TD746
.U545
United States
Environmental Protection
Agency
Office of Water and Waste
Management
Washington, D.C. 20460
January 1981
vvEPA
1990
PRELIMINARY DRAFT
STRATEGY FOR MUNICIPAL
WASTEWATER TREATMENT
OOOD81100E
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PRELIMINARY DRAFT 1990 STRATEGY FOR
MUNICIPAL WASTEWATER TREATMENT
TASK V - PLANNING STRATEGY
OFFICE OF WATER AND WASTE MANAGEMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
"This paper presents a preliminary draft
strategy, proposed by EPA staff, for
improving the national municipal waste-
water treatment program. EPA is now
considering the positions offered here.
The document is intended for public
review and discussion to assist EPA
in developing its final 1990 Strategy."
January 16, 1981
U.S. Environmental Protection Agency
Rcpicn V, Library
230 South Deai born S'reet
Chicago, Illinois 60604
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Enviro
nmental Protection AgS*»
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PREFACE
The proposals presented in the Strategy are the result of both a
major effort within the U.S. Environmental Protection Agency and exten-
sive participation on the part of the interested public through meetings
and the distribution of relevant issue and background papers prepared
by EPA.
The 1990 Strategy was prepared under the guidance of Eckardt C. Beck,
Assistant Administrator, Office of Water and Waste Management; James N. Smith,
Associate Assistant Administrator, Office of Water and Waste Management; and
Henry L. Longest II, Deputy Assistant Administrator, Office of Water Program
Operations.
The Chairman of the 1990 Strategy effort within the Agency was Merna
Hurd, Associate Assistant Administrator, Office of Water and Waste Manage-
ment. The Deputy Chairman was Carl Reeverts, Office of Water Program
Operations.
The Chairmen of Task V - Planning Strategy were Dave Ziegler, Office
of Water Program Operations and Jim Lounsbury, Office of Water Regulations
and Standards.
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CONTENTS
I. INTRODUCTION 1
Purpose 1
Background 1
Basic Policy Assumptions 2
II. EXECUTIVE SUMMARY OF PROPOSED STRATEGY 3
Goals and Objectives 3
Strategy El ements 3
Action Plan 6
III. CURRENT PROGRAM DESCRIPTION 7
The Point Source Problem 7
The Nonpoint Source Problem 7
The Intent of the Act 10
Status of EPA's Implementation 13
Issues 14
Basic Program Data 14
Basic" Pol icy Documents 14
IV. MAJOR PROGRAM ISSUES 17
V. PROPOSED STRATEGY 33
Goals and Objectives 33
Strategy El ements 33
VI. ACTION PLAN * 47
APPENDIX 55
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CHAPTER I
INTRODUCTION
PURPOSE
In carrying out their duties for controlling water pollution, EPA,
the States, and other units of government not only build sewage treatment
plants, they also perform many other related and equally important tasks,
including planning. Planning is a prerequisite for every action to clean
up or prevent water pollution.
The purpose of this paper, Task V of the 1990 Construction Grants
Strategy, is to define a broad planning and analytical process under the
Clean Water Act which will direct the use of pollution control funds for
maximum environmental benefit. This process is part of the comprehensive
water quality management (WQM) program which includes a wide variety of
EPA, State, and local actions.
BACKGROUND
The Background Paper for Task V (draft, October 6, 1980) presents a
discussion of the intent of the Act, the status of EPA's implementation of
the Act, and key issues which emerge regarding the planning provisions of
the Act. The reader should refer to the Background Paper for details.
To summarize, EPA has established an integrated water quality manage-
ment program, drawing on the provisions of key sections of the Act - 106,
205(g), 208, 303, 314, and others. Two important products of this program
are the State problem assessment and the State WQM plan, which consolidate
all State, areawide, and local water quality planning into comprehensive
Statewide documents.
To identify their problems, States first set water quality standards,
which provide benchmarks for gauging water quality problems and evaluating
solutions. Then, through the use of monitoring and water quality analysis,
the States identify problem receiving waters, pollutants, and sources. The
problem assessment process is an iterative process, in which States periodi-
cally evaluate water quality standards to make sure they are appropriate
for the water body and attainable.
Stemming from the problem assessment, the WQM plan identifies solutions
to problems, agencies responsible for those solutions, and necessary finan-
cial and institutional arrangements. The planning process varies according
to the source and severity of the water quality problem. The overall WQM
plan identifies permit conditions for point sources, priorities, and cost-
effective treatment options for publicly-owned treatment works, cost-effective
nonpoint source controls, tradeoffs between point and nonpoint source control
programs, and implementation mechanisms for all sources.
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An important contribution of the WQM plan to the construction of
sewage treatment works is baseline information for facility planning.
The WQM plans include population, waste load, and economic projections
for sizing decisions and identify appropriate service areas and manage-
ment agencies to receive construction grants.
The States are the central managers of the WQM program. To show
evidence of good planning and management, they provide EPA with periodic
information on their programs and negotiate annual priorities and work
programs. Some important outputs of the State management effort are
problem assessments, State strategies, and State/EPA Agreements.
BASIC POLICY ASSUMPTIONS
Although this strategy attempts to be objective about options for
planningand its management--under the Clean Water Act, several basic
policy assumptions influence the strategy.
First, planning is crucial to the development of efficient solutions
to water quality problems. Water quality management plans should stem
from problem assessments, should be comprehensive, and should include not
only technical solutions to problems, but also fiscal, financial, and in-
stitutional solutions.
Second, the States are the key managers and administrators of water
quality programs. With guidance and oversight from their EPA Regional
Offices, they have latitude to tailor their water quality programs. EPA's
role is generally to oversee State action, provide technical and financial
assistance, track the expenditure of federal funds, and act as a backstop
for States who do not perform adequate planning, management, and enforce-
ment functions.
It is important to note that this paper does not deal in depth with
all the aspects of the WQM program. Instead, it focuses on those elements,
such as point source planning and water quality standards, which relate
directly to construction grants. In its broadest sense, the WQM program
encompasses not only point and nonpoint source planning in the States and
sub-State agencies, but also the oversight and management of State programs
to control, eliminate, and prevent water pollution.
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CHAPTER II
EXECUTIVE SUMMARY OF PROPOSED STRATEGY
GOALS AND OBJECTIVES
With respect to construction grants and this 1990 Strategy, the
goal of the WQM program is to implement a responsive problem-solving
process for municipal sewage treatment which will allow the States to
meet the fishable/swimmable goals of the Act, where attainable, by
1990. This problem-solving process will direct available resources
to priority projects which have direct, significant impacts on im-
proved water quality.
The following objectives support the goal and represent action
areas for EPA and the other participants in the WQM program:
Emphasize the water quality impacts of construction grants
as the basis for priorities; consider nonpoint sources and
toxics in setting priorities and awarding grants.
t Modify monitoring programs to identify problems more effec-
tively and to evaluate environmental results.
Refine water quality standards (WQS), with eventual inclusion
of toxics, and incorporate them in State WQM plans; emphasize
the attainaility of WQS.
Periodically review program goals; establish within EPA a long-
range WQM strategy and improved oversight of State programs.
STRATEGY ELEMENTS
The WQM program has greatly assisted construction grants by estab-
lishing WQS and monitoring networks and preparing over 200 initial WQM
plans which contain a point source planning framework.
However, the WQM program must improve in several ways to assist
the construction grants program. Many of these improvements are aleady
in place in State and EPA Regions. Thus, EPA's intent is to increase
the overall national effectiveness of the WQM program to the level of
aggressive, well-managed States and Regions.
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The Problem-Solving Process
The Act sets up a comprehensive problem-solving process which, when
followed, greatly assists EPA and the States in meeting the program goals
arid objectives stated above. If the construction grants program is to be
more responsive to water quality problems, the integrity of the problem-
solving process is more important than ever, since it identifies problems
and sets water quality priorities.
Problem Identification:
In the area of problem identification, three actions are necessary to
assist the construction grants program. EPA and the States must improve
their problem assessments to provide the basis for construction grant pri-
orities based on water quality problems. Second, EPA and the States must
give more attention to water quality standards attainability and use only
attainable standards in planning. Third, the States must improve their
monitoring programs to provide crucial data.
Solution Development:
To improve solution development activities related to construction
grants, EPA, the States, and local agencies must pay more attention to the
potential cost savings associated with point/nonpoint source tradeoffs.
States must also become more involved in the fiscal, financial, and in-
stitutional aspects of planning for municipal facilities.
EPA is considering redefining secondary treatment to allow some
grantees to take advantage of cost savings in design and construction of
POTWs. This change would maintain the secondary treatment floor, but
reduce the costs of installing the maintaining secondary treatment in
certain controlled situations.
EPA will also emphasize the need for States to maintain their WQM
plans, which document Statewide solutions to water quality problems and
provide for public participation in the planning process. Finally, EPA
will provide new guidance on waste load allocations to help States do a
better job on these important analyses. In the short run, States should
focus waste load allocations on conventional pollutants.
Implementation of Solutions:
The funds which EPA, the States, and others spend on planning and
program management should ensure the efficient use of implementation
funds. The EPA Regional Offices will make sure implementation efforts
are consistent with WQM plans, as the Act requires.
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Evaluation:
As it relates to construction grants, evaluation has been weak.
Program participants have been frustrated by an inability to demonstrate
environmental progress and POTW effectiveness. States should evaluate
POTWs on site and, over time, evaluate the aggregate effects of pollution
from all the POTWs in the State.
EPA and the States must begin to evaluate environmental results,
that is, water quality results, rather than surrogates. Surrogates have
diverted attention from the basic purpose of the Act, cleaner waters.
