits like sewage sludge, which contain pesticides
and PCB's and release oxygen demanding material  to the overlying water.

Washington, D.C.  Metropolitan Area:  Few streams in the more urbanized
portions of the area consistently meet bacterial standards for safe
water contact recreation.  Sedimentation from excessive upstream erosion
is reducing the storage capacity of the Occoquan reservoir.   Periodically
high suspended solids loads result in higher water treatment costs.

Baltimore, Maryland:  As a result of urbanization, streams below Lake
Roland are devoid of life forms indicative of clean water and are not
suitable for human or animal  contact and recreation purposes.   One of
the most severely degraded streams in the Baltimore region is the Jones
Falls watershed.
                                     19

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Georgia:  Urban runoff and erosion of denuded areas in  Macon and Bibb
Counties contribute to violations of water quality standards or criteria
for human health, fish and wildlife (DO,  mercury, fecal  coliform, fecal
streptococcus, Lindane, suspended solids  and lead).  Concentrations of
lead exceeded 0.06 mg/1 level  which is toxic to fresh water fish.  In
Savannah, urban runoff contributes to suppression of DO  levels and
elevation of fecal coliform counts, lead, zinc and copper.   The presence
of toxic pollutants and pathogenic bacteria cause concern for the many
residents of the area who fish, especially in Casey Canal.

Alabama:  During winter wet weather conditions, shellfish harvest beds
in Mobile Bay are closed periodically because of violations of water
quality standards for bacteria.  Oxygen demanding loads  from critical
storms must be reduced 35 percent to maintain 3 mg/1 DO  standard at all
locations in Three Mile Creek.

New Mexico:  Coliform standards will not  be met on portions of Rio
Grande River around Albuquerque due to urban runoff.

Oklahoma:  Three lakes (Overholser, Arcadia, and Thunderbird) have
problems related to urban runoff.  Thunderbird Lake will  be denied
beneficial  uses due to urban runoff.

Texas:  In the Dallas area, Ray Hubbard and White Rock Lakes violate
nutrient, pH, DO, and taste and color standards due to municipal discharges
and urban runoff.  Problems are anticipated in Lakes Lavon, Arlington,
and Lewisville due to urban runoff.  Violations of DO and coliforms on
the Trinity River related to urban runoff are denying use for fishing
and swimming.

Arkansas:  High lead levels in streams and around Little Rock have been
attributed to urban runoff problems.

Washington:  In Snohomish County, uncontrolled drainage  from urban areas
causes flooding, erosion, sedimentation,  destruction of  fish habitat,
increased levels of oil, gasoline, heavy  metals, nutrients, pesticides,
and destruction of the aesthetic value of streams.  In Clark County,
standards violations or high levels of bacteria, pH, dissolved oxygen
nutrients, heavy metals and oil and grease make swimming unsafe and fish
habitat greatly degraded.

Colorado:  The South Platte River is impacted by urban runoff causing
fecal coliform standards to be violated 60 percent of time.  Violations
of suspended solids, nutrients and bacteria standards limit recreation,
fishing and irrigation.  The Arkansas River is impacted  by both urban
runoff and agriculture causing parameters for suspended  solids, nutrients,
TDS and bacteria to be violated.
                                      20

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C.   Other Nonpoint Sources

     Mining

     Mining operations can be highly disruptive to the environment,
causing both surface and ground water pollution.  Mining affects less
than two percent of the land surface in any one of the 50 States, but
the impacts on surface and ground water are much greater in area.
Sedimentation and acid and alkaline drainage are the most serious, and
common forms of water pollution from mining.

     A national survey by State fish and game personnel indicated that
almost every State had fish and wildlife habitat adversely affected by
surface mining.  The survey indicated that 13,000 miles of streams and
449 lakes and reservoirs having a surface area of 181,000 acres had
been affected.

     Figure III illustrates the extent and degree of nonpoint source
pollution from mining activities.

     States in the Appalachian region have a substantial number of their
streams affected by acid mine drainage from coal mining operations.
Table IV indicates the extent of water quality problems in major river
basins in the region.

     For example, Pennsylvania stated that 2,600 miles of its streams
and rivers were continuously in violation of water quality standards as
a result of acid coal mine draininge, and another 1,200 miles intermit-
tently in violation.  It reported that abandoned mine drainage, alone or
in combination with other sources, accounted for 75 percent of the
steam miles degraded in the State.  The diversity of mining operations
also results in a large number of potential pollutants.

     In its 208 plan, California has identified about 200 miles of its
streams in which water use is affected from inactive mining operations.
While the extent of the polluted streams is limited, some of these
abandoned mines are located in watersheds providing water supplies to
portions of the San Francisco metropolitan area and others are located
on State Park lands.

     Construction

     Construction activities impact about one million acres of land
annually, and they remove vegetative cover, disturb soil foundation
materials, and change topography and drainage.   The resulting sediment
is the principal  pollutant, but construction may also contribute water
pollution in solid form (asphalt, wood, fiber,  metal) or liquid form
(paint, oil, pesticides, and fertilizers).   Acre-for-acre, construction
activities are the largest contributors of sediment, averaging 100 tons
per acre per year.  Under the same rainfall and soil conditions, land
under construction may yield up to 100 times the sediment coming from an
equivalent amount of farmland.
                                     21

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     Sediment yield in streams in developed areas averages less than 1
ton per acre annually.  By contrast, areas undergoing urbanization have
a yield fromm 2 to 200 tons per acre annually.   Data collected  on  175
areawide water quality management plans showed  that 64 (36 percent)
identified construction runoff as a water quality problem.

     Silviculture

     There is a clear need to maintain high-quality waters in forested
regions, for otherwise, water supply costs would tend to increase  and
cold water fisheries would suffer.   Many major  cities, both in  the East
and West, have municipal water supplies located in forested areas.
Trout and salmon fisheries depend on high-quality water from forested
watersheds.

     Sediment is the primary pollutant from silviculture, with  sediment
loss from forest lands estimated at less than four percent of the  total
man-made sediment in the Nation's waters.  Chemical runoff from forest
lands is a localized problem, since less than one percent of our forests
receive chemical treatment each year.

     Figure IV indicates those basins in which  water quality has been
affected by pollution from silvicultural activities.  Recent events in
Maine, Oregon, and California indicate States and local  agencies and the
public are becoming more concerned with pesticide and herbicide use and
their affect in the environment.  In Mendocino  County California,  in a
recent referendum, residents voted by a 2 to 1  majority to ban  use of
2,4,5-T and Silvex.  Cancellation Hearings on these chemicals are  scheduled
in Washington, D.C. this fall.

     A number of States have identified problems resulting from silvicul-
tural activities where poor management practices have been used.  Some
examples are:

Oregon:  Eight priority areas having water quality problems related to
silviculture (southwest part of North Coast Basin, Yamhill River,  South
Fork of Umpqua River, part of Goose/Summer Lakes Basin,  Crooked River,
Malheur River, Umatilla River) have been identified.  Water quality
problems involve erosion and sedimentation, excessive debris, high water
temperatures, and algae growths.

Washington:  Six priority areas having water quality problems (Willapa
Bay, Kaloma River, part of Skykomish River, part of Snohomish River,
Newaukum River, Deschutes River) were identified.  Water quality programs
involve sediment, temperature, and slash/debris.

Maine:  A survey of 350 sites indicated that 10 percent have sedimentation
problems causing localized stream impacts; 25 percent have excessive
erosion.  Spraying of Sevin for spruce bud worm control  on 23 million
acres has resulted in fish kills.
                                     24

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D.   Ground Water Contamination

     In general, ground water is a high-quality, relatively low-cost,
readily available source of drinking water.  Half the population of the
country gets its drinking waterwholly or partlyfrom ground water
supplies, and the use of ground water is increasing at a rate of several
percent per year.  Unfortunately, waste disposal practices, agricultural
practices, and other problems have affected the quality and availability
of ground waterand the potential for contamination appears to be
increasing along with demand.

     Ground water is especially important to people living in rural
regions.  Almost all (96 percent) of the nation's rural households are
supplied by wells, and most of these are single family wells subject to
few, if any, water quality safeguards.  Approximately 67 percent of all
ground water used is for irrigation, and 61 percent of all water consumed
by livestock is ground water.  Nearly a quarter of all the water used in
the U.S. is ground water, yet nearly a quarter of that amount is "mined"
from aquifers that cannot be recharged.

     Over 17 million waste disposal  facilities place over 1.7 trillion
gallons of waste water into the ground each year.  Some 98 percent of
the facilities are septic tanks, but they account for less than half the
liquid discharged.  Ground water contamination occurs in local  areas in
all parts of the country, and occurs on a regional basis in some heavily
populated areas.

     The sources of ground water pollution are generally classified as
nonpoint sourcesseptic tanks, farmland, industrial impoundments,
agricultural impoundments, and oil and gas field activities are prime
examples.  The contaminants involved cover a wide range from nitrates to
heavy metals, complex organic compounds and radioactive materials.  The
chart (Figure V) shows some of the major pathways by which contaminants
enter ground water supplies.

     Perhaps the most alarming aspect of ground water contamination is
that removing the source of the contamination does not clean up the
aquifer.  Contamination may rule out desired uses of an aquifer for
decades or centuries, since the natural clean-up processes that occur in
surface water do not take place underground.  Man's clean up techniques
are limited in ground water and are generally extremely expensive, time
consuming and often marginally successful.  Therefore, protection of
ground water quality requires effective management of nonpoint sources
of pollution.

     Ground water contamination has proved difficult to detect, since
routine monitoring of aquifers is both difficult and expensive.  Almost
every known instance of ground water contamination has been discovered
only after a drinking water source was affected.
                                     26

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     As efforts progress to clean up discharges of pollutants to the air
and to surface water, more wastessome of them toxic or hazardouswill
be going onto the land in the form of liquids or residual  sludges from
other treatment processes.  EPA has estimated 30,000-50,000 hazardous
dump sites, many of which threaten ground water quality.  It costs far
less to place waste materials in a secure facility than it does to clean
up the contaminated aquifer later.

     When septic tanks are properly planned, constructed,  located, and
maintained, they are a safe, economical alternative to central  sewage
treatment and they use little or no energy.  But when they are not
properly used, or occur in high densities, septic tanks may contaminate
with nitrates and pathogens  the ground water supplies of the very
communities they serve.  At high concentrations, nitrates in drinking
water may cause human health problems, such as methemoglobinemia (similar
in effect to the "blue baby" syndrome in infants).

     Surface impoundments of various types are one of the most widespread
threats to ground water.  Surface impoundments serve many waste dis-
chargersmunicipal, agricultural, and industrialand contain all types
of wastes from the most innocuous to the highly toxic.  Few existing
impoundments are lined; thus, slow seepage of contaminants is a significant
threat to ground water quality.

     According to one recent survey commissioned by EPA, there is a
minimum of 133,000 sites where surface impoundments exist.  Each site
may contain more than one impoundment.  Industrial impoundments are the
most common (75 percent of the total) and are most numerous in oil and
gas extraction and mining.  Paper and pulp and electric utility industries
operate the largest impoundments.  Wastewater lagoons in industries
using toxic chemicals, however, may present more immediate risks.

     Municipal, commercial, and institutional impoundments comprise 10
percent of the surface impoundments.  They are used primarily for processing
and disposing sanitary wastes.  Agricultural impoundments represent 15
percent of impoundments, and are used for handling wastes from animal
feedlots.

     A problem which is affecting ground water quality across the country
is runoff from agricultural and urban areas carrying numerous contaminants
into the ground water.  Saline intrusion, primarily a problem in coastal
areasespecially along the California coast, can be a serious ground
water quality problem which is aggravated by overpumping.

     Until recently, many agencies involved in water pollution control
paid little attention to ground waterespecially when faced with difficult
and visible surface water problems.  However, because of many local
contamination problem and of well-publicized problems with industrial
waste contamination of drinking water supplies in the East and nitrate
contamination from agriculture and septic tanks across the country,
State and local agencies are starting to identify ground water programs
                                     28

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and attempt to develop solutions.   Ground water outflows comprise a
significant portion of the base flows/supplies of surface water bodies;
thus contamination of ground water can have a direct impact on surface
water quality.   Because of this ultimate hydrologic relationship between
surface and ground water, there is a need for States to expand their
surface water quality programs to address the conjunctive management of
surface and ground water quality.

     Quantification of ground water contamination trends is not as
extensive as for other quality problems due to very limited data.  The
following is a sample of ground water contamination problems in some of
the EPA Regions:

Region I:  A very important ground water situation is emerging in New
England, especially in Connecticut and Massachusetts.  The problems
involve the shutdown of numerous public supply wells due to contami-
nation from organic chemicals.  It is possible that a significant
portion of the ground water supplies for several communities will be
lost.

Region II:  Contamination of well  supplies from organic chemicals is
also a widespread problem in this Region.  Several of the initial 208
plans in Region II focused on ground water protection.   Extensive analyses
was done on the Long Island ground water supplies.  For 19 years, a
Hicksville factory dumped millions of gallons of wastes containing a
cancer-causing chemical into ground water recharge basins.  As a result,
50 of the island's 950 wells had to be shut down in 1978.  The local
planning board also found that domestic wastes and urban runoff were
threatening ground water.

Region III:  Ground water contamination by nitrates, particularly related
to septic system densities and commercial poultry operations, are major
regional problems.  Leachate from abandoned landfills has also threaten
major water supplies.

Region IV:  Florida is analyzing the impact of urban stormwater runoff
on the Biscayne Aquifer, which is a sole-source drinking water supply.

Region V:  Regional staff have experienced great demand for assistance
in responding to emergency ground water situations resulting from spills
and industrial waste disposal practices.

Region VI:  New Mexico is experiencing problems with ground water contam-
ination from uranium mining operations.

Region VII:  Nebraska is experiencing high nitrate concentrations in
ground water from agricultural activities.  Kansas is considering ground
water management legislation.  The Karst topography in Missouri is
having major problems with collapsing lagoons and waste disposal practices,
and these conditions are being studied.  A ground water supply in Iowa
has been contaminated with cyanide from a landfill and from land spreading
of sludge.
                                     29

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with nitrate contamination, either from septic tanks or from agricultural
activities.  The Region is also looking into possible ground water
impacts from uranium mining and milling.

