905R85104
FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
NATIONAL OBJECTIVE: Improve State Decision-Making for Pollution Control
on Priority Waterbodies
ACTIVITY: Update State Continuing Planning Process (CPP)
ANALYSIS OF REGIONAL PROGRAM:
The Region reviewed the States' CPP elements listed on the following chart.
Four of the States have prepared current CPPs (1984 or 1985) and use the
CPPs (and WQM Plans) to manage their programs. This is evident in the
quality of work produced by the States and their effectiveness in initiating
timely actions that respond to environmental issues. Michigan's update was
only partial and the State needs to improve their overall management of water
quality programs. Michigan's program suffers because there is no centralized
planning and grants administration functions. As a result of last year's
evaluation, Michigan is developing an analysis of 205(j) State planning needs
including CPP. Minnesota has not had any significant update of their CPP in
several years. Historically, Minnesota and Indiana did not have centralized
planning organization to conduct basic planning and advise the agency on pro-
gram integration matters. However, in FY 85 both States have agreed to doing
WQM plans and stabilizing their planning functions.
The States of Ohio, Wisconsin and Illinois all have good management structures
that use CPPs, WQM plans, 305(b) reports and other management tools to direct
resources to accomplish work in priority areas.
In reviewing the State CPPs, the Region used the Mid-Year evaluation of 1984
as a starting point for evaluation. The attached chart presents the overall
adequacy of CPP elements. The following narrative is designed to present
comments and state specific examples on each CPP element. The Region has
prepared a more lengthy summary of each State CPP that provides the detailed
analysis.
In addition to document program activities, some States use the CPP for staff
orientation.
1. Revision of WQS. Effluent Limits, TMDLs and WLA
a. Each State has a process for conducting WQS, WLA. Several States
do not prepare TMDLs as an intermediate step to prepare a WLA. The
processes were generally acceptable until the publication of the
Part 131 regulations that require each State to describe processes for
Section 24 reviews, AT reviews and general use attainability. Only
Ohio has a process that is fully compatible with the new guidelines.
Illinois, Indiana, Minnesota and Wisconsin still need a modest update
of their process. Michigan will have to completely rewrite its pro-
cesses in light of the guidelines to incorporate the use attainability
aspects of the program.
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2. Identification of Planning Areas
Each State has a process for identifying planning areas. There are
two aspects to consider. The first is the designation of water quality
planning areas and agencies. This task was accomplished in the 1970s by
the governors' offices for Section 208 planning. In Michigan, there
are inactive planning agencies, notably Region II Jackson, that are not
supporting State-wide water planning needs. In Indiana, there have been
three dedesignations of planning agencies and the State Board of Health,
although recognizing the need, has not factored these areas into the State
process for planning. In Ohio, one designated planning agency has failed to
produce acceptable outputs and is currently not receiving 205(j) funds.
Ohio EPA has undertaken priority planning work in this designated area
without dedesignating the planning agency. The other States are adequate
to exceptional in conducting planning to meet the intent of the Act.
For Construction Grant needs, the WQM plans contain the original facilities
planning areas and these areas are reviewed consistent with the SMAP agree-
ments as grants are considered. Plan of study area adjustments tend to be
noncontroversial and managed well by the States. The process is judged to
be adequate in all States.
3. Intergovernmental Coordination of WQM Planning
This element is adequate in all States. The following three examples are
cited. The State of Michigan has established a local/regional/State task
force to discuss planning and grant application procedures. They have been
meeting for two years and are improving their abilities to make decisions
based upon State level priorities. Illinois conducts several task forces
for planning, the best documented of which is the Agricultural Task Force.
They have involved a broad spectrum of agencies including the Regional
office on their task forces. Wisconsin still uses their environmental
State Water Quality Action Committee to obtain input to State programs or
even draft legislation.
The State of Michigan may produce a total water plan within two years.
Some update will be necessary to document the inclusion of Executive Order
12372 (40 CFR 29).
4. WQM Plan Update Process
Five of the States have a process for WOM plan updates. During 1984,
Illinois produced a significant plan update that combined the State and 3
areawide plans into a single cohesive document. Minnesota produced an
areawide plan update in 1984 and is working on a statewide nondesignated
area plan update. In FY 85 Minnesota presented the Region with a concept
paper on the development of a new point source standard. Its original
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schedule was for 1984, but they have slipped that to 1985. Wisconsin has
a five-year cycle for producing plan updates by 1987. Wisconsin will
certify a plan update for the nondesignated area this spring. Ohio certi-
fied a nondesignated area plan update this year including areawide plans as
well.
Michigan has no process for updating the WQM plans. Michigan will address
this issue as a part of its effort to assess Statewide planning needs.
5. Construction Grant Priority Lists
(See attached Construction Grants write-up).
6. Public Participation
Each State has a public participation process. The processes are appropriate
and consistent with the Part 25 regulations. Examples of public participa-
tion are found in number 3 above. Each State sends evidence of public
noticing of permits, applications for grants and production of the project
priority list. Each State grant application and annual program plan goes
through a public noticing process. Michigan has a Environmental Policy
Advisory Group that provides a forum for review and comment on major documents
and actions.
7. Priority for Permit Issuance
With the promulgation of the 130 regulations, CPPs are now to describe the
State process for determining priorities for permit issuance. Most State
permitting activity in Region V has focused on eliminating the backlog of
major permits or keeping current with the major permit workload. Under
this scenario, elaborate process descriptions for determining the priority
of permit issuance have not been necessary.
With the issuance of most backlogged major permits in Region V by the end
of FY 1985, in addition to minimizing the backlog of major permits, Region V
States will be addressing more minor permits. As a part of the State Specific
Guidance for FY 86, Region V requested the States to develop a strategy and
schedule for issuing minor permits. This integrates well with the need to
develop as a part of the CPPs a process for determining the priority for
permit issuance. Since this is a new CPP requirement, each State will be
addressing this topic during FY 85-86.
8. Process for the Control of Residual Wastes
(See attached Construction-Grants write-up).
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CONTINUING PLANNING PROCESS (CPP) STATUS
STATE
IL IN MI MN OH WI
LAST UPDATE
Revision of WQS, detenrring effluent
limits, wasteload allocations, and
TMDLs.
Identification of State and areawide
planning areas.
Intergovernmental coordination of WQM
planning.
WQM plan updates process.
Construction Grant priority list
development.
Process for determining controls for
disposition of residual wastes.
Public participation procedures
Process for determining the priority
of permit issuance.
A = Adequate procedure
U = Procedure needs update
85 85 85* 78 85 84
U U U U A A
A A A A A A
A A A A A A
A U U U A A
A A A A A A
A A A A A A
A A A A A A
/
U U U U U A
* Partial update in FY 85 program plan
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FY 1985 Mid-Year Evaluation of Region V Water Program
Objective; Improve Hater Quality
Activity 1: Manage Priority Systems and Lists
Qualitative Measure (A): Have Regions/States demonstrated that priority lists
are being used as management tools (page A-52)?
The Project Priority Lists (PPL) are used as management tools to varying degrees
1n all Region V States for construction grants, water quality, and enforcement
programs. For example 1n Ohio, scheduling of reviews of facilities plans,-plans
and specifications, and other documents 1s based on priority ranking. Study
areas for the preparation of Comprehensive Water Quality Reports are"selected
based on PPL projects which require AT reviews or whose effluent limits have
yet to be established. The PPL provides Information on funding status for
writing NPDES permits 1n terms of schedules or needs for Municipal Compliance
Plans. Similar program management activities occur 1n Illinois, Minnesota,
and Wisconsin, except that Wisconsin enforcement actions proceed Independent
of funding status due to the availability of State grant funds. Indiana has
begun to develop communication systems among the programs for use of the PPL
as a management tool. Indiana's use of the PPL to guide funding actions has
Improved significantly over the last 2 years. Michigan uses the PPL to manage
the construction grants program as In the other states, but there appears to
be room for Improvement 1n other Michigan water quality programs' use of the
PPL as a management tool. Although Ohio makes good use of the PPL as a manage-
ment tool, this fiscal year the extremely late submission of the PPL has caused
problems In the dec1$1onmak1ng process for all water quality programs.
As needs are Identified through applications from municipalities, permits and
enforcement activities, and water quality management planning; projects to
address these needs are subjected to the States' priority system ranking
processes. The State priority systems rank projects based on water quality,
public health, and other factors permitted by the regulations. Since future
growth and some need categories are Ineligible for funding, some newly emerging
needs will not be fundable.
All Region V States update priority 11st Information on a regular basis, some
more frequently than others. Significant updating occurs after submission of
Information by applicants during the public participation process and at the
time applications are completed. Region V reviews the priority lists for
accuracy when they are submitted for acceptance as well as when projects are
certified for grant award.
Qualitative Measure (B); Have Regions/States demonstrated that grant dollars
are going to priority projects with high WQ/PH ranking established at the
start of the fiscal year (page A-52)?
Brants 1n Region V are only awarded for projects 1n the funding range on the
State PPL's or to contingency projects reached through established State bypass
procedures. This ensures the funding of priority projects since the priority
system rankings are based on WQ/PH. Facilities plans, prepared as prerequisite
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to grant award, document public health problems, and waste load allocation
reports, prepared to establish effluent limits and to review water quality
standards, document biological and chemical water quality Impairments.
Either one (the facilities plan) or both of these documents are available
before a grant 1s awarded to demonstrate appropriate use of grant dollars.
In most of the States enforcement and construction grants staff coordinate
enforcement actions being considered or ongoing for those communities which
will or have received construction grants. Discussions among the staff occur
concerning planning, design, and construction schedules and timing of potential
grants. *^., „.- . '• ... * ^ -.
Qualitative Measure (C): • Do priority projects funded 1n (B) above correlate
with priority waterbodles Identified In the Hater Quality Standards, Planning,
and Assessment section of OWAS (page A-52)?
Although all the States coordinate the priority waterbody and construction
grants priority 11st processes, only Illinois and Ohio have reportecKt'hat
priority waterbody maps have been prepared to show the location of PPL projects.
For the Region V work plan, each quarter numbers of construction grants projects
completed and 1n compliance with NPDES effluent limits on priority waterbodies
are determined to reflect water quality Improvements. Numbers of completed
pipe or small system projects are used as Indicators of public health Improve-
ments. In addition, numbers of new awards on priority waterbodles are used as
Indicators of projected water quality/public health Improvement.
Regional Contact; John R. Kelley, Chief, Program Management Section, 353-2123.
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SLUDGE MANAGEMENT
HID YEAR REPORT"
OBJECTIVE: Ensure Financial/Technical Program Management (A-53)
ACTIVITY 1: Translate National Guidance Into Mechanisms for Oversight.
Qualitative Measure (A) are sludge management projects being
Implemented 1n a manner consistent with existing Agency
Guidance?
A direct response to this Inquiry would be Yes! We have
Initiated a self evaluation questionnaire which 1s being
utilized as a means of monitoring sludge management project
activities within each State. Thus far, 1n FY'85, three States
have completed the questionnaire and two more are 1n the process of
providing responses to the questionnaire. The entire monitoring
process should be completed by June. •=•
The questionnaire was developed so as to clearly Indicate'whether
or not sludge projects are being Implemented consistent with
existing Agency Guidance. Preliminary results to date Indicate
an affirmative response to the Implementation and consistency
aspects of this Qualitative Measure. Pertaining to the States
which have thus far been monitored we can say with some confidence:
- The States do monitor and track compliance by POTW's with
appropriate guidance and regulations.
_ State sludge management programs are applicable to all projects
regardless of the source of funding.
__ The States within the Region do use EPA guidance and Federal
regulations.
- Some of the States are gradually becoming aware of the problems
associated with the land application sludge disposal practice
within proximity to urbanized areas. Remedial actions are just
now being considered.
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SLUDGE MANAGEMENT - MID YEAR REPORT
OBJECTIVE: Ensure Financial/Technical Program Management (A-53)
ACTIVITY 2: Adopt Programs to Meet Requirements of the Regulations
QUALITATIVE MEASURE (A): Are the States developing sludge nanagement programs
which embody and enforce EPA regulations and guidance (Page A-53).
* Do the States plan to Improve their current sludge aanagement programs
to embody and enforce EPA regulations and guidance?
Region V has several waste treatment facilities which have reached or
exceeded their capacity to store or properly dispose of the residual
product (sludge) resulting from the wastewater treatment process\
Neither the Region nor the several States can positively s^tate that we
have a firm handle on each and every location which may be' experiencing
sludge management problems. Accordingly, the Region has Initiated
action with each of the States to ensure that an Inventory of each
sewage sludge generator and sludge disposal facility will be available.
This inventory is ongoing and 1s scheduled for completion as a part of
the FY 1986 Work Plan activities. This inventory will be a major part
of each State's sludge management improvement program.
While each delegated State's sludge management program will be actively
monitored and evaluated during FY 1985, the Region has noted that in
virtually all of the States a lack of resources at the State level has
resulted in slow advancement in the Improvement of each State's sludge
management program. In addition, and without exception, each State
1s awaiting the promulgation of new EPA sludge management regulations
and guidance. Each State is reluctant at this juncture to expend
resources toward the improvement of their current program in view of
the imminent promulgation of new State program requirements. (See
State by State assessment.)
- Which States have an inventory of sewage sludge generators and sludge
disposal facilities?
This qualitative measure was originally set forth in February 1985 as
a part of the FY 1986 Work Plan objectives, activities and performance
measures. It has been duly noted and will be accomplished during
FY 1986.
Our FY 1985 monitoring and evaluation activities Indicate that some of
the States have accomplished significant Inventorying as a part of their
pretreatment program and despite limited resources, the States will be
providing follow-up toward the expansion of this inventory program.
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Minnesota
During the first half of FY 1985 the Minnesota Pollution Control
Agency continued to be in the forefront of States encouraging the
beneficial uses of sludge. Monitoring data indicates that MPCA is
currently improving their sludge management program to the point
where over 90 percent of the sludge material produced within the
State is disposed of through land application. In addition, MPCA is
planning Improvements to the guidance document "Recommendations for
the Application of Municipal Wastewater Sludges on Land?-,- and is
providing quality assistance to local municipalities.
Ohio
'The Ohio sludge management program continues to be hampered by
fragmentation. The majority of project specific implementation
activity is disseminated to the several District Offices as well as
administrated by the Ohio Air, Land, and Wastewater Operating
Divisions. There is little likelihood that changes will take place
within the Ohio sludge management program pending the promulgation of
the Federal sludge program regulations. Improvement activity has
given way to a cautious wait-and-see position.
Wisconsin
The Wisconsin sludge management program continues to be a positive and
effective force in the implementation of practices throughout the
State toward the beneficial uses of sludge. The State sludge coordinator
is active and involved in the preparation of the new Federal sludge
program regulations and has contributed significantly toward asserting
the States viewpoints as the preparation of the new regulations went
forth. WDNR is currently hiring new staff with which to implement
improvements not only within the current State program, but also to
place into effect the new Federal sludge program regulations, when
promulgated.
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- Identify the agencies 1n the States that have sludge management
responsibilities.
This qualitative measure has been Included in the broader spectrum of
our FY 1985 monitoring and evaluation activities. Each State has been
requested to "provide an organizational chart or description clearly
defining areas of sludge management program responsibility and those
within the organization who will administer the sludge management
program".
The several States which have been monitored thus far 1n FY 1985 have
Indicated that agencies within that State which have sludge management
responsibilities can be Identified, and we should have this Information
available by the end of June 1985. - f-
- A State by State assessment of their activities to Improve their
current sludge management programs.
Illinois
During the early portion of FY 1985, Illinois upgraded and distributed
to local agencies, two key sludge management guidance documents. Both
of these publications encourage and promote municipal sludge disposal
systems which provide for the beneficial use of sludge. The State sludge
coordinator 1s highly competent and continues to show an active interest
1n Improving the State's sludge management performance, as evidenced by
his attendance and active participation in the National sludge coordinators
conference which dealt primary with the development of new regulations
and guidance as well as continuing Improvement in current sludge manage-
ment programs. Illinois has developed a wait-and-see position concerning
any plans for the improvement of current programs, depending upon the
requirements of the new State program regulations*.
Indiana
The Indiana State Board of Health refined their sludge management program
1n FY 1984 and in the early part of FY 1985. This refinement took place
1n order to deal with the complexities Involved In several sources of
contaminated sludge discovered during the contaminated sludge inventory.
The Indiana sludge program continues to be hampered by staffing problems,
however these are being resolved slowly and there has been Improvement
1n their current sludge management program.
Michigan
The State sludge coordinator, represented MDNR on the National Sludge
State Program Regulation Task Force and has been active 1n the formulation
of National policy. Action leading to any alteration or Improvement in
the Michigan current sludge management has been placed on hold, as the
State prepares to receive the new Federal State Program and Technical
Regulation and guidelines. The State sludge coordinator believes that
Michigan's current sludge program can be adopted to meet the new
Federal Program - only time will tell.
5
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FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
NATIONAL OBJECTIVE: Improve State Decision-Making for Pollution
Control on Priority Water Bodies
ACTIVITY: Identify Priority Water Bodies
ANALYSIS OF THE REGIONAL PROGRAM:
Region V implemented the priority water body concept in FY 83 and
fine tuned the process in FY 84. At the close of FY 84, a complete
report on the status of implementation of the tracking of priority
water bodies was sent to then Deputy Administrator Al Aim. The
Region stressed that nearly 90% of the planned activities in the
identified PWBs had been conducted.
For FY 85 the Region again negotiated a list of PWBs with the States,
prior to the development of annual program plan negotiations. The list
become a part of the work plans and the Water Division integrates the
lists and tracks progress on a quarterly basis with the assistance of
the States. Many of the activities are already in computerized systems
such as GICS and PCS. The Region is committed to entering the total
lists into the IBM-PC and then interfacing the lists with the River
Reach Files. At the present time, the lists have not been completely
entered into the computer due to the late arrival of the computer and
higher priority work. Work will be completed in May.
Overall, the States have produced high quality PWBs for FY 85 and there
was not much revision by the Region. The PWB lists reflect the highest
priority activities that are to be conducted to improve water quality.
With the major emphasis on permits and compliance during the past two
years, much of the work has been focused to issue high quality permits.
A-total of 314 PWBs were identified by the States for FY 85.
IL IN MI MN OH WI TOTAL
No. of PWBs 25 85 21 35 120 28 314
-• \
r
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FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
NATIONAL OBJECTIVE: Improve State Decision-Making for Pollution Control
on Priority Water-bodies
ACTIVITY: Update and Improve Water Quality Management Plans
ANALYSIS OF REGIONAL PROGRAM:
The following chart indicates the status and use of WOM plans in the Region.
Details on the adequacy of the update process are also contained in the
Continuing Planning Process and Consistency Review discussions:
WATER OUALITY MANAGEMENT PLANS
DATE OF
APPROVAL
PROCESS TO
UPDATE
STATE PLAN
UPDATE
AREAWIDE
UPDATE
* ELEMENTS
UPDATED
STATES
IL IN MI
Feb. 80 April 81 June 82
YES NO NO
July
1983
July
1983
6 - -
MN
March 80
YES
Draft
1983
April
1984
6
OH
March 81
YES
March
1985
March
1985
6
WI
Feb. 80
YES
1980-5
1982-2 #
1984-1
1985-1
fi
* Consistency reviews performed by areawide agencies
# 6 NPS updates and 2 sewer service area updates
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The following is a list of WQM elements that have been updated during
FY 1985.
1. WQM Plan Elements Updated:
a. Ohio
Ohio EPA certified its plan update to the Region during January 198R.
Region V approval of this plan update is projected for May 1985. The
following elements were updated with this certification: Total maximun
daily loads, effluent limitations, municipal and industrial waste treat-
ment, nonpoint source management and control, management agencies, im-
plementation measures and ground water.
b. Wisconsin
Wisconsin will certify this summer a plan update for the lower
Wisconsin Basin. The following elements will be updated with this
certification based on Region V's review of the draft plan update:
Total maximum daily loads, effluent limitations, municipal and indus-
trial waste treatment, nonpoint source management and control, manage-
ment agencies and implementation measures.
PLAN UPDATES
Five States, Indiana, Ohio, Wisconsin, Illinois, Minnesota, have a process
to update the Water Quality Management Plans. Minnesota does not have a
point source plan at the present time for the nondesignated area outside of
the Twin Cities, but they have excellent basin plans that serve most of the
basic function of a WQM plan. They have presented a schedule to EPA to
produce a point source plan. Ohio and Wisconsin are using a basin by basin
approach to update their plans and will be producing plans on a continuous
basis. Illinois has an overall State plan that encompasses the entire State
including the areawide plans. The areawides are utilized by the State in
the update process.
Indiana recently provided a process to partially update the plans. Three
areawides have been dedesignated and these areas have been subsumed under
the State plan. There is no centralized planning activity in the ISBH.
Michigan has no update process and their original plan did not contain point
source elements. The Michigan areawide WQM plans have limited point source
elements and provide a basis for consistency reviews.
NONPOINT SOURCE REVIEWS
Nonpoint Source reviews are conducted in Illinois, Ohio and Wisconsin. These
States have well-written CPP elements that show the inter-relationships of
program areas. They have used a basin approach to planning and recognized
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the Impact of nonpoint sources of pollution of streams. Illinois has gone
one step further in recognizing that the major NPS impacts are related to
inland lakes and have now focused their attention on their lakes. Wisconsin's
inland lake management program was not funded during FY 84 but additional
State funding may occur in FY 86. Wisconsin has found, similar to Illinois,
that the major problem facing their lakes is agricultural NPS problems.
Integration of Section 106 and 205(j) Funding
All States are now preparing unified work plans as the basis for their
Section 106 and 205 grants. All States have met the basic requirements for
public participation related to Section 205(j) funds.
Illinois, Wisconsin and Ohio use an integrated approach on their funds and N
involve the areawide agencies by contract to produce State specific outputs.
Minnesota integrates its funding but does not anticipate using Metro Council
to perform work. So far there have not been any funds awarded to Indiana
areawide agencies, although some funds were passed through to other sub-state
entities for State priorities.