Institutional Roles
The institutional roles that have developed since 1972 have hindered
the WQM program's contribution to construction grants. The main adjust-
ments needed are stronger ties between States and local governments on
such issues as fiscal and financial planning; further delegation of re-
sponsibility and authority to the States for planning and program, manage-
ment; and more direct contact between States and designated areawide
agencies.
Resources
To obtain the maximum payoff from the funds available for the WQM
program, EPA, the States, and other participants in the program should
direct construction grants and program grants to actions which have direct
impacts on water quality, and develop more imaginative funding schemes.
EPA will delegate more responsibility to the States to make program ad-
ministration more efficient, consider changing the definition of secondary
treatment, and provide the States with improved information on national
goals and objectives.
WQM Program Management
In managing the WQM program, three important changes are needed.
First, EPA will place increased emphasis on State 305(b) reports and
State strategies, since States will use these management documents to
identify problems and action plans for meeting water quality goals.
Specifically, State strategies should identify waters which are not
fishable/swimmable, but for which those uses are attainable, and describe
how States will meet fishable/swimmable standards by 1990. Also, the
State stategies should explain how the States will complete the construc-
tion grants program under two optional scenarios.
Second, EPA will conduct improved oversight of State programs.
Third, EPA will maintain a national WQM strategy to identify goals,
objectives, and priorities and give meaning to the oversight function.
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ACTION PLAN
The Act, the regulations, and EPA guidance set forth a problem-
solving process and management framework which are basically sound.
Although this strategy will require some regulatory changes and many
administrative changes and actions, EPA will not start a major legis-
lative initiative involving the WQM program at this time. The Proposed
Strategy, Chapter V, includes a detailed action plan for regulatory
and administrative changes.
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CHAPTER III
CURRENT PROGRAM DESCRIPTION
This portion of Task V presents information on the types of problems
the WQM program addresses, the programs the Congress established to deal
with them, EPA's implementation of the Act, and general program data. A
Background Paper preceded the development of Task V and explains in detail
the intent of the Act, the status of EPA's implementation of the Act, and
the issues which arise in the WQM area. (See draft Backgound Paper, October
6, 1980.)
THE POINT SOURCE PROBLEM
Point sources of pollution involve direct municipal, industrial and
commercial discharges to surface or ground waters through "discrete con-
veyances," e.g., pipes. They also include industrial or commercial dis-
charges into municipal sewer systems, combined sewer overflows, and small
and alternative wastewater systems (SAWs).
The Nation has made great progress since 1972 in controlling point
source pollution. EPA and the States have issued over 6500 permits, have
initiated a program to control underground injection under the Safe Drink-
ing Water Act, and have completed over 2100 sewage treatment plants.
The results of these actions are apparent in lowered biochemical
oxygen demand (BOD) and suspended solids entering surface waters, and to
some extent, lowered nutrient levels. An example of the dramatic improve-
ment point source controls can bring about is the improvement in dissolved
oxygen and turbidity in Lake Erie.
However, many problems still exist in the point source area. POTWs
are experiencing severe operations and maintenance problems, often causing
them to be out of compliance with their permits. There is still a large
backlog of necessary construction related to treatment plants and combined
sewer overflows. Point sources - both municipal and industrial - also
contribute to toxics problems and ground water contamination problems in
some situations.
Figure III.l provides data on the extent of point source pollution.
THE NONPOINT SOURCE PROBLEM
Nonpoint sources of water pollution include overland runoff to surface
waters, percolation of pollutants through the ground into ground water, and
pollution of surface water through runoff into separate storm sewers. EPA's
highest priority nonpoint source problems are agricultural runoff, urban run-
off, and ground water contamination. Other important problems are mining,
silviculture, hydrologic modifications, and construction runoff.
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FIGURE III.l EXTENT OF POINT SOURCE POLLUTION
Percentage of Basins Affected* by Type of Point Source
Region Combined Sewer
(Number of Basins)
Northeast (40)
Southeast (47)
Great Lakes (41)
North Central (35)
South Central (30
Southwest (22)
Northwest (22)
Island (9)
Total (246)
* In whole or in part, beneficial
uses of basins denied
Industrial
95
74
80
74
70
23
55
89
72
Municipal
95
91
95
86
100
64
73
100
89
Overflows
60
17
37
6
0
0
14
0
21
Source: EPA National Water Quality Inventory,
1977 Report to Congress, October 1978
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The Nation has made some progress under the Act in nonpoint source
control. Several States have passed sediment control ordinances and non-
point source control cost-sharing programs. Local governments have enacted
zoning ordinances to protect water quality and, for the most part, con-
trolled construction runoff. Together, EPA, the States, areawide agencies,
and local governments are building a technical and institutional data base
on the control of nonpoint sources. We know that nonpoint sources are a
serious problem and that much more information and experience on their
control is needed.
Taken together, pollution from nonpoint sources is greater than pollu-
tion from point sources. As point sources come under control, the ratio
will worsen. Thirty-seven States reported recently that they will be unable
to meet the "fishable/swimmable" goals of the Act by 1983 because of non-
point source problems; for example, toxic metals from urban storm runoff.
BOD loads from urban runoff are estimated as greater than, or equal
to, loads from POTWs. Sediment loads from human-induced land-disturbing
activity are 360 times greater than loads from point sources, and three
times the natural background. BOD pollution from nonpoint sources is five
times greater than point sources and the natural background. Total nitrogen
pollution is four times greater than point sources and three times the
natural background. Coliform bacteria from nonpoint sources would be 50
times higher than from point sources, assuming all point sources employed
secondary treatment and disinfection or the equivalent.
The effects of nonpoint source pollution are widespread. (See Figure
III.2.) They have closed beaches, shellfishing areas, and drinking water
supplies in coastal areas. Nonpoint sources have created unacceptable
levels of toxic chemicals in Great Lakes fish. One of our largest Western
cities suffers from bacteria, heavy metals, and nutrients from nonpoint
sources in its surface waters which supply both drinking and irrigation
water for the area. In the Midwest, nonpoint sources have caused lead and
pesticide contamination of major streams. As a Nation, we spend over a
half billion dollars a year to remove sediment from harbors, other naviga-
tional channels, and reservoirs - much of which could be prevented with
nonpoint source controls.
THE INTENT OF THE ACT
The Clean Water Act establishes a process for solving water quality
problems. This "problem-solving process" consists of problem definition,
development of solutions, implementation of controls, and evaluation.
(See Figure 111.3.) State WQM plans encompass the problem identification
and solution development steps. Specifically, with regard to construction
grants, the four steps in the process are as follows:
Problem definition includes the State process of setting water
quality standards, monitoring water quality, identifying situations
where desired and attainable uses of the waters are denied by
10
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FIGURE II1.3 WQM PROBLEM-SOLVING PROCESS
PROBLEM ASSESSMENT*
-- WATER QUALITY
STANDARDS
MONITORING
-- PROBLEM ASSESSMENT
-- PROBLEM PRIORITIES
SOLUTION DEVELOPMENT*
PERMIT CONDITIONS
-- STATE AND AREAWIDE
PLANS
FACILITY PLANS
-- CLEAN LAKES PLANS
IMPLEMENTATION OF
SOLUTIONS
-- DESIGNATED MGMT
AGENCIES
-- CONSTRUCTION
-- NPS CONTROLS
-- NPDES PERMITS
CLEAN LAKES
PROJECTS
-- ENFORCEMENT
EVALUATION
* Note: for detailed flow
charts of process modules
see Figure V.I
11
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pollution from municipal facilities, and setting priorities for
the development of solutions to POTW problems.
Solution development takes place through the development of (1)
State and areawide WQM plans, which lay out technical, financial,
and institutional plans for municipal treatment works, and (2)
facility plans, which identify cost-effective treatment processes
and lead to plans, specs, and construction. The WQM plans also
generally identify permit conditions for municipal treatment works.
The Act mandates consistency among these different aspects of sol-
ution development.
Implementation of solutions involves not only the construction of
treatment works, but also the designation of management agencies
to receive grants, implementation of structural or non-structural
nonpoint source controls, and permit issuance and enforcement.
Evaluation is the last step in the process, providing the feedback
necessary to determine whether treatment works, individually and
in the aggregate, are meeting their design parameters and the goals
of the Act.
One important feature of the 1972 Act (and the 1977 Amendments) was
the establishment of base-level technology requirements. The Act requires
all municipal dischargers, except certain dischargers to marine waters, to
provide a minimum of "Best Practicable Waste Treatment Technology," or
secondary treatment. Where necessary to meet attainable water quality
standards, the Act requires treatment more stringent than secondary, but
secondary treatment is a floor for all POTWs, solving the equity and per-
formance problems apparent in water pollution control programs prior to
1972.
With regard to roles, the Act gave EPA the ultimate responsibility for
protecting water quality, but left the States as the primary managers of
water quality programs. This was generally in keeping with the State role
prior to 1972. EPA's role in implementing the Act is one of management,
regulations, and assistance. The States are the key entity, since they ad-
minister most clean water programs. The Act established a new role for
Regional, or areawide, agencies to perform planning and management from a
broad geographical base in complex urban/industrial areas. Local govern-
ments also play a critical role under the Act, especially with respect to
implementing programs.
The management requirements of the Act are very brief, since it basically
leaves the responsibility for clean water on the States. The Act establishes
categorical grant programs for State, interstate, areawide, and local agencies
to help implement its many provisions and gives the EPA Administrator broad
discretion to manage programs and issue regulations and guidance.