Region IX:  Along the Pacific coast, California is having problems with
nitrate contamination, pesticide accumulation, and overpumping of ground
water and related salt-water intrusion problems.   Arizona has major
ground water problems from both a quality and quantity aspect.   In
Nevada, intensive ground water use is aggravating salt loadings to
surface supplies.

Region X:  Septic tank contamination of groundwater has resulted in
housing moratoriums.  Also, the use of drainage wells for the discharge
of irrigation return water, storm water runoff, and septic tank fluids
are causing ground water quality problems.   Other problems are unwise
use of sewage lagoons and spray irrigation for municipal  sewage disposal,
landfills, industrial waste lagoons, and land disposal  of sludge.
                                     30

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E.  Other Aspects of the Nonpoint Source Problem

     Nonpoint source pollution is a problem not only because of its scope and
the large number and amounts of pollutants involved, but also because of the
associated economic, social, institutional, and political issues which are
difficult to resolve.  Some of the more important issues are the costs of non-
point source control; the need for regulatory, as opposed to voluntary, control
programs; and complications in water law.   One possible benefit that could come
from increased emphasis on nonpoint source control is energy conservation and
production.

Costs of Nonpoint Source Controls

     Best management practices, although they are generally less expensive
than capital-intensive facility construction, nevertheless represent a signi-
ficant demand on manpower and financial resources which must be added to, or
diverted from, existing programs.  While there is no overall estimate of non-
point source control costspartly because we have not identified all the prob-
lemswe do have information on the costs  of individual activities in specific
areas.

     EPA's 1979 Construction Grants Needs  Survey estimated the costs of structural
urban runoff controls at over $60 billion.  EPA hopes to find non-structural
solutions to the urban runoff problem which are much less costly.  (Some pre-
liminary cost estimates for BMPs appear later in the testimony.

     BMP implementation costs for agriculture have been estimated as high as
$10 billion if all cropland and grazing lands are treated.  However, it may not
be necessary to protect the entire land resource to enhance or maintain water
quality.  A substantial portion of the more than 400 million acres in crop
production may not require BMPs for water  quality protection.  The implication
is that the ultimate cost of BMPs for water quality should be substantially
lower than the cost of installing practices on all farm lands.  Consider the
following facts:

t    The USDA National Erosion Inventory (December 1978) indicates that the
     average annual soil loss is less than three tons/acre in 20 States and
     less than five tons/acre in eleven other States.  Thus, 31  States are
     within the prescribed target of five  tons/acre, at least on average.

t    Studies in the Great Lake Basin showed that 60 percent of the sediment
     load was generated from 30 percent of the agricultural  land.

t    The Black Creek, Indiana, study funded by EPA indicated that treating
     only 80 acres of highly erosive soils out of the watershed's 1600 total
     acres could reduce the total sediment load by 40 percent.
                                     31

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     In terms of costs of control, mining pollution presents the most difficult
problem.  In some cases, technical solutions are not available within economic
reason.  The thousands of abandoned mines present a special  set of economic and
legal problems.  In Pennsylvania, the State estimates that the cost of acid
mine drainage controls would exceed one billion dollars and annual maintenance
would be $38 million.   An EPA study of the Monogahela Basin in Pennsylvania and
West Virginia identified over 7000 mine sites, of which 2900 were producing
polluting mine drainage.  California identified 30 sites in its 208 plan, for
which the cost of abatement was estimated at $20 million.

Regulatory versus Voluntary Programs

     The application of BMPs for nonpoint sources differs  from the application of
point source controls in that management agencies must work with private citizens
as opposed to local governments or corporations.  In dealing with owners and
operators of lands causing nonpoint source problems, the 208 program has used
both regulatory approaches and voluntary programs.

     Iowa, South Dakota, and Pennsylvania have all adopted regulatory controls
for agricultural erosion and sediment problems.  All States are subject to
regulatory controls on feedlot discharges through the Clean Water Act.  Six-
teen States have erosion and sediment control laws for construction runoff,
and the majority of the States have regulatory authorities for mining.

     In the absence of regulatory controls, the voluntary  control process appears
to be working in the early stages of 208 plan implementation.  The Model Imple-
mentation Programs (these are explained later in the testimony) which EPA and
USDA initiated in 1978 have brought levels of landowner participation beyond
our expectations.  In the first seven prototype project areas, well over half
of the farmers contacted agreed to implement the necessary BMPs.

     For silvicultural pollution, both regulatory and voluntary programs are in
use.  The West Coast States (Washington, Oregon, California, Idaho, and Alaska)
are using State Forest Practices Acts for implementing regulatory programs.  These
acts establish policies and authorities for meeting water  quality requirements on
public and private lands.  In other parts of the country,  however, State forestry
agencies are implementing non-regulatory programs.  These  States have assured EPA
that the voluntary system will work, and cite cooperative  reforestation and fire
prevention campaigns as examples of success.  In the South and East, the institu-
tional arrangements and good delivery systems exist to service many landowners
with varied interests.
                                         32

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     EPA and USDA are seeking a better understanding of the social  and economic
aspects of voluntary nonpoint source controls.   An attitude survey  is underway
in Nebraska, and research is beginning to quantify off-site water quality benefits
to downstream users.  (The on-site costs and benefits of a given practice are
fairly well known.)

Mater Law

     An issue of increasing importance, especially in the West, is  the question
of water rights.  While this question has normally involved surface water issues
in the past, both the increasing use of ground water and spreading  ground water
pollution problems make it imperative that we address both surface  and ground
water rights in the future.  The States' water rights authority is  well recognized.
There will be no attempt to change water rights authority through section 208.
However, EPA will work closely with the States as they identify problems in this
area and address the institutional and constitutional problems regarding water rights,
A number of States have recently made major decisions on water rights which enhance
water quality use, including Idaho and Colorado.

Energy

     The changing energy picture will have a great impact on the development of
best management practices.  Research in this area will need to be accelerated.
In some cases, BMPs have a positive effect on energy use.  For example, no-till,
a method of planting which is very effective in reducing erosion, is much more
energy and labor efficient than conventional tillage and planting methods.   In
some situations, it also produces higher yields.  More study will be required to
identify which soils are suitable for no-till and to determine whether there
are significant adverse effects from the additional pesticides no-till methods
require.

     The Agency is funding a research project in California to determine whether
animal wastes can be used to produce methane gas economically.  Since these wastes
have been contributing to water pollution problems in the State, a  solution wil
produce both water quality and energy benefits.  Another area that  holds promise
for energy savings is irrigated agriculture.  Many of the salinity  problems in
irrigation return flows result from too much water being used on crops.  The most
efficient BMP is to control water application, in some cases reducing it to less
than half of the amount formerely used by the farmer.  In those cases where pumping
is needed to transport the water, the reduction in water use will save energy and
enhance the water quality.  This illustrates only a few of the current BMPS which
can have a positive effect on energy costs.
                                         33

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                 Hi.  AVAILABILITY OF BEST MANAGEMENT PRACTICES
     While we recognize that data gaps exist, and that more information
is required for the Water Quality Management program to be fully effective,
we do have a large body of knowledge on nonpoint controls that is already
being successfully applied.  One of the initial  steps in 208 planning
was to determine the availability of Best Management Practices.  Where
it was determined that cost-effective BMP's existed, they were adopted
in the plans and approved by EPA.  Generally, they were practices which
had previously been used by agricultural, silvicultural, construction,
and mining operators to reduce sediment and water runoff.  This previous
experience provides strong assurance that they are the most feasible and
cost-effective methods now available to solve some of the more easily
identified nonpoint source pollution problems.

     In beginning to implement the known BMPs, therefore, we feel that
both private and public funds are being put to good use.  On the other
hand, there are many questions about BMPs which we have not answered and
which are being addressed in our continuing planning program.  I will
discuss the data gaps in more detail later in the testimony.

A.  Agriculture

     Perhaps the most extensive knowledge is available for agricultural
BMPs, since many of them have been used as soil  and water conservation
practices.  A recent Cornell University report provides the most complete
information available linking the effectiveness of soil and water conservation
practices (SWCPs) to reduction in pollutants.  Table VII indicates the
effect of selected SWCPs on sediment losses from sample cornfields in
Aurora, New York; Ames, Iowa; and Watkinsville, Georgia.  The results
indicate that SWCPs offer substantial control of sediment losses,
primarily because they reduce cropland erosion.   Runoff reductions are
also given in the table, and it is evident that the practices are substantially
less effective at controlling runoff than sediment.  The differences in
sediment and runoff reductions reflect variations in weather, soils, and
management practices at the three locations.

     The relative efficiencies of SWCPs for sediment control are best
illustrated by estimates of their cost-effectiveness.  In the Cornell
study the cost-effectiveness of a SWCP was determined by comparison with
conventional tillage and was defined as the reduction in annual sediment
loading divided by the incremental annual monetary cost.  Examples of
incremental costs for grain corn are given in Table VIII.  These costs
are the changes in net farm income associated with the practices, and
are sensitive to the effects of the practices on crop yields.  Although
                                        34

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                                     TABLE VII

                     EFFECTS OF SELECTED SWCPs ON RUNOFF AND
                       SEDIMENT LOSSES IN THREE LOCATIONS*
                                   Reduction in             Reduction in
                                   Mean Annual               Mean Annual
                                     Runoff                Sediment Loss
New York

Contouring                            40                         65
Terracing                             60                         95
Sod-based Rotation                    70                         70
Conservation Tillage                  20                         55

Iowa

Contouring                            15                         55
Terracing                             30                         95
Sod-based Rotation                    55                         60
Conservation Tillage                  30                         70

Georgia

Contouring                            30                         60
Terracing                             40                         95
Sod-based Rotation                    30                         60
Conservation Tillage                  15                         40
*The Role of Soil and Water Conservation Practices in Water Quality Control,
 Cornell, University, 1979.
                                         35

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                                      TABLE VIII

                TYPICAL INCREMENTAL COSTS OF SWCPs FOR GRAIN CORN
                                        % Change                 Incremental
SWCP                                 in Crop Yield             Cost ($/ha-yr)

Contouring                                0                           10
Terracing                                 0                          110
Strip-Cropping                           +4a                          95
Sod-Based Rotation                       +4a                          90
No-Tillage                              +10                          -65
                                          0                            5
                                        -10                           75
Conservation Tillage                     +5                          -35
                                          0                          - 5
                                         -5                           35


0 1st year corn after sod.
                                         36

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it appears that most SWCPs have marginal impact on corn yields, no-
tillage and conservation tillage are exceptions.  These practices decrease
yields on poorly drained soils but can increase yields on well drained
soils.  The incremental costs in Table VIII do not include the effects
of SWCPs on long-term soil productivity. Control of soil erosion should
increase farm income in the long run, but data is not available to
quantify these benefits.

     The Cornell study concluded that:

     1.   SWCPs significantly reduce edge-of-field pollutant losses in runoff.
          Reductions of solid-phase pollutants (sediment, strongly
          adsorbed pesticides, organic nitrogen, fixed phosphorus) are
          substantially greater than reductions of dissolved nutrients
          and pesticides.  The magnitudes of pollutant reductions are
          site-specific, depending on local weather, soils and crop
          management.

     2.   SWCPs will not reduce total (runoff plus percolation) edge-of-
          field nitrate losses unless they also reduce fertilizer nitrogen
          applications.

     3.   Cropland erosion controls may not efficiently reduce sediment
          loadings to streams unless they are concentrated on lands with
          high sediment deliveries.

     4.   SWCPs often have negative or marginal short-term monetary
          benefits to the farmer.  In many cases, however, conservation
          tillage and no-tillage can increase farm income.

     5.   Although SWCPs were not extensively compared with other pollution
          control measures, it is apparent that efficient management of
          chemical applications to croplands has significant potential
          for reducing pesticide and nitrogen losses.  Although such
          management is not always operationally or economically feasible,
          it does provide a major alternative to the use of SWCPs for
          pollution control.

     A more comprehensive summary of the principal available practices
for controlling agricultural nonpoint source pollution, with brief
descriptions of their effects, is contained in Table IX.

B.  Urban Storm Runoff

     BMPs available to help control pollution from urban runoff are
practices that control litter, vehicular deposits, construction debris,
and air fallout before they reach the receiving waters.  Techniques
identified in 208 plans include street sweeping, catch basin cleaning
(both in swept and unswept areas), detention tanks, sewer flushing and
                                        37

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                                   TABLE  IX

   PRINCIPAL PRACTICES FOR  CONTROL  OF AGRICULTURAL  POLLUTION
Table
Principal types of cropland erosion control practices and their highlights
Erosion Control  Practice
                                        Practice Highlights
No-till plant in prior-crop
residues
                       Most effective in dormant grass or small grain; highly
                       effective  in crop residues; minimizes spring sediment
                       surges and provides year-round control; reduces man.
                       machine  and fuel requirements; delays soil wanning
                       and drying; requires more pesticides and nitrogen;
                       limits fertilizer and pesticide placement options;
                       some climatic and soil restrictions.
 :onservation tillage
                        Includes a variety of no-plow systems that retain some
                        of the  residues on the surface; more widely adaptable
                        but somewhat less effective than El; advantages and
                        disadvantages generally same as El but to lesser de-
                        gree.
Sod-based rotations
                        Good meadows  lose virtually no soil and reduce erosion
                        from succeeding crops; total soil loss greatly re-
                        duced  by  losses unequally distributed over rotation
                        cycle;  aid  in control of some diseases and pests;
                        more fertilizer-placement options; less realized in-
                        come from hay years; greater potential transport of
                        water  soluble P; some climatic restrictions.
Winter cover crops
                        reduce  winter erosion where com stover has been re-
                        moved and  after  low-residue crops; provide good base
                        for slot-planting  next crop; usually no advantage
                        over heavy cover of chopped stalks or straw; may re-
                        duce leaching of nitrate; water use by winter cover
                        may reduce yield of cash crop.
Timing of field operations
                        Fall  plowing  facilites more timely planting in wet
                        springs,  but  it  greatly  increases winter and early
                        spring erosion hazards;  optimum timing of spring
                        operations  can reduce erosion and increase yields.
Plow-plant systems
                        Rough,  cloddy  surface  increases infiltration and re-
                        duces  erosion; much  less effective than El and 2 when
                        long rain periods  occur; seeding stands may be poor
                        when moisture  conditions are less than optimum.  Mulch
                        effect is lost by  plowing.
Contouring
                        Can reduce average  soil  loss by 50* on moderate slopes,
                        but less on steep slopes;  loses effectiveness if rows
                        break over; must be supported by terraces of long
                        slopes,  soil,  climatic  and topographic limitations;
                        not compatible with use of large farming equipment on
                        many topographies.   Does not affect fertilizer and
                        pesticide rates.