Michigan has involved areawide agencies in their 205(j) awards. They have
established a local/regional/State work group for reviewing and recommending
projects.
y
(
/
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FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
NATIONAL OBJECTIVE: Improve State Decision-Making for Pollution Control
on Priority Waterbodies
ACTIVITY; WQM plan Consistency
ANALYSIS OF REGIONAL PROGRAM:
Region V
Permits: The Permits Section of the Water Quality Branch receives from
each of the Region V States copies of proposed major permits prior to
issuance by the States. The Permits Section, in turn distributes copies of
the proposed major municipal permits to the Planning and Standards Section
of the Water Quality Branch. The latter Section reviews effluent limits
and monitoring requirements in the proposed permit against limits and
monitoring requirements in the WQM Plan, if applicable, and against current
monitoring data and wasteload allocations, for consistency.
Region V reviews proposed NPDES industrial permits against BPJ and available
BAT guidelines and pretreatment requirements. Since WQM plans have only
limited data on industrial discharges, no consistency reviews are possible.
Region V reviewed the following major municipal permits which were public
noticed during the first two quarters:
II _I_N IMI m _OH W_ Total
17 48 28 2 16 13 124
Construction Grants: Consistency reviews for proposed construction actions
have been delegated to the States.
States in Region V
Consistency reviews are handled in a variety of ways by the Region V States.
Illinois, Ohio and Wisconsin conduct a formal consistency review for popu-
lation projections, wasteflow and load allocations, treatment plant locations
and sewer service areas, for both areawide and nondesignated areas.
These same States delegate a consistency review of the proposed action to
the appropriate designated areawide WQM plan agency. The State then uses
the areawide review in their final review of the proposed actions. Illinois,
allows their areawide agencies to perform the consistency reviews and then
simply does a quality check of the consistency completed by the designated
agency, rather than also conducting a separate review of the proposed action.
Indiana reviews the proposed municipal action against that data in the WQM
Plan that is still current. The remaining states in Region V, Michigan and
Minnesota, do not have a certified point source element for their WQM Plan.
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These states rely on their monitoring and standards sections to generate
appropriate waste flows, water quality data and waste!oad allocations.
These data are used to directly determine state permit limitations and con-
struction grant facilities plan requirements. Minnesota has made arrange-
ments for the Metro Council to perform consistency reviews for all con-
struction grant projects and permits based upon the councils current WQM plan.
Michigan requires that areawide agencies (they completely blanket the state)
review proposed facilities plan actions for consistency with areawide WQM
plans. These reviews are then used in the state review of the proposed
action. All states in Region V use best professional judgement, BAT guide-
lines where available, and pretreatment programs requirements to generate
NPDES permits for industries.
Consistency reviews conducted by the States in Region V:
Permits (Municipal) Construction Grants
2
5
8
8
1
IL
IN
MI
MM
OH
WI
80
26
5
6
32
1
(includes
(includes
minors)
minors)
Totals 181
72
ISSUES: States do not formally certify their waste!oad allocation actions
for inclusion as WQM Plan amendments, or do not do so in a timely
manner. Region V has successfully negotiated with Indiana and
Michigan to revise their CPPs in FY 85 to include formally
certifying wasteload allocations as part of the WQM Plan.
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at-
STATE BY STATE ANALYSIS /^"^ £~/'V
Illinois
Illinois prepared a list of 25 PWBs for FY 85 based on the identification
of severe and moderately impacted waterbodies developed for the STFP project.
Illinois' PWB list also reflects necessary planning, monitoring, standards
and implementation work by PWB.
Indiana
Indiana's Water Monitoring Committee developed the PWB list. Prior to
committee meetings, each program manager lists anticipated monitoring data
needs according to program priority. Thus the PWB list shows where multiple
program activities need to be focused in order to achieve an environmental
result.
Michigan
Michigan has based its PWB list on the need to issue or reissue more than
1,300 NPDES permits. ,;•, k
/jf( *
This strategy entailed (1) identifying all surface water dischargers who -''\
were required to have an NPDES permit; (2) disaggregating the State into *'-,->
67 major river basins and compiling a list of dischargers for each basin ^ -
(3) having each water related functional unit within the MDNR assess each v
discharger in each basin and rank, by each unit's function, whether the
facility was high, low or unknown in terms of requiring action.
Since the issuance or reissuance of a1^ NPDES permit entails a broad spectrum
of activities such as monitoring and wasteload allocations, possible compliance
schedules or actions, and may affect the construction grants priority list or
the Michigan Municipal Strategy, the five year strategy functions both as a
priority water body list and a resource management tool.
Minnesota
The MPCA currently identifies Priority Water Bodies using three separate
lists. These are: 1) The stream segments receiving the discharges from
the 20 municipalities on the current Construction Grant Priority List; 2)
The stream segments receiving the discharges from the industries on the
industrial portion of the Compliance Monitoring Priority List current for
that year; and 3) those lakes with active Phase 2 Clean Lakes (Section 314)
Projects on them. Thus, the MPCA PWB List is generated by existing water
quality management programs. The process is not comprehensive. Streams
where designated uses are not being met may not be on the PWB list.
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fl (
i "'£
fit '-» -
Ohio
Ohio's priority water body list, developed during FY 1983, reflected both
water quality and program based criteria.
The FY 1985 priority water body lists developed during FY 1984 is designated
to eliminate program based criteria. The primary basis for Ohio's priority
water body list is significant problems or threats to high quality water
uses or conditions. This approach reflects Ohio's primary concern for
public health and habitat protection. Ohio is also investigating ways of
coordinating its priority water body list with its municipal project priority
system. The Ohio CPP includes a description of the priority water body list
and system developed during FY 1984. Ohio EPA's system and list is among
the best in Region V and was forwarded to USEPA Headquarters as a good example.
Wisconsin
The concept of prioritizing Department activities by waterbody is currently
being refined in conjunction with the re-evaluation of areawide Water
Quality Management Plans. Beginning with the Lower Wisconsin River Basin,
WDNR will be updating all river basins within the State. The projected
completion date for updating all the river basins is 1987.
During the update process, a list of priority water bodies will be prepared
for each basin. During 1985 WDNR is expected to finalize a methodology which
will ensure a consistent, comprehensive approach to program planning which
will focus on waterbodies identified in the WOM Plans as "Priority" water-
bodies. This approach relies on both water quality and program criteria.
However, WDNR has always implicitly prioritized Department activities to
address severe water quality problems. For example, major staff resources
have concentrated on the Lower Fox and Upper Wisconsin Rivers as well as
the Milwaukee Water Pollution Abatement Program. With resolution of these
.rejects, it is WDNR's intent to redirect staff and resources to other areas
of the State through an effort concentrated around WOM plans.
Summary
Region V States determine control priorities through a mixture of program
and water quality based criteria. The PWB list for Region V States reflect
this mixture with Michigan's list most program based and Ohio and Illinois
the most water quality based.
The impediments to achieving environmental results in Region V can be summarized
as follows:
1. Relatively high population density and industrialization.
2. Prevalence of low flow streams.
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3. Extensive agricultural land use.
4. Insufficient effective resources for pollution control activities
exacerbated by slowly recovering State economics.
ISSUES:
1. There is still reluctance on the part of some States to integrate
the PWB approach into their program planning process. They have
expressed uncertainty as to the regulatory requirements of this
approach when faced with a priority water quality area approach to
the Construction Grants Priority List under the new *0 CFR Part 35,
and Priority Water Quality Limited Stream Segments under the new
40 CFR Parts 35, 130, and 131 Water Quality Standards Regulations
as well as 305(b) report requirements. The States have expressed
that they have major commitments in place to fulfill obligations
under these various program mandates and are reluctant to reorient
program priorities. All six States have committed to preparing an
updated list for FY 86 and two of the States have included the
process for identifying PWBs in their CPPs.
2. PWB list development is not a statutory nor regulatory requirement.
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Program: Water Quality Management Planning
Activity: Manage Clean Lakes Program and Provide Technical Assistance
Narrative:
New Awards
The FY 85 Clean Lakes funding target for Region V was $535,000. Because the
funding criteria limited FY 85 monies to previously funded Phase II projects
that would be completed with FY 85 funds, only Minnesota applied for these
funds. MPCA requested and received a total of $1,269,381 (217% of the Regional
target) for five projects. The projects funded are listed below:
Big Stone Lake, Big Stone County $404,521
Clearwater River Chain of Lakes
Wright, Stearns and Meeker Counties 238,824
Long Lake, Chain of Lakes, Northern
suburbs of St. Paul and Minneapolis 255,999
Golden Lake, City of Circle Pines 158,871
Lake Como, City of St. Paul 211,166
Clean Lakes Environmental Management Report Strategy
Region V revised the EMR Clean Lakes Strategy to redirect the Regional Clean
Lakes Program toward preventing/reducing pollution problems on site/in the
watershed, before they enter the lake and impact water uses. The Ag NPS
policy was also updated along with this strategy and together, these are the
central portions of the Regional total NPS Strategy.
Technical Assistance
Region V added a new staff person to assist with Clean Lakes technical
assistance, and initiated a technical transfer program to assist the six
Region V states with resolving problems in inland lakes.
Issues:
- Several of the Region v states have candidate lakes for new Phase
I studies. Additional Clean Lakes funds and HO authority to begin
new Phase I studies are necessary to address this need.
- Two Region V states have several Phase I studies that were prepared
with other than EPA Section 314 funds. HQ authority is needed to
fund Phase II projects based on the independently prepared Phase I
studies in Wisconsin and Illinois.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES; Implement the Revised Water Quality Standards (WQS)
Regulation
ACTIVITY; Work With the State to Identify Problems and to Ensure Effective
Implementation of the WQS Regulation
ANALYSIS OF REGIONAL PROGRAM;
Are The States Making Significant Revision To State WQS?
Yes, a significant amount of work was recently accomplished in response to
Section 24 requirements.
Highlights by State:
REVISIONS
TYPE REVIEW
COVERAGE DATE APPROVED
ILLINOIS
INDIANA
MICHIGAN
MINNESOTA
OHIO
WISCONSIN
None
Use Categories
Toxic Protocols
General Refinement
Criteria for
Coventionals ajsd
Toxics
None
Section 24
Comprehens ive
and Section 24
Selective and
Section 24
Selective and
Section 24
Comprehens ive
and Section 24
Limited and
Partial
Section 24
Statewide
Selected
Statewide
Statewide
Statewide
Segment -
3/29/85
11/1/85
3/14/85
3/12/85
Pending
1/23/85
Are The States Encountering Problems?
Each State encounters some problems in meeting WQS review requirements.
Illinois' main problem appears to be one that lies outside the control of
Illinois EPA. Illinois EPA has had to change on its approach to WQS several
times in the past 6-7 years, due to the inability of other State agencies, such
as the Department of Conservation, to complete their assigned portions of the
WQS work on a timely basis. A recent proposal by Illinois EPA to change the
State's internal WQS review process has been prepared and the Region is hopeful
that this will lead to completion of WQS work on a much more timely basis.
Indiana lacks basic resources but accomplishes a great deal given its modest
staffing. Indiana will need assistance as it begins to review the numerous
waters that are designated for less than full swimming recreational uses.
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Michigan also requires assistance in use attainability analyses as evidenced
by the quality of the few reviews completed. Michigan needs to evaluate
numerous waters with less than full swimmable designation. Minnesota is quite
similar to Michigan in this regard.
Ohio does a good job with attainability analyses, but has been slow in
expanding its capabilities in toxic substances and toxic water quality criteria.
Wisconsin has capable staff but has suffered from lack of program priority.
This problem may be solved by recent adoption of a comprehensive WQS review
strategy. The Region will cautiously monitor.
The Region in cooperation with HQ has provided several forms of assistance to
the States. Aside from conference calls and commentary on products submitted,
the following highlight the major events during the first half of FY 85.
0 Headquarters sponsored a workshop in November on "Water Quality Based Permit
Limits for Toxics" which was valuable in relating WQS to the TMDL/WLA
process. Substantial Region V assistance was provided in setting up this
conference; very substantial attendance and participation by Region V staff
and by the staff of Region V States was noted.
0 Region V sponsored and conducted a WQS Workship in December for State
management and technical staff. Headquarters participation was requested
and provided.
0 As a result of the December workshop, a WQS Work Group comprised of State
and Federal officials was formed, and met initially on February 12, 1985.
The group will continue to meet periodically for the purpose of exchanging
information and solving common problems.
0 On February 13, a workshop was conducted by consultants on the topic of new
bacteriological criteria. Representatives of all Region V States attended
and participated.
Are The States Encountering Problems In Defining WQ Limited Segments?
The States Identified Water Quality limited segments several years ago.
However, Region V has asked for updates by the end of FY 85. We anticipate
problems identifying some segments impacted by pollutants where BAT has not
been defined.
ISSUES;
0 Region V would benefit from a clear policy on designating water quality
limited segments where a pollutant of concern has no BAT limits defined.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES; Implement the Revised Water Quality Standards (WQS)
Regulation
ACTIVITY; Undertake Use Attainability Analyses and Include Toxic Criteria
into Standards
ANALYSIS OF REGIONAL PROGRAMS;
Are The States Developing Use Attainability Analyses?
Thirty use attainability analyses were submitted by the States and reviewed by
Region V at mid-year. Over 60 additional reviews are in various stages of
development at the State offices. Because these analyses usually cover waters
that are less than f ishable-swimmable, these reviews have or will be sent to
Headquarters (HQ) for their concurrence. Experience to date indicates that
the Standards Branch staff is helpful and reflective of Regional views. The
Region particularly benefitted from a" HQ decision on the adequacy of the Ohio
attainability analysis for swimming uses.
Highlights by State:
0 Illinois; One analysis was reviewed in draft and final forms covering four
waterways in the Chicago area. As a result of our approval of
this analysis, Illinois has satisfied the Section 24
requirements. The State recently revised the WQS for Deep Run
Creek. This action is waiting formal submission by Illinois
EPA.
0 Michigan:
Indiana; Seventeen attainability analyses were submitted to justify
proposed limited use designation for standards revision.
These analyses are part of the State's program of evaluating
attainability for over 200 stream segments. The State must
also conduct attainability analyses for the Grand Calumet River
and Indiana Harbor Ship Canal and the less than swimmable use
designation applied to most of the intrastate waters.
No analyses were submitted, but the State was advised that many
waterways in southern Michigan require attainability analyses to
support less than full swimming uses. These must be finished
within the next three years, but the State was also informed
that Section 24 does not apply to these analyses.
Minnesota; Three analyses were submitted, but the State has over 200 streams
that require them. The State agreed to a three year review
schedule whereby approximately 70 streams per year will be
reevaluated in FY 85, FY 86 and FY 87.
Ohio : Nine attainability analyses were reviewed within the context of
comprehensive water quality reports. Ohio nevertheless identified
over 60 segments that need analyses as do hundreds of miles of
generic acid mine drainage streams.
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-2-
0 Wisconsin; No analyses were submitted as part of Wisconsin's limited WQS
review package. The state has agreed to a three year schedule
for completing numerous studies on their less than fishable/
Bwimmable waterways.
Are The States Identifying Toxic Problems And Incorporating Toxic Criteria
Into Water Quality Standards (WQS)?
The States vary in terms of their capabilities to identify toxics problems and
in their approach to criteria development.
Highlights by State:
The Illinois EPA is actively developing its biomonitoring capa-
bility. In addition, the State relies on a list of substances
for WQS that have been developed and adopted. These include
metallic toxins and selected pesticides. The State has also
submitted a preliminary package that will update more than
15 criteria for toxic substances.
Indiana has initiated a review of the WQS for the Indiana Harbor
and Ship Canal. This will address about 8 toxic criteria.
Michigan develops site-specific toxic criteria for numerous
substances following the procedures in Rule 57. This Michigan
rule was approved recently and can serve as a model for other
States.
Indiana;
Michigan;
0 Minnesota; Minnesota is currently developing a procedures document for
deriving WQS criteria for toxic substances. The procedures are
well developed and should assist Minnesota PCA's program.
0 Ohio; Ohio has been very effective in using USEPA guidance in updating
15 criteria for metallic toxic substances. The State is behind,
however, in developing criteria for organic toxins a procedures
document is currently in preparation.
0 Wisconsin; Wisconsin has not been active in the review of WQS for toxic
substances. The state has committed to a 3 year plan which will
ISSUE:
yield a comprehensive review.
The Region has not been granted access to the COGENT data base. This data
base has all segments in Region V listed along with use designations. This
computerized data base must be made available in order for Region V to track
segments which are less than fishable/swimmable. There are too many to track
manually.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES; Improve the Effectiveness of Monitoring Activities to
Support Water Quality Objectives
ACTIVITIES; Implement Regulatory Monitoring Programs and Develop TMDLs/WLAs
ANALYSIS OF REGIONAL PROGRAM:
To What Extent are the States Developing Water Quality Based Controls?
The Region received and reviewed 28 draft TMDLs in the first half:
Illinois - 0 Minnesota - 2
Indiana - 1 Ohio - 20
v Michigan - 4 Wisconsin - __1^
TOTAL - 28
In addition to 28 draft WLAs reviewed, Michigan reported the completion of an
additional 63 WLAs for POTWs and industries, and Indiana reported an additional
20 WLAs finished for POTWs. This yields a total reported production of 111
WLAs in the first half of FY 85. The States have reported many additional WLAs
in progress which will be completed by the end of FY 85. Through the delega-
tion of the construction grants program in Michigan it was agreed that only
WLAs for projects of over-riding Federal interest would be reviewed. The Region
notifies Indiana of the need to supply appropriate WLAs and then reviews them as
necessary to conduct permit and/or construction grant reviews.
Are WLAs/TMDLs Being Developed for Toxic Substances?
Of the 28 reviewed by Region V or under review, approximately 30% evaluate
toxics as part of the analysis and load allocate where appropriate. Most of
these substances are metallic toxins. The balance of the WLAs address
conventional and nonconventional pollutants pertaining to POTWs.
Are WLAs for Toxic Substances Based on Biomonitoring?
During first half, no WLAs were submitted based on allocation of toxicity units.
However, biomonitoring was employed in several situations to assess the relative
toxicity of a discharge.
What has Region V Accomplished Regarding the Scott Decision?
The Region obtained input from each of the four affected States. This data was
analyzed with results incorporated into a draft report on Lake Michigan TMDL
requirements that summarized the region opinion. The initial results indicate
that several TMDLs maybe necessary for conventional and nonconventional
substances. The report also identifies several data gaps that preclude a firm
decision on TMDLs for toxic substances. This paper will be fully discussed
during the mid-year visit.
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-2-
ISSUES:
An other potential issue includes the relationship of revised WLAs with the
"anti-backsliding" provision of the permit rules needs to be clarified. In
some cases, new information is available which justifies a revised, some-
times less restrictive WLA for a given discharger. An emerging issue con-
cerns "transferrable discharge allocation" and cluster permits. Wisconsin
is holding hearings on the transferrable discharge approach which essentially
would allow the transfer of loads from one discharge to another when certain
conditions are satisfied. USEPA needs to examine this approach within the
context of "anti-backsliding" and other rules.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Improve the Effectiveness of Monitoring Activities to
Evaluate Progress in Meeting Water Quality Objectives
ACTIVITIES: Improve State §305(b) Report
ANALYSIS OF REGIONAL PROGRAM:
During the first half of FY 85 the Region reviewed all of the State final 1984
§305(b) reports and identified significant problems with the reports, suggested
potential improvements and emphasized the need to use the report as a water
quality planning and management tool. Both Minnesota and Wisconsin have
indicated that they intend to use the report primarily as an informational
document because this purpose best suits their needs while still satisfying
the mandated requirements of §305(b).
In terms of incorporating groundwater data in the §305(b) reports, all States
in the Region included a specific section on groundwater in their 1984 report
some of which included specific data on well closures and quality while other
reports only included narrative descriptions of the State groundwater quality.
Additionally, all State reports contained data and narrative information on
lakes from various sources. Only Illinois made specific reference of data
from a Clean Lakes project. This is not to say that other States did not use
Clean Lakes data, it was simply not cited as such.
The Region is not aware that the States specifically use 305(b) reports to set
monitoring priorities and aid in reduction of permit back logs. It is unclear
to the Region how the type of information contained in the 305(b) reports
would he used to reduce permit back logs. The permit, program is basically
driven by the National priority to eliminate the backlog. Efforts will be made
in FY 86 to ensure that 305(b) reports are used in developing further permit
strategies. In general monitoring priorities are not determined soley by the
existence of water quality degradation but by program needs (i.e., permit
issuance, construction grants, WQS revision which may or may not be indicated
by degraded water quality.
All Region V states currently utilize some type of biological data in their
§305(b) reports. All States include data on fish flesh concentrations for
various toxic pollutants. In addition, Illinois and Ohio include specific
biological data in their reports and their appendices and the other States
conduct some narrative analyses of the health of biological communities. All
States in the Region currently include biological information in their reports
or intend to do so in the 1986 report.
Finally, the Region is attempting to improve the State §305(b) reports by
actively participating in the guidance development and requesting comments from
the States to assure the usefulness of the report to satisfy multiple needs.
To date, all Region V States have provided comments to Headquarters on the
draft §305(b) guidance.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Ensure Commitments to Great Lakes Water Quality
Agreement are Met
ACTIVITIES: Revised Water Quality Standards (WQS) to Determine Impact on
Great Lakes
ANALYSIS OF REGIONAL PROGRAMS:
Proposed WQS changes have been reviewed for all Region V states. As a result
of these reviews, Ohio and Indiana were put dn an accelerated schedule for
revising their WQS as they impact the Great Lakes. Minnesota has been advised
that its WQS for Lake Superior should be made more ijTcljJsjrve and restrictive.
Wisconsin is proceeding with a detailed use attainability~analysis for the
Milwaukee Estuary and Harbor. Michigan adopted Rule .£§57 as the basis for
establishing toxicant water quality criteFTa for all waters including the Great
Lakes.
Region V has identified 10 parameters (toxicants) in Lake Michigan that require
development of specific Water Quality criteria. A program to accomplish this
will be developed in the last half of FY 85.
ISSUES:
F>
The IJC objective for selenium is much more stringent tha;t' USEPA recommended
criteria. Can we defend the IJC objectives on technical grounds?
-------
National Objective: Improve the effectiveness of monitoring activities
Activity: Implement National Dioxin Study in Region V
Analysis of Regional Dioxin Study
Sampling activity has proceeded with limited problems. As of 3/21/85, 871
of national workplan sampling committioents were met, compared with 73%
nationwide. All sampling plans are prepared except for two tier 3 sites
which are momentarily delayed by disputes with the facilities over access.
States are.-participating .in the .Federal investigation and have limited
independent activities of their own, most prominently in Wisconsin . The
expense of chemical -analysis has generally precluded significant activities
outside the federal study.