12
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STATUS OF ERA'S IMPLEMENTATION
With respect to construction grants, the WQM program has accomplished
much, especially in light of the backlog of municipal pollution problems
that existed prior to 1972. All States have established water quality
standards and monitoring networks, and State and areawide agencies have
completed over 200 initial WQM plans. The initial plans include a strong
point source planning framework and have resulted in a general understand-
ing of municipal water quality problems.
One 1972 study showed that the cost savings from WQM plans in the muni-
cipal treatment area were much larger than the total section 208 appropria-
tions since 1974. Many States, counties, cities, and towns have implemented
the municipal recommendations of their WQM plans through the construction
of treatment works and the passage of environmental ordinances and financial
plans to support them.
However, despite the fact that the WQM program has succeeded in defin-
ing the context for construction grants in many EPA Regions and States,
implementation of the planning provisions of the Act has also experienced
several problems. Perhaps the biggest problem is that - in some States -
the WQM plans do not provide adequate data on problems and alternative
controls for the States to set water quality-based priorities for POTW
construction. Also, problems have arisen in the areas of point source/
nonpoint source tradeoffs, the definition of secondary treatment, the use
of water quality standards, and other areas. Fortunately, there are
realistic solutions to these problems, as the balance of Task V suggests.
Since the Act does not set up a management framework for the WQM
program, EPA has done this through its regulations and guidance. The WQM
program operates under a five-step management process which includes:
Continuing State problem assessments
Annually-updated five-year State strategies
-- Annual State/EPA agreements
-- Annual detailed work programs
-- Program evaluation
Through this management process, the States keep EPA informed on
problems, proposed actions, and environmental results of controls. The
States also negotiate short and long-term problem-solving priorities
with the EPA Regions. As in the problem-solving process, certain problems
have occurred within EPA's management of the WQM program, two of the most
important being inadequate EPA oversight and vague goals and objectives.
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ISSUES
By comparing the intent of the planning provisions of the Act with
EPA's implementation, the background paper identified major planning
issues which are adversely affecting construction grants. Chapter IV,
below, discusses the issues and proposes resolutions for them.
BASIC PROGRAM DATA
Of 225 State and areawide WQM agencies designated by their governors
in 1974-76, over 200 of them have State certification and EPA approval of
their initial plans. Virtually all of the certifications and approvals
have conditions attached, which EPA and the States are now working to
satisfy. As mentioned above, the plans are more complete with respect to
point source problems than nonpoint source problems. In fact, significant
gaps in nonpoint source problem assessment and solution development remain,
especially for ground water contamination, urban runoff, and agriculture.
Figure III.4 gives a funding history of categorical grants under the
Clean Water Act which support the WQM program. Through section 106 and
208 grants alone, EPA has awarded about $881 million between 1972 and the
present, to State and areawide agencies for planning and management functions,
Construction management assistance grants under section 205(g), facility
planning grants under section 201, and clean lakes grants under section 314
account for approximately another half billion dollars in funding to the WQM
program and the problem-solving process in the same period.
BASIC POLICY DOCUMENTS
See the Appendix for a list of important policy documents which govern
the various components of the WQM program. For a more complete list of
references, see the Supplemental Guidance for the WQM program, cited in the
Appendix.
14
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FIGURE III.4 CWA FUNDING SUMMARY (in millions)
201
205(g)
208
314
Authorizations
FY 72*
73*
74
75
76
77
78
79
80
81
FY 73
74
75
76
77
78
79
80
81
FY 78
79
80
81
FY 73
74
75
76
77
78
79
80
81
FY 73
74
75
76
77
78
79
80
81
60.0
75.0
75.0
0
100.0
100.0
100.0
100.0
75.0
5,000.0
6,000.0
7,000.0
0
1,480.0
4,500.0
5,000.0
5,000.0
5,000.0
92.1
85.3
70.2
66.1
50.0
100.0
150.0
0
150.0
150.0
150.0
150.0
100.0
50.0
100.0
150.0
0
50.0
60.0
60.0
60.0
30.0
Appropriations
15.0
20.0
40.0
48.5
50.0
50.0
52.4
52.4
48.7
48.7
2,000.0
3,000.0
4,000.0
9,000.0
1,480.0
4,500.0
4,200.0
3,400.0
3,304.8
92.1
85.3
70.2
66.1
50.0
100.0
150.0
53.0
15.0
69.0
32.0
37.5
34.0
0
0
4.0
15.0
15.0
2.3
14.6
15.0
11.0
Obligations
15.0
20.0
40.0
48.5
50.0
50.0
52.4
52.4
48.7
1,532.0
1,444.4
3,616.2
4,813.6
6,663.8
2,300.9
3,871.7
1,765.0
59.3
35.3
7.1
0
13.6
150.0
53.0
15.0
69.0
30.0
37.5
0
0
4.0
15.0
15.0
2.3
14.6
15.0
* Money appropriated under previous law, FWPCA, not CWA.
15
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CHAPTER IV
MAJOR PROGRAM ISSUES
During the preparation of the Background Paper and through the public
public participation in the early phases of developing Task V of the 1990
Strategy, EPA and others have identified several major issues affecting
the WQM program and its impact on construction grants. (The Current Program
Description, above, summarizes the Background Paper.)
The ten issues which follow, involving the problem-solving process,
institutional roles, and program resources, constitute the problem statement
of Task V. The following pages list the issues, provide brief discussions,
and propose resolutions.
Issue No. ^
The construction grants program must nave improved water quality data
and analysis to set water quality-based priorities.
Discussion
Many States and EPA Regions have strong water quality-oriented programs
which use up-to-date problem assessments and WQM plans to drive implementa-
tion efforts, such as construction grants. Indeed, the over 200 conditionally
certified and approved WQM plans are strongest in the municipal point source
source area. States such as Texas, Ohio, and Coloradoto mention just a
fewhave complete point source portions of their WQM plans which identify
service areas, population projections, management agencies, and other rele-
vant information.
However, there are States and Regions where the links between problem
assessments, plans, and actions are severed, leading to cost-ineffective
control programs. EPA's desire, through the 1990 Strategy, is to increase
program effectiveness in these States and Regions.
Problem assessments, summarized in State 305(b) reports, are generally
weak. Much water quality data, in STORET or included in WQM plans, is
occasionally misused, or unused, in subsequent decision-making. Also, some
States and Regions don't plan far enough into the future, looking instead
only at those immediate problems they can solve in one to two years. Pri-
orities, therefore, are often shortsighted.
Another factor which contributes to difficulty in setting water quality-
based priorities is inadequate monitoring. This is discussed in Issue 5.
A troublesome aspect of identifying problems and setting priorities is
the problem of prevention. Preventing degradation of existing water quality
17
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can be just as important as improving water quality in three situations:
pristine areas, water-short areas, and ground water.
Resolution
To resolve this issue, EPA will stress the use of WQM plans and two
management documents - 305(b) reports and State strategies - to tie con-
struction grants priorities to water quality problems.
EPA will work with the States to develop stronger problem assessments,
segment by segment. Where applicable, EPA and the States may use environ-
mental indices or similar tools to assist with priority determinations.
EPA will provide improved guidance for preparing 305(b) reports and use
the reports in decision-making.
EPA will also require strong, comprehensive State strategies, in
accordance with the WQM regulations, and prepare improved guidance for
the States to follow. The State strategies will provide long-range action
plans related to the seriousness of municipal pollution.
Specifically, starting in FY 83, EPA will ask the States to include
in their strategies the following information:
The strategies should identify waters which are not fishable/
swimmable (but for which those uses are attainable) and describe
how the States will meet the fishable/swimmable goals by 1990.
The States should give priority to treatment works needed to
achieve fishable/swimmable uses.
The strategies should explain how the State will complete its
construction grants program under the Clean Water Act under two
scenarios: (1) unconstrained construction funds, i.e., the
"fastest" scenario, and (2) a constant annual level of funding
which EPA will specify in guidance.
The State strategies should, as management tools, explain how
other State water quality management resources will contribute
to meeting the fishable/swimmable goals. Thus, the strategies
should set priorities tied to the problem assessment for water
quality standards reviews, monitoring, waste load allocations,
nonpoint source planning, evaluation, and other activities.
State WQM plans pick up where problem assessments leave off in the
continuous process of identifying problems, setting priorities, developing
solutions, and evaluating results. The WQM plans document primarily the
solution-development step of the problem-solving process. The EPA Regions
and States should use the WQM plans, work to remove conditions on certi-
fication or approval, and - as plans change - use the streamlined certifica-
tion and approval mechanisms in the regulations to keep them up to date.
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Where the State and EPA agree that prevention of pollution is important,
the State should integrate long-term prevention and correction programs in its
strategy.
Issue No. 2
The States must set attainable water quality standards, and use them in
planning POTW improvements.
Discussion
The issue revolves about the goal in section 101(a) of the Act, that
the Nation achieve fishable/swimmable water quality in all stream segments,
"where attainable." As the background paper discussed, the States and EPA
seldom considered attainability in setting and approving water quality
standards after passage of the 1972 Act. To be attainable, a water quality
standard must pass three tests: it must be environmentally, technologically,
and economically achievable.
Where WQS are unattainable, they lead to high costs for point and nonpoint
source controls, with limited environmental or societal benefit. But most
participants in the WQM program do not wish for .a widespread downgrading
of standards either. At a minimum, standards must protect the existing use
of a segment.
Another aspect of this issue is that, under section 510 of the Act, the
States may set standards more stringent than what EPA might otherwise approve.
The recent lawsuit of the State of Illinois against EPA included this issue,
saying that, since the State had set more stringent standards, EPA could not
deny the State construction grants for advanced treatment to meet these
standards, and should not delay the construction grant process.