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Table  IX,  cont.
   Contour strip cropping
Rowcrop and hay in alternate 50- to 100-foot strips
reduce soil loss to about 50% of that with the same
rowtation contoured only; fall seeded grain in Heu
of meadow about half as effective; alternating corn
and spring grain not effective; area must be suit-
able for across-si ope fanning and establishment of
rotation meadows; favorable and unfavorable features
similar to E3 and E9.
   Terraces
Support contouring and agronomic practices by re-
ducing effective slope length and runoff concentra-
tion; reduce erosion and conserve soil moisture;
facilitate more intensive cropping; conventional
	 terraces often incompatible with use of
large equipments, but new designs have alleviated
this problem; substantial initial cost and some
maintenance costs.
   Grassed outlets
Facilitate drainage of graded rows and terrace chan-
nels with minimal erosion; involve establishment and
maintenance costs and may interfere with use of large
implements
   Change in land use
Sometimes the only solution.  Well managed permanent
grass or woodland effective where other control prac-
tices are inadequate; lost acreage can be compensated
for by more intensive use of less credible land.
                                    39

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Table IX.  cont.
       Table      Practices for Controlling  Direct Runoff and Their Highlights.
Runoff Control Practice
No-till plant in prior crop
Conservation tillage
Sod-based rotations
Winter cover crop
Timing of field operations
Plow plant systems
Contouring
Contour strip cropping
Terraces
Grassed outlets
Contour listing
Change in land use
Construction of ponds
Practice Highlights
Variable effect on direct runoff from substantial
reduction increases on soils subject to compaction.
Slight to substantial runoff reduction.
Substantial runoff reduction and sod year; slight to
moderate reduction in rowcrop year.
Slight runoff increase in moderate reduction.
Slight runoff reduction.
Moderate runoff reduction.
Slight to moderate runoff reduction.
Moderate to substantial runoff reduction.
Slight increase to substantial runoff reduction.
Slight runoff reduction.
Moderate to substantial runoff reduction.
Moderate to substantial runoff reduction.
None to substantial runoff reduction. Relatively ex-
pensive. Good pond sites must be available. May be
considered as a treatment device.
                               40

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Table  IX,  cont.
                            Practices for the Control of Nutrient Loss  From
                      Agricultural Applications and Their Highlights
Nutrient Control Practice
Eliminating excessive
fertilization
Practice Highlights
May cut nitrate leaching appreciably; reduces fer-
tilizer costs; has no effect on yield.
Leaching Control
Timing nitrogen application
Using crop rotations
Using animal wastes for
fertilizer
Plowing-under green legume
crops
Using winter cover crops
Controlling fertilizer
release or transformation
Reduces nitrate leaching; increases nitrogen use
efficiency; ideal timing may be less convenient.
Substantially reduces nutrient inputs; not com-
patible with many farm enterprises; reduces erosion
and pesticide use.
Economic gain for some farm enterprises; slow re-
lease of nutrients; spreading problems.
Reduces use of nitogen fertilizer; not always
feasible.
Uses nitrate and reduces percolation; not applicable
in some regions; reduces winter erosion.
May decrease nitrate leaching; usually not econom-
ically feasible; needs additional research and de-
velopment.
Control of Nutrients in Runoff
Incorporating surface appli-
cations
Controlling surface applica-
tions
Using legumes in haylands
and pastures
Decreases nutrients in runoff; no yield effects; not
always possible; adds costs 1n some cases.
Useful when incorporation is not feasible.
Replaces nitrogen fertilizer; limited applicability;
difficult to manage.
Control of Nutrient Loss by Erosion
Timing fertilizer plow-down
Reduces erosion and nutrient loss may be less con-
venient.
                                41

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Table  IX, cont.
                         Practices for the Control of Pesticide Loss from
                     Agricultural Applications and Their Highlights
Pesticide Control Practice
Practice Highlights
Broadly Applicable Practices
Using Alternative pesticides
Optimizing pesticide placement
with respect to loss
Using crop rotation
Using resistant crop varieties
Optimizing crop planting time
Optimizing pesticide formu-
lation
Using mechanical control
methods
Reducing excessive treatment
Optimizing time of day for
pesticide application
Applicable to all field crops; can lower aquatic
residue levels; can hinder development of target
species resistance.
Applicable where effectiveness is maintained; may
involve moderate costs.
Universally applicable; can reduce pesticide loss
significantly some indirect cost if less profitable
crop is planted.
Applicable to a number of crops; can sometimes elim-
inate for insecticide and fungicide use; only slight
usefulness for weed control.
Applicable to many crops; can reduce need for pesti-
cides; moderate cost possibly involved.
Some commercially available alternatives; can reduce
necessary rates of pesticide application.
Applicable to weed control; will reduce need for
chemicals substantially; not economically favorable.
Applicable to insect control; refined previctive
techniques required.
Universally applicable; can reduce necessary rates of
pesticide application.
Practices Having Limited Applicability
Optimizing date of pesticide
application
Using integrated control pro-
grams
Using biological control
methods
Using lower pesticide appli-
cation rates
Managing serial applications
Planting between rows in min-
imum tillage
Applicable only when pest control is not adversely
affected; little or no cost involved.
Effective pest control with reduction in amount of
pesticide used; program development difficult.
Very successful in a few cases; can reduce insecticide
and herbicide use appreciably.
Can be used only where authorized; some monetary
savings.
Can reduce contamination of non- target areas.
Applicable only to row crops in non-plow based
tillage; may reduce amounts of pesticides necessary.
                               42

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diversion berms.   Many of the agricultural  erosion and sediment BMPs can
be adapted to construction activities in urban areas.   Work to date has
shown that the best results are obtained when a combination of techniques
is applied to manage (1) runoff, (2) erosion, and (3)  sources.

     The following two charts illustrate BMP application for urban
runoff. Figure VI is a summary of urban runoff management techniques,
and Table  X gives estimates of costs and effectiveness of various BMPs.

C.  Other Nonpoint Sources

     Silvicultural BMPs rely largely on practices which minimize soil
disturbance and reduce runoff velocity.  Most involve  site-specific
planning for timber harvesting, road construction, forestry practices,
and protection of critical zones adjacent to streams.   Silvicultural
BMPs include:

         planning road and skid trail  systems to minimize erosion;
          providing guidance on soils,  slopes, streambanks, bridges,
          and road drainage

         selecting site-preparation techniques which  minimize soil
          erosion; consideration is given to soil conditions, slope,
          vegetation, and other environmental factors

         protecting streamside management zones from  destruction of
          ground cover and soil disturbance; BMP may include a prohi-
          bition of tracked and wheeled vehicles from  the zone, or a
          requirement that trees cut in the zone be skidded away by
          cables

     Specific BMPs to control nonpoint  source pollution from active and
abandoned mines are generally available.  For active mines, many BMPs
have been shown to be both economically feasible and more than 80 percent
effective in preventing or reducing nonpoint source pollution problems--
at least in particular locations or within particular  segment^ of the
minerals industry.  Some of the most important practices available
include:

         special handling of pollution-forming overburden, often aimed
          at isolating toxic materials  from contact with water

         rapid soil stabilization through top-soiling, mulching, and
          revegetation

         water runoff management at disturbed sites through diversion,
          terracing, contour trenching, slope control, drainway construction,
          gradient control, and concentrated flow handling practices

         excavated ponds and sediment  basins

     t    construction, maintenance, and closure of roads to prevent
          erosion and off-site transport of sediment
                                       43

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     BMps for underground mining include:

         bore hole grouting and sealing

     t    preplanned flooding and shaft sealing

         application of surface mining BMPs to surface disturbances

     t    avoidance of post-mining gravity drainage,  which  often occurs  from
          drift mines

     BMPs for ancillary areas include:

         careful  selection of waste disposal  sites  together with use  of
          infiltration and leachate controls

         application of water runoff management controls,  or collection and
          treatment, where needed to control nonpoint pollution

     Abandoned mines present a special  set of problems in  controlling
nonpoint source pollution.  BMPs are generally available,  but some problems
are so severe that they are not amenable to solution  other  than direct treat-
ment of runoff, perpetually.

D.  BMPs for Ground Water Contamination

     As discussed in the description of the ground water contamination
problem, the most effective method for protecting ground water quality
is to monitor and control the potential source of contaminationnot  the
aquifer or the point of withdrawal. Often, when an aquifer  becomes polluted,
the only way to control the movement of contaminants  is to  restrict the  with-
drawal of ground waters.

     Where waste disposal sites are located in critical ground water  areas,
treatment and containment of the wastes may be necessary.   In someareas,
land disposal is simply not a good idea, and alternatives  must be con-
sideredwaste transport, resource recovery, ocean disposal, or surface
discharges may be more sound environmentally.   Regulatory programs
designed to protect ground water quality must reflect a close relation-
ship among land, surface water, and ground water programs.

     An EPA survey of surface impoundments (June 1978) identified several  actions
that can be taken to prevent leachate from impoundments from polluting ground
water.  They are:  impermeable liners; collection and recycling systems  such
as underdrains, infiltration galleries, and wells; retarding movement of con-
taminated ground water by means of hydraulic or physical barriers; or simply
closing the impoundment.
                                         46

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     Some States commonly issue various types of approval  for different types  of
waste impoundments.  These may be simple authorizations or very restrictive permits.
Many States provide guidelines and requirements for siting, construction,  operation,
and monitoring of surface impoundments, but often the requirements  apply only
during construction, or they are not enforced.   State programs are  often hampered
by manpower and budget deficiencies, inadequate knowledge  by staff  of the  scope
and nature of the ground water problem, or requirements which are not stringent
enough.

     Other BMPs which agencies can use to control ground water contamination
are the same ones they would apply for surface  water problems.  Two examples
are zoning ordinances which prohibit certain activities over ground water
aquifers, andfor agricultural pollutant sourcesirrigation scheduling
and reduction of nitrate fertilizer application.  For the  control of salt-
water intrusion, regulation of pumping and/or physical  barriers are BMPs.

     Septic control practices include better regulation of new systems,
rehabilitation of old systems where feasible, prohibition  of toxic  septic
tank cleaners, and management of existing systems by cleaning out the tank
periodically.  Density of septic systems is also becoming  a major problem.
Land use zoning for ground water protection, and revised fee schedules are
being explored.

     Local citizens and agencies on Long Islandwhere ground water problems
are becoming critical--agreed on a comprehensive set of solutions ranging  from
sewer development plans and tighter industrial  discharge controls to better septic
tank maintenance, lighter use of lawn fertilizers, and safeguards for landfills.
By choosing a minimum-sewer approach, the plan  will  keep the island's sewer con-
struction costs down to $2 billion over the next 20 yearsfar below the $10
billion cost of complete sewering.  This will also provide for necessary
ground water recharge to maintain adequate level of supplies.
                                           47

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                       IV.   FILLING DATA GAPS


     In your letter of June 5,  1979 regarding this hearing,  you raised a number
of questions regarding nonpoint sources and water quality standards,  our alloca-
tion process between point  and  nonpoint waste loads,  how we  measured  natural
NPS pollution and the need  for  better data and more monitoring.  A primary
objective in the continuing planning program will  be to fill  in the  critical
data gaps to build the basis for future controls on the more difficult nonpoint
source problems.  A recent  6AO  report* questioned EPA's ability to solve NPS
problems without better data.   The report called specifically for better data
on cause-effect relationships.

     EPA doesn't agree totally  with the findings of the GAO  report.   We discussed
our problems with the report in Mr. Costle's letter of January 12, 1979, to
Congressman Bo Ginn, the former chairman of this Committee.   Basically, in
spite of the data problems, EPA is overseeing the implementation of BMP's now,
and--at the same timefilling  the gaps which the GAO identified.

     We know that NPS pollution is a problem of serious national significance.
Also, we know that controls and methods exist which will reduce the nutrient,
pesticide, sediment, and coliform levels in NPS runoff.  However, we  lack inform-
ation to evaluate the application of a specific BMP in a specific situation and
the resultant improvement in downstream ambient water quality for the receiving
waters.

     For example, agricultural  residues of nitrogen and phosphorous may enter
surface and ground waters from  runoff and leaching of animal wastes,  fertilizers,
and crop residues and from  movement of sediments with adsorbed nutrients.
However, the total amount of nitrogen and phosphorous lost to surface or ground
water in any specific situation depends on many variables.

     For cropland, these variables include application rates, soil properties,
terrain, cropping practices, and rainfall amount, intensity, and duration.
Many experiments have determined the amount of nutrients lost in individual
agricultural situations, but we cannot predict how effective a particular BMP
will be when applied to a particular farming enterprise when we have
no previous data on that particular farm or receiving water.

     We need to develop better  understanding of these relationships so that we
can make accurate predictions without having to collect specific BMP cause-and-
effect data for each site.

     Water quality standards provide the ambient requirements necessary to sus-
tain the uses of the water resource to meet social needs.  Water use classifi-
cations, which such standards support, are determined by a State through the
public hearing process when standards are periodically reviewed.  Pollutants
introduced to a, waterway from either point or nonpoint sources may affect the
   The Comptroller General's December 11, 1978, report on the 208 program in
   which he noted that water quality management planning was not comprehensive
   and that serious data deficiencies needed to be addressed.
                                        48

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degree of attainment of water quality standards but such pollutant sources are
not controlling in the development of ambient standards to meet water quality
needs.  Water quality criteria, which are designated in water quality standards
to meet specific water uses, are developed from scientific information and are
designed to provide for protection and propagation of aquatic life and for
the protection of human health.  Where the meeting of water quality criteria
in water quality standards would result in widespread economic or social
hardships, provisions are provided in the regulations for downgrading the
designated water uses.

     The determination of the use classification is based on "actual" or
"attainable" water conditions.  In this determination, the concentration of
nonpoint source pollutants could be a factor when the pollutants associated
with the nonpoint source:  (1) represent a continuing input and are considered
an existing condition and  (2) exceed the concentration for the criteria
specified for the water use in question.  For example, in reviewing established
standards, nonpoint source pollution may be considered in downgrading the
designated stream use with a justification of man-induced irretrievable
conditions.