.4 '
All but 2 of"the 25 Tier 3 and 6 facilities have been sampled, roughly
1/2 of the data is back with one positive finding for 2,3,7,8 - TCDD.
Other isomer data incorporated into the regional study has not yet produced
actionable results.
National Tier 4 sites have been sampled with the exception of incinerator
ash. The region has added extra sites to the ash program as well as the
analysis for scrubber water at a group of sites, using analytical services
to be provided by Dow Chemical as settlement of a consent judgement.
The Region's Tier 5 site is mostly sampled. Additional isomer work will
be done at this site by the Duluth Lab as part of a pilot project.
All of the Region's Tier 7 soil sites have been sampled, no data has been
returned as yet.
•
11 of 80 Tier 7 fish samples have been taken with some results returned,
positive results have been obtained in some Michigan and Wisconsin locations.
Other isomer analysis is intended on all the fish but the contract for
the purpose has not been let. /
Issues
Some difficulties are being experienced in the disposal of barrels' from
tier 3 and 6 sites -m- •".,?,
>v-<~/<
Some delays are of concern for the other Isomer and priority pollutant
contract for tier 7 fish. This is a regional add on to the national
study.
Some delays are being experienced in getting lab data back but nothing
terribly serious thus far.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Improve State Decision-Making for Pollution Control on
Priority Water-bodies
ACTIVITIES: Develop list of Water-bodies Impacted by Nonpoint Source (NPS) and
Implement NPS Control Programs
ANALYSIS OF REGIONAL PROGRAMS:
All States within the Region are updating their priority waterbody list to
include water-bodies impacted by NPS. All the states are using their priority
waterbody list to target special NPS control efforts to such water-bodies. New
priority waterbody lists are scheduled to be submitted in May and June and
used to negotiate FY 86 work plans.
Two of the States (Ohio and Wisconsin) have approved Agricultural NPS
Strategies, 3 States (Minnesota, Michigan and Indiana) are developing NPS
Strategies and Illinois is revising its strategy. Four States are actively
participating in the ASIWPCA project for the "NPS STEP" report. The Region was
involved in the ASIWPCA meeting in St. Paul in January 1985. NPS implementa-
tion activities are occurring within each of the States.
Four States have agricultural cost-sharing programs and one State has/a'
proposed an agricultural cost-share program. Region V States on In average
allocate a lower percentage of their annual ACP allocation for water quality
than the national average. There are five NPS/Clean Lakes demonstration
projects being implemented within the Region.
The Region has prepared a NPS strategy that is consistent with the National
policy. The implementation of the Regional policy is through two EMR strategies
and the Division's work plan. Further work is anticipated to link Clean Lakes
program activities to the NPS efforts and wetland protection program.
ISSUES:
Proposed reductions in ongoing USDA technical and financial assistance
programs may seriously impact NPS control efforts, without some funding
support from USEPA.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Ensure that Commitments to the Great Lakes Water Quality
Agreement and to the Chesapeake Bay Plan are Met
ACTIVITIES: What Efforts are GLNPO/Region/States Making to Ensure Schedule
of Appropriate Activities, Work Plan Development and Interim
Outputs are Provided in a Timely Fashion so that Draft Reduction
Plans can be Completion by November 30, 1984.
ANALYSIS OF REGIONAL PROGRAM:
The Region has provided substantial technical and financial assistance to the
State Water Quality Management Agencies in Michigan, Ohio and Indiana for NPS-
focused water quality monitoring and planning. In addition, the Region has
initiated a cooperative review of USDA program activities in the Saginaw Bay
and Lake Erie Basins.
Regional staff reviewed all Task Force Reports and Draft U.S. Plans in the
alloted timeframe. The Regional staff also provided technical assistance to
states while they were preparing their Phosphorus Load Reduction Plans. The
Water Division is providing staff support to work with the State NPS contacts,
review data and draft reports, analyze the data, and recommend solutions as a
portion of the Region's efforts to develop a Phosphorus Load Reduction Plan.
Two staff people are providing weekly support on this project. (See details
in the GLNPO write-up.)
The Region maintains communication with the State Water Quality Management
Agency, USDA Agencies and local DMA's via a NPS newsletter ("Vth Connection"^,
technology transfer process and responding to requests for technical assistance.
The Regional staff tracks USEPA programs (108a Demonstration Projects, Clean
Lakes Projects), USDA programs and projects including RCWP, as well as
participating on the National NPS Task Force and the ASIWPCA Project.
Water Division staff also provide technical assistance to GLN-PO on the
Section 108a demonstration projects and the Upper Great Lakes Connecting Channels
Study and to Headquarters and the States on the RCWP Projects.
Regional staff has provided each State with a copy of "Model State NPS Program"
and technical assistance upon request.
ISSUES:
There are a number of anomalies^ among the State Phosphorus Load Reduction
Strategies which must be resolved. Insufficient manpower and financial
resources for NPS programs appear to be widespread problems at the State level.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Ensure That Commitments to the Great Lakes Water Quality
Agreement and to the Chesapeake Bay Plan are Met
ACTIVITIES: Assess Municipal Compliance With Objectives of Great Lakes Water
Quality Agreement
ANALYSIS OF REGIONAL ACTIVITIES:
The major activity in this area is the Phosphorus Load Reduction Plan that is
being prepared by the GLNPO. The Water Division is providing staff support to
work with the State NPS contacts, review data and draft reports, analyze the
data, and recommend solutions. Two staff people are providing weekly support
on this project. (See details in the GLNPO write-up.)
The Region maintains communication with the State Water Quality Management
Agency, USDA Agencies and local DMA's via a NPS newsletter ("Vth Connection"),
technology transfer process and responding to requests for technical assistance.
The Regional staff tracks USEPA programs (108a Demonstration projects, Clean
Lakes projects), USDA programs and projects including RCWP, as well as partici-
pating on the National NPS Task Force and the ASIWPCA project.
WatevDivision staff also provide technical assistance to GLNPO on the Section lOBa
demonstration projects and the Upper Great Lakes Connecting Channels Study and
to Headquarters and the States on the RCWP projects.
Regional staff has provided each State with a copy of "Model State NPS Program"
and technical assistance upon request.
ISSUES:
There are a number of anomalies among the State Phosphorus Load Reduction
Strategies which must be resolved. Insufficient manpower and financial
resources for NPS programs appear to be widespread problems at the State level.
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FY 85 MID-YEAR EVALUATION
NATIONAL OBJECTIVES: Ensure That Commitments to the Great Lakes Water Quality
Agreement and to the Chesapeake Bay Plan are Met
ACTIVITIES: Implement Nonpoint Source (NPS) Controls in Lake Erie and Saginaw
River Basins
ANALYSES OF REGIONAL ACTIVITIES:
The Region has provided substantial technical and financial assistance to the
State Water Quality Management Agencies in Michigan, Ohio and Indiana for
water quality monitoring and planning. In addition, the Region as initiated a
cooperative review of USDA program activities in the Saginaw Bay and Lake Erie
Basins.
(See GLNPO write-up for details.)
ISSUES:
The length of time it takes to get end of year information on USDA programs.
Anomalies of program costs and effectiveness among Lake Erie and Saginaw Bay
States (Indiana, Michigan and Ohio).
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NATIONAL DIRECTIONS: Implement the Ground-Water Protection Strategy
ACTIVITY: Implement Section 106 grant program in accordance with guidelines
and FY 1985 budget allocations, monitor State progress, conduct mid-year reviews,
assist States with program management problems, identify innovative and exemplary
State ground water programs and projects for distribution to other States.
Regional Analysis:
Headquarters funding guidance was the basis for Region V's State ground water
guidance. The guidance directed what type of activity Region V would consider
for funding under the Section 106 supplemental, 205(j) and UIC, and served as the
format for the State consolidated work plans.
Initial and supplemental state specific guidances were sent on July 5, 1984, and
August 14, 1984, respectively, to each of Region V's States. Draft work plans
were received from Illinois (2-1-85), Indiana (1-18-85), Michigan (1-25-85),
Minnesota (12-21-84), Ohio (1-8-85), and Wisconsin (2-1-85). State visits and
or telephone conference calls were made to discuss the guidance documents and
to resolve any outstanding issues.
The State ground water program plans were reviewed by the Regional Ground Water
Coordinating Committee (RGWCC) whose membership includes program Directors for
all ground water related programs. On February 4, 1985, RGWCC determined
funding targets and identified priority activities for each State's assistance
application. The States were informed of the decision on February 6, 1985.
Final work plans were received and grant awards offered as follows;
Indiana (2-26-85 $238,656), Michigan (3-13-85 $131,959), Minnesota (2-13-85
$389,770), Ohio (3-6-85 $75,000), and Wisconsin (2-24-85 $270,896). Through
these awards all supplemental FY 1985 106 grant dollars were allocated.
In its February 4, 1985, meeting RGWCC decided not to fund the Illinois assis-
tance application as proposed. Illinois' application focused on the establish-
ment of an ambient ground water monitoring network. The Office of Ground Water
is currently negotiating a work plan with the State that more fully reflects
National and Regional priorities.
Additionally, each State has designated an accountable lead agency which is
responsible for managing the ground water grants. Moreover, the State work
plans contain milestones and due dates for activities and attendant technical
documents.
As a part of each ground water grant awarded, Region V included a Monitoring
and Evaluation Plan (MEP). The MEP calls for quarterly reporting by the
States on 1) the status of each funded activity, 2) programmatic problems and
recommended changes and 3) the impacts of related ground water efforts.
As previously noted, in Region V ground water assistance applications are
reviewed within the context of the National Ground Water Protection Strategy
funding guidance and Regional priorities. Only those activities which lead to
enhancing or institutionalizing a State's ground water effort/program have been
approved for funding. Examples of specific benefits are enhanced data management
efforts, increased public awareness of the State's efforts to resolve/remediate
ground water problems and development of regulatory efforts to address
inadequately or unaddressed ground water problems
-------
Since the grants have just been awarded it is premature to identify
exemplary State programs and projects for distribution to other States.
Internal coordination at the States and delineating specific commitments for
the water protection program were the principal problems which had to be over-
come.
1. Indiana: The Indiana State Board of Health experienced difficulty
in pulling together the appropriate State agencies necessary to
begin developing a comprehensive ground water program proposal.
2. Illinois: Reorganization to establish a lead ground water department
did not occur until the end of the first quarter FY 1985. This
resulted in a significantly reduced effort towards the development
of a viable ground water grant application.
3. Minnesota: The traditional recipient of the CWA 106 funds was not
the designated department for the State's ground water efforts.
Consequently, the designated department experienced difficulty in
dealing with the grant process.
4. Michigan and Ohio: Both States expressed little enthusiasm about
the completion or development of a ground water strategy. They
wanted to focus their grant request strictly on program implemen-
tation without developing the conceptual bases for those activities.
Issues:
Ground water funding guidance needs to be provided to the Regions in
conjunction with Agency Operating Guidance.
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-3-
Detailed State Specific Analysis:
In FY 1984 OGW representatives reviewed the status of ground water programs in
the six Region V states. The results of this review provided the basis for
FY 85 State specific program guidance. Regional program guidance, as well as
National funding guidance directed the type of activities Region V considered
for funding. Grants were issued to all of Region V's states, except Illinois
at or near the end of the second quarter of FY 85. Since the grants have just
been awarded, it would be premature to report on the States' progress.
Illinois:
During OGW state visit, the Illinois Environmental Protection Agency (IEPA)
indicated a need for federal assistance in (1) the establishment of a State
wide ambient ground water monitoring program, (2) development of a computerized
ground water data base management system, (3) improvement of laboratory capability,
(4) site inventory and mapping, (5) and information on other States' ground
water programs. FY 1985 state specific guidance reflected items 2, 3, 4 and 5
since they were consistent with National and Regional program guidance which
emphasized strengthening State program capabilities. The establishment of an
ambient ground water monitoring (Item 1} program was considered to be an
implementation activity, and therefore would not receive funding support.
On February 1, 1985, IEPA submitted a draft assistance application for $360,100
in supplemental 106 funds, to support the purchase of equipment and the hiring
of personnel necessary to carry out an ambient ground water monitoring network.
In its February 4, 1985, meeting, RGWCC decided not to fund lEPA's assistance
application as proposed. The OGW is currently negotiating a work plan with
IEPA that more fully reflects National and Regional guidance. We anticipate
receiving a revised application from IEPA by May 15, 1985, and awarding a grant
by June 7, 1985.
Indiana:
In FY 84 the Indiana State Board of Health (ISBH) used a relatively small portion
of their EPA grant dollars to support ground water activities. ISBH had received
a $26,000, 205(j) grant to fund the development of local ground water controls
by the Elkhart County Health Department and to fund staff in a newly created
Ground Water Unit.
With the establishment of this Ground Water Unit, ISBH's ground water activities
have been directed toward problem assessment. Since ISBH is just beginning a
ground water program, OGW's FY 85 State specific guidance placed a high priority
on the development of a comprehensive ground water strategy. The ISBH assistance
application proposed, and EPA's grant provided, $238,656 in 106 and 205(j) funds
to put into place the staff and the prerequisite documentation necessary for a
comprehensive ground water protection program.
ISBH has embarked on an eight point program which will culminate in the develop-
ment of a ground water protection strategy during FY 1986. The key elements of
ISBH's program are: 1) organization of an interprogrammatic/interagency ground
water coordinating committee; 2) public participation in program development;
3) development of a ground water policy; 4) regulatory analysis; 5) aquifer iden-
tification and evaluation; 6) case studies; 7) evaluation of local ground water
protection programs; and 8) initation of state ground water strategy.
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Michigan:
Historically, more ground water projects were funded under Sections 106, 208
and 205(j) of the CWA in Michigan (almost $2.3 million) than in any other
Region V State. Included in these grants was $939,000 of Section 208 CWA funds
for the Michigan Department of Natural Resources (MDNR) to develop a comprehensive
State ground water strategy.
Due to internal reorganization and a shift in priorities, MDNR did not complete
the State ground water strategy in FY 1984. During its FY 84 State evaluation,
OGW staff received copies of two of the five remaining tasks. However, there
was no indication of any intent to finish the remaining three tasks.
On October 16, 1984, staff from the OGW and the PSS met with Richard S. Johns,
Chief of the Ground Water Division of MDNR. The primary purpose of this
meeting was to secure the completion of the EPA funded State ground water
strategy. At this meeting MDNR agreed to complete Task 21: Final Strategy.
This document, based on the Governor's Cabinet Council report entitled "Ground
Water Protection Initiatives", was submitted on February 18, 1985.
MDNR agreed to complete Task 14: A Compliance and Enforcement Strategy. A
detailed outline was submitted on January 18, 1985, a final product will be
completed by January 31, 1986. At the October 16th meeting, Mr. Johns supplied
EPA with copies of the final Facility Design and Operations report prepared to
fulfill the requirements of Task 13.
The products submitted for completion of Tasks 13 and 21 were reviewed in
light of the agreement reached at the October 16, 1984, meeting. These products
have been accepted in that they minimally meet the criteria established at
said meeting.
MDNR's FY 85 assistance application for supplemental 106 funds reaffirmed the
State's emphasis on remedial action activities. In an application for $888,010,
$756,051 was earmarked for implementation of a State LUST program. The
remaining component called for the establishment of a public information program.
Pursuant to the Assistant Administrator for Water's memorandum of November 21,
1984, RGWCC decided not to fund the LUST component of MDNR's assistance
application. RGWCC did approve $131,959 for MDNR's public information effort.
The OGW is currently working with PSS to develop a strategy which will encourage
MDNR to reexamine its intensive involvement in remedial action activities; a
course of action which has occurred at the expense of ground water program
planning efforts. MDNR has not been receptive to Region V's recommendation
that it increase its program planning efforts. MDNR's position on this issue
stems from the fact that it has sixty million dollars in State funds for
ground water activities. The primary focus of State appropriations is remedial
action not program planning.
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Minnesota:
In FY 84 the Minnesota Pollution Control Agency (MPCA) did not use any of its
106 or 205(j) funds for ground water attivities. During its FY 84 State
visit, the OGW was informed that ground water protection activities are the re-
sponsibility of MPCA's Division of Solid and Hazardous Waste. However, MPCA's
Division of Water Quality administers 106 and 205(j) CWA funds and has committed
these funds to meet surface water program priorities.
Since long term funding for ground water activities was limited, the primary
focus of OGW's FY 85 program guidance was on activities that would enhance ground
water program capabilities. MPCA's Ground Water Protection Strategy Framework
provided the basis for these activities. On December 21, 1984, MPCA submitted its
consolidated ground water program application. On January 14, 1985, RGWCC
decided to fund the development of a data management system, and evaluation
of ground water monitoring programs at waste water treatment facilities, and a
program management component for $389,770. These activities will be accomplished
over the course of 20 months and thus two grants were awarded, one for the
remainder of FY 85, the other for FY 86.
Ohio:
The focus of OGW's interaction with the Ohio Environmental Protection Agency
(OEPA) in FY 85 has been to secure the completion of a previously funded compre-
hensive State ground water protection strategy. The OEPA has received funds
under Section 208 and 205(j) to develop a state strategy. The document
was prepared by the Battelle Columbus Laboratories under OEPA WQM Planning
Grant P005630 (FY 1981). It was reviewed by OGW on August 23, 1984.
OEPA was informed in the August 23rd letter that its ground water strategy did
not fulfill OEPA's commitment under its WQM Planning Grant. Additionally,
U.S. EPA would not consider funding ground water programs in Ohio until a satis-
factory strategy was completed.
As a result of this review, subsequent letters and meetings OEPA committed to
completing the strategy. OEPA would submit a consolidated ground water work
plan/grant application by December 4, 1984. U.S. EPA agreed to process OEPA's
grant application concurrent with OEPA's efforts to complete the strategy.
However, no award would be made until OEPA showed that it was making substantial
progress toward completion of the strategy.
On January 17, 1985, OEPA submitted an "Interim Ground Water Protection Strategy."
This doucument was to function as a framework which would guide the development
of a comprehensive ground water protection strategy. Based on the strength of
this document, it was decided to fund, for $75,000, several of the activities
proposed in OEPA's consolidated workplan.
Ground water data management, program administration, aquifer classification
and public participation activities were funded. These activities are an expan-
sion of existing efforts and would be accomplished over the course of FY 85 and
FY 86 and were awarded as two seperate grants.
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In the same action, OEPA was allowed to incur costs on previously awarded, but
related Section 205(j) funds. OPEA had not been allowed to incur costs against
these 205(j) funds until the strategy issue had been resolved.
The only remaining issue pertains to an OEPA proposed task to do additional
site-specific landfill work and related regulatory development work. The work
program did not describe the level of effort associated with the two phases of
work. OGW was concerned that more emphasis than necessary was placed by OEPA on
the site-specific landfill work rather than on the regulatory development work.
Consequently, a special grant condition prevents OEPA from incurring costs on
this work pending further negotiations.
Finally, in conjuction with this review, Region V on March 18, 1985, allowed
the Miami Valley Regional Planning Commission to proceed with its proposed
ground water work with Section 205(jJfunds.
Wisconsin:
Ground water is incorporated into Wisconsin's Department of Natural Resources
(WDNR) ongoing water planning program. An active 205(j) grant is funding the
preparation of ground water related policies, guidelines and administrative
rules associatd with the State's ground water legislation, and the development
of site-specific and or regional ground water management plans for incorporation
into the "area wide" water quality management plans.
WDNR's consolidated ground water assistance application, for $270,896, corre-
sponded with OGW guidance which encouraged the States to focus on activities
which would enhance broad based program capabilities. Under its ground water
106 grant, WDNR will develop programs which addresses agricultural best management
practices, nitrate sampling, waste water (standards evaluation, data management,
and field inspections) and animal waste management. These activities are
scheduled to be completed by the end of FY 85.
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NATIONAL DIRECTIONS: Implement the Ground Water Protection Strategy
ACTIVITY: Implement the organization and staffing proposal by December 1
in accordance with approved plan, including established coordinating committee
consisting of division director level participants who will engage in specific
substantive review affecting all Regional programs impacting on ground water.
Analysis:
Region V has in place an Office of Ground Water (OGW) as approved by Headquarters,
The OGW is currently staffed with one supervisor, three technical staff and
one secretary. The OGW is responsible for providing staff support to RGWCC.
The OGW coordinates Region V's activities pertaining to inadequately addressed
sources of ground water contamination. It provides the maximum possible
assistance to the States in the development of ground water protection programs.
Also, OGW is responsible for insuring that aquifers or aquifer systems are
afforded formal U.S. EPA recognition as "sole source aquifers."
The OGW is assisted by the Planning & Standards Section (PSS) in the review and
approval of work plans and preparation of grant awards. A MOU was developed
two years ago that details the responsibilities of each group. Essentially,
each State Project Officer in PSS assists OGW on an individual basis to assure
timely grant awards.
Region V has had a RGWCC for approximately two years. The RGWCC has a
charter which is in the process of being re-drafted to reflect the Regional
priorities and requirements under the National Ground Water Protection
Strategy. The RGWCC meets at least once per month.
The RGWCC and Office of Ground Water have identified those principal issues
associated with the National Ground Water Protection Strategy and Regional
ground water priorities. An annual agenda which identifies those issues in
which the RGWCC will be involved throughout the fiscal year has been prepared.
Issues to be addressed include, but are not limited to: MOU's to ensure ground
water coordination among Regional programs, state ground water work planning
efforts, status of legislation (state and federal) and Regional/State priority
sources of ground water contamination.
The RGWCC has established a number of work groups and efforts to facilitate
the development and enhancement of Region V ground water programs in the
area of ground water monitoring, data management, public information and
technical and administrative coordination of related ground water programs.
Issues:
None.
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NATIONAL DIRECTIONS: Implement the Ground Water Protection Strategy
ACTIVITY: Develop Regional work plan or comparable management mechanism.
Analysis:
The OGW is actively involved in the mainstream Water Division Planning
Process. All actions are conducted in the context of this overall
schedule, (see the Planning Process write-up for details)
The Region V ground water work plan represents a realistic approach to
implementing the primary objectives of the National Ground Water Protection
Strategy and the Region V ground water priorities. There are 12 key items
identified in the FY 1985 workplan. The ground water work plan provides
for participation for all ground water related programs directly and through
the RGWCC. This represents 11 program offices. Principal objectives of
the work plan include:
1. Increasing inter-divisional coordination of all ground water related
programs.