The suit was settled out of court. The settlement agreement stipulates
that EPA revise its guidance on reviews of advanced treatment projects to
minimize unnecessary delays and, at the same time, to respond to the concern
for cost-effectiveness in treatment works.
The matter of attainability involves both designated uses and exact
criteria to support those uses in WQS. . Even when the use of a stream is
attainable, the criteria may not be if they don't match the specific situa-
tion. Attainability determinations are also affected by seasonal conditions,
such as high flow situations, which might violate the criteria but not harm
the use.
Resolution
EPA has already acted to resolve this issue by rescinding its policy of
"presumptive applicability" of the Red Book criteria. States now have more
flexibility in setting criteria to support designated uses.
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EPA is also developing guidance for the States to use in attainability
determinations. The guidance will describe the environmental, technological,
and economic tests for checking a particular use or criteria.
Upon issuance of this guidance, the States should include more attain-
ability determinations in their required cycles of standards reviews and
revisions, and fold the results into their WQM plans. The States should
set priorities and review the most critical water bodies first, particularly
where they have proposed advanced waste treatment or where they need attain-
ability determinations to determine the relative priority of secondary
treatment plants. States should give special attention to blanket water
quality standards which may not prove attainable on specific segments.
Ideally, the best time to analyze attainability is early, before the States
need decisions on construction grants or permit conditions.
Where attainability determinations show that uses in existing WQS
are unattainable, the States should revise the uses. (At a minimum, however,
WQS must maintain the existing uses.) States may lower the criteria with-
in a given use on a segment except in Outstanding National Resource Waters
(ONRW).
Issue So. 3
The participants in the WQM program must do a better Job of identi-
fying point/nonpoint source tradeoffs that could save construction grant
funds. They need better NFS data for this purpose.
Discussion
EPA's recent experience with proposed advanced treatment projects
shows that Step 1 grantees often do not consider point/nonpoint source
tradeoffs in facility planning, nor do the States consider them in priority
list development. Since Federal law does not require or substantially
assist the control of nonpoint sources, there is little incentive to con-
trol them, even where control would be more cost-effective than advanced
waste treatment.
For many proposed treatment works, point/nonpoint source tradeoffs
are not an issue, since point source problems usually occur during dry
weather and nonpoint source problems during wet weather. However, there
are often direct tradeoff possibilities in situations involving eutrophi-
cation in the receiving water.
In addition to the direct tradeoffs, there are also indirect point/
nonpoint tradeoffs which occur when nonpoint sources would deny or impair
the use of a water quality-limited segment regardless of the degree of
point source treatment. To attain the use, both advanced municipal treat-
ment and nonpoint source controls would have to be in place.
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If the construction grantee falls to take advantage of available
tradeoffs between point and nonpoint sources, it wijl diminish the ulti-
mate cost-effectiveness of the treatment works. However, data on the
extent of NPS problems, the effectiveness of NPS controls, and the cause-
effect relationships between NPS and water quality is often lacking, making
it difficult for Step 1 grantees to assess potential cost savings.
Resolution
To help resolve this issue, EPA will continue to develop a technical
base on NPS problems, the effectiveness of point and nonpoint controls, and
the linkages between the two types of problems. EPA has recently published
draft guidance on conducting tradeoff analyses and will work with the States
to provide technical assistance.
States should focus tradeoff analysis on nutrients from proposed POTWs
above "still" water bodies such as estuaries, lakes, and reservoirs, where
eutrophication may be a problem. They should screen their needs lists and
priority lists for proposed projects of this type and require the facility
plan or the WQM plan to include a point/nonpoint tradeoff analysis.
In the case of indirect tradeoffs, this is a complex technical issue
which EPA is addressing in PRM 79-7, currently under revision in accordance
with a court order.
Wherever nonpoint sources cause water quality problems, whether point
sources are involved or not, it is generally the State's role to control
them. Since there are many situations where nonpoint source control is
necessary by itself, States should maintain balanced point and nonpoint
programs for the sake of overall cost-effectiveness and clean water.
EPA will continue to manage the agricultural, urban runoff, and ground
water prototype projects the States initiated with 208 grants in FY 79-81 to
increase our knowledge of nonpoint source problems and controls. A corner-
stone of EPA's strategy for solving NPS problems is an emphasis on informa-
tion transfer. EPA Headquarters and Regions will increase their efforts to
transfer successful approaches among similar settings.
Issue No. 4
EPA could bring about significant cost-savings in construction by
redefining secondary treatment to include consideration of siiuational
factors.
Discussion
The 1972 Act set forth the principle of base-level treatment tech-
nology for all point source dischargers, including POTWs. This policy
21
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was In response to the poor track record of water quality-based require-
ments prior to 1972, and the equity problems associated with that approach.
The Act requires all POTWs to provide "Best Practicable Waste Treat-
ment Technology" (BPWTT) to meet water quality standards and other environ-
mental objectives such as the protection of ground water. At a minimum,
each plan must provide secondary treatment, which EPA defines as an effluent
quality of 30 mg/1 BOD and suspended solids ("30/30"). The 30/30 requirement
generally necessitates the construction of sophisticated activated sludge
processes. However, activated sludge plants can be difficult and expensive
to operate and maintain, and have been plagued by compliance problems.
Some other types of biological treatment than activated sludge, includ-
ing its predecessor, the trickling filter, are cheaper and generally more
reliable, but cannot usually meet 30/30 all year round. (Trickling filters,
for example, work less well in the winter.) In certain situations, however,
these other types of biological treatment may be perfectly acceptable and -
some feel - should be included in secondary treatment.
EPA cannot return to the total water quality-based system of pre-1972.
The water quality-based approach is extremely difficult to implement, is an
administrative nightmare, and incurs the equity problems referred to above,
for example, when virtually identical communities might have vastly different
treatment requirements. However, the definition of secondary treatment could
be adjusted to allow a broader range of technology in controlled situations.
The cost savings of redefining secondary treatment this way are not
known at this time. However, EPA feels this option could save considerable
expense for State and local governments, especially in small communities
and rural areas.
Resolution,
EPA will soon issue an Advance Notice of Proposed Rulemaking (ANPRM)
which will open the issue of the definition of secondary treatment for con-
sideration. The definition could possibly be broadened to take into account
local factors such as climate, presence or absence of toxic pollutants, and
treatment works performance requirements. EPA would maintain a technology-
based requirement of biological treatment, while attempting to trim the
costs of "treatment for treatment's sake."
One possible drawback to this option is an equity problem between new
projects, which could take advantage of the cost-savings accompanying the
new definition, and projects already in the grants pipeline or on the
ground.
One possible advantage to a broader definition of secondary treat-
ment, however, is that it could simplify enforcement by increasing POTW
reliability, while allowing some flexibility in the 30/30 requirement.
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Another option related to the definition of secondary treatment is
reconsidering the overall definition of BPWTT. Under the existing
definition in EPA guidance, potential construction grantees must consider
not only WQS but also ground water and alternative treatment technologies
in interpreti-ng BPWTT in their given situation. It might also be possible
to use the requirement for BPWTT to establish toxic effluent requirements
for POTWs, since we now have better analytical tools and treatability
information for assessing and resolving municipal toxic effluent problems.
Issue No* S
EPA and the States must improve their water quality data through more
cost-effective monitoring programs, and refine their water quality analyses
to facilitate construction grants.
Discussion
Monitoring is a key input to the problem-solving process, yet it has
generally suffered from a lack of planning and has not, as a rule, been
cost-effective. State ambient monitoring networks measure long-term trends
for entire segments or basins. The networks don't identify specific dis-
chargers in violation; don't assist with decisions on advanced treatment,
which require more specific data; don't always detect problems; are expensive
to maintain; and usually cover only conventional pollutants.
Also, State monitoring networks rarely include gathering biological data
for general assessments of stream quality. Ground water monitoring networks,
which are more costly to install and operate than surface networks, are just
beginning to be developed.
One of the frustrations of the construction grants program today is its
inability to demonstrate the effectiveness of treatment works constructed
since 1972. This is primarily because the monitoring networks were not
designed up front to provide useful information such as before-and-after
water quality.
Quality assurance (QA) is also a problem, compounded by the multiplicity
of agencies and purposes involved in monitoring. There is a lack of stan-
dardization in monitoring and analytical methods, which is important for
toxics, where quality assurance is critical. A lack of QA may render months
or years of monitoring useless.
In the area of models, modeling of the behavior of conventional pollu-
tants in aquatic eco-systems for simple flow situations is fairly reliable
today. For non-conventional pollutants, especially toxics, and for complex
flow regimes (e.g., estuaries) modeling is much less reliable. Since WLAs
involve modeling, and since modeling tends to be expensive, there is a need
for consistent policy on WLA methods and applications to ensure that funds
devoted to this purpose are used equitably and efficiently.
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Resolution
One key to resolving this issue is better planning of monitoring ac-
tivities. EPA will ask the States to include monitoring chapters in their
annual State strategies to spell out goals, objectives, priorities, and
resources for monitoring - ambient, intensive, and compliance. The States
should tailor their monitoring programs segment by segment and target re-
sources at their highest priority needs, as defined in their overall State
strategies.
As mentioned in the Background Paper, EPA has already taken some
actions to improve the effectiveness of State and EPA monitoring programs.
In rethinking the national monitoring network, EPA is pursuing the follow-
ing objectives: (1) to describe water quality nationally in terms of the
goals of the Act, (2) to determine the reasons for problems, and (3) to
describe the effectiveness of existing controls and predict the effective-
ness of proposed controls.
In FY 81, EPA is working on several prototype stream segments to
develop monitoring programs which will describe the integrity of their
waters in biological, chemical, and physical terms. EPA will transfer
the lessons learned from the prototypes for general implernentation in
FY 82-83. EPA will also establish several prototypical before-and-
after monitoring efforts for new POTWs in the near future.