     The current approach to nonpoint source control has primarily been
based on long term loadings and not on specific water quality parameters or
standards.

     Nonpoint source control programs are based on the use of best management
practices (BMP's) which initially may not completely achieve water quality
goals.  An iterative process of tightening BMP requirements may be necessary
to achieve this objective.  Water quality criteria are based on water quality
necessary to support a designated use, and therefore are equally applicable
whether the load comes from point or nonpoint source discharges.

     Water quality standards have been set by the States.  This question of
allowable inputs during design storm events is receiving direct attention
through activities of EPA's Office of Research and Development where nonpoint
source inputs are being defined as functions of storm hydrographs and where
probablistic and statistical concepts are being explored.  Office of Research
and Development is also developing monitoring programs that preclude the need
for continuous water quality sampling.

     Studies are also underway to better define what constitutes adequate
stream quality for a given use.  For example, the EPA research laboratory
in Corvallis, Oregon has a number of research projects ongoing which are
designed to define the critical parameters for stream systems where the main-
tenance of a fishery is the desired use.  In addition, the Model Implementation
Program projects in South Carolina, Nebraska, Indiana and New York are being
monitored with the same objectives in mind.  In these efforts a total approach
is being used and concepts such as streamside vegetation for temperature and
sediment control are being integrated with instream habitat and water quality
requirements.  The objective is to improve the stream system to allow a
desired use as opposed to the Improvement in a single water quality parameter
or the reduction of the annual load.

     We also need more work done on NPS pollution occurring from natural  sources,
While the state-of-the-art is improving, our techniques are quite general.
                                        49

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     One technique that is used is the comparison of current levels of a given
parameter to background data available for that area prior to the existing
land use, provided the previous use was a "natural"  one.   Comparisons to other
areas can also be utilized in a similar way.   One problem with this approach
is that the available data are likely to be limited  to low flow periods since
little monitoring has been done on wet weather conditions, when NPS pollutants
are normally transported.

     Another approach that has been tried is  the paired watershed concept
where impacted and non-impacted areas are compared.

     EPA has approached this problem in two ways:  (1) EPA's Office of Research
and Development has initiated studies which will seek answers to questions
about natural conditions both through computer modeling and on-site techniques
a,nd (2) EPA in cooperation with USDA has initiated a series of demonstration
projects in agricultural areas where project monitoring is being used to provide
insight into these problems.

     Our urban runoff program is currently in the process of assessing the non-
point source contribution of pollution from urban runoff during rainfall and
snowmelt events.  Thirty cities are being studied to determine the magnitude,
extent and type of water quality problems caused when rainfall washes the sur-
face of our cities.  The program is designed to determine what the relationship
is between water quality degradation and urban runoff.

     By establishing nonpoint source inputs the reductions in instream loads
can be determined and natural levels established.

     For natural materials, like sediment, which are pollutants only when present
in sufficient quantity to impact a desired use, the distinction between natural
and man-made conditions is particularly difficult because the sediment load
is flow or energy dependent and relative contributions will differ.  Sediment also
represents an unlimited source and the volume transported will vary directly
with flow.

     Earlier, the testimony discussed the work being done on AWT projects,
particularly our intensive analysis of waste load allocations to determine where
AWT is required and where secondary treatment will meet the water quality goals.
Although, historically, the orientation of most AWT projects revolved around
a design at low flow conditions, the water quality impacts of a project at
higher flows are now more generally considered.  With the availability of 208
data and the growing emphasis on nonpoint source controls (including Clean Lake
grants), comparisons of advanced wastewater treatment against nonpoint source
contributions are now being done.  In years past, most AWT projects were built
before the problem or contribution of nonpoint sources was understood.  The
Headquarters Task Force on AWT review has noted that significant nonpoint source
issues are identified in about 10 percent  of the projects sent in for review.

     At present, few precise quantitative NPS analyses are available.  Accurate
cost comparisons of point and nonpoint tradeoffs are seldom available.  Thus,
the importance of nonpoint source loadings will usually be qualitatively con-
sidered  in the WLA process, until a better data base is assembled  in the next
(current) generation of WLA's.
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     There are three general types of wasteload allocation (WLA) studies where
nonpoint sources of pollution could be a factor:  flowing streams, lakes/
reservoirs and estuaries (tides).  In these situations a critical or worst
condition is used as a base of reference.  The resultant WLA, if done to
include NFS issues, reflects the most stressful environmental condition(s)
under which point and nonpoint sources are collectively evaluated, for compliance
with water quality standards.

     In most free flowing systems, nonpoint sources are usually not a direct
factor at low flow.  Nevertheless, nonpoint source pollutants generated during
higher flow periods can cause problems indirectly because of sediment deposits
on stream and lake bottoms.  These deposits may have a water quality impact
during low flow periods by exerting a benthic (bottom) oxygen demand.  This impact
can be approximated quantitatively by benthic demand analysis and be quantitatively
included in the WLA model.

     During higher flow or runoff events, various methods are available to esti-
mate the sediment loading to streams, lakes and estuaries.  These estimates,
allow conceptual comparisons that are useful for judging the general trade-off
between point and nonpoint source controls.  Later, when actual sampling and
analysis of runoff is done, better analyses are possible.  Quantification of
overall loadings of soluble and insoluble nutrients as well as toxic loadings
become very useful extensions of simple sediment estimates.

     Nutrients can create problems in slow moving streams, estuaries, and lakes.
The effects of nutrients on the dissolved oxygen profile of streams can, like
benthic demand, be quantitatively approximated as part of the WLA model.

     Lake models can similarly be prepared to assess the significance of nutrients
on the DO of a lake.  Lake models are highly complex and expensive.  Most often
annual nutrient budgets are calculated instead.  From these budgets, or mass
balances of nutrient input/output, the general state of the lake is determined.
Prevention of eutrophication by a combined program of nutrient contols can have
direct benefits since excessive algal decomposition will not occur on the lake
bottom.

     Many sediment loading estimates and nutrient budgets on streams and lakes
have been made available through the WQM process.  But, few estimates have been
made for estuaries.  Since estuaries are subject to tidal influence, the added
complexity makes modeling very difficult and expensive.  Mathematical techniques
are available to deal with this complexity, but the models are difficult to
comprehend and their accuracy is largely unknown.  Allocations for estuaries
including nonpoint sources are usually done on a qualitative basis.  Gross allot-
ments of nonpoint source loadings for broad categories of land use are usually
calculated.  For estuary-NPS studies, loadings are usually calculated at a
combination of low (slack) tidal stage and rainfall (runoff).  If nonpoint sources
are Ignored the design condition assumes that the critical event occurs when
freshwater flow rates are at their lowest.
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     If a study area has suspected urban, agricultural,  or other nonpoint
source runoff problems, they should not be ignored.   For nonpoint source runoff
assessments a design (critical) rainfall  event is chosen to generate the non-
point source sediment loadings.  These loadings are  then factored into various
runoff models, which generate loadings for nutrients, oxygen demand and other
parameters.  These loadings, in conjunction with a point source inventory and
water quality impact models, can then be  used to approximate water quality
standards violations at low and high flow.

     There is little question that more accurate data, more monitoring, and
refined analytical tools are desirable.  Generally,  the  problems to date have
been identified by using limited data, and observations.  For example, all
point source discharges to a stream are being controlled but the historic or
desired use of the stream has still not been restoredit's still eutrophic, there
are no fish, or the coliform counts are too high for safe bathing.  We are
working to meet these needs in a number of programs  in the Agency, including
more intensive surveys by EPA monitoring  teams, additional  research, and emphasis
on better data in the 208 and Clean Lakes programs.

     Free flowing systems present the real problem because we do not have
acceptable methods of measuring the "health" of the  system relative to NFS
loading.  Methods do exist to identify degraded areas resulting from point
source inputs but it is not clear, as yet, whether these are applicable to
diffuse sources.

     Probability and statistical theory are adequately developed to be used to
address the problem.  However, there is an absence of data from which to develop
approaches that can be proven to be adequate and thus accepted by the technical
community.  More important, at this point, is having adequate data to demon-
strate in a quantitative manner the extent to which  nonpoint source problems
exist and to show by example that their control is not beyond reason.

     EPA has undertaken this latter task through the use of prototype projects
in urban runoff,  agriculture, silviculture, and ground water.  Progress (i.e.,
the restoration of degraded aquatic systems) is being made.  The most dramatic
success is with impoundments or lakes where the mass balance or long term load-
Ings approach works and where acceptable methods of measuring the "health" of
the system exists.

     Lake restoration grants to the Cobbossee Watershed  District (ME) and to
Moses Lake  (WA) are examples where positive results have occurred.  In Maine
the project resulted in an animal waste management program in the watersheds
of three eutrophic lakes.  This, in combination with a nutrient inactivation
project, will significantly reduce nutrient loadings to  these lakes.  In Moses
La,ke the controlled release of dilution water during the spring-summer season
has resulted in water quality improvements that are significant and actually
greater than expected.

     Another prime example is Skinner Lake located in Noble County, Indiana,
where a variety of NPS controls are being applied to control the input of
sediment and attached phosphate to the lake.  The project utilizes the joint
resources of USDA and Indiana-Purdue Universities at Fort Wayne.  This project
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concentrates on:  (1) controlling septic tank effluents,  (2) controlling
nutrient and sediment inputs, and  (3) removal and inactivation of nutrients
by weed harvest and chemical treatment.

     As stated earlier, we have sufficient knowledge in many areas to proceed
with BMP implementation and are doing so.  The continuing 208 program will
focus on those data gaps where more information is needed before we embark
on a costly nonpoint source control program.
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                        V.  NONPOINT SOURCE RESEARCH


     EPA's goals for nonpoint source research encompass most of the research needs
identified above.  Our first goal will  be to understand further the complex relation-
ship between nonpoint source pollutant discharges and the quality of the affected
waterways.  Here, particular emphasis will be placed on the effects of toxic
pollutants.  Our second goal will involve the development and evaluation of
cost-effective management methods to limit pollution from nonpoint sources.  This
goal will address structural as well as nonstructural approaches to the control
of these pollution sources.  Finally, our third goal for research will focus on
the development and demonstration of effective implementation strategies for
nonpoint source control methods.  This research goal is needed for the development
of improved voluntary acceptance approaches to the use of control methods for
nonpoint sources.

A.  Understanding How Nonpoint Sources Impact Hater Quality

     Our first task will be the development of methods to evaluate the physical,
chemical, and biological water quality impacts from the discharge of nonpoint source
pollutants from urban runoff and agricultural production.  Here techniques will be
developed which relate climate conditions and urban and rural land use activities
to enable the prediction of the total amount of pollutants discharged to a receiving
stream.  (Other nonpoint sources such as forestry activities will receive attention
in the future.)  This information will then be used to obtain criteria for the level
of nonpoint pollutant discharges allowable for specified water uses.

     In addition, monitoring techniques will be developed to measure the amount of
nonpoint source pollutant, discharges.

B.  Research Will Aid in Determining the Most Cost-effective Method of Meeting
    Established Water Quality Standards

     Some of this research will  improve our capability to monitor and predict both
the quantity and quality of precipitation and should therefore assist in the evaluation
of watershed impacts caused by acid rain.  Here, we plan to focus on  impacts in the
following general areas:  aquatic environments, soils, agriculture, forestry,
natural ecosystems, and long term trends.

     Finally, we will address the relationships between point and nonpoint source
pollutants on an individual watershed basis.  This  research will aid  in determining
the most cost-effective method of meeting established water quality standards.  As
part of this work, methodologies will be developed  for determining allowable dis-
charges for both conventional pollutants  (such as organic matter, suspended solids,
and fecal coliform) and toxic materials based on land use, climate, soil types,
and pollutants  for an entire watershed.

C.  Methods for Controlling Nonpoint Source Pollution

     The first  step here will be to evaluate the effectiveness of existing methods
to  control conventional as well  as  toxic  nonpoint source pollutant discharges  in a
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watershed.   Since local conditions may be such that more than one nonpoint source
control method is required, various combinations of methods will be evaluated.
Methodologies will be developed to match the most appropriate control method or
combination of methods to a given set of local problems.  In line with this
approach, we will publish guidelines for planning, conducting, and evaluating
field demonstrations of nonpoint source control methods to assist State and local
water quality management agencies in developing effective nonpoint source control
programs.

     Because nonpoint source control for agriculture and silviculture is a
voluntary program, it will be crucial that users in the field be aware of the
latest developments.  To this end, we will evaluate information transfer mechanisms
currently available for nonpoint sources to determine their effectiveness in
reaching the user community.  In the years ahead, these mechanisms will play a
major role in the transfer of nonpoint source assessment and prediction capabilities,
results from demonstration studies, and improved or new management concepts to
the field.

     As a final task, we will demonstrate and evaluate new or improved control
methods which have been developed by other Federal and State agencies.  Par-
ticular emphasis will be placed on those methods which are appropriate for multi-
ple uses.  Since accurate and timely information will be needed by State and local
management agencies during the implementation phase of nonpoint source control
programs, we will also develop an information system to retrieve water quality
monitoring data on the effectiveness of nonpoint source controls.

D.  Implementing Nonpoint Source Controls

     In order to improve our capability to implement nonpoint source control
programs, EPA1s research will focus on the development of relevant economic
impact data, the analysis of existing institutional mechanisms, and opportunities
to integrate nonpoint source control programs with other pollution control
programs.  Special attention will be paid to economic impacts at the local,
regional, and national levels for agricultural and silviculture nonpoint source
control methods.  Here, various incentives also will be investigated to determine
those that are the most feasible and appropriate for local problems and conditions.

     Second, we will evaluate the effectiveness of existing institutional mechanisms
in encouraging the use of nonpoint source control methods.  Current laws and
regulations will be reviewed to identify impediments to effective nonpoint source
control.  Educational programs will be assessed and successful examples of voluntary
implementation of nonpoint source controls will be evaluated and documented.

     Finally, we will investigate opportunities to integrate nonpoint source
control efforts with other pollution control efforts.
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             VI.  PROGRESS IS BEING ACHIEVED IN THE CURRENT PROGRAM


     After five years of 208 planning, it is reasonable to ask about progress.
What measure of success has been attained?  Given that NPS pollution is a major
national problem, that certain data gaps need to be filled, and that many feasible
BMP's already exist for controlling NPS pollution, what is EPA's strategy for
solving the NPS problem?