2. Increasing inter-agency/institutional coordination of all ground water
related activities.
3. Developing and coordinating public information, ground water monitoring
and data management efforts with States, other Federal agencies and EPA
Headquarters.
4. Working with the States to develop programs, thereby insuring State
participation in preventive and remedial action activities.
5. Providing an overview of EPA financial assistance earmarked to
support ground water activities.
The work plan provides milestones for each key ground water activity and
the progress of implementing these activities are reviewed quarterly by
senior management.
Issues:
Operating guidance should be more definitive in the outline of objectives
for the Regional Offices of Ground Water. As the program becomes more
mature, what direction(s) does H.Q. see the Regional Offices going?
The workload model activities need to reflect actual Regional ground
water issues along with National priorities.
The ground water measures of the evaluation guide should address environmental
concerns.
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NATIONAL DIRECTIONS: Implement the Ground-Water Protection Strategy
ACTIVITY: Protect Aquifers that are Sole or Principal Sources of Drinking
Water.
Analysis:
Within Region V there are currently no designated sole source aqui-
fers. In the first quarter of FY 85 OGW staff met with Oscar Boyea
of the Oakland County Health Department (Michigan) to discuss a pre-
viously filled petition. The Oakland County sole source petition had
been reviewed in FY 84 and returned after OGW determined that said
petition was incomplete.
Oakland County intends to resubmit and therefore requested further
guidance and clarification of proposed sole source regulations, which
was provided at the October 16, 1984, meeting.
Region V is currently reviewing a sole source petition submitted by
the Village of Pleasant City located in Guernsey County, Ohio. We
will be requesting, from the Village, additional information concerning
population, well location, stratigraphic and geologic location and
boundaries of the aquifer and the recharge zone or zones for the aquifer.
Issues:
Based on telephone and written inquiries, there appears to be an increased
public awareness of the sole source provisions of the Safe Drinking Water Act.
The proposed sole source regulations issued in September of 1977 serve as our
yard stick for evaluating petitions and insuring compliance. These regulations
need to be finalized so that the Agency can uniformly implement the sole source
aquifers program.
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FY 85
Mid-Year Evaluation of Region V Water Program
National Objective: Improve the Effectiveness of Monitoring Activities to
Support Water Quality Control Decisions and to Evaluate
Progress in Meeting Water Quality Objectives
Activity: Implement Ambient Water Quality Monitoring Program
Analysis of Regional Program;
Monitoring Strategy
The Final Region V Water Monitoring Strategy was submitted to Regional
Administrator on May 25, 1984. The Region V Water Monitoring Strategy will be
reviewed to assure conformance with the new Headquarters Basic Water Monitoring
Strategy which is due May 25, 1985. A Region V water monitoring work group was
established in first quarter of FY 85 to assure better communication among all
water programs, to surface monitoring needs for the future and to review the
State Water Monitoring Strategies durirtg FY 85. Illinois and Michigan submitted
their first draft Water Monitoring Strategy in late March 1985. Outlines of
their proposed water monitoring strategies were also received from Ohio EPA
and Minnesota Pollution Control Agency. These documents were sent to the
Regional Water Monitoring Workgroup members for comments. The workgroup members
were also asked to review the Final Region V Water Monitoring Strategy for
updates. The workgroup members are to comment by April 15, 1985. Comments will
be coordinated and a meeting will be scheduled in early May to discuss the
comments. Final comments from the workgroup will be sent to the States for
responses.
A brief State Water Monitoring Strategy was included as Appendix I of Indiana's
FY'85 Program Plan. The State of Indiana's letter dated October 19, 1984 in-
dicated that "during our FY'85 negotiations, we agreed that during the fiscal
year, we would review and revise our Water Monitoring Strategy as appropriate."
A comment letter from Region V will be sent to the State for response.
No State Water Monitoring Strategy has been reviewed from the State of Wisconsin.
At the FY'86 program guidance visit on March 21 - 22, 1985, with WONR, it was
indicated that an outline and draft would be forwarded to USEPA during the
third quarter FY'85 to assure completion by the end of FY 85.
Monitoring Data
Monitoring data are used In a number of ways, Including NPDES permitting, estab-
lishing and implementing water quality standards, 305(b) reporting, non point
source Impact, trend analysis, use attainability studies, and toxics evaluations
through biomonitoring.
A description of State's Monitoring activities is described below:
ILLINOIS
The Illinois EPA operates an ambient water quality monitoring network designed
to support the State monitoring needs and the national ambient monitoring
system. The network currently Includes 206 stream stations and 80 Lake Michigan
stations as well as 37 ambient program lakes and 60 volunteer lakes. Forty of
the 206 stream stations are in PWB's (191).
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Data are analyzed by basin for water quality standards violations and trends
for the 305b report to Congress every two years. Percent standard violations
and means are also calculated for each station, and printed along with the
raw data on microfiche. USGS also publishes raw data every year for the pre-
ceding water year.
Data are not available in STORE! within 90 days of the end of each fiscal
quarter because there is a 6 month time lag in the transfer of data from
HATSTORE to STORET. WATSTORE is the USGS computer systems. USGS is under
contract to Illinois EPA to obtain water quality data within the State.
Illinois has had no field activity for intensive survey work during the
first half of FY'85.
Reports have been prepared for 87 facility-related stream surveys, 3 of which
were in PWB's.
Reports were prepared for 85 volunteer lake monitoring surveys, 4 of which
were in PWB's. These were summarized in a state-wide lake monitoring report.
Phase III report was completed for Highland/Silver Lake watershed, a section
208-related project.
A Lake Michigan PWB report concerning 1983 data was completed and distributed.
A basin survey is planned for this summer (1985) on the Rock River.
INDIANA
Since 1957, the State has maintained a network of 92 fixed stream monitoring
stations at key locations throughout the State. Of the 92 fixed stations,
21 are "core stations" for use in the EPA national water quality monitoring
network. Currently, most are sampled monthly. Forty Six (50%) of the fixed
stations are located in priority water bodies.
The Fixed Station Monitoring Network was established to provide basic informa-
tion which would reveal pollution trends and provide water quality data for the
many existing and potential users of surface water in Indiana.
Indiana completed two intensive surveys on Lick Creek at Hartford City, Indiana.
MICHIGAN
Michigan's ambient network consists of monthly monitoring of 43 fixed station
tributary mouths and urban area stations.^ the 43 fixed Stations, 3fi (84%)
are located in priority water bodies. The urban area program is intended
to assess water quality impacts of urban areas. Monitoring is conducted up-
stream and downstream of 11 urban areas. The Detroit urban area network con-
sists of 20 fixed stations sampled on the Detroit River - 10 at the head and
10 at the mouth. The sampling design was intended to allow water quality trends
to be observed and to calculate annual pollutant loads to Lake Erie, particular-
ly for phosphorus.
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Michigan committed to conduct one intensfve water quality field study. To date,
two surveys have been completed on the Kalamazoo River. The purpose of these
surveys were model calibration and model verification. In addition, two
quantitative surveys were completed on Shiawassee River at Owasso.
Michigan committed to 5 water quality site investigations. To date, two site
Investigations have been completed. These were performed on the S. Branch of
the Black River and on Silver Creek.
MINNESOTA
Minnesota maintains 71 fixed network stations; eight of these are on PWBs.
State routinely enters data into Storet within 30 days of receipt from their
laboratory. They have also taken the Lead in Region 1n integrating STORET
with program data system PCS. Eight of the 71 stations are in priority
water bodies (11%).
To date state has completed the following surveys: Four AT justification for
PWB's, nine Use Attainability Studies, three Site-Specific Water Quality Studies
and Four Surveys for WQS/WLA. All in total, Minnesota completed 20 surveys and
seven reports were written for these surveys, nine of the surveys were on PWBs.
OHIO
The State is operating 49 stations. Thirty nine of these are "CORE" stations.
The stations are sampled monthly. Thirty two (65%) are 1n priority water
bodies.
Twenty one field surveys were completed. Four reports were written. Fourteen
of the surveys were 1n priority water bodies.
WISCONSIN
The primary monitoring network, or monthly ambient monitoring.network consists
of 46 stations on significant water courses which document statewide trends of
water quality Improvement or degredation and provide a data base for the
biennial Wisconsin Water Quality Report to Congress. In addition intensive
surveys of limited duration and scope are used to address specific issues
and support permit revision and planning. Categories of intensive surveys
are (1) response, (2) basin assessment, (3) statewide problem, and (4)
specially funded surveys.
Twenty three (23) Intensive surveys were completed. The 23 completed intensive
surveys include 13 point source Impact related and 10 were for stream classifi-
cation. Sixteen (16) out of 23 were also biological in nature. Forty six (46)
fixed stations are operated on a regular basis statewide, with 8 of these
stations on priority waterbodies (17%). Though the majority of Wisconsin's
point source dischargers have met their permit requirements, a select group of
watersheds have been chosen for non point source and toxics Impact.
Biomonltoring Activities
The Region does have a Regional Biomonltoring work plan which Is being imple-
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mented this FY with Region V States participating. Pete Redmon Is Chairman
of the Regional B1omon1tor1ng Committee. The laboratory work Is being done at
the CRL, which consists primarily of AMES tests as well as some static bioassays
conducted at selected Industrial and municipal sites.
A description of biomonitorlng activities for each State 1s given below:
ILLINOIS
Macrolnvertebrate samples are collected at approximately six week intervals
during the summer months on an annual basis. Fish tissue analyses are conduct-
ed biennially during low flow periods at each core network station. No work
has been done in these areas during the first half of the FY. All fish are
collected in cooperation with the State Department of Conservation. This
work is usually done during 3rd and 4th quarters.
There are no biosassay tests completed thus far this FY. Illinois is 1n the
process of developing a bioassay program which 1s projected to be operable
sometimes during FY'85.
Macronlnvertebrate sampling and fish tissue analyses are done at core network
stations. Illinois 1s Involved in a basin assessment program where biological
sampling 1s conducted. This work is done during the summer months (3rd and
4th quarters).
INDIANA
Each core network station is sampled biennially for biological parameters, with
one half of the stations being sampled one year and the remaining half the
following year. F1sh and macroinvertebrate sampling will be completed during
the 4th quarter of FY'85.
Twenty 48 hour static bioassays using daphnia as the test organism have been
completed thus far this FY. Eighteen were from industries and two from muni-
cipalities taken from the "Majors" 11st. No flow-through bioassays are being
conducted. Indiana has also completed four habitat evaluations which included
biological studies.
Fish tissue data are entered directly Into STORET.
MICHIGAN
Michigan does not conduct biological sampling at designated core network stations
except if It Involves a special study. Fish tissue analyses are conducted at
locations where toxic problems are suspected, but not necessarily related to the
core network activities. Fish sampling is conducted during the fourth quarter.
Michigan's commitment to biological work for FY'85 includes 3 flow-through bio-
assays and 20 static bioassays. To date, one flow-through bioassay and all 20
static bioassays have been completed. Michigan has completed four of twenty
full scale biological field surveys and eight of fifty investigations. The re-
mainder will be completed during the third and fourth quarter.
MINNESOTA
Biomonitorlng is not done at ambient sampling sites but State conducts biomoni-
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torlng and toxics on specific aspects of PWBs as part of Use Attainability
and Site-Specific Water Quality Studies. Minnesota is primarily concentrating
its efforts on lake surveys. Fish are collected and analysed for special
toxics program activities in streams, add lakes but not necessarily related to
core network activities. State does not have a routine fish tissue analysis
program at core network stations. Furthermore, state is not doing any biolopical
field surveys or biology at any of the core network stations.
Minnesota has completed 30 static bloassays to date and plans to complete 40
more within 3 to 4 weeks thus meeting their 70 static bioassays committment
for FY'85. State selects one of their five Regions in the State each year and
conducts bioassays at all POTW's and some industries within that Region. .
OHIO
During the first half of FY'85, Ohio completed nineteen (19) 48 hour screening
(static) bioassays and fourteen (14) 96 hour definitive (static) bioassays using
Ceriodaphnia and fathead minnows as test organisms.
Ohio is committed to doing 58 screening tests and 14 definitive tests during
FY'85. They are well on their way to meeting this commitment.
Ohio conducts macroinvertebrate sampling at 15 core network stations. This work
is done during the 3rd and 4th quarters. No fish tissue sampling is done as
part of the ambient monitoring program.
Sixteen biological field surveys for construction grants have been completed.
All samples have been analysed and reports are being written. Reports" are to
be completed in early June.
WISCONSIN
With respect to biomonitoring activities, WONR performs only fish tissue analysis
and only at six "core" ambient stations statewide 1n FY 85 to be completed
during the fourth quarter. The agency, however, presently limited by manpower
and funding constraints, sees an important need to expand monitoring of sediment
and fish in Northern lakes and have requested additional funding from the state
legislature for this expanded capability. It looks very promising for the
biennial budget submitted in June for FY 86-87. This effort would support work
on the Great Lakes, and the Mississippi River for FY 85. The agency attached a
Task Description to the final FY 85 program plan entitled Toxic Investigations
and Evaluations and will be further defined in the anticipated State Water
Monitoring Strategy. Finally, a Wildlife Contaminant Monitoring Program In
cooperation with the DNR and State Lab of Hygiene was established to investigate
accumulation and residuals of agricultural pesticides, PCB's and heavy metal
contaminants in the tissue of selected wildlife. No flow through and static
bioassays are scheduled. Six Intensive surveys which Included biological sampling
were conducted during the first half of FY 85.
Status of QA/QC
Illinois and Indiana have an approved Quality Assurance Program Plan for water
monitoring programs.
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In FY'84 Michigan received approval of selected portions of the QAPP. At this
time, some of Michigan's test procedures for organic analyses are not approved by
the Quality Assurance Office. The areas needing further improvement are: scan
4 for fish tissue analysis, whole fish analysis, and the methodology for phenols.
The deficiencies in organic analysis may impact the total amount of grant dollars
earned by Michigan for FY'85.
Minnesota has an approved Quality Assurance Program Plan for water monitoring
programs. However, State needs to provide laboratory capability to analyze
pesticides and PCBs.
Ohio has approved Quality Assurance Program Plan for water monitoring program.
However, OEPA's laboratory has not developed an acceptable organics capability.
The problem arose because OEPA terminated the contract with the Ohio Department
of Health for organics in water samples. OEPA has since not been able to develop
water organic analysis capability due to staff and resource shortages.
Wisconsin has an approved Quality Assurance Project Plan and at this time has no
major problems with respect to QA/OC procedures.
Laboratory Capabilities
The evolution of the toxic/hazardous programs has generated the need to purchase
sophisticated complex equipment capable of detecting and measuring low levels of
toxic and hazardous substances. This type of equipment requires a high level of
expertise and has generated increased salary demands. These salary demands can-
not be met in some states and is causing the States to lose or not be able to
hire key staff. Some other general problem areas are listed below.
1. The handling of hazardous/toxics samples requires the availability
of a high hazardous laboratory area to prevent contamination and
to meet health, and safety requirements. The cost of these "hot labs"
run from about $100k to $500K. Most State laboratories do not have
the space nor the funding to meet this need.
2. Laboratory automation coupled with automated data management is needed
to improve efficiency on existing procedures and to implement new
procedures. State laboratories are aware of this and some hardware
and/or software is being implemented. If new program are going to be
implemented in the laboratories, this total computerization process
must be expedited.
3. In several States means must be found to increase the salaries of the
laboratory scientists. If the continued lost and inability to hire
qualified scientists cannot be turned around, some state laboratories
will be incapable of operating full environmental laboratories.
4. Most State laboratories are currently operating at close to the maximum
of their usable analytical capacity as defined by space, equipment and
expertise of staff. Generally, the present level of laboratory
capability is probably 50-80% of what programs want. Obviously any
new program analytical needs will tend to increase an already existing
problem. This problem is especially acute in the organic analyses
area.
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Specific State Needs
Illlnofs:
State needs additional organic laboratory space and the new space should
contain a high hazardous laboratory area.
Indiana:
To increase the laboratory out-put of the Water and Sewage laboratory addi-
tional staff is needed.
Michigan:
Additional space is needed to accommodate the laboratory equipment and
personnel. This space should be equipped with a high hazardous laboratory
area.
Minnesota:
Minnesota is currently addressing additional space needs in that some
new space has been acquired. Also, the ventilation system in the
existing lab space is being updated but a problem of having an inbalance
in the incoming air supply may be a major problem.
Ohio:
Both the Ohio EPA laboratory and the Ohio Department of Health laboratory
have an inadequate staffing problem. Recent staff losses at the Ohio EPA
laboratory reflect the problem.
Wisconsin:
State needs PC (computers) to link the automated analytical systems to
the central computer (a systems report will be needed to fully define
this need).
Data Integration
ESD, GLNPO and Water Division have jointly identified monitoring needs and are
working on several items to improve the existing systems.
ESD designed a Fortran program to monitor the Great Lakes Tributary
Stations and parameters of interest to GLNPO. This "Quik-Look" report
which reads an inventory listing as input data provides a one line per
site summary along with a table indicating the parameter analyzed.
. Station identification information includes the primary station number, a
core station Indicator, the agency collecting the sample, the county code,
sampling type, location description, major basin and latitude and longitude.
The sampling summary indicates the last year and quarter the analysis was
performed for each parameter.
ESD wrote a SAS program for GLNPO correlating concentrations of
various metals with aluminum. The outputs will be used in a report.
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ESD created a report to focus on the 0 & M problems experienced by the
POTW with respect to Industrial wastes. This report will be provided
to the Hater Division quarterly.
ESD has established the basic structure for a Water Monitoring Activities
computed file. The purpose of this file Is to facilitate the tracking of
monitoring activities conducted on priority water bodies. The software
package being used In INFORM. INFORM programs are now being developed.
ESD has rewritten the documentation on the Use Impairment Program.
The Use Impairment Computer Program provides an assessment of water quality
based on available data at monitoring stations. This documentation provides
the detailed steps necessary to modify and properly execute the program.
In addition, ESD wrote a SAS program that generates required Input lines;
a detailed account of how to use this program Is also provided 1n the
documentation. In essence, executing the Use Impairment Computer Program
1s a straight-forward process due to the documentation.
ESD 1s currently developing a "Fish Kill Computer Data Base" for storing
and tracking fish km events 1n Region V.
Integration of NPDES Facility information and effluent data with STORE!
using River Reach and Industrial Facilities Discharge Files has continued
especially with respect to Wisconsin, Minnesota, and Illinois. The Statis-
tical Analysis System (SAS) was used to create STORET compatible records
Approximately 1500 Wisconsin NPDES facilities were recently updated to the
system, and the corresponding pollutant discharge information will be
updated when the software is completed.
Operation and Maintenance
The Region solicits nominations for 0 4 M award from each State in October of
each year. From these submissions a panel at EPA, Region V reviews projects 1n
three size categories (small plant < 2.0 mgd; medium plant > 2.0 to < 20 mgd;
large plant >20 mgd), with two types of treatment (secondary and advanced) under
each, for a total of six Regional categories. The results of the review become
recommendations for awards presented to the Regional Administrator. This FY,
the awards will be presented during May and June, 1985. Region V is currently
the only Region In EPA to have a municipal wastewater treatment plant 0 * M
award program.
Problems encountered and approaches for resolving them
The "Issues" section (page 9) of this report Identifies the major problems,
concerns, and short comings facing Region V States in Implementing their
Hater Quality Monitoring programs. The overriding limiting factors in bringing
about stronger programs are (1) need for additional laboratory equipment and
space, especially to handle Increased loads in bi onion 1 tor ing and hazardous
materials analyses; and (2) need for additional personnel to fill critical
skills areas to accomplish the need in item (1) above.
Recently, the Central Regional Laboratory through a contract with ICF Contractors
of Washington D.C. has completed , or is in the process of completing a compre-
hensive laboratory assessment of all Region V State laboratories. Data gathered
-------
-9-
from these assessments will be valuable tools in providing added emphasis in
negotiating with Federal, state and local governments for better laboratory
programs.
Some Region V States have expressed an interest in developing the capability to
run Ames tests. The Biology Section of the Central Regional Laboratory is pre-
pared to conduct training sessions at the CRL as the need arises. Illinois, for
one, has expressed an Interest in receiving this training.
Another area of concern is in data integration as it relates to the Management
of Water monitoring data. The Environmental Services Division's Water Monitoring
Team has contributed much in this area as discussed on page 7 and 8.
Illinois, Michigan, and Indiana have submitted their draft Water Monitoring
Strategies. Region V will be sending comment letters in May 1985. Ohio has
submitted an outline and will submit a draft strategy by the end of April, 1985.
Minnesota has also submitted an outline and plans to complete a draft strategy
by early June 1985. Wisconsin indicated that an outline and draft would be
forwarded to USEPA during the third quarter FY'85 to assure completion by the
end of FY'85.
Issues
0 All the States committed to a water monitoring strategy for FY 85, yet only
three States have submitted draft strategies.
0 The QA deficiencies regarding organic chemical analysis must be resolved
prior to FY 86.
0 Ohio's QA program will have to be expanded in order to Include increased
laboratory capability. The QA project plan will have to be expanded to
reflect newly added organic analysis responsibilities which was previously
performed by Health Department Labs.
0 The Federal-State "partnership concept" Involves the U.S. E?A delegation
of environmental programs to the States. While the programmatic aspects
of this delegations rely on the States' management capability, programs such
as RCRA, CERCLA, (Superfund), SDWA (Drinking Water), and the other standard
environmental program covered by the 106 and 105 Grants require extensive
laboratory capability. Laboratory capbllity needs can be delineated in terms
of space, personnel, and equipment needs. The major problem is that the
programs analytical needs have Increased without commensurate growth in
equipment, space, and personnel.
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FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
National Objective; Improve Performance of Completed Facilities
Activity: Improve Facilities Performance
Regional Analysis:
Qualitative Measure (A-l): Are States effectively implementing on-site
training and technical assistance programs for bringing small facilities into
Improved compliance?
Qualitative Measure (A-2): Are States conducting annual on-site O&M reviews?
Overall the six Region V States are doing a good job of implementing on-"site
operator training. The FY 85 work plans were developed by each State to address
the national guidance. State-by-State summaries are:
Illinois
Illinois conducts regular on-site 04M reviews of completed facilities. Utilizing
the EPA Form 7500-5, they have completed 52 Inspections thus far in FY 85, with
their commitment being 55 inspections. These were completed at major municipal-
ities, mostly on PWB's.