In the area of quality assurance, EPA has drafted Federal/State QA
procedures and targeted implementation for mid-1982. The procedures
cover policy, coordination, personnel, facilities, equipment, services,
data generation, quality assessment, corrective action, and schedules,
and deal primarily with toxic pollutants.
With respect to modeling, EPA has already started to develop a
waste load allocation regulation, along with more detailed WLA guidance.
In the short term, the States should focus on conventional pollutants
when performing waste load allocations for construction grant projects.
The guidance EPA is developing will initially focus on conventional
pollutants also, and will include information on the level of sophistica-
tion needed to model various parameters and situations, the types of models
and other tools needed, necessary data, and the transferability of water
quality analysis approaches.
In the long run, EPA will develop WLA procedures for toxic pollutants
using either a chemical-by-chemical or general toxicity approach. EPA is
conducting pilot studies to assess toxic problems in POTWs, and the results
will help formulate the long-term policy. Before this information is avail-
able, EPA will not address toxic problems at POTWs unless they are located
in toxic hot spots or have known toxic problems.
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Other current activities EPA is conducting to assist with development
of guidance on toxic WLAs are:
An assessment of the state-of-the-art of toxic modeling
An assessment of approaches, such as general toxicity, for setting
effluent limits more stringent than base-level technology
Research on bioassay techniques for analyzing toxicity and making
WLA calculations
Issue No. 6
EPA, the States, and construction grantees must give more attention
to fiscal, financial, and institutional planning to ensure the long-range
viability of their POTWs.
Discussion
The planning process at the State and local levels has suffered from
a frequent inability to implement solutions to problems (e.g., construct
treatment works) because of a lack of fiscal, financial, and institutional
capability at the implementing level. Some examples of problems resulting
from inadequate fiscal, financial, and institutional planning are the opera-
tions and maintenance record of POTWs, the lack of operational control
programs for nonpoint sources, the continuing need for consolidation of
municipal service areas, and the high sewer charges which often accompany
POTW construction.
EPA has been providing technical assistance through the Financial
Management Assistance Project (FMAP). However, in pu6lic workshops during
the development of this 1990 Strategy, several representatives of local
government expressed significant sensitivity to federal involvement in
local financial planning.
Resolution
The resolution of this issue requires an increased State role in finan-
cial management. EPA will provide technical assistance in this area.
In the course of its regular planning process, each State should plan
for the future control of point and nonpoint sources in terms of capital
budgeting and tracking the useful lives of existing facilities and their
component parts. They should also build capability in State and sub-State
agencies through hiring, training, and the use of outside contract assis-
tance and review the capabilities of the designated management agencies to
ensure they have appropriate fiscal/financial expertise.
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Two examples of funding mechanisms the States can employ to ensure that
funds are available for necessary pollution control activities are bond
issues and revolving funds. To ease the burden on local governments, States
may wish to develop guaranteed loan programs. Thirteen States have already
passed cost-sharing legislation for nonpoint source control, but EPA would
encourage more States to develop similar incentives.
In the area of EPA assistance, EPA will continue its Financial Manage-
ment Assistance Project (FMAP) in a coaching mode and apply recently-developed
FMAP tools in facility planning and nonpoint source control planning. In
conjunction with FMAP, EPA will transfer information on successful fiscal,
financial, and institutional approaches among State and sub-State agencies.
Issue No. 7
Over time, the WQM program must consider toxic pollutants in POTW -in-
fluents and effluents, to increase the effectiveness and efficiency of
POTWe.
Discussion
As the nation brings conventional pollutants (e.g., BOD, suspended
solids) under control, and as we learn more about the presence of toxic
pollutants in the environment, toxics become an emerging problem. Because
of the high costs of toxics monitoring and analysis, their persistence in
aquatic ecosystems, and questions about pathways, fates, and environmental
effects, the WQM program was unable to define or resolve the toxics problem.
The initial WQM plans did not generally address toxic pollutants.
The Agency is building toxics capability. It has published ambient
water quality criteria for 64 toxics, and will soon issue toxic effluent
guidelines under 304(a)*and a toxic treatability study for POTWs. Also,
the WQM program is gaining information on nonpoint source toxics from
carefully-designed prototype projects.
Resolution
Management of toxic pollutants in the future will depend to a great
extent on EPA to identify toxic pollutants and controls. EPA must define
the state of the art in toxic controls for point and nonpoint sources,
and continue to refine the ambient criteria.
Since EPA has published its ambient criteria, the States should begin
to incorporate toxics in State standards and monitoring programs. The
Administrator may use his authority to require States to consider certain
toxic parameters for inclusion in their water quality standards at the
national level and State by State.
One concept which may eventually help control toxic pollutants enter-
ing and departing POTWs is Integrated Waste Management (IWM). In integrated
26
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waste management, entire communities would inventory all the wastes produced
there, both solid and liquid, and, before disposing of them, attempt to find
a use for the wastes. Where no one wants to buy or take a waste product,
the community would plan environmentally sound disposal in concert with
overall waste disposal plans for the entire area. Thus, IWM would help
eliminate toxic pollutants from the waste stream before they reach POTWs
by bringing about process changes and integrated waste disposal practices
in a given community. EPA will undertake several pilot IWM studies in the
near future.
Issue No. 8
EPA, the States, and local agencies must cooperate -in developing a
long-range strategy for controlling pollution from combined sewer overflows
and urban storm runoff.
Discussion
Urban storm runoff and combined sewer overflows are two problems
closely aligned with construction grants but accompanied by great uncer-
tainty regarding their severity and control.
In the area of urban runoff, EPA realized after the completion of
the initial WQM plans in the late 1970's that it needed much more informa-
tion on the problem before it could recommend a national control effort.
Therefore, EPA initiated the Nationwide Urban Runoff Project (NURP) with
208 grants to States and areawide agencies to answer key questions by 1983.
The NURP will provide answers on the extent of the urban runoff problem,
the cause-effect relationships between runoff and water quality, the im-
pacts of urban runoff on aquatic ecosystems, and the effectiveness of alter-
native control measures.
Combined sewer overflows (CSOs) are a problem of major proportions in
the country today. The recently-updated construction grants needs survey
will show that reported needs for controlling CSOs have climbed dramatically
in recent years. Although many of the same uncertainties that apply to
urban runoff also apply to CSOs, they represent a more immediate threat to
public health and safety due to the presence of raw sewage in the overflows.
The solution of CSO and urban runoff problems involves the difficult
problem of accounting for high-flow (i.e., wet weather) conditions in
identifying problems, developing solutions, evaluating results of controls
in urban areas, and enforcing regulatory controls. Both CSOs and urban run-
off from separated sewers can be covered under the general permit provisions
of the NPDES program, which do not dictate effluent standards per se, in
favor of mandatory management controls.
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Resolution
EPA will work with the States and local agencies to develop a combined
sewer overflow and urban storm runoff control strategy by the end of FY 83.
This strategy will include a policy on redefining NPDES compliance to take
high flows into account.
Between the present and FY 83, EPA will continue the NURP projects
initiated in FY 79-81 to build up the data base on urban runoff problems
and controls. With respect to combined sewer overflows, States should
move to correct the most severe overflows where they have documented public
health problems or where CSOs are denying beneficial uses of water bodies.
Issue No* 9
The participants in the WQM program must adjust and agree upon roles,
especially regarding planning for construction grants. EPA 's role should
include less direct involvement but more effective oversight.
Discussion
The WQM program has experienced some conflicts in the past among
different levels of government involved in planning solutions to POTW
problems. These conflicts sometimes stem from confusion regarding roles.
For example, in some persons' opinion, EPA infringed upon the State role
by working directly with areawide planning agencies on section 208 grants,
rather than using the States as the central managers of planning within
their boundaries.
The States are under ever-increasing financial and administrative
burdens for water quality management, given the added requirements of the
1977 Amendments and the general economic conditions. In this situation,
the State role must be clear, but EPA has failed to give the States strong
leadership through a national strategy, for instance, and has not tracked
and evaluated State progress toward achieving environmental results, that
is, clean water.
The areawide agencies, which received many section 208 grants for
point and nonpoint source planning, have depended largely on Federal
funding. Often, they lack authority to implement their plans or advocate
implementation. Nevertheless, they serve a valuable role by providing a
regional perspective on capital investments and institutional arrangements.
Local agencies, which must implement many environmental controls, are also
under heavy financial and administrative burdens.
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Resolution
The proposed strategy, below, discusses preferred institutional roles
in detail. In summary, to improve the nature of their contribution to the
nation's construction grants program, the participants in the WQM program
should take the following actions or make the following adjustments in
their roles:
EPA will provide technical assistance, and issue improved guidance
on WQS attainability, point/nonpoint source tradeoff analysis effectiveness
of nonpoint source controls, monitoring, modeling, waste load allocations,
State problem assessments, and State strategies. EPA will also oversee
State programs with improved tracking and evaluation and take necessary
approval actions on WQS and WQM plans.
In addition, EPA will work with the States and others to develop an
urban runoff/CSO strategy and possibly to redefine the definition of
secondary treatment. Finally, EPA will help define toxic problems, set
the direction for toxic controls and, if necessary, require consideration
of certain toxic parameters for inclusion in State WQS.
Regarding the State role, it is most important that they develop water
quality-based priorities for construction grants and other activities, with
consideration of long-term problems and approaches. To do this, they will
have to improve their problem assessments and State strategies, with EPA's
assistance.