     Many of the pollution problems first identified in 208 plans are on their
way to being solved.  The continuing program strategy has increased emphasis
on providing solutions to site-specific priority problems in each planning area.
Activities under the continuing program include the preparation of ordinances
and legislation; the preparation of site-specific plans (e.g., diversion structure
for mine drainage control); analysis of manpower requirements and methods of
financing and allocating costs for implementation; presentations to public groups
and decision-makers (e.g., city councils and State legislatures) for appropriate
action.  In essence, the program is taking planning recommendations through
the political process to implementation.

     In addition, on selected projects, EPA is funding detailed monitoring and
evaluation of BMPs being implemented.  EPA has placed increased emphasis on
these prototype projects to define the extent of the problems, identify cost-
effective solutions, and provide a technical base for controls.  The highest
national priorities for 208 funding are urban storm runoff, agricultural pollution,
and ground water protection.   To expedite solutions, EPA will continue problem-
specific technical assistance contracts with technical experts to assist EPA,
the States, and other agencies with their difficult NPS problems.

     EPA is now relying on prototype projects to develop cost-effective controls
on selected sites for transfer to other sites.  Information transfer is a key
aspect of the strategy because of the limited monies available to monitor and
evaluate each project.  EPA recognizes that only a certain level of information
is transferrable and that it must be tailored to each exact situation.  To enhance
the potential of information transfer? EPA has selected prototype projects in a
variety of settings with different types of receiving waters, designated uses,
possible controls, and involved pollutants.

     EPA has also made several modifications in policy and in management to improve
the program.  These changes are discussed later in this testimony.

A.  Point Sources

     Since early planning was centered on point sources, we could expect results
to be most obvious in this area.  And they are.  In the initial stages of this
program, major efforts were directed to resolving population projections, sewer
capacities, and service areas and developing facility plans.  By November of this
year, an area must have an approved 208 facility plan prior to continuing construc-
tion grant funding.

     We have saved more money by reducing costs for municipal waste treatment
facilities through 208 planning than has been appropriated for section 208 to
date.  Several examples follow:
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New Castle County 208 Agency (Wilmington. Delaware):  An evaluation of
proposed sewer extension plans to provide service to homes with septic systems
included a determination of on-lot disposal methodologies considering environmental
constraints such as soil type, topography and hydrology.  The 208 plan developed
a priority list for septic system needs which identified those areas most in
need of sewering and those areas suitable for continued operations of on-lot
disposal systems.  The County revised the Capital Improvement Plan to include
only those areas in need of sewering, resulting in a $2 million cost savings.
In addition, an approved sludge pipeline was abandoned upon examination
of sludge disposal alternatives, for a $9 million cost savings.

North Beckley and Bruceton Mills, West Virginia:  Revised waste load allocations
helped tailor municipal wastewater treatment technology to local receiving stream
conditions.  In North Beckley, the original allocation set limits of 10 mg/1 for
BOD,- and 3.2 mg/1 for TKN. The treatment selected to meet these limits was an
oxidation ditch followed by a nitrification unit.  The new limits are 30 mg/1
for BODc and 18 mg/1 for TKN.  It is anticipated that only an oxidation ditch
is needed to meet this requirement and, therefore, no nitrification unit is needed.
This results in a capital cost savings of $1,900,000.  In Bruceton Mills, the
original allocation set limits of 12.0 mg/1 for BODg and 3.2 mg/1 for TKN.  Treat-
ment required to meet this limitation is extended aeration followed by nitrification
and filtration units.  The revised allocation is 25 mg/1 for BODr and 6.9 mg/1
for TKN.  It is anticipated that at least the filtration unit may be omitted
within the facility to meet the revised limitations.  This results in an
approximate savings of $30,000 in capital costs.

Solomons Island, Maryland:  The original wasteload allocation set limits
of 20 mg/1 for BODr and 10 mg/1 for SS, based on old State policy of
requiring filtration for all discharges into shellfish waters.  The
State reassessed this project, and the allocation was changed to secondary
treatment (lagoon).

Mississippi (Small Communities):  Mississippi, like several  other southern States,
presently has numerous small communities which use oxidation ponds as the primary
wastewater treatment system.  The Clean Water Act and State water quality standards
are such that oxidation pond systems cannot comply with their requirements.  It
appeared, therefore, that all of these small communities would be faced with the
installation and operation of expensive "concrete and steel" treatment plants.

     Early in the State 208 program it was decided that a major effort
to determine a better method to design and/or operate oxidation ponds
should be undertaken.  Although some additional  limited study is still
preceding, the results of the initial  studies are beginning to be imple-
mented through the 201 construction grants program.
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     There are presently about 252 oxidation pond facilities of less than
2.0 MGD i,n Mississippi  alone.   A rough estimate of potential cost savings to
these municipal facilities by  installing the recommended hydrologic controlled
release oxidation pond  system  rather than biological  "concrete and steel" systems
is $25,000,000 in construction cost alone.   If these  same facilities were all
required to install  facilities designed to meet water quality standards in
small low flow streams, the potential  savings of construction costs would be
approximately $100,000,000.

     Thus it appears that construction cost savings in the range of $25,000,000
to $100,000,000 can  be  attributed to a study element  of the Mississippi Air and
Water Pollution Control Commission 208 plan, which was executed at a cost of
$143,700 from Federal 208 funds.

Mississippi (Gulf Coast Region):  After a moratorium  was declared on wastewater
discharge permits in the Gulf  Coast area, action was  initiated to develop a cost-
effective wastewater facility  plan for the Gulf Coast region.  The facility plan-
ning efforts were partially funded by two separate grants under step one of the
Construction Grants  Program (section 201).   The plans were actually developed
under individual agreements between each of the nine  municipalities and three
counties and their individually selected consulting engineers.  Coordination of
these separate planning efforts proved difficult, and it became apparent that a
central focus was required to  tie the planning program together.

     The Mississippi Air and Water Pollution Control  Commission, through the
statewide 208 program,  was the mechanism used to resolve problems experienced
in the 201 program.   The study resulted in a certified plan for the Gulf Coast
that establishes a regional treatment scheme for the  three county area.  Although
capital construction costs have actually increased as a result of higher required
levels of treatment  identified during the 208 process, significant cost savings
have resulted from enactment of State legislation that establishes an interim
regional commission  to  implement the Gulf Coast Plan.

     Cost savings will  be realized in two areas:  (1) reduced interest rates
available to the regional authority; and (2) improved management capabilities.
Because of the regional commission will be authorized to collect a 2 mill tax
as a standby method  of generating revenue, its bonding capability will be
significantly increased above that of individual communities (in the 208 plan,
a financial analysis showed existing bonding capability of several municipalities
was  inadequate to finance treatment plant construction).  Also, the interest rate
in the bond market for the regional commission should be about 1 percent
lower than that obtainable by individual municipalities.  Based upon a local
share of about $31,000,000 that would be included in  the initial bond sale, this
results in a cost  savings of approximately $7,500,000 over the life of the bonds.  A
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comparison of costs for centralized versus decentralized operation and maintenance
of treatment and interceptor facilities showed that cost savings of $3,700,000
over a twenty year period could be expected.   Actual  services at existing plants
(dencentralized operations) should be significantly improved as a result of the
regional operation (centralized operations).

North Carolina:  The North Carolina 208 process identified, evaluated, and is
nearing imp!ementation of a management practice which will  result in a conservative
savings estimate of $3,000,000 per year in operation and maintenance costs.  The
practice, seasonal effluent limitations, would provide increased discharge of
oxygen consuming wastes (BOD and NH3 -N) during the winter months (November thru
March).  During this season, high stream flows and low temperatures allow for
greater natural assimilation of oxygen consuming wastes.  The summer period (April
thru October) is the critical season in relation to the effects oxygen consuming
wastes have on natural waters; however, it is also the period when oxygen consuming
waste treatment is most effective.

     The management practices analysis was developed into regulations which
allow winter season effluent limits to exceed summer effluent limits by as much
as a factor of two.  In addition, a benefit-cost study of the seasonal effluent
limits showed no significant social or environmental  costs but considerable
economic savings.

     For example, for one city with a 16 MGD facility, the savings were estimated
at $9,000,000 for capital costs and $250,000 for operation and maintenance costs.
It is estimated that design modifications, more accurate accounting of industrial
savings, and other factors could easily make actual savings in the $5,000,000 to
$10,000,000 per year range for North Carolina.

Nashville, Tennessee:  Work conducted by the Nashville 208 agency, the Mid-Cumberland
Council of Governments and Development District, led to substantial cost savings
for construction of one of the area's sewage treatment plants.  The Dry Creek Sewage
Treatment Plant, with a design flow of 12.3 MGD, had been given effluent limits by
the State of Tennessee of 20 mg/1 for BODS and 5 mg/1 for NH3 -N, corresponding to
secondary treatment levels with nitrification.  Field data collected by the 208
study was utilized to calibrate a computer model.  The results of the modeling
indicated that straight secondary limits for this plant would be adequate to
protect the instream standard for dissolved oxygen.  After much discussion between
the 208 agency, EPA, and the State, the effluent limits of the facility were
reduced to straight secondary treatment levels.  The estimated cost saving in
capital construction costs is approximately $3 million dollars.

Knoxville, Tennessee:  Several years before the start of the 208 program, the City
of Knoxville received a court order to expand and upgrade existing treatment faci-
lities.  A recommendation for a regional facility received strong opposition.  A
plan was finally developed for expanding of two treatment facilities and upgrading
them to tertiary treatment.  Water quality analysis for the 208 program indicated
that municipal point sources are the most serious pollution sources in the Knoxville
area.  Further modeling under the 208 program showed that incremental improvement
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in water quality from secondary to tertiary treatment was negligible.  The
solution developed on the basis of these findings was to expand and upgrade the
Third and Fourth Creek Sewage Treatment Plants to better than secondary treat-
ment for some constituents but to secondary treatment as adequate for others.
The Tennessee Water Quality Control  Division and EPA reduced effluent limits
accordingly.  The revised plans for upgrading of facilities in Knoxville will
result in almost the same degree of improvement in water quality and a cost
savings of $2 million to $3 million.

First Tennessee-Virginia Development District (Johnson City, Tennessee):  Briston,
Virginia, Briston, Tennessee, and the outlying areas of Washington County, Virginia,
were covered by two separate, poorly coordinated 201 plans which proposed three
new treatment facilities for the area.  The mayors of the two towns are on the 208
Policy Advisory Committee of the First Tennessee-Virginia Develooment District.  The
208 staff reviewed the 201 plans and found that one regional facility would be
more cost-effective.

     The mayors and members of the Boards of Commissioners for the two cities
and a representative from the county are meeting regularly with the 208 staff.
Agreement has already been reached on upgrading an existing facility to serve
as the regional facility and the project is underway.  This single facility will
result in a cost saving of approximately $42 million, including $30 million for
construction of one of the proposed new plants and $12 million from upgrading
the existing plant rather than constructing a new facility.

Chattanooga, Tennessee:  The water quality work conducted by the Chattanooga 208
agency has resulted in a substantial cost savings to the residents of the area
and the U.S. Government.  The Moccasin Bend. Sewage Treatment Facility was given
effluent limits by the State of Tennessee which required treatment levels of
30 mg/1 for BOD5 and 5 mg/1 for NH., -N.  The water quality modeling efforts of
the 208 study snowed that an ammonia limit of 5 mg/1 was not necessary to meet
dissolved oxygen instream standards.  The size of the facility involved is 90  MGD,
 and the estimated cost savings are in the $20 mi 11 ion ranae.  Construction is
currently underway on this facility.

Volusia County COG (Daytona Beach, Florida):  Water quality analyses performed by
the 208 agency in the Volusia area led to reduction of treatment requirements  from
AWT to secondary for discharges to the lower Halifax and Northern Indian Rivers
with no significant effect on water quality.

Myrtle Beach, South Carolina:  The Myrtle Beach waste water treatment facility was
modified after modeling studies funded by 208 determined that if the discharge was
combined with another plant, effluent requirements could be reduced to secondary.

Arkansas/Louisiana:  The most significant cost savings in water quality activities
which will be realized in Arkansas and Louisiana as the result of 203 planning is
the development of a policy pertaining to point source discharges to intermittent
streams, man-made water courses, and nonpoint source dominated streams.  As a result,
many dischargersnow required to provide AWT/AST because of the way the Arkansas
and Louisiana water quality standards are writtenwould need to provide only
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secondary treatment.  This has a potential for saving millions of dollars in
in both capital costs and operation and maintenance costs.  In addition, this
would provide more protection for the environment since many of the affected
dischargers are very small and would be unable to operate a sophisticated treat-
ment plant properly.

Indian Nations COG (Tulsa, Oklahoma):  INCOG was able to demonctrate, as a result
bT the 208 monitoring program, that chlorination of the effluent of Broken Arrow's
wastewater treatment plant was not environmentally necessary, and this resulted
in a savings of $63,000 in construction costs and undetermined savings in
O&M costs.

North Central Texas COG (Arlington, Texas):  AST, rather than the originally-proposed
AWT, will be required of wastewater treatment plants on the Trinity River.  A large
cost-savings (approximately $100 million is anticipated). Continuing monitoring
will identify future treatment levels.

Mountain! and AOG (Utah):  Water quality information from 208 planning indicated
that a reduced level of wastewater treatment was adequate to meet standards.
Eliminating sand filters on the Timpanogos Regional Treatment Plant will save
$1.5 million in capital costs (1976 dollars).  In addition, regional ization recom-
mended by the 208 plan eliminated three small plants resulting in a savings of
$2.04 million in capital costs and $112,000 in annual O&M costs.
Salt Lakp County 208 Agency (Utah):  Water Quality information funded through 208
indicated that a reduced level of wastewater treatment was adequate to meet stan-
dards.  Plant reaional ization in the Jordon Valley (seven existing plants combined
into two regional plants) will save $18 million in capital costs and $9005000 in
annual O&M costs.

Larimer-Weld COG (Colordao):  A consultant, performing work under a 201 grant for
the rural towns of Frederick, Firestone and Dacona, recommended an activated sludge
system with an estimated price tag of $2.7 million which would have imposed an exor-
bitant monthly cost on the citizens of this low population area.  The 208 planning
agency, concerned about the monthly cost, developed an alternative plan which resulted
in an estimated yearly assessment of well less than $200 per tap with a lagoon
system while still  meeting permit conditions.