Illinois also has a substantial program for inspection of minor municipal WWTP's,
construction grant compliance inspections, and operational assistance.
Overall, Illinois has an effective O&M program.
Indiana
Indiana conducts regular on-site O&M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have completed 13 inspections so far in FY 85, with the
commitment being 15 inspections. These were completed at major municipalities,
mostly on PWB's.
«
Indiana also has a substantial program for inspection of minor municipal WWTP's,
and operational assistance. The construction grant compliance inspection pro-
gram shows minimal activity, but the Corp of Engineers performs additional
Inspections.
Overall, Indiana has an effective 04M program.
Michigan
Michigan conducts regular on-site O&M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have completed 14 inspections so far in FY 85, with the
commitment being 15 inspections. These were completed at major facilities,
mostly on PWB's.
-------
Michigan also conducts Inspections at minor municipalities, a few construc-
tion grant compliance inspections, and operational assistance. A short-coming
of the Michigan program is that most of their field inspection resources are
used for 24-hours sampling surveys with little or no evaluation of the O&M
of the plant surveyed.
Michigan should devote more resources to O&M inspections, with less resources
for 24-hr, sampling surveys.
Minnesota
Minnesota conducts regular on-site O&M reviews of completed facilities.
Utilizing EPA Form 7500-5, they have met their commitment of 25 inspections
at major municipalities, mostly on PWB's (thru second quarter FY 85).
Minnesota also has a substantial program for inspection of minor municipal
WWTP's, construction grant compliance inspections, and operationaT'assistance.
Overall, Minnesota has an effective O&M program.
Ohio
Ohio conducts regular on-site O&M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have met their commitment of 50 inspections at major
municipalities, mostly on PWB's (thru second quarter FY 85).
Ohio also has a substantial program for inspection of minor municipal WWTP's,
and operational assistance. The construction grant compliance inspection
program shows minimal activity, but the Corps of Engineers conducts additional
inspections.
Overall, Ohio has an effective O&M program.
Wisconsin
Wisconsin conducts regular on-site O&M reviews of completed facilities, but
they refuse to use EPA Form 7500-5. Utilizing narrative reports with EPA
Form 3560-3, they have met their commitment for 25 inspections thus far in
FY 85, mostly major facilities on PWB's.
Wisconsin also has a substantial program for inspection of minor municipal
WWTP's, construction grant compliance inspections, and operational assistance.
Wisconsin is the only State in the Region to make commitments for intensive
operational assistance studies. They have exceeded their commitments for
6 such studies thus far in FY 85.
Overall, Wisconsin has an effective O&M program.
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Qualitative Measure (A-3). In regard to operator training. Are the Regions/
coordinating the operator training, technical assistance, construction grants.
permits and enforcement program?
The Regional 04M program consists of three separate parts located in the
Municipal Facilities Branch and Water Quality Branch of the Water Division
and in the Environmental Monitoring Section 1n the Environmental Services
Division. The work activities are coordinated through the Chief of the
Water Quality Branch, who implements the Regional Operations and Maintenance
Trocedures established in May 1983. This memorandum delineates the specific
responsibilities for all Involved programs (Construction Grants, Permits,
Compliance, Great Lakes National Program Office and Environmental Services
Division). The Region solicits nominations for 04M awards from each State
in October of each year. From these submissions a panel at EPA, Region y
reviews projects 1n three size categories (small plant < 2.0 mgd; medium
plant > 2.0 to < 20 mgd; large plant > 20 mgd), with two types of ^treatment
(secondary and advanced) under each, for a total of six Regional categories.
The results of the review become recommendations for awards presented to
the Regional Administrator. This FY, the awards will be presented during
May and June 1986. Region V is currently the only Region in EPA to have
a municipal wastewater treatment plant O&M award program.
The Regional office makes operating training grants to the State agencies
in order to enhance the activities funded by either the States (109(b)
funds) and/or USEPA (Section 106 funds). The grants awarded under Section
104(g)(l) to the State during FY 84 and FY 85 are summarized on the table
below. The Section 104 grants have been used as supplemental funding to the
States to augment Sections 106 and 205(g) activities. This has happened due
to the delayed availability of funds over the past several years. The
Regional coordinator of the technical portion of the O&M awards is located
1n the Compliance Section in the Water Quality Branch. The coordinator is
assisted by the Planning and Standards Section in the preparation of grant
awards.
During FY 85 the following resource distributions were made by the States.
IL IN MI ' MN OH WI
WY
Section 106 $1000
WY
Section 205 (g) $1000
Section 104(g)(l) WY
(FY 84 funds) $1000
10.6
599.6
6.0
242.4
1.2
75.0
1.75
49.9
0
0
1
75.0
0
0
0
0
I
75.0
4
20.90
3
154.0
1
50.0
265
11.6
0
0
+
50.0
0
0
4.92
245.0
+
50.0
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Mid Year Evaluation of Water Programs
National Direction: Ensure that commitments to the
Great Lakes Water Quality Agreement are Met
Introduction
Oversight of U.S. commitments resulting from the Agreement are the primary
responsibility of the Great Lakes National Program Office (GLNPO).
Implementation of programs to achieve the commitments is the joint
responsiblity of several federal and state agencies, but in large part rests
upon the Water Divisions in EPA's Regions II, III A V. GLNPO's implementation/
direct operational responsibility is for monitoring of conditions in the
Lakes. The coordinative arrangements between GLNPO and Region V Water Division
are summarized in the memorandum of agreement between the two organizations.
A discription of GLNPO's programs and strategic directions are contained in
the Great Lakes Strategy. It includes the Great Lakes monitoring strategy
which is also reflected in the Region V monitoring strategy. Water Division's
programs and strategy directions are set by national policies and strategies
such as the National Municipal Policy. Further detail on objectives and
activities is contained in the GLNPO and Water Division FY '85 work plans.
Areas of Concern require special comment. Areas of Concern (AOC) designation
has been given to the geographic areas of the Great Lakes basin which continue
to contain nearshore and estuary waters where beneficial uses are seriously
impaired. All of the areas involve the permit program; most involve the
construction grant program, and most involve a large number of other EPA
programs. The importance of addressing pollution problems in the AOC's is
gaining increasing recognition by both state and federal agencies. For
example, all of the AOC s within Region V are now included on the States
Priority Water Body lists. There is also an increasing awareness of the need
for action plans that define the problems and clearly describe the key steps
needed to solve them. This is reflected by the IJC Water Quality Board's
recent revision of the classification system for AOC's to focus on
progressive stages from problem definition to full remediation. Also, the
Board has asked the states to identify dates by which remedial action
plans will be completed. A table listing the areas and projected dates
is attached. GLNPO plays a major role in the development of the new AOC
system. In order to assist the states in preparing the plans, GLNPO is
providing consultant support through contract. In preparation for the
effort, prototype plans have been prepared for the Indiana Harbor/Grand
Calumet and Rouge River areas using consultant assistance.
The Rouge River plan is being coordinated with the Upper Great Lakes
Connecting Channels study which includes the Rouge and three binational
AOCs: the St. Mary's, St. Clair and Detroit Rivers. The study Includes
both intensive ambient work on the rivers and remedial action plans.
Preparation of all plans is being coordinated with the preparation of
305(b) reports and water quality management plans.
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Mid Year Evaluation of Region V Water Program
NATIONAL DIRECTIONS: Ensure that Commitments to the Great Lakes Water Quality
Agreement are Met
Activity: #1-6 OWOGAS Great Lakes Basin Program
1. Areas of Concern (AoC): All of the Areas of Concern were listed in the Priority
Waterbody Lists of Region V States for 1985. This includes one
each for Minnesota (St. Louis River), Illinois (Waukegan Harbor), and Indiana
(Grand Calumet River/Indiana Harbor Canal), four each in Wisconsin (Fox
River - So. Green Bay, Sheboygan, Milwaukee Estuary, Menominee River) and
Ohio (Maumee River, Black River, Cuyahoga River, and Ashtabula River) and
fourteen for Michigan (Torch Lake, Deer Lake, Mainistique River, Menominee
River. Fox River/So. Green Bay, Sheybogan, Milwaukee Est., Saginaw River/Bay,
Clinton River, Rouge River, Raisin River, St. Mary's River, St. Clair River,
and Detroit River), for a total of 24 in Region V. There are an additional
six Areas of Concern in New York and seventeen in Ontario, Canada. Revised
waterbody lists were sent to the GLNPO for review and comment, as they were
received from the States. GLNPOs comments regarding omissions were
brought directly to the States' attention or through the State Project
Officers located in Water Division , who ensured that the GLNPO comments
were brought to the States' attention. The States cooperated by amending
their Priority Water Body Lists.
Actions taken by the Great Lakes National Program Office to ensure that the
Areas of Concern were considered and that priority activities to abate
problems are underway in these locations are:
A. Support for the Water Quality Programs Committee in its re-evaluation
and reclassification of the IJC Areas of Concern. This reclasification
over-came the difficulties of the previous classification - lack
of specificity in classification guidelines and data interpretation,
data gaps, and the slowness of environmental systems to respond to
remedial measures.
B. The Office was also instrumental in obtaining commitments from the
States to submit Category 4 (Causitive factors known and Remedial
Action Plans developed, but remedial measures not fully developed)
plans for review by June 1985, and to make commitments to submit
plans for other Areas of Concern as soon as ongoing studies are
completed.
C. GLNPO also participated in the Niagara River Toxics Committee and
provided funding to support the activities of this Committee.
D. Initiated and provided leadership to the binational, multi-agency
Upper Great Lakes Connecting Channel Study, which is a special study
to better identify problems and remedial actions for the connecting
-------
channels, which encompasses 3 AoC's (St. Mary's River, St. Clair
River and Detroit River.) This major study at present has a
budget of 5 million dollars and participation by 12 agencies and
the City of Detroit. It is a major work commitment for GLNPO.
Two prototype remedial plans have been prepared. Water Division
took the lead in the development of a Master Plan for the Grand
Calumet River, coordinating the overall work with the GLNPO and
the State of Indiana local environmental groups. GLNPO is also
providing input to the U.S. Army Corps of Engineers (Chicago
District) research to study the dredging, disposal and management
of highly contaminated sediments, so that more information about
the proper means of handling and disposing of highly contaminated
dredged materials in the Great Lakes becomes available. The locus
of this study will be the Indiana Harbor.
A second prototype AOC plan has been prepared for the Rouge River
in Michigan. It is in draft form at present.
Nonpoint Source Control: (1) Supported and participated in the
development of the United States Plan for Phosphorus Load Reductions
from Nonpoint and Point Sources on Lake Erie, Lake Ontario and
Saginaw Bay. Regional input was provided for this major effort. A
draft of the report is now available and the plan will be submitted
to the International Joint Commission in May 1985. (Affects
Saginaw Bay, Maumee River, Black River and Cuyahoga River). (2)
Supported Tillage Demonstration Project in 31 counties of Lake
Erie Basin (Affects all Lake Erie Areas of Concern). (3) Supported
the Saginaw Bay Monitoring and Evaluation Project and Defiance
Tillage Projects, major studies of agricultural phosphorus controls
as related to tillage changes (Affects Saginaw and Maumee AoC's).
(4) Supported phosphorus fertility management study in several
counties of the Saginaw Bay drainage area (Affects Saginaw Bay AoC).
(5) Supported development of a phosphorus budget and longterm Bay
model for the Fox River/Southern Green Bay Area of Concern. (6)
Supported nonpoint source loading evaluations and hi-flow monitoring
in the major tributaries of Lake Erie and for Saginaw Bay (Affects
all four Lake Erie AoC's and Saginaw Bay AoC). (7) Supported Answers
Model Evaluation and Development, affecting the Fox River/Southern
Green Bay and Milwaukee Estaury AoC's in Wisconsin as well as
other Great Lakes areas where ANSWERS model applications are
anticipated - ( affects the Maumee AoC and Saginaw AoC). (8)
Finally, the Office supported a demonstration project in the Lake
Ontario Basin which relates phosphorus fertility management on
muck soils to phosphorus discharges to the Lake (affects to Rochester
and OSWEGO AoCs-).
-------
G. CSO Control: (1) The GLNPO funded and managed CSO control demon-
strations, using best management practices and in-line storage in
Cleveland AOC and the Saginaw River - Bay AoC working with ORD in
technical oversight. (2) GLNPO negotiated a CSO study with the
Water Division for a full evaluation of issues in the Grand Calumet
River/Indiana Harbor AoC. The study was conducted by the Water
Division's LOE EIS contractor and technically managed by teh GLNPO
project officer.
H. Toxics Assessments: (1) Laboratory results and data analysis
completed for nearshore fish, with reports to be published by
close of FY'85 for all AoC's (2) Cooperated with EPA ORD on
study of toxics and failures in fish reproduction in the Fox River
(Green Bay). (3) Negotiated (with Water Division assistance)
fish trend monitoring in Waukegan Harbor AOC. (4) Published
results of sediment sampling in numerous AOC's. (5) Convened an
interagency meeting on coordinating activities and providing
funding for a study of potential removal of in-place pollutants in
the Sheboygan River and Harbor.
I. TOXICS AND NUTRIENT ASSESSMENTS, LAKE SURVEYS: Conducted trend
analysis of Lake Michigan, Lake Huron and Lake Erie Open Waters
through interpretation of annual surveillance data for chemical
contaminants, trophic status, microbial contaminants, radionuclide
contaminants and biological community and habitat status. GLNPO
also supported toxic trend monitoring of Open Lake Fish, (according
to elements #3 and #4 of the Great Lakes Fish Monitoring Strategy)
and cooperated with the National Dioxin Survey.
J. Provided for contractor assistance for States in preparing AOC
remedial action plans.
Actions taken by Water Division to ensure that priority activities to abate
problems in Areas of Concern include operation of the national baseline grant
and regulatory water programs throughout the Great Lakes basin. Some specific
activities are summarized below.
A. WLAR's: The Regional staff maintained oversight on the develop-
ment of the WLAR for the Grand Calument River/Indiana Harbor Canal
AoC.
B. PERMITS: Sixty-six Great Lakes associated permits were reviewed
by the Region in connection with issuance/reissuance of major
permits over the first two quarters of FY 1985. Of these 66
permits, 28 (42%) were targeted for streams/harbors associated
with Areas of Concern, an increase over the number reviewed at
this time last year (when 21 permits were reviewed for AoC's. All
of the necessary permits have been reissued in three AoC's.
-------
(St. Louis River, and the Rouge River and St. Mary's River in Mi.)
Overall eighteen Areas of Concern benefitted, at least partially,
from State permit revisions, as tracked and reported by the Water
Division. For key dischargers GLNPO provided review and technical
support. In some cases Water Division referred permits for review, in
others, GLNPO made special requests to ensure review. Cooperation has
been good, but GLNPO has been able to devote only very limited work
effort to this area during FY '85 and '85.
C. PRETREATMENT ACTIVITIES: Regional pretreatment reviews/actions affected
19 of the 24 Areas of Concern, at least partially, as reported by the
Water Division's special tracking of "special interest cities". Two
AoC (Sheyboygan, Wisconsin, the Black River, Ohio) are benefitting from
completion of the pretreatment-permit issuance process. There was a
very substantial improvement in the amount of pretreatment work done in
the State of Michigan over the past six months, which affects the 12
Areas of Concern in that State very positively. This improvement was
due in large part to the Region's dedicating considerable time and
effort and resources for training MDNR staff, in connection with a
legal suit brought by environmental groups which sued for dedelegation
of the Pretreatment Program from the Michigan DMR and back to Region V.
D. CONSTRUCTION GRANTS: Construction is progressing on key facilities
in four Areas of Concern (Grand Calumet River/Indiana Harbor, Fox
River/Southern Green Bay, Milwaukee Estuary, and the Saginaw Bay/River
System). Sixteen additional AoC facilities have high construction
grant priorities, and most of these are well into the process of facilities
planning. (The affected AoC's include: Menominee River, Michigan/
Wisconsin, St. Clair River, Clinton River, Rouge River, Detroit River
and Saginaw River in Michigan; the Maumee River, Black River, Cuyahoga
Rivers in Ohio.)
E. GROUNDWATER CLEANUPS: Two cleanups are in progress in Areas of Concern
- Menominee River, MI and White Lake, MI.
F. SUPERFUND: A superfund project proposal for cleanup of PCB's in Waukegan
Harbor has been published, heard at public hearings, and has been
accepted by Headquarters and the Illinois EPA. Because site access has
been denied by the landowner, (s^erf uodjripni^s_^£ebei ng reallocated
and imjgTjmjejvyition has been i mfeTtnfte Ix cfiOjy~edT71>up^
¥eerT involved inTnTETar"praffnTTigjT6r'"the St. Louis Bay, MN., Sheyboygan, WI
and Milwaukee Estuary Areas of Concern.
G. RCRA: Regional on-site inspections and cleanup of hazardous waste
dumps have occurred at two Areas of Concern - Ashtabula, Ohio, and the
Grand Calumet/Indiana Harbor in Indiana.
2. Review Revised Water Quality Standards to Determine Impact on Great Lakes:
In the past six months the Great Lakes National Program Office has reviewed
the proposed water quality standards changes from five States - all except
Illinois. In each case, the Office recommended changes in toxic substances
-------
standards. Water Division sent these recommendations to the States, asking
for comments or clarification regarding GLNPO's recommendations. Two
statelyffetognized the need to revise their toxics standards Ohio and Indiana.
These states were put on an accelerated schedule for revising the toxics
standards. Evaluation of the proposed Minnesota water quality standards
changes led the GLNPO staff to recommend revision and improvement - that
the water quality standards for Lake Superior needed to be more inclusive
and restrictive. The GLNPO staff is awaiting Minnesota's response to these
recommendations and expects to be actively involved in evaluating the
proposed revisions to the Lake Superior water quality standards for toxic
pollutants. Wisconsin is still in the process of developing its Toxic
Substances Strategy, consulting with the GLNPO and Water Division as its
works on the Strategy, as well as in the development of a use attainability
analysis for the Milwaukee Estuary/Harbor. Michigan submitted Rule 323.1057
as the basis for its toxic substances water quality standards, which were
accepted, pending clarification from the IJC as to whether the concentrations
in water are consistent with requirements of the 1978 Water Quality Agreement.
3. Assess Municipal Compliance jn'th Objectives of the Great Lakes Water Quality
Agreement: There are currently 205 major dischargers in Region V which dis-
charge to the Great Lakes. Of this number, 34 dischargers need to construct
facilities to meet the 1.0 mg/1 phosphorus requirement. Two dischargers in
Indiana, East Chicago Municipal STP and Portage Municipal STP, have con-
structed facilities but are not meeting their final limits of 1.0 mg/1
phosphorus. Thus, 169 major dischargers are in compliance with the IJC
phosphorus requirement - for a compliance rate of about B2%. Of the 36
major dischargers in noncompliance with the IJC requirements, U.S. EPA has
taken action against five and the states have taken action against an
additional six dischargers. Furthermore, ten of these noncompliant dis-
chargers have been issued permits or orders where they are under con-
struction. These permits/orders place the facilities on a fixed date
schedule requiring them to meet the 1 mg/1 phosphorus requirement by at
least July 1, 1988. The remaining 15 dischargers are being tracked by the
Compliance Tracking Unit during monthly/bi-monthly calls to the States to
determine the most current compliance status. These facilities are also
reviewed during the quarterly compliance report evaluations and file audits.
Dischargers that are not actively moving to meet the phosphorus requirement
will be surfaced through these procedures and considered for Federal enforce-
ment action.
During the past several years, significant phosphorus dischargers to the
Great Lakes have been tracked by the Compliance Tracking Unit. Over this
time period, 23 major dischargers have been moved off of the CTU tracking
report, as they have come into compliance with IJC requirements. The major
reason for these facilities coming into compliance was that they had completed
construction of phosphorus removal and/or sludge handling equipment.
Additionally, two of the facilities ceased discharge, as the treatment plant
was closed when the influent lines tied into regional facilities.
-------
At the request of GLNPO, Water Division established and maintains a list
of the 30 municipal STP's that would provide the largest reductions in
phosphorus if brought into compliance. These 30 receive special monitoring
and prompting toward compliance.
Overall during the first six months of FY 85 compliance remained about the
same as last year. Minnesota and Wisconsin continued to maintain their
100% compliance record. Indiana continued to have three noncompliant plants
(Valpariso, East Chicago, Portage), Michigan added one noncompliant plant to
the "Dirty Thirty" special tracking list - Saline, while Ohio improved
slightly with the dropping of Lake County-mentor, which has consistently
achieved 1 mg/1. Illinois industrial dischargers continued to meet permit
limitations.
Action which the States are taking to reduce NPS loading to the Great Lakes
include:
Illinois: Encouraging the local regional planning agency to obtain
implementation of the Lake County construction erosion controls
in nine cities and villages in that county.
Indiana: Participated in Great Lakes Phosphorus Task Force; developed
State Plan to achieve reduction in Lake Erie loadings.
Michigan: Participated in Great Lakes Phosphorus Task Force; developed a
State Plan to achieve reduction in Lake Erie and Saginaw Bay
loadings. The State has constructed with two regional planning
agencies to develop a statewide nonpoint source strategy, one
for urban and the other for rural areas. The State is also
cooperating with local agricultural agencies in developing
erosion control/water quality elements for several sections of
the Upper and Lower Penninsulas.
Ohio: Participated in the Great Lakes Phosphorus Task Force and developed
a State Plan to achieve reduction of phosphorus in Lake Erie
loadings. The State also cooperated with local planning and
agricultural agencies to identify critical areas and develop
abatement plans and initiate implementation of these plans.
Minnesota: Minnesota is developing a statewide nonpoint source abatement
element for its Water Quality Management Plan.
Wisconsin: Wisconsin has a viable, active nonpoint source control program
in place, funded by the Wisconsin Fund. Over the past six months,
the State has been evaluating the ANSWERS model as a management
tool for this nonpoint nource control program.