The States should also develop more cost-effective monitoring programs
with EPA's help, keep WQM plans up to date, review WQS for attainability
and revise them as necessary, identify potential point/nonpoint tradeoffs
and analyze them for cost savings, and undertake more direct involvement
in the fiscal and financial aspects of managing POTWs.
Finally, the States should work wltn EPA on developing an urban runoff/
combined sewer overflow strategy, manage the NPS prototypes funded with 208
grants, and, in general, control nonpoint source pollution.
The designated areawide agencies will take a regional look at POTW
problems as appropriate, under the direction of the State WQM agencies.
Local governments should conduct facility planning in most cases and, as
POTW owners and operators, plan and budget for future sewage treatment
needs.
Issue No. 10
Since it is unlikely the WQM program will receive increased funding
in the future, EPA and the States must adopt a resource plan to ensure the
maximum amount of environmental protection for each dollar invested, es-
pecially on construction grants.
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Discussion
The resource needs of an ideal, or ultimate, WQM program far exceed
realistic expectations for resources. State needs for program support are
growing, yet State legislatures have cut back State resources and Federal
appropriations under Clean Water Act sections 106, 208, 314, and 207 (which
is the authorizing section for 205(g) grants) have declined steadily in
constant dollars. (See Figure IV.1.) The WQM program has not pulled in
significant funding from other Federal agencies or from private sources.
Nevertheless, many of the activities the WQM program encompasses -
such as general point source planning, nonpoint source planning, monitoring,
modeling, and water quality standards development - are necessary pre-
requisites to construction grants. A small investment in planning at the
front end can have a dramatic payoff during implementation, as shown by
the recent study that said WQM planning had saved far more money in con-
struction grants than was spent on the total section 208 appropriation
since FY 74.
Resolution
To obtain the maximum environmental payoff under existing resource con-
straints, the participants in the WQM program should adhere to the following
resource principles:
EPA and the States should fund first only those construction grants
needs, and other supporting actions, which will have a direct, significant
impact on water quality; that is, achieve (or possibly maintain) a desired
use of a water body.
EPA will delegate much responsibility and authority to the States, and
monitor the results of State programs rather than process details to save
funds in the area of program administration. To ensure the effectiveness
of the national water quality management program, EPA will issue improved
guidance and exercise improved oversight. It is important for all the par-
ticipants in the WQM program to focus their management attention on environ-
mental results, that is, cleaner waters.
The States should help develop more imaginative funding schemes, such as
State bond issues, revolving funds, or guaranteed loans. These mechanisms
could include support for planning for other WQM activities, such as moni-
toring, in addition to capital construction.
EPA will consider revising the definition of secondary treatment (i.e.,
BPWTT) to save money in facility planning, construction, evaluation, and
enforcement in controlled situations.
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FIGURE IV.1 HISTORICAL CONTRIBUTIONS TO 106-FUNDED PROGRAMS
75 76 77
FISCAL YEAR
Source: Draft WQM Needs Assessment, FY 80-84
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CHAPTER V
PROPOSED STRATEGY
GOALS AND OBJECTIVES
With respect to construction grants and this 1990 Strategy, the goal
of the WQM program is to implement a responsive problem-solving process for
municipal sewage treatment which will allow the States to meet the fishable/
swimmable goals of the Act, where attainable, by 1990. This problem-solving
process will direct available resources to priority projects which will have
direct, significant impacts on improved water quality.
The following objectives support the overall goal and represent action
areas for EPA and the other participants in the WQM program:
t Place greater emphasis on the water quality impacts of proposed
construction grants as the basis for priorities; consider the
contributions of nonpoint sources and toxics in setting priorities
and awarding construction grants.
t Modify current monitoring programs to identify and assess
problems more effectively and evaluate environmental results.
Continuously refine water quality standards (WQS), with eventual
inclusion of toxic criteria, and incorporate them in State WQM
plans to assist decision-making; emphasize the attainability of
WQS.
Periodically review program goals to make sure they are en-
vironmentally, financially, and technically desirable and
realistic; establish within EPA a long-range WQM strategy
and improved oversight of State programs.
Continue to develop the technical and institutional data base
for nonpoint source controls.
STRATEGY ELEMENTS
Since the passage of the 1972 Act, the participants in the WQM program -
Federal, State, areawide, and local - have solved many water quality problems,
as discussed in the Background Paper. They have controlled, in many situa-
tions, not only conventional pollutants from point and nonpoint sources, but
also non-conventional pollutants such as toxics.
As mentioned in the current program description, above, the WQM
program has greatly assisted construction grants by establishing water
quality standards and monitoring networks and preparing over 200 initial
WQM plans which contain strong point source planning frameworks and a
general understanding of municipal water quality problems.
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Despite its successes, however, the WQM program must improve in
several ways to be more useful to the construction grants program. This
strategy outlines necessary changes. Actually, many parts of this strategy
are already in place in States and EPA Regions throughout the country,
where they have moved ahead independently in much the same direction this
strategy suggests. EPA's intent in Task V is to increase the overall
national effectiveness of the WQM program to the level that well-managed,
aggressive States and Regions have already achieved.
The following pages present the proposed strategy for Task V in
four sections: the problem-solving process, institutional roles, re-
sources, and management.
The Problem-Solving Process
The Act sets up a comprehensive problem-solving process which, when
followed, greatly assists EPA and the States in meeting the WQM goals
and objectives stated above. (See Figure V.I.) The integrity and use-
fulness of this process are key to this strategy. If the construction
grants program is to become more responsive to water quality problems,
the WQM program and the problem-solving process are more important than
ever, since they identify problems and set water quality priorities.
EPA and the States will get the most rewards from the problem-
solving process if they define precisely what they will accomplish with
construction grants and how they will track progress toward that goal.
States should determine which of their waters will not support designated
or future uses and develop programs to achieve those uses - assuming they
are attainable - integrating point and nonpoint source controls.
Problem Identification:
In the first step of the problem-solving process, problem identifi-
cation, three important actions are necessary to improve the contribution
of the WQM program to construction grants. First, EPA and the States must
improve their problem assessments to provide the basis for construction
grants priorities based on achieving beneficial uses of water bodies.
Second, EPA and the States must give more attention to water quality
standards attainability and use only attainable water quality standards
in formulating plans for POTWs. Third, the States should improve their
monitoring programs to provide crucial data for WQS review and priority
setting.
Problem assessments, in general, have been weak. This is unfortu-
nate, since they are critical for setting construction and planning
priorities. To improve the State problem assessments, EPA will provide
new guidance for the semi-annual State 305(b) reports which document the
problem assessment process.
34
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TABLE V.I DETAILED PROBLEM-SOLVING PROCESS
Part 1 Problem Assessment Module
SEGMENT IDENTIFICATION
REVIEW
USE
REVIEW WQS
CRITERIA
REVIEW WQS
AS NEC'Y
EPA
PROMULGATION
DISCHARGER
INVENTORIES
PROJECTIONS:
POPULATION,
ECONOMIC,
WASTE LOADS
AND FLOWS
I
SET (OR REVISE) WQS
I
WQS ATTAINABILITY
DETERMINATIONS
I
IS USE
ATTAINABALE?
ARE
CRITERIA
ATTAINABLE?
ll
ARE WQS
APPROVABLE?
IDENTIFY PROBLEM
SEGMENTS
IDENTIFY POLLUTANTS
CAUSING PROBLEMS
IDENTIFY SOURCES OF
PROBLEM POLLUTANTS
I
PROJECT EFFECTIVENESS
OF BASE-LEVEL CONTRLS
I
CLASSIFY SEGMENTS
1
RANK SEGMENTS
SET TMDL, WLA
PRIORITIES
L
USE DESIGNATION;
AMBIENT CRITERIA;
INTERMITTANT
FLOW, MIXING ZONE,
ANTI-DEG POLICIES
ECONOMIC,
TECHNOLOGICAL,
ENVIRONMENTAL TESTS
TREND MONITORING,
INTENSIVE SURVEYS,
BIO-MONITORING,
STREAM INDICES,
MODELLING
p
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A
S S
E S
S M
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N T
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FIGURE V.I DETAILED PROBLEM-SOLVING PROCESS
Part 3 Solution Development Module, Municipal Pt Source Sub-Module
CALCULATE
TMDL'S
PS/NPS TRADE-
OFF ANALYSIS
IS THERE
POTENTIAL
PS/NPS
TRADEOFF?
N
PERFORM
WLA'S
DEVELOP BPWTT PERMITS
TO MEET WQS
ADVANCED TREATMENT
REVIEW
APPROPRIATE
CORRECTIVE
ACTION
IS NEED FOR
ADV. TRTMT.
CONFIRMED?
IS SEGMENT WQL
FOR BOD, SS,
NUTRIENTS?
N
DEVELOP BPWTT
PERMIT CONDITIONS
IS WAIVER
REQUESTED?
IS WAIVER
APPROVED?
IN.
'4-
IS POTW OVER
5 MGD?*
REVISE
PERMIT
CONDITIONS
DEVELOP LOCAL PRE-
TREATMENT PROGRAM
ADD PRETREATMENT
CLAUSES TO PERMIT
IDENTIFY TREATMENT
TECHNOLOGY ALTERNATIVES
IDENTIFY FISCAL, FINANCIAL
AND INSTITUTIONAL OPTIONS
SELECT COST-EFFECTIVE
ALTERNATIVES
IDENTIFY MGMT AGENCIES
OBTAIN MGMT AGENCY
COMMITMENTS
or meet other
requirements in
regulations?
37
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The assessments should identify and rank water quality problems
segment by segment and identify treatment works necessary to attain fish-
able/swimmable conditions. Although the existing data base in STORET,
State WQM plans, and problem assessments is imperfect, it contains a vast
store of information. There is great potential for making better use of
this information.