Pikes Peak COG (Colorado):  The 208 planning agency conducted an in-depth study of
a septic tank problem in the Ute Pass Development.  The agency determined the prob-
lem not to be as significant as thought, resulting in a savings of $3 million in
central sewage collection and treatment systems.

Denver Regional COG (Colorado):  The use of the COG's population projections by local
government for wastewater treatment facility design will result in a potential savings
of $100-200 million.   The planning agency's projections (2-2 million) were significantly
lower than the local  figures (combined 4.0 million).
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Southwest Wyoming 208 Agency:  Some towns have taken facilities plans developed
under this 208 grant and proceeded without financial assistance to develop plans
and specifications, and in at least one case (Mountain View), construct the faci-
lity without EPA funds.  Cost savings to EPA was more than the cost of the initial
208 grant ($415,000).

Phoenix, Arizona:  Phoenix had population projections varying from 1.9 to 3.0
million people and had 9 existing service areas.  A population projection of 2.2
million was adopted, which resulted in smaller treatment facility requirements.
The facility plan examined phasing of facilities, better utilization of capacities,
and consolidation of service areas to six.  These findings resulted in a $15-20
million construction cost savings plus undetermined savings in 0 & M.

Southeast Idaho COG (Pocatello, Idaho):  A joint municipal/industrial land appli-
cation project for water reuse was recommended by this 208 agency.  The industry
is a fertilizer manufacturing plant that discharges to the Pocatello municipal
treatment system.  This phosphorus rich effluent will be applied to cropland in
the area.  The proposed AWT facility would have cost $9 million.  The cost of the
proposed land application system will be $6 million, resulting in a $3 million
capital cost savings.  0 & M cost savings of at least $900,000 annually will
also be realized.  The AWT facility would have cost $1.5 to $2.8 million annually
to operate, while the cost for land application will be about $600,000.

Mid-Willamette Valley COG (Salem, Oregon):  MVCOG developed and implemented regional
projections for population, land use, and wasteloads in the three counties and 33
incorporated cities within the Region.  This resulted in a documented municipal
treatment facility construction cost savings of an estimated $1,466,000 for
four cities in the Region.

Lane Council of Governments (Eugene/Springfield, Oregon):  The City of Eugene, the
City of Springfield, and Lane County signed a joint Powers Agreement establishing
the Metropolitan Wastewater Management Commission.  The new commission was created
to construct, operate and maintain regional sewerage facilities for the Eugene-
Springfield Metropolitan area.  Financial and technical assistance and political
mediation, which were part of the 208 effort, helped realize a $3 million cost
savings through regionalization of sewerage treatment facilities.

B.  Advanced Waste Treatment/Waste Load Allocations

     A limited number of proposed AWT projects will be selected for detailed
analysis in the 208 program.  These will generally be projects which have more
complex institutional and political problems (multi-jurisdictional) and could not
be resolved in a single community.  Since in FY 80 we will nnt utilize ?08 funds
for point source planningsuch as these AWT decisionswe will utilize construction
grant funds through interjurisdictional agreements a* required.
                                    62

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     The objectives of the AWT planning program are to assist municipalities
States and EPA in improving the methodologies and guidance for wasteload
allocations, including the impact of nonpoint source pollution and to assure
that economic factors are fully assessed so that better AWT decisions will
be made.

     A list of the initial projects to be evaluated in the 208 program appears
in Table XI.

C.  Agriculture

     Until the 208 program was initiated five years ago, little attention had
been given to agricultural sources of pollution.  While agricultural activities
were generally thought to cause water quality problems in many lakes and streams
there was, and still is, a lack of adequate data on the extent of the problem and
the controls required to correct or prevent it.  Many of the answers we need
will take both time and money.  However, we have made progress in the
agricultural nonpoint source area.  As a result of the initial findings of the
208 program, most States have identified those areas which have the most critical
agricultural nonpoint source problems.

     We have made full use of the expertise and resources of USDA to assist us
in implementing agricultural nonpoint source controls.  Their agricultural delivery
system is both widespread and effective.  Many farmers and ranchers have applied
conservation measures on their lands for years.  Our objective is to accelerate
that progress in critical water quality areas and provide more information to land
owners regarding more effective BMPs.

     Working with the U.S. Department of Agriculture, EPA selected seven critical
areas, out of 50 identified by the States, to carry out an accelerated program
of water quality management, measure the results, and provide some of the informa-
tion on nonpoint source pollution that is lacking.  This program, which is named
the Model Implementation Program (MIP) has these objectives: (1) to determine how
well the agricultural community's delivery system will work in water quality manage-
ment, (2) to see if farmers will accept a program for establishing best management
practices (BMPs), and (3) to monitor the BMPs and water quality to provide information
on the best methods for agricultural w*pint source control and prevention.

     The seven projects selected represent various types of farming and are located
in New York, South Carolina, ladi-w^, Oklahoma, Nebraska, South Dakota and Washington.
Each area has an agricultural nnf>oint source pollution problem which adversely
affects water quality in downstream lakes and streams.  This program is described
in some detail below:

Indiana:  The project is located in the Indiana Heartland Region, which includes
the Eagle Creek and Stotts Creek watersheds.  About 80 percent of the area is
cropland.  The project involves land treatment to protect a 1,400 acre reservoir
within the Nation's largest city park.  The 146,000 acre area covers part of six
                                      63

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                               TABLE XI

                  AWT PROJECTS  BEING EVALUATED  IN 208
EPA Region


    I



    II
    III
State


Vermont



New York
Delaware
                                  Maryland


                                  Indiana


                                  Wisconsin


                                  Ohio
freject Area
o  Lower Winooski River
   (Burlington, Montpelier)
o  Seneca, Oswego, Oneida
   River System

o  Upper Hudson (Glen Falls)
o  Kent County

o  LeCato Plant (Lewes,
   Rehoboth Beach)

o  Patuxent River
                         o  Little Calumet  River
                            (Portage,  Valparaiso)

                         o  Rock  and Upper
                            Wisconsin  Rivers

                         o  Major effort ($450,000)
                            to re-evaluate  WLA's
                            for much of State
    VI
Texas
o  Major effort (over
   $1 million) to develop
   WLA's in several areas
   of State
    IX
Nevada
o  Las Vegas/Clark Co.
                                      64

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counties.  Measures used include:   establishing vegetative cover,  cover crops,
terraces, critical area seeding,  ponds, sediment and chemical  retention, sod
waterways, diversions, and windbreak restoration.

Nebraska:  In the MepTe Creek Watershed in northeast Nebraska, an  area with about
230 miles of streams, farmers crop intensively on uplands sloping loose soils.
High intensity, short duration storms wash soil  from this cropland, producing
water quality problems downstream.  The watershed has 33,000 acres in three
counties.  Measures used include:  terraces, diversions, conservation tillage
ponds, sod waterways, windbreaks, erosion control structures, animal  waste
control, and seedings.

Oklahoma:  Sediment is the problem for this MIP area in the Little Washita
Watershed.  This is an experimental watershed of USDA's Science and Education
Administration (SEA), which monitors water quality.   Measures used: seedings,
terrace, diversions, grazing land protection, windbreak restoration,  sediment
retention, erosion, sod waterways, and ponds.

South Carolina:  Anderson County's Broadway Lake, located in a 24,196 acre MIP
area, is plagued by erosion, sedimentation, agricultural chemicals, and animal
wastes.  All 302 acres of lake show sediment damage.  Local groups strongly
support the project aims of improving the lake for fishing, swimming  and boating.
Measures used:  seedings, terraces, diversions, conservation tillage, critical
area seeding, ponds, erosion control structures, and sod waterways.

South Dakota:  Water quality problems in this MIP area are from feedlnt runoff
and sediment from cropland.  The project provides land treatment in the 45,000
acre watershed draining into Lake Herman in Lake County.  The Lake Preservation
Committee of South Dakota ranks Lake Herman among the 40 most in need of treatment.
Measures used:  seedings, terraces, grazing land protection, windbreak restoration,
conservation tillage, permanent wildlife habitat, seedings, and crop  rotations.

Washington:  Farmers in the Sulphur Creek Watershed in Yakima County, this
63,835 acre MIP area, use irrigation in growing a variety of fruit, vineyard,
vegetable, and grain products.  This farming technique creates erosion problems
on the sandy loam soils and rolling terrain.  Measures used:  irrigation
water conservation, erosion control structures, sod waterways, seedings, and
water management systems.

New York:  In the West Branch of the Delaware River, this MIP area is marked by
a concentration of dairy farms and large acreages of sloping cropland and forest
land with erosion problems, causing water quality difficulties in a municipal
reservoir--a condition the project hopes to correct by applying animal waste
management and erosion control practices such as seedings, stripcropping, diver-
sions, erosion control structures, timber stand improvement, tree planting, and
cover crops.  The area covers 287,000 acres in Delaware County.

     The New York project is located immediately above the Cannonsville Reservoir,
one of the major dams supplying water to New York City.  The Cannonsville Reservoir
contains 98 billion gallons of water and is the third largest reservoir in the  City
system.  The 4800 acre lake has a safe yield of 310 million gallons daily (MGD) of
which 200 MGD is used on an average day, 15 percent of the City's needs.  Although
the reservoir has been in use only since 1964 its water quality is deteriorating.
As a result the City does not use all of the water it could from Cannonsville with
only 8 percent of the water released from the dam going to the City w>th the remain-
der used to maintain flows in the Delaware River.

                                      65

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     The water supply has taste and odor problems caused by severe algal  blooms
in the summer and early fall.  The algale blooms result from the high level of
nutrients entering the stream with phosphorus presumed to be the major cause.
Since the City will require additional water in the near future and Long Island
may tie into the City supply, cleaning up the water would result in significant
savings from not having to build additional  storage.

     The 450 square mile watershed is predominantly dairy farms, with about
25 percent in cropland and pasture and 70 percent in woodland.  BMP installation
started in the spring of 1978.  It is progressing very well.  One of the objectives
of the program was to determine how well farmers would cooperate.  Participation
has been excellent with most of those contacted to date agreeing to cooperate.
The work is being concentrated on certain critical watershed areas.  In the first
area 37 of the 43 farmers in the watershed indicated willingness to cooperate.
Of those 37, three had no problems and the remaining 34 are installing the
needed BMPs.  The people working at the local level believe this level of
cooperation can be attained throughout the entire county if they had the
resources to work with all of the farmers.

     Most of the BMPs required are animal waste facilities such as barnyard
controls, manure storage and better feedlot operations.  The average per farm
cost of the facilities has been $3,500.  While not excessively high, it can be
seen that capital investment requirements are significant.

     Since this watershed is typical of much of the northeastern dairy country,
EPA will monitor and evaluate the BMPs being installed and determine their effects
on water quality.  This work will be done in conjunction with New York State and
Cornell University.  New York City has a number of monitoring stations in the
watershed and our work will tie into the monitoring being done by the City.  One
of the reasons more data does not exist for identifying the causes of agricultural
nonpoint source pollution is because intensive monitoring of this type is
expensive.  We will spend about one million dollars on the New York project in the
next 3 to 5 years for data collection and analysis.  In addition, USDA will spend
a similar amount of funds to provide both technical and financial assistance
to the farmers in establishing BMPs.

     A major feature of the MIP projects is the use of presently available
resources to implement the program.  In the New York project both USDA (through
the Agricultural Stabilization and Conservation Service and Soil Conservation
Service) and EPA are providing substantial support.  This activity can be
carried out in only a few projects.  Additional technical and financial
assistance will be required if significant progress is to be made.

     Another MIP is the Broadway Lake project located near Anderson, South
Carolina.   It provides an example of the typical water quality problems which
are associated with farming in the Piedmont area of the southeastern United
States.  This 25,200 acre area has 6,500 acres in cropland, 8,200 in hay and
pasture, 7,000 acres in woodland and the remaining 3,500 acres in residential
and recreational uses.
                                       66

-------
     The one crop pattern of farming, continuous soybeans, results in large
amounts of erosion and sediment.  Although many of the slopes are only 3 to 4
percent, the fields wash badly with erosion rates of 10 or more tons per acre
common.  The sediment is very evident on the roads, in ditches and streams, and
in Lake Broadway.

     Lake Broadway is a 300 acre lake formed by a 40-year-old dam.  The Lake
provides extensive recreational opportunities such as fishing, swimming and
boating for the people in the area.  It is owned by Anderson County, which
maintains recreation facilities at a number of locations around the Lake.
The area surrounding the Lake has been developed with more than 500 homes.
Deteriorating water quality is affecting the use of the Lake by the general
public and surrounding homeowners.

     There are about 400 farmers in the watershed, many of them part-time,
working relatively small farms with a single cash crop soybeans.  This is a
typical situation in many areas of the southeast.  The average yield of 25
bushels of soybeans per acre at the present price of $8.00 per bushel brings
a gross return of about $200/acre to the farmer.  Farm income is not very high.

     The project, initiated in 1978, has made a lot of progress in 2 years.
Of the 400 farmers in the watershed 85 had been cooperating with their local
Conservation District when the project started.  Within one year more than
90 additional farmers have begun to install BMPs.

     The local people working on the project have indicated they believe 80
to 90 percent of the farmers will cooperate in establishing required BMPs, but
it will take about six years to get all of the work done.

     The BMPs being used are terraces, grass waterways and sediment dams on the
cropland and seeding and renovation of the hay and pasture areas.  In 1978, 7.5
miles of terraces were established while 15.5 miles were constructed in the spring
of 1979 with more scheduled this fall.  BMPs are being established in the watershed
at a rate of three times that being done in the remainder of Anderson County.  People
working on the project indicated the program could be duplicated in surrounding areas
if additional technical and financial resources were made available.

     This project, along with all of the MIPs, has had good cooperation among
local, State and Federal agencies.  Not only did the environmental and agricul-
tural agencies work together, but others such as highway and forestry agencies have
assisted in establishing BMPs.  An estimated 2-3 years of volunteer assistance is
being provided by the local people in managing the project.

     The entire project will cost about $750,000 in Federal funds, of which
about half is being provided by USDA and the remainder by EPA.  The USDA funds
are for technical assistance by the Soil Conservation Service and Forest Service
and cost sharing of BMPs by the Agricultural Stabilization and Conservation
Service.  EPA funds are being used to help construct sediment basins on critical
                                       67

-------
watersheds and for monitoring and evaluation of the stream quality to determine
the effectiveness of BMPs.  EPA has combined three programssection 208
water quality management, Clean Lakes, and research--to assist this project.