4. Implement the Great Lakes Monitoring Program: GLNPO assures that the Great
Lakes monitoring program is being implemented by the States through quarterly
receipts of Quik-Look data summaries received from Environmental Services
Division. Inspection of the Quik-Look data for State monitoring stations
-------
and parameters analysed. (ESD volunteered this service and wrote the
Quik-Look program after GLNPO provided tributary names, station numbers and
parameters desired.) GLNPO is checking to determine whether resources
are being used for trend monitoring when it checks the Quik-Look retrieval
for tributaries, station numbers and parameters analyzed. Detection of
emerging problems usually is not provided by monthly tributary monitoring
reports. Rather it comes from fish flesh analyses obtained through
implementation of the Great Lakes Fish Monitoring Strategy and the annual
fish flesh collections. Element Number 4 relates to collections for
toxic contaminant trend analyses, while Element Number 3 relates to
collections for toxic contaminant emerging problem analyses. The States
agreed to the Great Lakes Fish Monitoring Strategy by signing agreements
drafted by the GLNPO.
The results of tributary monitoring conducted in the past few years show
that tributary loadings are higher than anticipated, given the load
reductions reported by the POTW's. The causes of the discrepancy may
have been due to unmonitored phosphorus loading from (1) POTW bypasses;
(2) lack of CSO controls; (3) data quality problems associated with some
analytical laboratories; and (4) phosphorus processing and removal by the
sediments in the rivers.
The results of the atmospheric deposition network are not conclusive
because only 1981 data are available. Analysis of the 1982 atmospheric
deposition data is being conducted during Spring 1985, and results are
likely to be released in June 1985. GLNPO is undertaking a major analysis
of the Great Lakes Atmospheric Deposition Network.
The results of recent lake surveys indicate that the open waters of Lake
Superior, Lake Michigan, and Lake Huron are oligotrophic with localized
areas of degradations in several nearshore areas. Remedial programs for
reducing phosphorus loadings attributable to sewage treatment plants have
resulted in a substantial decrease in total phosphorus loadings to Lake
Erie. Total phosphorus loadings from all sources have decreased by 56%
over the last 15 years, and annual mean total phosphorus concentrations
in the surface waters of the central basin have declined approximately
44%.
The open waters of Lake Ontario showed an average decline of 1.0 ug
P/L/Yr since 1970, raising expectations that the target concentration of
10.0 ug P/L will be reached in 1986. Loading reductions in Lake Ontario
are also due to POTW performance and decreased loadings from Lake Erie,,
For complete analysis of trends for several nutrients and contaminants
in the Great Lakes, please refer to Chapter 4 of the Water Quality Board
Report for 1985.
-------
5. Implement NPS Controls in Lake Erie and Saginaw River Basins; Efforts
which the States and GLNPO are making to ensure NPS implementation include:
various State plans to track agricultural land use changes and implementation
of BMP's; tracking plans contained in the U.S. Plan; GLNPO's support of
a demonstration project utilizing remote sensing to track changes in
conservation tillage implementation; and GLNPO's support to Ohio DNR to
identify cost-effective tracking systems, using existing data bases.
Results of NPS implementation will be modeled to determine changes in
water quality Improvements, and annual/periodic surveys will be utilized
to check the predictions of the models. ^ • ' ' ,g ^'
Ohio EPA gives this estimate of the number of acres in the Lake Erie Basin
with BMP's in place from 1983 and 1984 as:
6. Prepare Phosphorus Load Reduction Plans for Lake Erie, Lake Ontario and
and SaginawJSay*Drafts of the "U.S. Plan for Phosphorus Load
Reductions from Non-point and Point Sources on Lake Erie, Lake Ontario
and Saginaw Bay" and the detailed "Task Force Report" were submitted to
Headquarters during April 1985. The final versions of these reports will
be completed in May.
The States generally enlisted aid from other institutions in the State to
expand their staff: Michigan relied heavily on the senior staff of the Soil
Conservation Service; Indiana relied heavily on faculty at Purdue University;
and OEPA relied for help on Ohio DNR. GLNPO assigned a staff detail to the
work and obtained expert assistance to aid in developing the full U.S. Plan
as well as writing the summary of the U.S. Plan. GLNPO also relied on Water
Division staff for assistance.
-------
FY85
Mid-Year Evaluation of Region V
National Objective; Implement the Section 404(b)(l) Guidelines
Activity: Review and assess the environmental impact on Public Notices
for permit and refer those projects for evaluation where the
COE/EPA disagree.
Analysis of Regional Program;
The Region receives approximately 1500 public^ notices a year from (9) Corps
of Engineers Districts. All public notices are reviewed and comments prepared
and submitted in accordance with applicable regulations. The response time vary
between 15, 20, and 30 days from the COE publication of the public notices. Due
date for responding was met 90% of the time. The Region was successful 89% of
the time in convincing the COE to incorporate EPA's comments and/or recommendation
in permit decision on all public notices reviewed.
SPMS Reporting
The tables below depict the actions that have been taken through the reporting
period.
PUBLIC NOTICES THAT WERE RECEIVED AND RESPONDED TO
DURING THE REPORTING PERIOD
I OCT| NOV| DECl JAN| FEB| MAR| APR| MAY|JUNE|JULY| AUG|SEPT
RECEIVED
CUMULATIVE
RESPONDED
CUMULATIVE
1
TOTAL
1
TOTAL
1381
1
129|
1
69 1
207 |
67|
1961
801
287|
78|
274|
104|
39l|
80 1
354 1
1091
5001
82 1
436|
911 1
591| |
64| |
500| |
till
1 1 1 1
1 1 1 I
1 1 1 1
NUMBER OF UNRESOLVED §404 PUBLIC NOTICES FROM PREVIOUS QUARTERS
WHICH RAISED SIGNIFICANT ISSUES
CARRY OVER [1st QT. [2nd QT. I
] 53 | 32T
These numbers will vary based on the COE ability to issue or deny applications for
permits. The resolution to these applications are reflected in the monthly reports
Region V receives from the COE. These reports are received one month behind.
-------
ACREAGE OF WETLANDS IMPACTED BY ACTIVITIES WITH SIGNIFICANT EPA INPUT
Acres of Wetlands Pro-(Acres of Wetlands thatIThe Percent Reduction in Acreage
posed to be Filled by I EPA has Recommended be I Filled that would Result from
Applicants [Permitted to be Filled I Implementing EPA's Recommendation
233.28 Acres
I
31.54 Acres
I
86%
(Acres of Wetlands Per- |The Percent Reduction in Acreage
jmitted to be Filled by I Filled that Resulted from the
I the COE JCOE Issued Permit.
33.35 Acres
85.7%
Status On AID Program
WISCONSIN
EPA and COE have signed and distributed the public notice initiating AID for
all primary environmental corridors in the SEWRPC area on March 4, 1985. The
identification process should be completed by May 4, 1985, and we expect to
find that all primary environmental corridors are unsuitable for the disposal
of dredged or fill material. We have already received support from USF&WS
and BLM.
ILLINOIS
Twenty-nine sites were found unsuitable for filling under AID in Lake County.
The comment period closed on February 6, 1985, and EPA and COE will prepare
and maintain a final Basis and Record of Decision for those sites. However,
IDOT (DWR) raised an objection to the process and asked for a meeting with
EPA and COE to resolve differences. Dave Beno will arrange the time and place.
The earlist tentative date for all partipants to meet is May 21, 1985.
Aerial surviellance of Me Henry, Cook, Kane, Du Page and Will Counties
was conducted on November 15 and 16, 1984, by Tom Glatzel. Photos and list of
sites were turned over to Dave Beno. He will prepare a Public Notice for these
sites as soon as possible.
INDIANA
The survey of Kosciusko County is complete, and all AID participants on the
site visits had reached tentative agreement on a list of suitable and unsuit-
able sites and the language of the Public Notice. However, the management
level of the Louisville COE District objected to the inclusion of the entire
Tippecanoe River and we are now attempting to resolve this disagreement.
MINNESOTA
A request to OFA for funds to designate the Savage Fen as unsuitable under
AID was denied for FY85. They may reconsider for FY86. We also asked Gene
Wojcik about EOY FY85 EIS funds. We discussed focusing AID on major wetland
systems adjacent to lakes that may play a part in WQ control. MDNR is
interested, as is USF&WS and St. Paul COE.
-------
Status On State Delegation
A draft of the final revised State regulations were completed on March 28,
1985. As an on-going policy, we have discussed assumption of the 404 program
with each State. A special effort was made with the State of Minnesota regarding
assumption of the 404 program in the first quarter, however the State advised that
they were not interested in the assumption at that time. The reason is that they
have taking on other initiatives that requires all of their attention. On August 1,
1984, Michigan became the first State in the Nation to receive Federal authority
to administer and enforce within its boundaries the Clean water Act (CWA) Section
404 program. Since the assumption of the 404 Permit Program, EPA has received
26 public notices for proposed projects to review and evaluate. All public
notices were coordinated with U.S. Fish and Wildlife Service and COE for their
input. The Region has conducted an audit on January 23, 1985 on the State
program and found no irregularities in their operation. The State submitted
their Annual Report with an analysis of their program. Our analysis indicates
that Michigan has an acceptable program.
-------
FY 85
Mid-Year Evaluation of Region V Water Program
Nat ional Objective: Improve NPDES Program Management to Reduce Backlog of Expired
Major Permits and Issue Major NPDES New Source and New
Discharge Permits
Activity: Issue/Reissue Industrial and Municipal Permits
Analysis of Regional NPDES Permit Programs:
A Regipnal Summary
In Region V, all NPDES permit issuance programs are delegated to the States and
FY 84 and FY 85 Regional program guidance emphasizes the need for substantial
reduction of the major permit backlog by the end of FY 85. State projections for
reissuing industrial and municipal permits received and State commitments are being
tracked. State programs are monitored closely and technical assistance is being
provided as resources allow. The following is a summary of commitments and
accomplishments.
Cumulative Total 2nd Q 3rd Q 4th Q
Category P A % P A % P A %
Industrial (127) 80 (91) 63 (72) (194) (292)
Municipal (122) 98 (102) 80 (84) (180) (250)
Total (249) 178 (193) 71 (78)
* Includes "no permits required (NPR)" determination
For the second quarter the major municipal backlog was reduced by 102 permits, 84%
of the 122 permit commitment. The 102 permits included 98 reissued permits and 4
that were reviewed and officially determined to be no permit required (NPR). Three
States, Illinois, Indiana, and Michigan, issued at least 100% of their major muni-
cipal commitments. The major industrial backlog was reduced by 91 permits, 72% of
the 127 permit commitment. The 91 permits included 80 reissued permits and 11
NPRs. Michigan also achieved 92% of its industrial commitment, the highest of all
the States, with 24 permits, which included 21 reissuances and 3 NPRs. Refer to
Table 1, Monthly Status Report For Major Industrial and Municipal NPDES Permits,
period ending March 31, 1985, for analysis of Regional and State permit activities,
Attachment 1.
The difference between the Regional commitments to Headquarters and accomplish-
ments, and those of the States, is due to Headquarters reluctance to credit NPRs.
Since such NPRs reduce the backlog, we are crediting NPRs for the States. We have
also raised this as an item to be resolved as soon as possible with Headquarters.
(See April 15, 1985, memorandum from Sutfin to Prothro, following the table and
graphs) State and Regional commitments for FY 85 included some NPRs. The slight
difference between projected accomplishments for Headquarters (Part A) and the
States (Part B) results from allowing Michigan to reduce its mid-year commitments by
one industrial and four municipals and to increase its third quarter and fourth
quarter commitments. The change was so slight that the Headquarters commitment was
never revised.
-------
2
Of the 193 permits processed, 77 (40%) were in priority water bodies.
Other Significant Accomplishments
• Detailed evaluations of State NPDES permit programs were conducted in Indiana on
December 5-6, 1984, Wisconsin on December 10-12, 1984, and Illinois on
January 13-14, 1985. Written reports were transmitted to Illinois, Indiana and
Wisconsin.
• The Permits Section is utilizing the IBM/Personal Computer to track State permit-
ting commitments. This information is being used in monthly conference calls
with the States and in written reports to identify progress.
• The EPA Industrial Technology Workshops, conducted with Headquarters and Regional
staff, were held for Ohio (January 29-30, 1985), Michigan (February 5, 1985),
and Illinois (February 20-21, 1985), and Indiana (April 17, 1985) to cover areas
of effluent guidelines where States are expected to have questions. These
meetings were well attended by State permit writers. Wisconsin and Minnesota
were not scheduled because of no outstanding guideline issues.
• JRB contract assistance has been provided to help the Ohio EPA to draft five
major industrial permits. JRB assistance was also obtained to help Minnesota
draft a permit for the 3M Chemolite Plant. Region V's EDO is also providing
technical permit drafting assistance to Ohio.
• A grant was obtained for Michigan DNR to enable the State to start a chronic
biomonitoring program addressing toxicant controls in NPDES permits. A similar
grant for Wisconsin is expected in April. The Region expanded its biomonitoring
capability from 1 W.Y. to 3.5 W.Y.
• The Region raised concern to Headquarters regarding proposed regulations that
would establish an additional mixing zone (zone of initial dilution (ZID)). The
Region's comments were largely instrumental in modifying the policy so that it
is now considered acceptable.
• A number of face-to-face meetings have been held with the States to address
policy and procedure issues to better address toxicants and reduce administrative
problems. This has resulted in better quality and quantity of permits (Wisconsin
municipal toxicant strategy, Ohio water quality toxicant issues, etc.). The
Region has worked with Wisconsin to revise their toxicant water quality permit
strategy, Wisconsin is now addressing organic and other industrial toxicants in
municipal discharges. This will result in toxicant limitations and special
monitoring requirements being established for most major municipal discharger
permits. This joint policy resulted from the Region's previous proposed veto of
the Milwaukee permit. The new policy has also tightened the State's industrial
limitations policy.
• Regional Combined Sewer Overflow (CSO) policy activities ongoing. Initial CSO
draft policy completed 9-30-84, and subsequently revised. (Revised draft to
State on 1-9-85, for this review. Several States are utilizing permit reopening
clause until CSO-Bypass Policy is finalized and approved by States. All States
except Illinois and Michigan responded. Michigan has committed to respond after
April WRC meeting. Illinois has review underway and comments expected soon.
CSO policy will be discussed during meeting in May with States.
-------
• Permit Section is working with Planning and Standards Section on Water Duality
Standards work group that includes State representatives.
NPDES PERMITS
Response to Questions in Qualitative Measures for Mid-Year
1. FY 85 Regional Guidance to the States focused on issuance of NPDES permits that
limit the discharge of pollutants, including toxicants, to navigable waters to meet
water quality and technology based requirements as soon as practicable and on the
elimination of the backlog of expired major permits in FY 85 and reissuance of
permits consistent with priorities, deadlines in national policy, guidance and
regulations. A State/EPA mutually agreed major dischargers list was available
prior to the start of FY 85. All States except Illinois, submitted schedules, with
named facilities, for drafting, public noticing and reissuance by month or fiscal
quarter. These were entered into the Permits Section IBM/Personal Computer and are
being tracked. Illinois submitted only the number of permits it will issue each
month. State commitments are being tracked and include monthly conference calls
with permitting and pretreatment staff to update status and resolve issues impacting
permit issuance. Letters assessing progress are sent to the State Directors and
staff routinely.
It is anticipated that most of the major permit backlog will be eliminated this
year. There will be an agreed upon permit carryover in two States, Ohio and
Michigan. Because of the tremendous workload it is anticipated that water quality
and other issues will arise that may prevent the issuance of some permits. However,
the Region will continue to actively work with the States to reduce to a minimum
the backlog while continuing to ensure the quality of permits.
Each major permit is reviewed by the Region prior to issuance by the States for
consistency with Federal and State requirements. Usually, the Region works with
the States early to assure that all significant water quality toxicant and other
issues are addressed. However, at times, policy or technical differences have
occurred. A misunderstanding arose in Ohio concerning use of water quality
standards to develop toxicant limits. Coordination with Water Quality Standards
Section resulted in several telephone conversations with State staff followed by a
conference in Columbus that appears to have resolved the issue. Similarly,
Wisconsin was not fully addressing toxicants in municipal permits. We then worked
with them to develop a municipal toxicant strategy which they are now implementing.
We have asked Minnesota for additional justification for four permits on matters
dealing with design flow, and limits less stringent than those in the previous
permits. State progress is mixed. State-by-state and mid-year evaluations are
covered in Attachment 2. Because of the large number of permits to be issued,
continuing effort is needed by each State to draft, public notice and reissue
permits to meet FY 85 commitments. Any new activity or competing activity reduces
the limited resources available for the State permitting effort. All EPA programs
must be careful not to identify new activities in FY 85 that take away the already
limited State effort devoted to permitting.
Minnesota and Ohio are being provided contract support, Headquarters and Regional,
to help develop permit conditions. However, Ohio contract assistance has been
discontinued because the contractor developed permits that did not address water
-------
quality toxicant issues. All other States decided not to use EPA contract support.
There is a feeling in these States that the amount of time and effort required in
working with the contractor and the resultant product is not worth the effort.
Some States asked that the contractor staff be assigned full time to the State.
This could not be accommodated.
States are utilizing biomonitoring, special chemical analyses and other monitoring
requirements and reopening clauses in permits to surface and confirm toxicant
discharge problems which need to be controlled. The States have or are increasing
their staffing and efforts in this area. Along with the previous static monitoring
they and we are developing and implementing the capability to conduct chronic
biomonitoring tests and in addition to do limited Ames or other tests to try to
surface mutagenicity problems. Presently five of our States are doing biomonitoring
on a routine basis at selected sites. Major effort is being focused on the muni-
cipal toxicant problem through pretreatment program development and implementation.
The focus is on toxicants outside the national priority pollutants that may
cause local water quality problems. The existing national monitoring strategy has
not been of assistance since it has very little focus on emerging problems.
Hopefully, proposed revisions will rectify this.
The Region and Headquarters Industrial Technology Division staff conducted State
specific training sessions for four States that needed help in addressing questions
regarding implementation of the guidelines. These workshops were very effective in
moving the permit issuance process. The States are issuing permits where guidelines
are issued and utilizing limited BPJ to cover parameters not addressed by guidelines.
However, the States, in general, have been reluctant to move ahead to utilize BPJ in
the organic chemical or other industries where BAT has not been issued. We would
suggest that because of the highly complex nature of the organic chemical and
related industries that the most reasonable way to move forward would be to turn
guideline information over to the States/Regions and have them develop site specific
BAT/BPJ. Headquarters guidelines staff would provide technical assistance.
Generally, the States are incorporating the new secondary treatment definition,
case-by-case, at the time of reissuance rather than by permit modification. Several
cases of potential backsliding have been identified. The backsliding regulations
are vague in some cases, such as "new information", and open to several interpreta-
tions. States are continually reminded to develop fixed date schedules for
municipalities consistent with the National Municipal Policy. Some of the
municipalities have objected to complying with the NMP without federal financing
and litigation is expected; therefore, their permits cannot be issued as projected.
Issues: Headquarters needs to recognize that in pressuring the Regions and States
to reissue permits that they must also address quality, as well as quantity. We
have been told by dischargers with facilities in other Regions that Region V and
its States are requiring more than other Regions in the control of toxicants.
They report that others are not fully addressing toxicants unless they are covered
by effluent guidelines and certainly are not looking at human health implications.
The Headquarters draft permit toxicant strategy is a good strategy. We would like
to see a more active role by Headquarters in assuring that all Regions are addressing
toxicant issues and not just focusing on acute toxicity. We do not want to place
our dischargers, both direct and indirect, at an undue economic disadvantage.
-------
2. Activity: Issue/Reissue General Permits
The Regional strategy for FY 85 has been to assist States in obtaining general
permit authority where needed and utilize general permits to reissue minor permits
without impacting the issuance of major permits or pretreatment activities. All
States were provided with guidance and sample permits. Michigan and Ohio must
first take legislative action to amend their laws before they can issue general
permits. The Region and Headquarters assisted Michigan by funding a contractor
study on the necessary revisions to the State's rule to allow issuance of general
permits. The first phase was completed; however» additional work on general permits
has been postponed until FY 86 because of the press to reissue major permits.
Michigan is expected to need contract assistance in FY 86 to develop needed
legislation and regulations. Ohio also received the same type of assistance and
the contractor has reviewed the State's statutory authority. There is a need for
additional Headquarters funding to continue work in Ohio. Illinois received
authority to issue general permits on January 4, 1984, but has not issued any to
date. Indiana has statutory authority but,the Region has been unable to get the
State to submit a program modification to date. The Wisconsin general permit
modification was processed and is awaiting Headquarters approval (submitted on
2-1-85) which is overdue and expected shortly. The Region has been working with
Minnesota. A draft request was reviewed and the State is expected to submit a
formal program modification in the fourth quarter of FY 85.
Issues: Need for Headquarters contract assistance
3. Activity: Conduct Evidentiary Hearings
There are no EPA evidentiary hearings pending in the Region since all programs are
delegated. FY 85 guidance to the States required expedited processing of permit
hearings affecting major permit issuance. EPA provided supplemental Section 106
funds to Michigan ONR to hire a hearing officer to help reduce the backlog of
permits under litigation. To date, no State other than Wisconsin has cited
scheduled or ongoing hearings as a serious impediment to reissuing any specific
majors. There is a reluctance among the States to go to hearing; however, because
of the large amount of staff time required to negotiate and resolve permit issues.
Wisconsin has had to divert resources to work on the Scott Paper, Owens Illinois
and Milwaukee MSD hearings.
Issues: None
4- Activity: Review and Approve/Deny Variance Requests
The Region has been working with the States and Headquarters to process variance
requests that impact major permit reissuance. A summary of variance requests is
shown in Attachment 3.
Issues: The 301(g) variance process has been very resource demanding, the format
for Headquarters approval revised and several major permit reissuances delayed. We
are updating several of our previously submitted 301(g) variances utilizing the new
format. We understand Headquarters is considering the delegation of approval
authority for 301(g) variances to the Regions. The Regions supports this effort.
-------
TABLE 1
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APR 2 2 J985
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NUMBER OF PERMITS
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NUMBER OF PERMITS
(75
-------
2 2
NUMBER OF PERMITS
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APR i-
NUMBER OF PERMITS
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APR 2 2 193S
NUMBER OF PERMITS
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NUMBER OF PERMITS
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APR 2 2 1335
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NUMBER OF PERMITS
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NUMBER OF PERMITS
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APR 2 *
NUMBER OF PERMITS
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-------
APR 2 2 1985
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
OAT* AP* 5 1966
Reducing the Backlog of Major NPDES,
Permits and FYJWj SPMS Commitmej
Charles H./ut,
Director, we^er Division (5ft
Martha Prothro, Director.