Over time, the problem assessments should shift to include toxic
pollutants, once EPA has identified pollutants of interest in different
States and feasible controls. (EPA published ambient criteria for toxics
in November, 1980.)
Water quality standards, which represent State water quality bench
marks, have not always proved attainable. Once the States set them and
EPA approves them, they tend to become fixed, arbitrary reference points,
rather than integral parts of the WQM plans and the planning process.
In their periodic reviews of water quality standards, which the Act
requires every three years, the States should verify WQS attainability
based on environmental, technological, and economic tests. Where WQS
are not attainable, States should modify them and incorporate the modi-
fications in their WQM plans.
EPA's goals in the area of water quality standards are to implement
the highest attainable standards, establish sound scientific and technical
bases for standards, and coordinate technology-based and water quality-
based requirements.
Rather than review WQS on every.segment arbitrarily, the States should
set priorities for these reviews - as they do for other activities - to
respond to known water quality problems or situations where major capital
investments are proposed to achieve WQS. To give the States more flexi-
bility in setting WQS, EPA has rescinded its policy on presumptive applica-
bility of the Red Book criteria. EPA is also revising its WQS regulations
and developing guidance on how to make attainability determinations.
States may lower the criteria in a stream within a given use except in
Outstanding National Resource Waters (ONRW). Downward adjustments in uses
and criteria may be approved due to natural background, irretrievable
human-induced conditions, or substantial social and economic impacts.
Over time, as our knowledge and expertise grow, States should expand
their WQS to include toxic criteria. The Administrator may use his autho-
rity to require States to consider certain toxic parameters for inclusion
in their WQS, nationally or State by State.
Monitoring is a key input to the construction grants program for
problem identification, solution development, and evaluation. However,
it has suffered from a lack of planning and has not, as a rule, been
cost-effective. EPA Regions will work with the States to include moni-
toring plans in their annual State strategies and focus monitoring of
POTW performance where it will do the most good.
38
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During FY 81, EPA is performing several prototype monitoring pro-
grams which will describe the chemical, physical, and biological integrity
of selected stream segments. EPA will transfer the lessons learned from
these prototypes to the States for implementation in FY 82-83. EPA has
also initiated several prototype before-and-after monitoring studies
related to POTW construction to determine the effectiveness of new POTWs.
Quality assurance is another key need in the monitoring area. EPA
has published draft QA procedures which it will finalize soon and imple-
ment nationwide by mid-1982.
Solution Development:
Solution development is the second step in the problem-solving pro-
cess. To improve solution development activities related to construction
grants, the participants in the WQM program must take certain actions
and make several changes.
First, EPA, the States, and local agencies must pay more attention
to the potential cost savings associated with point/nonpoint source trade-
offs, as discussed above in Issues. State planning agencies should con-
sider the possibility of tradeoffs for every proposed treatment works that
would discharge above a lake, reservoir, or estuary likely to suffer eutro-
phication problems. EPA will continue to assess, through prototype projects
and research, whether other direct tradeoffs are important. PRM 79-7, under
revision at this time, will set forth policy on handling indirect point/non-
point tradeoffs in construction grants.
To facilitate evaluation of possible cost savings from tradeoffs and
assist in meeting the fishable/swimmable goals, EPA will build up its non-
point source data base on problems, solutions, and cause-effect relation-
ships, especially for agriculture, urban runoff, and ground water problems,
and issue guidance on evaluating tradeoffs.
In addition to considering tradeoffs, the States must also become
more involved in the fiscal, financial, and institutional aspects of con-
struction grants. Each State should plan to control pollution into the
future through such tools as capital budgeting, manpower planning, and
tracking of the useful lives of facilities. To ensure appropriate fiscal/
financial expertise, they should build State and sub-State capability
through hiring, training, and outside assistance. They should also review
the financial and institutional capabilities of their designated manage-
ment agencies which receive construction grants.
Next, so that grantees can take advantage of some cost savings in
design and construction of POTWs in the future, EPA is considering re-
defining base-level secondary treatment. The new definition would
allow, in controlled circumstances, biological treatment other than
activated sludge based on performance, climatic, and reliability con-
siderations. By doing this, EPA would maintain the treatment floor
the Act calls for but reduce the costs of installing and maintaining
secondary treatment in some instances.
39
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In the area of planning to control pollution from urban runoff and
combined sewer overflows, EPA will not recommend a national strategy
until it gathers and analyzes more data on the scope of these problems,
their impacts on water quality, and the costs and effectiveness of
various controls. Working with the States and others, EPA will develop
a comprehensive urban runoff/combined sewer strategy which will take into
account, among other factors, high seasonal flows and how to account for
them in NPDES permits and questions of WQS attainability.
So that solutions don't become fragmented, EPA will emphasize the
need for the States to maintain their WQM plans, which document selected
solutions for all types of water quality problems and which explain how
they relate to each other and the State's problem assessment. The WQM
regulations provide streamlined certification and approval procedures
for routine plan updates which should make it easy for States to keep
their plans current and workable.
Waste load allocations (WLAs) and water quality analysis in general
are crucial inputs to the development of solutions to municipal point
source problems. EPA is developing a new regulation and several pieces
of guidance to help States do a better job on waste load allocations.
The guidance will discuss general requirements, procedures for simple
systems, procedures for complex systems and large dischargers, and in-
structions for evaluating nonpoint source impacts and controls.
In the short term, until EPA has advanced the state of the art in
planning for toxic pollution control, the States should focus their WLAs
on conventional pollutants. Each WLA should contain documentation of
models, constants, and assumptions; stringent enough effluent limits,
taking into account seasonal variations and a margin of safety; gross
allotments for nonpoint sources; and a description of the mixing zone
policy employed.
Implementation of Solutions:
Implementation follows the problem definition and solution develop-
ment steps described above. For construction grants, implementation
involves Step 2 and 3 grants, NPDES permits for POTWs, and enforcement
against dischargers who are in violation of their permits. The funds
which EPA, the States, and others spend on planning should ensure the
efficient use of implementation funds. The EPA Regional Offices will
make sure implementation efforts, specifically construction grants and
permits, are consisent with WQM plans, as the Act requires.
EPA will work with the States, local governments, USDA, and the State
and local conservation agencies to direct available nonpoint source con-
trol funds to situations where they will have the most benefit, either on
their own or as part of a coordinated control effort involving a POTW.
EPA may also develop, over the long run, a legislative initiative under
the Clean Water Act to support implementation of nonpoint source controls
40
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in some way. EPA encourages the States to develop cost-sharing programs,
as 13 have already done.
Evaluation:
In the problem-solving process, evaluation follows the implementation
of solutions. As it relates to construction grants, the evaluation step
has been weak. Program participants have been frustrated by an inability
to demonstrate environmental progress and POTW effectiveness. To improve
their evaluations, the States should evaluate POTWs on site, and also
evaluate the aggregate effects of pollution for all the POTWs in the State.
They should identify new POTWs they wish to evaluate in advance, so that
they can conduct before-and-after studies. EPA is aware that studies of
POTW effectiveness for single plants of an entire State may not be possible
in one or two years, but may require much longer times.
As mentioned above, EPA Headquarters is developing information on
before-and-after monitoring through the use of prototype efforts for
eventual transfer to State agencies.
With respect to evaluation, EPA and the States must begin to evaluate
environmental results, that is, water quality results, rather than surro-
gates such as the number of treatment plants completed or the number of
pounds of BOD removed at a particular plant. The program's dependence on
surrogates has diverted attention from the basic purpose of the Act,
cleaner waters.
Institutional Roles
As previous portions of this strategy have discussed, the development
of institutional roles has hindered the WQM program's contribution to con-
struction grants. The main adjustments in roles needed to improve the
program are stronger ties between State and local governments on such issues
as fiscal and financial planning, further delegation of responsibility and
authority to the States for planning and program management, and more
direct links between States and designated areawide agencies under section
208. (For additional discussion, see also Issue 9, above.)
EPA Role:
EPA's role is primarily to oversee and direct the national program;
delegate authority; build State capability; provide assistance; issue
regulations and guidance; review and approve various State outputs; iden-
tify toxic pollutants, criteria, and feasible controls; and evaluate the
effectiveness of the national program. To help with oversight and direc-
tion of the program, EPA will develop with the States and others an annual
national strategy to define WQM goals, objectives, related actions, and
priorities.
-------
To put resources closer to problems and avoid duplication of effort,
EPA will delegate functions to the States. EPA Regions will review State
planning processes and existing delegation agreements to determine what
activities the States are performing now, and encourage the States to
manage the WQM program and plan solutions to problems with the assistance
of involved sub-State entities.
One of EPA's main functions is to provide technical assistance and
guidance on a variety of topics. (See the Action Plan, below, for details
on upcoming guidance documents.) Two of the most important areas which
require improved guidance and assistance are controls on toxic pollutants
and nonpoint sources as they affect both ground and surface waters. In
the toxics area, EPA recently published toxic water quality criteria and
will soon conclude a toxics treatability study for POTWs.
State Role:
Over the life of the WQM program, the trend has been toward a stronger
State role in both planning and program management. This strategy rein-
forces that trend and also encourages stronger ties between the States and
units of local government to solve some of the problems affecting construc-
tion grants.
States should carry out general management functions, implement the
planning process, maintain workable WQM plans, and review and revise
water quality standards. They should also focus on the problems and capa-
bilities of local units of government involved in POTW construction or
operation, especially for capital budgeting and long-term financing, to
ensure the long-term operation and maintenance of on-lot disposal systems,
POTWs, sewers, and nonpoint source controls.