     As with the other MIP projects, one of the primary objectives is to
obtain more information on nonpoint source problems and the effectiveness
of BMPs.  EPA has provided $190,000 to Clemson University to conduct a water
quality monitoring program in the watershed.  The monitoring program was set up
in 1978 and extensive sampling has already been completed.  The sampling program
is concentrating on storm events since this is when runoff occurs and most of
the sediments and nutrients enter the streams and Lake.  The Clemson group is
working on six small drainage basins within the watershed.  It is measuring
physical, chemical, and biological parameters on areas where BMPs are being
established on three similar watersheds where no work will be done during the
project in order to compare the water quality results.  The information gained
from this project will be used to determine BMP effectiveness and water quality
benefits in similar southeastern farming areas.

     The success of the MIP projects encouraged EPA and USDA to expand their
cooperative authorities.  In 1979 the Agricultural Stabilization and Conservation
Service, USDA, and EPA selected 21 special water quality projects for BMP imple-
mentation.  These projects are listed in Table XII.

     The benefits to be achieved through a control program on the farms and
ranches of the country will be widespread, and may include better crop yields
for some areas.  Many benefits will be downstream and not on the farms or ranches
where the BMPs are established.  In many cases, the costs of the BMPs for an
individual farmer will be greater than the benefits which he receives.  Hence
the need for some financial incentives.  EPA strongly supported the Clean Water
Act Amendments of 1977, which recognized the need for assisting farmers in
establishing BMPs and authorized a cost-sharing program for that purpose.  The
Administration requested an appropriation of $75 million to USDA to initiate the
program in FY 80.  Implementing the Rural Clean Water Program, as this part of
section 208 has been named, will enable EPA and USDA to reduce agricultural
NPS pollution in many of the most critical problem agricultural watersheds
in the Nation.

     EPA's Agriculture strategy is to develop the cause/effect relationship data
by evaluating selected MIP and ACP projects and other special projects such as the
Well ton-Mohawk irrigation districts.  Additional funds will be sought from other
sources such as ORD, ACP and Small Farmer Demonstration projects.  Continual
technical assistance will be pursued from the Extension Service and SCS.

     Steering Committees are being established in each State to administer the
RCWP and several applications have been prepared.  The Committees will continue
to work toward putting as many implementation monies  (such as ACP funds) as pos-
sible to the identified priority areas.
                                        68

-------

















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D.   Urban Runoff

     Many 208 studies began with the assumption that urban runoff was an
important cause of water quality problems.   Although the studies have progressed
and much information on runoff and receiving waters has been developed, it is
still difficult to assess comprehensively urban runoff's role as a major cause
of problems.  That is partly because of interferences by other sources and
complex relationships within the receiving  waters.   But it is also because of
difficulties in deciding what constitutes a "problem."  In some cases, "problems"
are synonymous with standards violations; in others, "problems" are synonymous
with an impairment or denial of beneficial  uses.

     The practical implication of these differences of opinion is that local
agencies are reluctant to make commitments  to implementing controls, in the
Absence of clear problem definition.

     Another major obstacle to implementation is  associated with the uncertainty
surrounding the effectiveness of controls.   Many  of the measures proposed
for controlling urban runoff are either new or special applications of convention-
al practices used for other purposes.   Engineers, planners, public works personnel,
and other decision makers are understandably reluctant to invest large amounts
of time and money in controls which may not perform as hoped.

     Congress, in its Clean Water Act Amendments, did not provide implementation
funds for urban runoff, because it felt that the  current state of technical
knowledge was insufficient to justify large-scale action.

     We have initiated the Nationwide Urban Runoff Program (NURP) to provide
some of the required answers.  The objectives of  NURP are twofold.  First, the
objective at the local level is to establish the  link between planning and
implementation.  To establish that link will require answering the questions  posed
earlier:  what are the problems, the pollutants causing the problems, the
pollutants' sources, the controls for those sources, and the cost and effect-
iveness of the controls in meeting water quality  goals?

     The second objective is to conduct an  assessment of urban runoff (not
including combined sewers) on a nationwide  scale  and present the findings
in a report to Congress in 1983.  The report will describe:

    The nature of urban runoff problems where significant problems have
     been identified.

    The causes of these problems (e.g., source,  transport modes, impact
     mechanisms).

    The severity of these problems, based  on consideration of beneficial
     uses and water quality standards.

    Opportunities for controlling urban runoff problems, including
     descriptions of control measures,  their effectiveness, costs,
     and strategies for broad-scale implementation.
                                     71

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Ancillary program objectives will be:

    To develop the information base required to assess urban runoff
     problems, including the occurrence of heavy metals and other toxics
     in urban areas.

    To examine the adequacy of current dry-weather water quality stan-
     dards when used to judge the significance of storm-dominated
     pollution problems.

    To develop the information base required to identify, assess,
     and implement effective controls.

     The Nationwide Urban Runoff Program involves selecting a limited number
of locations for intensive data gathering and study with the purpose of:

t    Developing implementation plans for those areas.

    Demonstrating transferability, so  that solutions  and knowledge
     gained can be applied in other areas (without the need for intensive
     data gathering efforts).

     Thirty such studies will be conducted nationwide, with some pairing
in order to demonstrate transferability.  This number  of studies is needed in
order to coyer a wide range of climatic regimes.  The  first projects selected
are those with obvious problems (e.g.,  beach closures, impacted water supplies,
impacts on aquatic life).  A list of projects currently funded appears
below.

     The strategy calls for providing a full range of  technical and management
assistance to each project and for communication of experiences, sharing of
data, and transfer of lessons learned on a timely basis.  The strategy recognizes
the need for program coordination, both within and outside of the Agency, to
maximize the use of limited resources and minimize conflict and overlap.  As
the program gains momentum and information is generated, mechanisms will be
implemented to insure that the information gained is communicated to local govern-
mental  officials.  An important activity will be to involve the public so they
become acquainted with the program and  its benefits and costs, and so they can
provide inputs to decisions at the local level.

Projects Underway In National Urban Runoff Program (Funded Before FY 1979)

Myrtle Beach,^South Carolina:  Maine problem identified is bacteria entering
the storm drainage system.Project is  to determine magnitude of problem and
identify control methods.

Illinois:  A project will be carried out in Champaign-Urbana, Illinois,
to test the effectiveness of a street sweeping program.

Southeast Michigan COG:  The objective  of the program  is to test the effective-
ness of detention basin storage.  The project is in the Clinton River Basin
in Oakland County, Michigan.
                                      72

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Tri-County RPC (Lansing, Michigan):  The objective of the study is to gather
information on detention basins and correlate it with land use and related
pollutant generation.

Bellevue, Washington:  In this joint project in cooperation with ORD and USGS,
several management practices will  be evaluated including street sweeping, catch
basin cleaning, and sewer flushing.

Seattle METRO:  This study is to identify the importance and effect of priority
pollutants in receiving waters.  Twenty priority pollutants will be evaluated.

Castro Valley, California:  The project will determine street surface contaminant
loadings and accumulation rates and the effectiveness of erosion control techniques
and street sweeping.

Ann Arbor. Michigan:  The objective of this project is to determine cause and
effect relationships for stormwater runoff pollution and evaluate effectiveness
of retention areas and detention basins.

Projects Funded in FY 1979

Southeast Wisconsin RPC:  This project, in conjunction with the Wisconsin DNR,
will evaluate street sweeping timing and frequency effectiveness.  Stormwater
detention will also be evaluated (USGS).

Denver Regional COG:  The specific objectives are to characterize runoff
pollutant loadings by land use type and determine the effects of nonpoint
source pollution loads on receiving waters (USGS).

Austin, Texas:  The program will focus upon evaluating the effectiveness of
preventative measures for stormwater control that can be applied to new develop-
ments in order to preserve Lake Austin from degradation.

Long Island, New York:  The study is to determine the source, type, quantity and
fate of pollutants in runoff and evaluate changes in runoff quality in response
to selected management practices.

Mystic River, Massachusetts:  The aim of the project is an overall assessment of
the urban runoff problem in the watershed with particular emphasis on the effects
of direct stormwater discharges into the Upper or Lower Mystic Lakes.

Lake Quinsigamond, Massachusetts:   This project will build upon a Clean Lakes
Program intensive survey to provide the necessary information about urban runoff,
resulting in control recommendations.

Durham, New Hampshire:  The project will measure mass loading of urban runoff
constituents during individual storm events and evaluate maintenance practices.
Practices to be evaluated may include litter control, chemical use control,
street sweeping and detention basins.
                                       73

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Northeastern Illinois Planning Commission (Chicago Metro Area):   The major
objectives of this project are to evaluate source controls and determine the
effectiveness of stormwater detention.

Lane, Oregon COG:  The project will  focus on special  concerns such as toxics
and air quality/runoff interaction,  pilot studies for management practice
definition, and promotion of public  awareness and action.

Los Angeles, California:   The purpose of the urban runoff study in Upper
Newport Bay is to identify sources of urban runoff pollution entering the Bay
and evaluate a variety of best management practices.   These practices include
street and sidewalk sweeping, catch  basin cleaning and using sumps to collect
runoff from service stations.

Winston-Sal em. North Carolina:  This project will focus on pollutant source
evaluations and management practice  evaluation.   Biological sampling will be
carried out in streams draining the  managed watersheds.

Washington (D.C.) COG:  The basic objective is to develop planning tools to
estimate nonpoint source loads.

Potential Projects

Tampa, Florida:  Specific objectives of the proposed project are to assess the
water quality of the receiving water, determine amounts and impacts of pollutants
on receiving water and review and evaluate a variety of strategies.

Liittle Rock, Arkansas:  The proposed project is to analyze current and proposed
IMF's to control urban runoff and determine which are effective.

Lake George, New York:  The purpose of the proposed study is to determine the
nature and magnitude of the urban runoff problem so that appropriate control
strategies can be developed.

Irondequot Bay, New York:  The objective of the program is to establish the
significance of urban runoff as a contributor to eutrophication and put urban
runoff into perspective with point sources.

Baltimore RFC:  The major objective of the project is to define the pollutant
contributions from the Jones Falls watershed to Baltimore Harbor and the impact
of pollutant loads on the Harbor's designated beneficial uses.

St.  Louis. Missouri:  The project is to evaluate the water quality effectiveness
of the St. Louis County stormwater control program.  BMP's to be implemented will
be chosen from the list prepared  in the 208 study  (USGS).

Salt Lake County. Utah:  The principal objective is to characterize the hydrology
9f urban runoff and demonstrate the effectiveness  of alternative strategies
in reducing measured  impacts.  Management approaches to be evaluated may include
detention basins, street sweeping, erosion control and public education  (USGS).

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     In some cities, implementation of urban runoff BMP's based on the findings
of 208 plans is proceeding even though the data gaps listed above exist.
Some examples are:

Georgia:  Strategies for NPS controls developed by the city of Macon include
retention basins, street sweeping and stormwater and solid waste facilities
inventory and maintenance.

Tennessee:  Nashville/Davidson County passed a stormwater management ordinance.

Florida:  Tallahassee has implemented a street sweeping program costing
$150,000 with an annual budget of $60,000.  Also, a large detention basin
is under construction to remove 67 percent of the annual runoff into Lake Jackson.
Volusia adopted a stormwater management ordinance to control stormwater from
future developments.

Washington:  Snohomish County is initiating adoption of storm drainage/erosion
control ordinances, and initiating an inspector training program to achieve
implementation and upgrading of surface drainage control ordinances.  Clark
County is purchasing property for retention basins and will implement BMP's as
recommended in the 208 plan.  Metro Seattle is adopting ordinances leading to the
establishment of stormwater drainage districts.  A salmon enhancement program
has been started as part of a broa*! water quality project to rehabilitate urban
streams.

E.   Silviculture

     EPA's overall strategy for controlling silviculture nonpoint source pollu-
tion is to  (1) implement the recent (February, 1979) agreement with the Forest
Service, which provides the mechanism for the two agencies to work together
to achieve common goals,  (2) implement BMP's contained in certified and approved
HQM plans, using available assistance programs, and  (3) continue to develop
the technical and institutional bases for controls through prototype projects.
EPA's role will be largely one of providing expert technical and financial manage-
ment assistance for agencies addressing silviculture NPS problems.

     Many of the silvicultural activities within the 208 program have been
accomplished in close coordination with the Forest Service.  The Forest Service/
EPA Agreement uses existing programs and institutional arrangements to
strengthen forestry WQM planning and implementation projects.  New forestry
programs are not required, simply a re-emphasis to highlight the WQM aspects
of existing programs.  Forest Service personnel are located in EPA Headquarters,
Region VIII, and Region X to coordinate FS/EPA activities such as the following
examples:

    EPA through an Interagency Agreement with Forest Service is supporting
     a national training package for loggers and operators.  This will in-
     crease the knowledge and understanding of individuals involved in
     planning and implementing forestry BMP's.  The package will include a
     national inventory of existing forestry WQM training materials and
     develop new materials to fill voids.
                                      75

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    FS/EPA and State cooperators will  implement a National  Forest land
     management planning project to strengthen communication links among the
     agencies and better define each agency's role in relation to the
     National Forest Management Act regulations.

    FS/EPA jointly developed two basic planning documents for section 208.
     The Water Resources Evaluation Nonpoint Source (WRENS)  Report provides
     the state-of-the-art hydrologic knowledge for WQM planning.   The report
     is being printed and will be distributed to State and local  WQM agencies.

    The Streamside Management Zone (SMZ) Report describes existing laws and
     ordinances for protecting sensitive water zones.  New Mexico is using
     examples in the report to draft legislation to protect SMZ's.

t    WQM aspects of forestry practices  are being highlighted in the Upper Rio
     Hondo special water quality project in New Mexico.  Special  forestry
     emphasis is placed on streambank protection and road stabilization.  A
     similar project is anticipated in  the North Fork of the Forked Deer.