Permits Division (EN-336)-
In our negotiations with the States, we clearly defined that our goal was
to eliminate the backlog of major permits by the end of FY 1985. State
and Regional commitments, except for a few, generally reflect that goal.
At the beginning of the year, States reported that a few of the majors
may not require permits (NPR) because they may have been required to
cease discharging or to connect to some other facility and would thus
have eliminated their discharges. We directed the States to make certain
that either the discharge was eliminated or that a permit was reissued in
FY 1985. Therefore, State/Regional commitments include a few major
permits that will become official NPRs in FY 1
-------
2 2 1985
NPDES INDUSTRIAL PERMITS
WO-1
WD-2
WD-3
WC-4
Region
Z
EPA
NPDES
States
XI
EPA
NPDES
States
III
EPA
NPDES
States
rv
EPA
NPDES
^-Stales
V ^"v
EPA )
NPDES /
x^StateV
VI
EPA
NPDES
States
VII
EPA
NPDES
States
VIII
EPA
NPDES
States
IX
EPA
NPDES
States
X
EPA
NPDES
States
NATIONAL
EPA
NPDES
States
Total
10/1/84
BaMline
•Expired By
BOY 84 85
53
63
15
182
0
209
17
157
333
99
15
1
11
7
40
59
40
251
1050
11301
56
104
20
200
0
222
30
172
353
108
24
1
21
9
47
60
43
284
1186
1470
I 1st
Quarter
Target Actual
5 3
12 5
0 6
29 10
1 0
46 14
4 0
42 17
42 35
10 3
5 7
0 0
0 2
0 0
10 3
2nd
Quarter
(Cumulative)
Target Actual
13
30
0
60
5
77
10
79
127 80
20
™
13
3rd- *
Quarter
(Cumulative)
Target Actual
27
42
0
107
5
106
18
110
194
35
17
0 0
1 10
1
11
0 1 9
2 3 13
20 13
188 81
20fl 94
58
411
464
1
12
14
25
100
4th
Quarter
(emulative)
Target Actual
56
51
5
156
5
137
25
135
292
60
21
0
10
2
13
1
19
27
1
172
842
1014
-------
JS05
NPDES MUNICIPAL
WO-5
WD-6
wrv
WD-9
II 10/1/84 I
1 ItaMlirw I
Region j j
{•expired By j
• BOY 84 85
I 1
EPA 61 82
NPDES (I
States 25 93
II
EPA 3
NPDES
States 148
m ||
EPA 1
NPDES
States 9fl
IV
EPA 14
NPDES
.States 69
'Y. ^
EPA \
NPDRS I
^ States/I 1 224
vi "-• 1 1
EPA 95
NPDES
States
VII
EPA
NPDES !
States 55
VIII
EPA 22
NODES [
States 27
IX
EPA 11
NPDES
States || 37
£ 11
EPA 20
NPDES
States 35
NATIONAL
EPA 227
NPDES
States 718
1
Total 945
8
229
1
213
33
111
«
263
1 1st 2nd 3rd
| Ouarter CXarter Quart
j (Cumulative) (Cunula
f _ Target Actual Target Actual Target
15** 11
5 0
' 0 2
34 16
1 0 0
34 22
5 0
35 27
-
61 37
175 25 10
•» — •»
106 24 24
26
32
13
53 1
35 47
36 56
0 0
70 122
0 0
82 131
12 18
[ 65 90
122 96 180
50 75
43 5*
659 10
I
8 4 10 13
1 0
33 4
1
27 1 3
44 6 2
3*5
1144
1509
2 3
37 42
8 12
10 19
53 31 llfi 165
240 126 475 709
293 157 591 «74
4th
er" * Ouarter
tive) (Cumjlative)
Actual Target Actual
60
78
3
175
1
P«
25 ;
1
101
25n
I
130 i
P2
11
13
4
47
19 i
i
20 '
253
i 1
942 ;
1
1195
-------
FY 85
Mid-Year Evaluation of Region V Water Program
National Objective: Provide National Direction and Assistance to the Pretreatment
Program
Activity: Establish and Overview Local Pretreatment Programs
Analysis of Regional Program: All pretreatment programs are delegated to the States
except in Illinois and Indiana. In these two States, a cooperative agreement has
been worked out whereby these States review and public notice proposed program
approvals which are formally approved by the Region. In FY 85 Regional guidance
emphasized program approvals as a first priority effort and permit modifications to
include approve programs as a secondary effort. State activities are monitored
closely and assistance provided where necessary as resources allow. The following
is a summary of commitments and accomplishments.
Cumulative Total 2nd Q 3rd 0 4th Q
Category P A % P A % P A %
Non-403 States (35) 29 83 (57) (95)
403 States (65) 6£ 102 (138) (230)
Total (100) 95 95 (195) (325)
For the second quarter, the delegated States and EPA approved 89 pretreatment
programs and completed 6 referrals for a total of 95, achieving 95% of the second
quarter commitment to Headquarters. In addition to the 95 programs processed, 10
applications were reviewed and determined not to require pretreatment programs.
Also, at the end of the second quarter, a total of 38 programs had been public
noticed as approvable but not yet approved. Refer to Table 2, Pretreatment Program
Status Report for Period Ending March 31, 1985, for analysis of Regional commitments
to Headquarters (Part A) and State commitments to Region (Part B), and Table 3
Summary of Pretreatment Activities, Attachment 1. State-by-State mid-year
evaluations are covered in Attachment 2.
The difference between Part A and Part B results from requiring States to process
as many programs as possible early in the fiscal year to assure the greatest chance
of accomplishing end of year commitments to Headquarters. It should be noted that
end of year commitments for Parts A and B are identical at 325.
Of the 95 pretreatment programs fully processed 60, (63%) were in priority water
bodies.
Other Significant Accomplishments
• A considerable amount of time and resources has been devoted by Headquarters,
Region and State relative to NWF's suit over our delegation of the pretreatment
program to Michigan in June 1983. A public hearing held in Lansing on January 29,
1985, was attended by 30 individuals representing industrial, municipalities,
environmental groups and MDNR. The Regional staff in coordination with Headquarters
staff have reviewed the comments and prepared an Action Memorandum for the
Regional Administrator, requesting concurrence by Headquarters, to approved
-------
Michigan's pretreatment program. The Michigan program was reconfirmed by the
Regional Administrator on April 16, 1985, and that decision is scheduled to he
published in the Federal Register on April ?6, 1985.
• On November 19 and 20, 1984, the Region held its first Pretreatment Program
Implementation Seminar. This Seminar was attended by over 350 people representing
local, State and Federal agencies, industries, and consultants. Compilation of
the evaluations completed by the attendees resulted in an overall rating of "good"
to "very good".
Response to Questions in Qualitative Measures for Mid-Year
Establish and Overview Local Pretreatment Programs and Establish State Pretreatment
Programs
A. Of the 123 local programs approved to date, all incorporate categorical standards
into their legal authority documents. However, industries must comply with the
applicable pretreatment standard that is the most stringent. Consequently, what we
have found (in most cases) is that local limits are more stringent and became the
enforceable standard under Section 307(d) of the Act.
Problems encountered with evaluating baseline monitoring reports and compliance
requirements vary from State-to-State. The major problem we have found is the lack
of available resources and time to conduct detail review and follow-up on these
reports since the first priority is to get all local programs approved and secondly,
modification of NPDES permits to incorporate approved program conditions. Contract
funds are needed to supplement our efforts for this activity.
Quantitative Measures EiPA *States
2(a) # of Categorical Determinations Made 5 ?1
# of Removal Credits Applications Received 5 9
*NOTE: Final approval cannot occur without FPA's concurrence.
B. The Region is the Approval Authority for Illinois and Indiana. All remaining
States (Michigan, Minnesota, Ohio, Wisconsin) have been delegated this authority.
Audits have been conducted and more are planned for the third and fourth quarter
of FY 85.
If a program is denied, the Region/State may allow the city additional time to
remedy the deficiencies or we initiate the appropriate enforcement response.
Each situation is evaluated on a case-by-case basis.
After a local program is approved, an informational notice prusuant to 40 CFR
403.11(e) is issued for a 1 day period. The NPDES permit for that City's program
is subsequently public noticed and issued to include the conditions of the approved
program. Some of our States (Indiana, Wisconsin) have concurrently public noticed
the program approval action with the permit notice action to conserve resources and
time, as well as enhancing the enforceability of the program immediately.
-------
Local audits by the Region and State of approved programs have been, and will be,
conducted to ensure effective enforcement activities are being implemented by the
cities. To date, very few audits have been conducted by the Region/State. However,
several are planned for the third and fourth quarter of FY 85, provided no travel
constraints or other issues prevail. Contract assistance would be ideal for this
activity.
NOTE; No C. and D. in Mid-Year Evaluation.
E. Problems we and our States encounter with the review of categorical determi-
nations, PDF variances, removal credit requests, net gross request, and sulfide
waivers are the lack of available resources to conduct timely reviews; lack of
review guidance for these requests and the large number of requests required to be
processed.
F. In Region V, the impediments to local pretreatment program approvals vary from
city-to-city; however, the major impediments are:
1) enacting local sewer use ordinances is a very lengthy process;
2) local limits are not adequate and require more work before approval can be
made;
3) multi-legal agreements are not adopted; and
4) program procedures are deficient.
G. Contract support for development and review of local program is not extensively
used in Region V. However, the limited support we have received in Michigan, Ohio,
and Minnesota has been adequate.
H. Criteria for review of local pretreatment programs has been established with
all of our States and this criteria has served in development of National Guidance
to other States, Cities, and Regions. This criteria is consistent from State-to-
State and we confirm and ensure consistency via Regional audits of State and local
programs. In addition, we confirm and ensure consistency in technical and adminis-
trative requirements for local programs via Regional/State audits.
Issues: There is a need to revise the number of pretreatment programs in SPHS WO 18
from 370 to 336 for FY 85 to account for cities that have been determined not to
require programs. This matter is discussed in more detail in the April 1?, 198B,
memorandum from Sutfin to Prothro, subject FY 85 SPMS Municipal Pretreatment
Commitments, following graphs, Attachment 1.
?.. Activity: Establish State Pretreatment Programs. (Approve NPDES State Program
Requests and Overview Program Implementation).
a. Program Approvals and Modification for Pretreatment
All States in Region V have full NPDES permit and pretreatment programs except
for Illinois and Indiana. Although the Region did not make a formal commitment
to approve the Illinois and Indiana pretreatment programs in FY 8B, the Region
has been working with these States to help them submit complete applications
which can be approved. See Table 4, for tentative schedule for delegating
pretreatment programs in Illinois and Indiana, Attachment 3.
-------
A complete program application was received on March 29, 1985, fron Indiana.
The Region has been coordinating its review with Headquarters staff to resolved
any remaining issues and begin the public notice process. Public notice is
anticipated in early July with approval possible, if no significant public
comments are received in September 1985.
The Illinois EPA is now expected to submit a draft application in June 1985.
It is anticipated that with timely coordination with Headquarters, Region and
State, Illinois could submit a complete application by September 1985, which
could be then taken to public notice.
Issues: Although not confirmed from the Indiana Attorney General Office, it
appears that the State lacks the necessary authority to seek and assess criminal
penalties for industrial users noncompliance with pretreatment standards. If
the statute requires amendment, then it will be difficult to fully authorize
the 403 program to Indiana by September 30, 1985.
b. Overview NPDES State Program Implementation
As a first step to ensuring that approved States are implementing the programs
and are upgrading regulations revisions, the Region is conducting formal
evaluations of State permit and pretreatment programs in FY 85. These evaluations
consider the universe of facilities requiring permits and pretreatment programs,
the adequacy of resources to operate these programs and the technical quality
of issued permits and approved pretreatment programs. They also help to identify
potential statutory or regulatory problems. Three States, Illinois, Indiana
and Wisconsin, have had their NPDES permit program evaluated. The remaining
three States will be evaluated in the third and fourth quarters. Also, for
four States, Illinois, Indiana, Michigan and Ohio, a general evaluation of the
pretreatment program has been conducted. The two remaining States will be
evaluated in the third and fourth quarters. These evaluations will be used to
move into the second and more detailed phase of State program evaluations for
statutory and regulatory authority. For FY 86, a key State performance measure
is to have States assign responsibility and conduct program authority reviews
of their NPDES programs and submit findings or certify to EPA Region that
programs are current and consistent with Federal laws and regulations. Where
necessary, States must take appropriate action to obtain adequate authority.
We are also asking States to identify the extent of procedural consistency with
Federal law and regulations, identify changes to State laws and regulations
where necessary, and develop schedules for obtaining adequate authority. Even
though authority may be consistent with Federal requirements, States are asked
to identify and take action to implement improvements to facilitate operation
of their programs.
Issues: None. The Region will be coordinating with Headquarters to assure
these reviews are conducted consistent with National procedures.
-------
TABLE 2
PRETREATMENT PROGRAM STATUS REPORT FOR PERIOD ENDING MARCH 31. 1985
,. REGION'S FY
Category
85 PRETREATMENT APPROVAL COMMITMENT TO HEADQUARTERS - SPMS
2nd Qtr* 3rd Qtr*
P A % P A %
Non-403 States (3?) 29 83" (57)
403 States (65) 66 102 (138)
Total (TOOT 9? 95 TT95T
Cumulative
**Cumu1ative
B. STATES' FY
1 . APPROVE
State
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
TOTAL
2. MODIFY
State
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
4th Qtr*
P A %
(95)
(230)
Total P = Projection A = Actual % - Percent of P
Total Actual includes referrals. (5 in Non-403 States and 1 in Ohio).
85 COMMITMENT TO REGION (WORK PLANS)
PROGRAMS
2nd Qtr* 3rd Qtr*
P A** % P A %
23 5 22 38
30 24 80 42
112 13 12 112
900 9
50 45 90 96
13 8 62 13
237 95 40 310
PERMITS WITH APPROVED PREREATMENT PROGRAMS
2nd Qtr 3rd Qtr
P A % P A %
23 0 0 38
28 19 68 43
20 0 0 40
500 7
10 2 20 30
11 13 118 21
4th Qtr*
P A %
53
42
112
9
96
13
325
4th Qtr
P A %
53
49
60
11
50
21
TOTAL 97 34 35 179 244
NOTE: See Regional and State graphs following Tables.
-------
TABLE 3
SUMMARY OF PRETREATMENT ACTIVITIES
(Period Ending Marcn 31, 1985)
F194-
TCTAL
E * U.S. EPA
S = State
Columns (1) + (2) = Total program required at beginning of FY 85
19 + 336 = 355
Programs currently required 355 - 10 (Col. 5) - 345
-------
NUMBER OF PROGRAMS
8
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NUMBER OF PROGRAMS
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NUMBER OF PROGRAMS
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-------
APR 12 1986
FY 85 SP*S tanldpal Pretre«t»ent Commitments
Charles H. Sutfln /S/C/)arte«H-SuWn
Director. Water Division (5W)
Martha Prothro, Director
Pemlts Division (EN-336)
! an writing to clarify the Region's FY P5 SP*S commitments as they relate
to WC-18, Municipal Pretreatment reporting ^ormat. There appeared to
have been sane misunderstanding concerning the number of pretreatment
programs required at the beginning of the fiscal year.
Early on, the Region and States Identified many cities that might be
required to develop local pretreatment programs. This numher Included
many cities with flows less than S MGT and was hased on best avallahle
Information or judgement without benefit of a formal program application.
Initially, many of these cities were required to submit only part of the
Information which Included the industrial Inventory for evaluation. As a
result of this e^ort, many of the cities with flows less than 5 MGC were
relieved of further program development requirement because no known or
potential pass-through/Interference problems exfstp<* or the delegated
States decided to operate the pretreatrwnt program in lieu of requiring a
local program. For facilities under 5 MOD, delegated States have the
option to either require a local program or to Implement a State operated
pretreatment program.
Minnesota 1s the only State that has elected to 170 tMs route, and we
believe the difference In the total number of crcgrams required as of
10-1-P4, 1s largely due to this factor. However, since we were Informed
that the Peglon would not he given credit *or the Minnesota "limited"
local pretreatment program, our commitment was hased on 255 Federal
programs required and not the 37C programs reflected 1n your report.
In FY 84, 19 of the 355 programs were approved consistent w1t»» the current
definition of approved which we understand 1s after public notice and a
letter of approval sent to the city. TMs left 336 programs to he approved
1n FY 85. Our FY 85 comnitment of ^25 anticipated a few more night he
dropped and represented our best estimate of all remaining programs to he
approved 1n FY 85.
The attached two sheets for WP-lfl, Municipal Pretreatment, have heen marked
to show the number nf municipalities needing approved programs as o*
ID-l-ft*. and our *1rst and second quarter cowMtments and accomplishments.
We have also Identified t»ie six facilities which we received credit for
program approval based on referrals for civil action. I trust this
clarifies the number of facilities Identified 1n our FY P5 co«w1tments.
-------
If you «rt uiublt to revise the number require* 'ran 370 to 32fi, then I
sug
-------
WO-1ft
MUNICIPAL PRETREATMENT
On t!T» attached form, please provide, by Region and
nationally, the actual cumulative number of municipal pretreat-
»«nt programs approved through the _qu«,rter by EPA and the number
•pprov**-Ur"WPDES Ttatrj. wrth approved pretreatment programs.
Indicate wjfrat percent of the quarter's target was achieved for
each. Please note under "COMMENTS,- below, any Regions or States
which received credit for-~pT5gTam approval" based on a "referral'
and how many of the "approvals" were actually "rel
COMMENTS
6 referrals -
Geneva, Illinois
Carol Stream, Illinois
Lafayette, Indiana
Terre Haute, Indiana
South Bend, Indiana
Mahoning County, Ohio
U.S.
U.S.
U.S.
U.S.
U.S
Ohio A.G.
-------
i
HIMICIPAL PWETTW
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2nd Ouartei
(Cumulative
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-------
FY 85
Mid-Year Evaluation of Region V Water Program
National Directions: Improve Compliance Rates for Municipals and Industrials
Activity: Identify Municipal and Industrial Compliance Problems and Guide
Corrective Actions
Analysis of Region V Program: Review of SPMS/OWEG Data for Fixed Base,
Exception Report, Moving Base, and P.L. 92-500
Facilities
Fixed Base
Under the Strategic Planning and Management System (SPMS) Region V was
required to commit to insure that all fixed base permittees either return
to compliance or be subjected to State or Federal action. Any fixed base
permittees which were unresolved by March 1, 1985, were to be placed on
the April 1, 1985, Exception Report. The fixed base facilities for FY 1985
are those which were in significant noncompliance at the conclusion of the
April-June 1984 reporting period and which had not been subjected to
formal enforcement action. A table describing the status of the FY 1985
fixed base permittees is attached.
Of the 52 facilities on the fixed base at the start of the fical year, 44
or 85% have been returned to compliance or are under formal enforcement
action. Eight facilities were unresolved, by March 1, 1985, and were
placed on the April 1, 1985, Exception Report. Since that time many of
these facilities have attained compliance or received formal enforcement
action from the States. The names of the fixed base facilities are included
in the attached list of persistent noncompliers.
Exception Report
Under SPMS, tracking of the FY 1985 fixed base facilities ceased after
the evaluation of the October-December 1984, QNCR and was replaced by the
SPMS Exception Report. Any facilities appearing on the QNCR for two
consecutive quarters which have not returned to compliance or been
subjected to formal enforcement must be listed on the exception report.
The Regional office has until the next Exception Report to initiate
formal enforcement or otherwise insure that exception report facilities
return to compliance. The status of these facilities is being closely
monitored by compliance staff and Federal action will be initiated if
appropriate. Facilities which were in SNC on the July-September and
October-December 1984 QNCRs and have not been addressed by a formal
action by March 1, 1985, have been included on the April 1, 1985 Exception
Report. Thirteen facilities are listed on the Exception Report. Many
of the 13 were either under State enforcement initiated after the
reporting cut off date or in the process of starting up new treatment
facilities. These facilities are identified in the already mentioned
list of persistent noncompliers.
-------
-2-
Moving Base
0 The moving base facilities are all major dischargers in the Region.
0 Regionally there is a 12% significant noncompliance rate for major
municipal dischargers and an 8% significant noncompliance rate for
major industrial facilities with interim and final effluent limitations
and compliance schedule requirements.
0 A table containing all of the Moving Base compliance statistics is
attached.
0 EPA and the states have completed reviews of EPA/state enforcement
agreement checklists. This process identified instances where
state Enforcement Management Systems needed updating. These agreements
are formalized in state 106 program plans. Our states have stressed
that they do not desire separate agreements but rather, for management
purposes, that all program requirements be folded into the 106
planning process. This approach has been successful in that states
clearly understand what is expected. There can be problems however
if there are late changes to the national guidance after state
program plans have been negotiated.
0 A recent study has been completed by the Division of causes of
noncompliance by dischargers on the FY 1984 Fixed Base. While
causes of noncompliance are often complex and in fact caused
by multiple factors, a number of observations were made.
The most frequent cause of noncompliance was operations and
maintenance (O&M) related. The next most significant factor in the
study was weather. Conditions such as cold winter temperatures,
high spring preciptation and snow melt runoff, and a tornado were
instances cited by the study. The study also found that the least
influential variables causing noncompliance were such items as
service area changes and industrial pretreatment.
0 Each Region V state has an Enforcement Management System (EMS)
which is comparable to the Federal EMS. The states use their EMS
in day-to-day program operations. Region V utilizes the EMS in
reviewing and approving the state/EPA agreement checklists and 106
program plans and in conducting our state file audits. All of the
EMS principles' are strictly implemented in the states. The states'
EMSs are included in their program plan. If the states do not
follow their EMS, this often will result in the Region detecting
violations during file audits and initiating Federal enforcement
action due to the state's failure to take timely and appropriate
enforcement as required in the EMS.
-------
-3-
The SPMS commitment for Fixed Base dischargers is that they either return
to compliance or be subjected to state or Federal action by March 1, 1985.
To meet this commitment the Region and states use these lists as the driving
force for enforcement action. During monthly conference calls, the
Region reviews that status of these dischargers with the state. The discharger
file is also reviewed during the quarterly file audit. The high emphasis
of compliance tracking and enforcement for these dischargers points
out their priority. If the State fails to take timely and appropriate
enforcement action, Federal action will be initiated. Exception reporting has
been a very effective management tool and should contribute to improved
compliance rates.