Regarding the involvement of sub-State planning agencies, specifically,
the designated areawide planning agencies under section 208, the States
should manage their involvement and make sure they receive funds to perform
the tasks for which they have expertise. At the same time, the States must
make sure that the Statewide use of funds is non-duplicative, focused on
priority problems, and making use of transferable information from neigh-
boring Regions or States.
In general, it is the States' role to control nonpoint sources, since
the Congress has reserved this responsibility for the States. The States
can employ regulatory programs, such as general NPDES permits for storm
sewers, or employ incentive programs such as cost-sharing under USDA or
the State.
Areawide and Local Agencies:
The designated areawide agencies provide important planning inputs
to the WQM program on such items as definition of municipal service areas,
42
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identification of management agencies, development of fiscal/financial
plans, consideration of integrated waste management, identification of
operations and maintenance programs, and identification of cost-effective
controls for certain nonpoint sources, particularly urban runoff and con-
struction runoff. The areawide agencies also serve an advocate function
for implementation of certified and approved WQM plans.
Since areawide agencies tend to be weaker in terms of authority and
capability than the States, the States should oversee and coordinate their
efforts. The State agencies may contract with the areawide agencies to
perform vital planning or implementation functions if they do not receive
grants directly. Also, the areawide agencies should develop self-sustaining
funding sources, if possible, with State and EPA assistance.
Local governments are deeply involved in both planning and management
activities related to POTWs. Through their areawide or regional agencies
they participate in facility-related aspects of arawide planning. Where
WQM plans designate them the management agencies for this purpose, they
receive construction grants for POTWs and operate and maintain existing
POTWs in their jurisdictions.
Units of local government also generally conduct Step 1 facility
planning which includes identification of service areas, fiscal/financial
aspects, operations and maintenance, and point/nonpoint source tradeoffs
(unless a certified and approved WQM plan already includes this informa-
tion). Local governments should give full consideration to no-action or
non-structural alternatives and innovative/alternative technology when
conducting facility planning to ensure the ultimate cost-effectiveness
of the systems they select.
Resources
All available evidence indicates that the ideal or ultimate needs of
the WQM program far exceed anticipated Federal, State, and local budgets.
Therefore, the participants in the program must set priorities and work
to develop or redirect additional funding sources.
To obtain the maximum payoff from the funds available, EPA, the
States, and the other participants in the WQM program should observe
the resource principles discussed above in Issue 10. Briefly, the States
should direct construction grants and program grants to actions with direct
impacts on water quality, and develop more imaginative funding schemes.
EPA will delegate more responsibility to the States to make program ad-
ministration more efficient, consider changing the definition of secondary
treatment, and provide the States with improved information on national
goals and objectives.
Since there is no broad implementation authority or program for non-
point source controls under EPA's mandate, EPA will attempt to achieve
necessary nonpoint source controls through State and Federal cost-sharing
43
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efforts, USDA conservation programs, and the use of private funding sources
such as land developers. After further study, EPA may recommend a Federal
nonpoint source implementation program to augment State programs.
EPA will use its national WQM strategy to set priorities for the use
of WQM funds nationally, such as grants to States under sections 106, 205(g),
208, and 314. (For more information on the strategy, see Management, immed-
iately below.)
WQM Program Management
In managing the WQM program, three important changes are needed.
First, EPA will put increased emphasis on State 305(b) reports and State
strategies, since States will identify in these management documents their
problems and action plans for meeting water quality goals. Second, EPA
will conduct improved oversight of State programs. Third, EPA will main-
tain a national WQM strategy which will clearly identify goals, objectives,
and priorities, and, therefore, give meaning to the oversight function.
The States must conduct, under the Act and EPA regulations, contin-
uous problem assessment processes and submit 305(b) reports summarizing
their assessments every other year. To stress the importance of the
problem assessment process in setting construction grant priorities, EPA
will issue improved guidance on 305(b) reports which will ask the States
to identify, segment by segment, streams which aren't meeting their desig-
nated uses and whether municipal sewage treatment problems are involved.
EPA will also ask the States to develop strong, comprehensive State
strategies to provide the long-range action plans for solving municipal
point source problems and keeping intact the designated uses of all water
bodies in the State. Specifically the strategies should identify:
waters which are not fishable/swimmable, but for which those uses
are attainable, and how the State will meet the fishable/swimmable
goal by 1990
plans for completing construction grants programs under the Clean
Water Act, under two scenarios: (1) fastest possible completionn
assuming unconstrained resources, and (2) constant annual federal
funding at a level EPA will specify in its State strategy guidance
priorities and action plans for all components of the State WQM
programwater quality standards reviews, monitoring, waste load
allocations, nonpoint source and ground water management programs,
and other activitiesto ensure cohesive, coordinated State pro-
grams
After considering several options for the timing of this proposed re-
quirement, EPA recommends that States should begin to provide this informa-
tion by FY 83, since that is the earliest feasible time.
44
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By stressing improved oversight of State programs, EPA does not
wish to imply more detailed or burdensome reporting of State activities.
As discussed above under the problem-solving process, EPA will stress
environmental results (cleaner water) in preference to surrogate measures
of State performance.
Since some tracking of State management functions is necessary, how-
ever, to analyze where Federal and State funds are going and whether they
are being used effectively, EPA will conduct limited tracking of State
program activities. This will involve two types of information: data on
proposed expenditures of funds on priority outputs and data on accomplish-
ment of those outputs.
To provide the context for improved oversight, EPA will use its na-
tional WQM strategy. Working with the States and others involved in the
WQM program, EPA will develop priorities through a rational process of
defining goals, identifying long- and short-range objectives, identifying
associated activities and outputs, then deciding on national priorities
which the EPA Regions will stress in their annual negotiations with the
States.
Priority activities are generally those which are either mandatory
under authorizing legislation, or those which are necessary before other
important parts of the program can operate. Some of EPA's short-range
priorities which relate to construction grants are water quality standards
attainability determinations, waste load allocations for situations
involving proposed AST/AWT plants, State and local pretreatment programs,
construction grants management delegation, POTW operator training, and
305(b) reports and State strategies.
45
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CHAPTER VI
ACTION PLAN
In general, Task V of the 1990 Strategy assumes that the Act, the
regulations, and EPA guidance set forth a problem-solving process and
management framework which are basically sound. Although this strategy
will necessitate some regulatory changes and many administrative changes,
EPA will not start a major legislative initiative involving the WQM pro-
gram at this time.
Legislative Changes
Although EPA anticipates no major changes in the law in the short
run as a result of Task V, there may be a need for legislative changes
in the nonpoint source area within five years, after more information
on the effectiveness of present control programs becomes available. EPA
may suggest some type of Federal regulatory authority to ensure NPS con-
trol or may pursue expanded Federal cost-sharing programs.
Regulatory Changes
One of the assumptions of this strategy is that EPA will propose,
before the end of FY 81, new regulations for water quality standards
and waste load allocations. Beyond these two areas, EPA is assessing
the construction grants regulations and the WQM regulations to determine
what adjustments are needed to implement Task V.
Preliminary findings on necessary regulatory changes are as follows:
EPA may revise the definition of BPWTT/secondary treatment
in the construction grants regulations and will issue an
Advanced Notice of Proposed Rulemaking in FY 81.
EPA should review the goal statement of the WQM program and
revise it to reflect the goals stated herein (see 40 CFR 35.
1505).
EPA may wish to expand its description of what States are
required to include in their Continuing Planning Process
descriptions, especially with respect to setting water
quality-based priorities (see 40 CFR 35J509)
EPA should change the statement in 35.1511 that problem assess-
ment activities should be funded only with section 106 funds.
As with the Continuing Planning Process, EPA should expand its
requirements for State strategy preparation to set the basis
for water quality-based priorities (see 35.1511-2).
47
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§ EPA should say in the WQM regulations that designated management
agencies in certified and approved WQM plans may receive con-
struction grants to perform eligible construct ion-related tasks
(See 35.1513-6.)
The discussion of roles in 35.1521-2 should be updated to include
a stronger State role in planning and program management
Appendix A - Water Quality and Pollutant Source Monitoring - of
the WQM regulations should be updated to reflect this strategy
and other recent developments.
Other Actions
The Action Plan, shown on the following pages, presents a calendar
of action items this strategy identifies. The items are identified by
the part of the problem-solving process they are associated with, or as
part of needed improvements in program management.
48
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1990 STRATEGY TASK V -- PLANNING
APPENDIX
Major WQM Policy Documents
1. 40 CFR Part 35, Subpart G, "Grants for Water Quality Planning,
Management, and Implementation." Final Regulations. May 23, 1979.
2. US-EPA, Water Planning Division, "Water Quality Management Five-
Year Strategy, FY 81 Baseline." January 1980.
3. US-EPA, Water Planning Division, "Supplemental Water Quality
Management Program Guidance for FY 81." June 1980.
4. US-EPA, Office of Planning and Management, "Agency Operating Year
Guidance for FY 81." February 1980.
5. US-EPA, 440/9-76-025, "Basic Water Monitoring Program." Revised 1978,
6. 40 CFR Part 35, Subpart E, Appendix A, "Cost-Effectiveness Analysis
Guidelines." September 27, 1978.
7. US-EPA, Criteria and Standards Division, "Clean Lakes Program
Strategy." August 1980.
8. US-EPA, Water Planning Division, "Draft WQM Needs Assessment for
FY 80-84." September 1980.
9. US-EPA, Office of the Administrator, "Handbook for FY 81 State/EPA
Agreements." March 1980.
U.S. SOVERHMEOT PHINTIIIQ OFFICE: 1981-0-7aO-0!6/5983
55
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