    State projects to strenghten relationships between State WQM plans and
     State forest resource programs are being initiated in Washington, Colorado,
     and Indiana.  These projects will  further identify commitment of resources
     and personnel to implement silvicultural elements of State WQM plans.

t    An EPA/FS/State cooperative effort produced a booklet titled "Forests
     Protect Water Quality."  This booklet is part of an informational and edu-
     cational effort to make landowners aware of forestry BMP's.   The publica-
     tion was prepared in cooperation with 13 southern States. Puerto Rico,
     and the Virgin Islands.

     As a result of initial 208 planning, silvicultural BMP's are being estab-
lished in most States where silvicultural NPS problems were identified.  These
include:

Florida:  A WQM project in Blackwater State  Forest is being initiated to
evaluate the effects of forestry BMP's on water quality.  EPA is providing $25,000
through the State WQM agency to evaluate the forestry practices applied in a
300-foot wide zone along streams.

Georgia:  The Georgia Forestry Commission is implementing a project near
Gainsville, Georgia to demonstrate how WQM practices are integrated into improved
forest harvesting techniques.  These practices are also being applied in stream-
side management zones.  This project is funded by USDA, Forest Service.

South Carolina:  The State Forester assigned a full-time forester to  initiate
BMP implementation in the Broadway Lake Model Implementation  Project  (MIP).
Through his actions, 39 landowner contacts were  made.  This  has  produced 10
land management plans for 850 acres.  Forty  miles of firebreaks were  installed
and nearly 1,200  acres were prepared and planted under cooperative forestry
programs.
                                       76

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New York:  Through State forestry efforts in the West Branch of the Delaware
River Model Implementation Program (MIP), technical  assistance is being provided
to landowners and loggers for log road and landing design, road stabilization
and road maintenance.   Forest land management plans  and harvesting guidelines
are being proposed on  the Cannonville Reservoir.  BMP demonstration and evaluation
areas are being developed on the watershed area.

Oregon:  Oregon passed a State Forest Practices Act  in 1972 which was
the first of its kind  in the U.S. to set forth procedures and methods to control
nonpoint source pollution from forestry lands.  This law establishes a firm
instrument for implementing the approved silvicultural 208 program.  The
Governor has designated the Oregon State Forestry Department as the management
agency for the program and designated the USDA Forest Service and USDI
Bureau of Land Management as the implementing agencies for NPS pollution
control on Federal lands under their jurisdiction.

     As a result of 208 planning, the Board of Forestry amended over 50 of their
existing rules to better reflect water quality considerations and revised their
public participation procedures to obtain better public input.

Wyoming:  Teton County is implementing ordinances and performance standards
developed in the WQM plan.  Teton National Forest has adopted and is implementing
BMP's under the authorization of the Forest Supervisor.  The success of this
effort is the result of the intergovernmental coordination developed during
the planning process.

Vermont:  The Timber Truckers and Producers Association (VTTPA) volunteered
to assist the State in reducing erosion from logging.  When complaints are
received, a committee  from the Association makes an  on-site visit with the
logger to attempt to resolve the problem through persuasion.  If this fails,
State enforcement officials are called in to take appropriate action.

F.   Ground Hater Contamination

     Although large-scale ground water contamination is not documented, localized
contamination problems are becoming more common, and are often associated with
nonpoint sources of pollution, such as leachate from landfills and septic tanks,
saltwater intrusion, and seepage from agriculture.  Several of the WQM agencies
have been analyzing ground water problems.  Ventura, California, has recommended
a program to control salt-water intrusion; Middlesex County, New Jersey, closed
an open dump that was  impacting ground water; New Castle County, Delaware,
initiated a retreival  well system to stop a leachate plume from contaminating
a major water supply;  Spokane, Washington, is preparing a plan to prohibit the
contamination of its aquifer from septic systems.  In their continuing programs,
Kansas and Connecticut are preparing legislation for ground water controls.

     Although there are many current projects on ground water protection, the
problems and issues are many, and knowledge and data are limited.  The impact of
ground water quality on surface water is little understood.  We are just
beginning to think about ground water pollution.
                                       77

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     As with nonpoint sources in general, the WQM program is the only Federal
program taking a systematic approach to the protection of ground water quality.
The Drinking Water program is responsible for the Underground Injection Control
regulatory program, a survey of pits, ponds, and lagoons, and the designation
of sole source aquifers.  (The sole source designation requires an EIS for all
Federal projects but does not have authority to control other pollution problems.)
The Solid Waste program is responsible for regulating landfills and the disposal
of hazardous wastes and for a survey of open dumps.   The WQM program has the
capability to consider the entire ground water problem in an area, using data
from other programs, to develop and coordinate controls from various authorities.

     EPA is currently developing a detailed ground water strategy and examining
the ground water issues.  This is being undertaken jointly among the Offices
of Water Planning and Standards, Drinking Water, Solid Waste, Water Program
Operations, and Research and Development.

     Through FY 1980, the WQM program will spend between $10 and $20 million on
the development and implementation of ground water quality protection projects.
Water Planning Division has retained several ground water experts to assist
State and areawide agencies with work plan development, analyses, and evaluations.
 Several (8 to 10) prototype projects are in the selection process.  They will
cover a cross-section of issues.  Technical assistance will be provided during
the project.  Information acquired from these projects will be utilized by EPA
for program direction, needs assessment, and formation of ground water policies.

G.   Other Nonpoint Sources

     In the other nonpoint source problem areasconstruction runoff, mining
runoff, and other less-common problems--EPA will continue to both implement BMP's
identified in certified and approved 208 plans and develop technological and
institutional bases for control.

     In the construction runoff area, WQM program efforts in FY 1980 and beyond
will focus on States developing regulatory programs since BMP's are readily
available.  The overall objective for construction runoff is for all States with
problems of this type to have regulatory programs in place by FY 1983.  Many
States already have adequate controls.

     With respect to mining runoff, EPA is working closely with, the Office of
Surface Mining (Department of the Interior) in implementing the Surface Mine
Reclamation Act.  The authorities and resources available to OSM under their
Act are substantially greater than those available under section 208.

     A new 208 activity which a number of States will  address as a result of
the CWA amendments  is the 208 dredge and fill program.   In the 1977 amendments,
Congress provided for a State section 404 dredge and fill program to replace
the Corps of Engineers  program where States desire the responsibility.  In
addition, States delegated the 404 permit program can  also develop a regulatory
dredge and fill program under section 208 which would  not require permits.  This
program would replace certain parts of a State's 404 permit program and eliminate
paperwork on small  dredge and fill projects with minimal environmental  impacts.
                                      78

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     EPA recently published draft 404 regulations and is in the process of
developing 208 dredge and fill regulations which it will issue this fall.  We
expect a number of States to develop dredge and fill  programs in the 208 con-
tinuing planning process in FY 1980.

     For these problem areas (construction, mining, dredge/fill, and others)
implementation has been relatively slow to occur.  One reason is that the
legislative process, including the need for broad public support, takes time.
However, there are some examples of State and local implementation actions
resulting from 208 planning.  They include:

North Carolina:  North Carolina's mining act was recently amended to include
civil in addition to criminal  penalties for mining without a permit.  This
move was made in response to a Statewide 208 WQM plan recommendation.  Criminal
penalties in the old mining act worked against effective enforcement because
they were regarded as being too drastic to be used to deal with routine
violations of the act.

Colorado:  State mining regulations were revised to strengthen water pollution
control provisions dealing with mining tailings disposal.

Virginia:  The Lenowisco Planning District Commission is a designated areawide
planning agency in southwest Virginia's coal mining district.  LPDC examined
abandoned coal mine pollution  problems and established priorities for pollu-
tion abatement work as a part  of its local 208 planning effort.  This information
from the local 208 plan is being used by the State of Virginia as the basis for
the State's Abandoned Mine Reclamation Plan under the Department of the
Interior's Abandoned Mine Reclamation Program created by the 1977 Coal  Surface
Mining Act.

California:  The State of California has developed abandoned mine pollution
abatement project specifications for sulfur, copper,  and other metallic mines
as a part of that State's continuing 208 WQM program work plan.  Previous
studies have shown 200 miles of California streams to be completely sterile
or to have seriously limited aquatic diversity as a result of mine drainage.

North Carolina:  The State passed a tough erosion and sediment control  law in
1973.  For any project (public or private) in the State involving the disturbance
of an acre or more of land, a  developer must first prepare an acceptable erosion
and sediment control plan.

     The State law allows cities and counties to develop their own erosion control
programs.  Presently, 19 municipalities and 16 counties in North Carolina have
such programs.  In those jurisdictions, the State does not review a developer's
erosion control plansunless  the project is financed with State or Federal
funds.  In jurisdictions having no erosion and control programs, the State
reviews such plans for all projects, public or private.  The State's erosion
control program is performance-oriented.  It is flexible, encourages a developer
to use his imagination to install any erosion control measures he see fit--so
long as they do the job.
                                      79

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     In effect since 1974,  the North Carolina erosion control  program is con-
sidered to be fairly successful,  substantially decreasing sediment pollution.

Lewis and Clark County, Montana:   A sediment control  ordinance was approved by
local referendum, as a result of  technical  assistance and public participation
provided under 208 planning.

     In response to the 1972 Federal Water Pollution  Control  Act Amendments, the
Montana legislature requested the State Department of Natural  Resources to
head up a study of sediment control problems and legislative  issues.   The
study yielded three major findings:  (1) erosion is a serious  water pollution
problem in Montana;  (2) existing enabling legislation provides sufficient
authority to address erosion; and  (3) any sediment control  program should be
locally administered and enforced.

     The Montana Conservation District law permits local  conservation districts to
develop soil conservation ordinances, which must be adopted by local  referendum.
The ordinances are administered and enforced locally.  This enabling legisla-
tion had never been carried out,  until EPA funded a pilot program to promote
the enactment of a sediment control ordinance in Lewis and Clark County.

     Lewis and Clark County was selected for this pilot program because it was
willing to participate and its land use patterns and erosion  problems typify
Montana conditions.

     On June 20, 1977, voters of Lewis and Clark County approved the enactment of
a sediment control ordinance.  This ordinance incorporates land management
standards (best management practices) developed by:  the Soil  Conservation
Service for agriculture; the Montana State Forestry Committee for silviculture;
and the Lewis and Clark County Conservation District for subdivision construc-
tion.  These best management practices (BMP's) are based on site-specific
soil, climate, and use characteristics.

     Implementation of a Conservation District-approved erosion and sediment
control plan is the primary means of complying with these standards or practices.
Erosion and sediment control plans are optional for agricultural activities,
as long as standards are met or exceeded and no erosion problems occur; they
are mandatory for most construction/subdivision activities.  In addition,  forestry
operators must either prepare an erosion and sediment control  plan or give the
Conservation District notice before starting forestry activities.

     Any land occupier, District Supervisor, or State or county water quality
official may file a complaint alleging that accelerated erosion or sediment
damage has taken place.  If a violation of the ordinance is verified by the
Conservation District, the land occupier is given an opportunity for voluntary
compliance.  If the violation is not corrected, the District Supervisors are
authorized to issue stop work orders and impose fines up to $500 a day.
                                       80

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                   VII. ERA'S MANAGEMENT STRATEGY
     In conjunction with the program strategy above,  EPA will  implement a
management strategy for the long run, geared toward achieving  the Clean Water
goals of the Act for nonpoint sources in a cost-effective, efficient manner.
In FY 1980, and beyond, EPA will initiate a more active management stance for
the WQM program, including:

t    Initiation of a long-term Financial Management Assistance Project
     (FMAP) to help State, areawide, and local  agencies develop financial
     expertise for water quality management planning and implementation.

    Assessment of five-year costs of planning and administering solutions
     to point and nonpoint source water quality problems for budget justi-
     fications and analysis of priorities.

    Implementation of revised and consolidated regulations for the program
     (40 CFR, Part 35, Subpart G, May 1979).  Requirements for activities
     under sections 208, 303(e), and 106 were combined into a  single manage-
     ment programs.  The regulations represent a significant simplification
     of the process.  In addition, the regulations require that an agency
     be implementing a portion of its plan by FY 1980 in order to have con-
     tinuing funding.  The roles of State and areawide agencies have also
     been more clearly defined in an attempt to minimize jurisdictional
     issues.

    Participation by EPA Regions, State and areawide staffs,  and the
     public in annual State/EPA Agreements which coordinate and integrate
     programs, identify high-priority problems, lay out approaches to
     solving these problems, and assign responsibility.

    Use of WQM public participation mechanisms to support not only planning
     activities but also State/EPA Agreement development, WQM  plan imple-
     mentation, and refinement of WQM plans through site-specific projects.

t    Emphasis on better Regional Office and Headquarters management of
     the WQM program through training for project officers, development
     of management strategies, and annual management reviews;  EPA will
     use contract funds to expand management capability at all levels of
     the program.

     The WQM program has made great progress in cleaning the Nation's waters.
The program has brought about documented water quality improvements and cost-
savings, and will bring more as additional WQM plans enter the implementation
stage.
                                   81

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     Since FY 1974,  State and areawide  208 agencies havewith  208 grants--
identified their water quality problems,  developed solutions  for the less complex
problems, and identified responsible units of government to implement the
solutions.  In FY 1980-1983,  these agencies will  fill  in gaps in their WQM plans,
largely through the  use of prototype problem-solving projects for more difficult
problems.  EPA will  provide funding, expert technical  assistance, and information
transfer to ensure the success of their efforts and the transferability of their
results.

     Thus, by FY 1984, EPA and the WQM  agencies will have gained much knowledge
of both problem-solving techniques and  future program needs.   Based on this
information, EPA will recommend future  directions for the WQM programs, roles
for the various levels of government involved, and necessary changes for the
existing program.
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                        VIII.   CONCLUSION


     Today's 208 Water Quality Planning and Management Program is far removed
from initial days of confusion and delay.  This program has a definite
problem-solving orientation.   It directs itself toward those pervasive nonpoint
sources of pollution which, without controls,  will  prevent us from achieving
the goals and requirements of the Clean Water  Act.   It can contribute much to
our knowledge of control technologies and to achieving the goals of the Clean
Water Act at the least possible cost to the taxpayer.   EPA has developed a
realistic, implementable five-year strategy for nonpoint controls which must
accompany our point source achievements if we  really seek to make the waters
of our Nation fit for swimming, fishing, recreation, irrigation, and drinking.
To carry out that strategy, EPA will need continued authorization of the Water
Quality Management program past FY 1980.  Just as importantly, we will need
the support and endorsement of the Congress, in its oversight role, for the
course we have mapped out.
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