All facilities that are not on final efffluent limits are actively tracked
by the Region and the states. In developing the list of facilities that
need Municipal Compliance Plans (MCPs) as part of the National Municipal
Policy (NMP), all municipal facilities were reviewed and prioritized as
to whether or not they needed construction and would not be able to receive
grants. To meet the commitment for March 1, 1985, enforcement action
would be taken at these priority dischargers.
National Directions: Improve Compliance Rates for Municipals and Industrials
Activity: Improve Quality of PCS Data
Analysis of Region V Program: Status of PCS Implementation/Interface
Region V is undertaking a number of activities to improve the quality of
data in the Permit Compliance System (PCS). Activities at this point
consist of developing interfaces for three states which will load
discharge monitoring report data into PCS from state systems and
working with three remaining states in their assumption of PCS data
entry responsibilities. Each states' status is discussed below:
0 Indiana, Ohio and Wisconsin will be interfaced with PCS. The Indiana
interface is operational. A major problem is the timely receipt of
data tapes from the State of Indiana. The Ohio and Wisconsin interface
should be completed by the end of the fiscal year.
0 Illinois has begun inputting Discharge Monitoring Report Data and
permits for major municipal dischargers into PCS. They have submitted
a work plan that will result in the State assuming full PCS responsiblity
as soon as staff are hired and trained. PCS should be fully on-line
in Illinois by late this summer.
0 The Michigan interface has been debugged and the system is now capable
of converting State facility and limits data into PCS format and
adding it to PCS. A detailed plan for verifying data is under
development.
0 Minnesota has submitted a draft workplan for implementation of PCS.
Development has been slow due to problems with the STORET interface.
-------
-4-
0 Region V does not at this time routinely enter DMRs for all states into
PCS because we do not receive self-monitoring reports for most major
dischargers since the NPDES programs are delegated. If self-monitoring
reports were received the Region does not have the data entry staff that
would be required in order to accomplish this task. The Regional office
only enters DMRs for major industrial permits in the State of Illinois.
When the state takes over this responsibility we will begin providing
assistance to other states assuming PCS responsibility.
0 Changes to the PCS majors list are negotiated by the Permits Section
in the state planning process. These changes are coordinated with
the compliance and enforcement program and nationally established
procedures are followed for making changes in the majors list.
The PCS majors list is the official list of priority facilities
in the compliance programs both at the state and Regional levels.
This list is used for planning inspections, NMP activities and
compliance status is reported on the quarterly noncompliance
reports.
0 PCS is used as the primary data system in the compliance program,
however, its use is somewhat limited because it does not contain
all effluent data. The Region has a number of regional tracking
systems set up on the personal computer as well as a separate enforcement
action tracking system similar to the GREAT system in Headquarters
(ENF-V). We expect to phase out the ENF-V system as soon as the
modifications are made that allow for entry of our enforcement
action information. We currently enter all Federal enforcement
actions into PCS.
0 A particular problem with PCS is it's slowness in anticipating
program needs. For example, we have developed a Regional system
for tracking National Municipal Policy Actions primarily because
there was no national tracking system. We may have to keep our
Regional system for NMP because the tracking capability currently
being proposed is extremely limited.
0 Another major problem is that the conversion to ADABAS has seriously
impaired the efficiency of our interfaces. The old system contained
a master file which was used in the interface process. The master
file was used to detect differences between the state system and
PCS. Now that the master file is no longer available changes in
permits must be manually coded into PCS. The interfaces can only
be used to input DMR data.
National Directions: Improve Compliance Rates for Municipal and Industrials,
and Federal Facilities
Activity: Improve Quality of Monitoring Data
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-5-
Analysis of Region V Program: Review of Discharge Monitoring Report -
Quality Assurance Program (DMR-QA) Follow-up
0 The States of Illinois, Indiana, Michigan and Ohio have not actively
followed up on the latest DMR-QA Study #4. The States do use the results,
however, to assist in identifying problem facilities and conduct follow-
up during their periodic compliance inspections.
0 Region V has assisted the above states by contacting nonrespondents.
In Indiana three nonrespondents were sent Administrative Orders and
one nonrespondent was sent a warning letter. In Illinois, three
nonrespondents were sent Administrative Orders and five nonrespondents
were sent warning letters. In Michigan, one nonrespondent was sent
a warning letrer. In Ohio, 17 nonrespondents received telephone
calls and were instructed to submit sample results.
0 It is difficult to assess whether the quality of self-monitoring
has been improved as a result of the DMR QA effort. However, there
is a definite trend toward improved analytical capability in the
DMR QA results. DMR results are frequently evaluated by the states
when split samples are taken and compared with the permittees' results.
0 In addition to state efforts VERSAR conducted approximately 50
Performance Audit Inspections (PAI) this past year at facilities
which did not complete Round 3 analyses successfully.
0 Because of resource contraints at the state level, four Region V
states have indicated that they will not be able to actively follow-up
on Round 5 activities. Regional resources will also limit our
offices' ability to do more follow-up work in this area. Delays
in the JRB contract for the VERSAR PAI's will also contribute
significantly to the delay in the Region's ability to follow-up in
this area.
National Directions: Improve Compliance Rates for Municipals
Activity: Identify Municipal Compliance Problems and Guide Corrective Actions
Analysis of Region V Program: Status of National Muncipal Policy Implementa-
tion
0 All states except Wisconsin have developed a Municipal Compliance Strategy
(MCS). Wisconsin was not required to implement on MCS since the state
essentially has achieved compliance with their state statutory deadline
of July 1, 1983.
0 There are a total of 114 major dischargers in the Region that require
MCPs. To date, the States have taken 51 actions and Region V has taken
eight actions requiring municipalities to submit MCPs. The states
have taken seven actions and Region V has taken two actions establishing
MCP fixed date schedules.
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-6-
There are a total of 24 major dischargers in the Region that require
CCPs. To date, the States have taken three actions and Region V
has taken seven actions requiring municipalities to submit CCPs.
The States have taken 10 and Region V has taken two actions establishing
CCP fixed date schedules.
Attached is a computer listing (MUNICOMP) of all major and minor MCP
and CCP candidates and all other major nonmunicipalities on interim
effluent limits. Also attached is the Region V NMP Status Report.
The Region and states have developed and are implementing MCSs
to ensure that compliance schedules are established by 9/30/85 for
all POTWs that need construction to comply with permit requirements.
Most states have committed in their MCS to issue actions for at
least all major dischargers by this time except Ohio which anticipates
that approximately 20 schedules will not be finalized. In addition,
Region V has developed a computer tracking system (MUNICOMP) which identifies
POTWs needing action and tracks actions that are taken. In instances where
the states have been unable to issue enforcement schedules, Region V has
initiated enforcement action and begun to place POTWs under enforcement
schedules.
As part of Region and state MCSs, the states are required to identify
and initiate enforcement action on a priority basis to all noncomplying
P.L. 92-500 POTWs. The states have committed to addressing, and in
many cases have already addressed noncomplying P.L. 92-500 POTWs
with Composite Correction Plans (CCPs).
Where states have not initiated enforcement against noncomplying
P.L. 92-500 facilities, the Region has conducted diagnostic evaluations
using contractor support and has issued Administrative Orders requiring
POTWs to return to compliance in as short of time as possible. In
one instance, Hamilton County-Mill Creek, Ohio, Region V proceeded
through litigation and finalized a Consent Decree placing the facility
on a construction schedule for plant improvements and included a
$750,000 set aside to be used for environmentally beneficial projects.
States are required to report any violations of Consent Orders
on the Quarterly Noncompliance Report. By definition, outlined in
the states Enforcement Management Systems (EMS), any violation of a
Court Order is a signficant violation and should be pursued by a
formal enforcement action including referral to the State Attorney
General's Office. Also, during monthly telephone calls to the
State, Region V receives the number and name of final actions taken
the previous month by the state. These figures include actions taken
for violating Court Orders. Any Court Orders that were issued as
a result of Federal action are tracked by Region V and enforcement
action is escalated if Court Orders are violated.
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-7-
0 The Region and state MCSs have been developed as a tool for achieving
NMP requirements. The documents themselves are dynamics and are
updated as new information is discovered or policies are interpreted.
In particular, the various categories that municipalities were placed
in to determine their need for an MCP are very dynamic and change
as a result of municipalities receiving grants, completing water
quality studies, etc. Categories are routinely updated almost
every six months. The Region and states' also track status of NMP
facilities on a day-to-day basis.
0 The foundation of the Regional and states MCS is the coordination
between the permit issuance, compliance and construction grant
activities. Various agreements have been reached among these groups
to coordinate their activities. Draft permits, enforcement actions
and grant offers are routed to the various groups for review and
concurrence. Any discrepancies discovered are discussed/resolved
through meetings of the Water Quality and Municipal Facilities
Branch Chiefs. Similar activities are carried out by the state
staffs.
National Dischargers: Improve Compliance Rates for Municipals and Industrials
Activity: Identify Municipal and Industrial Compliance Problems and Guide
Corrective Actions
Analysis of Region V Program:
Review of SPMS/OWEG Data for State and
Federal Inspections
Inspections are credited and completed when they are received by the
Compliance Tracking Unit and entered into PCS. So far this fiscal year,
Region V has conducted 205 inspections (189 are SPMS countable).
This is well above the mid-year commitment of 140. The following
numbers of Federal and State major inspections have been received in
the Compliance Tracking Unit and have been coded into PCS. These
numbers reflect inspections coded into PCS from July 1, 1984 to the
present.
Compliance Inspections
Major
Municipals
86
423
Minor
P.L. 92-500
28
70
Major
Industrial
89
192
Major Fed.
Facilities
2
4
Total
205
689
2nd Qtr.
Target
140
184
TE
As part of the program planning cycle, states develop their compliance
inspection plan. The states make specific commitments for conducting
municipal and nonmunicipal inspections with emphasis on major
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-8-
dischargers. The program plan includes these commitments and a
permittee specific schedule for conducting the inspections. After
the inspection commitments were made and a schedule was in place,
Region V used it to determine which permittees will receive Federal
inspections. This is done to avoid duplication of effort for
inspections conducted by the state and Region V.
0 Region V and the states have specific commitments for minor P.L. 92-500
facilities. Other minor facilities, however, are also inspected.
Region V conducts a portion of inspections at minor dischargers
usually as a result of citizen complaints or others knowledge of
potential problems at the specific minor facilitiy. The states conduct
numerous reconnaisance inspections at all their dischargers annually.
A large part of this effort is to verify permittee compliance.
National Directions: Improve Compliance Rates for Major Federal Facilities
Activity: Identify Federal Facility Compliance Problems and Guide
Corrective Actions
Analysis of Region V Program: Review of SPMS/OWEG Data for Major Federal
Facilities
0 There are 12 major Federal facilities in Region V. Nine or 75% of
these are in compliance. The three facilities in noncompliance
are U.S. Department of Energy (U.S. DOE) facilities in Ohio. The State
has been active in addressing these noncompliers, and all three have
been or will soon be subjected to formal State enforcement action.
On September 15, 1984, the U.S. DOE Feed Materials Production Center
(Fernald) was referred to the State Attorney General's Office for
failure to complete construction of the necessary treatment facilities
to meet final effluent limits by July 1, 1984. Director's Final
Findings and Orders (DFFOs) with a fixed date compliance schedule
and interim effluent limits were issued to the U.S. DOE Mound Facility
(Miamisburg) on February 26, 1985, for noncompliance with effluent
limits. DFFOs are also being finalized for the U.S. DOE Gaseous
Diffusion Plant (Piketon).
National Directions: Improve Compliance Rates for Municipal, Industrials
and Federal Facilities
Activity: Take Actions as Required to Attain Compliance with NPDES
Permits
Analysis of Region V Program: Review of SPMS/OWEG Data for Regional
Enforcement Actions
0 Through the mid-year, 27 Administrative Orders have been issued.
Nineteen (19) of these were issued to facilities for failure to submit
completed pretreatment programs and 6 were issued for failure to
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-9-
participate in the DMR-QA program. One was issued to begin the
development of a MCP and one was issued to an industrial user of a
municipal facility for failure to submit baseline monitoring reports.
One NOV was issued to the City of Berea, Ohio for delays in developing
a MCP.
Seven facilities have been surfaced for referral for civil litigation.
They are:
U.SS. Lead Refinery, East Chicago, IN
Inland Steel Corp.
Carol Stream, IL
Geneva, IL
Lafayette, IN
South Bend, IN
Terre Haute, IN
East Chicago, IN
- NPDES violations
- NPDES violations
- Pretreatment Municipality
- Pretreatment Municipality
- Pretreatment Municipality
- Pretreatment Municipality
- Pretreatment Municipality
0 Both the Region and states follow the Enforcement Response Guide
which is part of their EMS. This tool is a basis to evaluate the most
effective enforcement action that should be used for a particular
violation. By definition the Enforcement Response Guide identifies
the most effective enforcement action to be taken. Overall, effectiveness
can also be determined by the number of escalated enforcement actions
that are taken where an original enforcement action did not result
in compliance. Also, the overall compliance rates can serve as a
guide to determine effectiveness of actions. Recent high compliance
rates are indicative of the effectiveness of current activities.
0 The Region has been assisting the states in identifying violators of
pretreatment schedules and in issuing follow-up enforcement actions.
Currently, the states are reporting directly to the Region on their
efforts to get municipalities to develop and implement pretreatment
programs and on industrial user noncompliance with categorized pretreatment
standards. Through the mid-year, Region V has issued 19 Administrative
Orders' to municipalities for failure to submit completed pretreatment
programs. In addition, one Administrative Order was issued to an
industrial user of a municipal facility for failure to submit baseline
monitoring reports. See the pretreatment portion of Permit's mid-year
for details of pretreatment enforcement efforts.
National Directions: Improve Compliance Rates for Municipals and Industrials
Activities: Initiate Enforcement Actions as Required to Obtain Compliance
with Non-NPDES Requirements of the Clean Water Act
Analysis of Region V Program: Review of Non-NPDES Activities
The non-NPDES enforcement actions are of three types. Under the SPCC
program, violators are issued a warning letter or a Notice of Violation,
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-10-
depending on the type of the violation. For spills that require use
of Federal funds to effect clean-up, referrals are made to the U.S.
Coast Guard for cost recovery. During the first half of FY 1985,
54 warning letters and 52 Notices of Violations were issued. These
resulted from 168 SPCC inspections completed during this period. Six
Federally funded oil spill clean-ups were completed. Five actions
were referred to District 9, U.S. Coast Guard for consideration for
cost recovery.
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REGION V
OWEB DATA SHEET
OFFICE OF WATER ENFORCEMENT AND PERMITS
MUNICIPAL
MAJOR PERMITEES
REGION V
N/MUNICIPAL
COMPLIANCE TRACKING OF
FY 1985 FIXED BASE
STATUS AS OF DECEMBER 31,1984
A.NO.IN SNC WITH FEL. 22
1. RETURNED TO COMPLIANCE 16
2.NOT IN COMPLIANCE BUT ADDRESSED
THROUGH ENFORCEMENT ACTION 4
B.NO. IN SNC WITH CONSTRUCTION
SCHEDULES 0
a. RETURNED TO COMPLIANCE 0
b. NOT IN COMPLIANCE BUT ADDRESSED
THROUGH ENFORCEMENT ACTION 0
.NO. IN SNC WITH INTERIM EFFLUENT
LIMITS 13
a., RETURNED TO COMPLIANCE 9
b. NOT IN COMPLIANCE BUT ADDRESSED
THROUGH ENFORCEMENT ACTION 0
14
11
0
0
0
0
o
FEDERAL
0
0
0
o
-------
OWEG DATA SHEET
OFFICE OF WATER ENFORCEMENT AND PERMIT
MAJOR PERMITTEES
________
MUNlcIPAL~N/MUNTciPALFEDERAL"
III. EXCEPTION REPORT TRACKING OF
PERSISTENT NONCOMPLIERS.
*A. NO. IN SNC WITH FINAL EFFULENT
LIMITS (FED ON 9/30/84 AND
12/31/84 QNCRs ?< NOT ADDRESSED
WITH A FORMAL ENFORCEMENT ACTION
BY 3/1/85:
*B. NO. IN SNC WITH CONSTRUCTION
SCHEDULE ON 9/30/84 b 12/31/84
QNCRs ?> NOT ADDRESSED WITH A FORMAL
ENFORCEMENT ACTION BY 3/1/85: 7 O
fcNAMES ATTACHED
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,;..' REGION V
STATUS OF PERSISENT NOCOHPLIERS
NAMES NPDES.MO. STATUS
tA.
_ 1 EBUARDSVILLE CITY OF IL0026310 MEN TREATMENT FACILITY HAD BREAKAGE OF CHLORINATM. EOUIPKNT MAS REPAIRED
FEBRUARY 1985. COttPLIANCE OF CHLORINE RESIDUAL IS EXPECTEJ.
*
- 3 CORHONHEALTH EDISON CO-PONERTON IL0002232 CONSTUCTION COMPLETED 12/84. IN COMPLIANCE 01/85.
4 BRONSON HF6 PLATIN6 CO HI0000825 PERMITTEE SHOULD COMPLY KITH LESS STRINGENT LIHITS OF MODIFIED PERMIT OF
JANUARY 19B5.
5 MAC STEEL, DIV. NICH. SEAMLESS HI0028461 STATE HAS ENFORCEMENT ACTION IN SIGN-OFF PROCESS.
7 HAYNE CO.-KYANDOTTE HI0021156 PERMIT ISSUED 01/17/85 KITH INTERIM LIMITS NHICH THE PERMITTEE IS MEETING.
- 12 NAHONIN6 COUNTY(MEANDER CREEK) OH0045721 OEPA REFERRED TO A6 ON 03/21/85.
_ 14 USDOE PORTHTH 6AS DIFF PLANT OH0006092 OEPft ORDER BEIN6 FINALIZED.
IB. NO RECORDS
1C.
- 2 . NAPERVILLE SPR1N6BROOK NTR REC IL0034061 CONSTRUCTION RECENTLY COMPLETED. PLANT IN START-UP.
6 NAYNE CO.-TRENTON HI0024317 PERMIT ON PUBLIC NOTICE KITH RELAXED INTERIM LIMITS. FACILITY TO CEASE
OPERATION AND CONNECT TO HURON VALLEY SYSTEM BY 12/01/87.
8 SALINE STP MI0024023 USEPA ISSUED AO 8/30/82. STATE ISSUED PERMIT 8/17/84 HITH RELAIED INTERIM
PHOSPHORUS LIMIT. CHRONIC NONCOHPLIANCE DUE TO FORD'S INDUSTRIAL CONTRIBUTION. STATE EVALUATING FORD'S REDUCTION IN OPERATION
REDUCED IMPACT ON POTN.
- 9 LAPEER, CITY OF HI0020460 CONSTRUCTION OF NEK FACLITY TO BE COMPLETED BY 4/1/85.
10 SA6INAN TNP. "MI0023973 STATE STIPULATION V ORDER DRAFTED AND UNDER NEGOTIATION KITH PERMITTEE.
AS SOON AS COMPLEX ISSUES ARE RESOLVED STATE MILL ISSUE THE ORDER.
11 AHHERST, CITY OF OH0021628 CONSTRUCTION WHICH NILL ENABLE A RETURN TO COMPLIANCE BILL BE COMPLETED BY
HAY 1995.
- 13 LANCASTER, CITY OF OH0024026 RECENTLY DETERMINED THAT CITY IS NOT ELIGIBLE FOR FY 1985 GRANT AND OEPA
L ISSUE ORDER FOR CONSTRUCTION (PLANS SUBMITTED). OEPA HAS DRAFTED A DIRECTOR'S LETTER REQUESTING AN ENFORCEMENT MEETING.
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REBION V
ONES DATA SHEET
OFFICE OF HATED ENFORCEHENT AND PERUITS
HUN1CIPAL
REMITTEES
REGION V
PL 92-5001
MAJORS MINORS
NON-KUNICIPAL
FEDERA1
CBttPLIANCE TRACKING OF THE HOVING BASE.
FOR THE QUARTER ENDING DEC.31,1984.
A. NO ON FINAL EFFLUENT LINITS IFEL): 417
i. NO. AND PERCENT IN SIGNIFICANT
NONCOHPL1ANCE (SNC) NITH F&: 42 10
". NO. NOT ON FEL 220
» 1. NO. AND PERCENT IN SNC NITH
CONSTRUCTION SCHEDULES: 8 4
2. NO. AND PERCENT IN SNC KITH
INTERIH EFFLUENT LIHITS: 26 12
C. TOTAL NO. OF FACILITIES 637
193
15
299
12
198
310
569
44 8
18
0 0
3 17
587
11
2
1
0
1 li
12
I APPLIES TO COHPLETED, OPERATIONAL PLANTS ONLY
WHERE A FACILITY IS IN SNC NITH BOTH ITS SCHEDULE AND
AND INTERN LIHITS, IT SHOULD BE REPORTED IN NONCOHPLIANCE HITH
ITS SCHEDULE.
-------
Mid-Year Evaluation Report
Region V
This report is composed of two parts. Part 1 consists
of 48 pages which follows the Headquarters suggested
format. Part 2 consists of the Regional monthly monitoring
report. Where activities and the respective quantitative
and/or qualitative measures are addressed in Part 2, there
is a cross reference in Part 1.
Questions on this report should be addressed to one of
the following:
Todd A. Cayer, Chief, Municipal Facilities Branch
John R. Kelley, Chief, Program Management Section
Robert E. Lee, Chief, Policy and Management Unit
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FY 1985 Mid-Year Evaluation of Region V Water Program
Objective: Improve Water Quality
Activity 1: Manage Priority Systems and Lists
Qualitative Measure (A); Have Regions/States demonstrated that priority lists
are being used as management tools (page A-52)?
The Project Priority Lists (PPL) are used as management tools to varying degrees
1n all Region V States for construction grants, water quality, and enforcement
programs. For example 1n Ohio, scheduling of reviews of facilities plans, plans
and specifications, and other documents 1s based on priority ranking. Study
areas for the preparation of Comprehensive Water Quality Reports are selected
based on PPL projects which require AT reviews or whose effluent limits have
yet to be established. The PPL provides information on funding status for
writing NPDES permits in terms of schedules or needs for Municipal Compliance
Plans. Similar program management activities occur in Illinois, Minnesota,
and Wisconsin, except that Wisconsin enforcement actions proceed Independent
of funding status due to the availability of State grant funds. Indiana has
begun to develop communication systems among the programs for use of the PPL
as a management tool. Indiana's use of the PPL to guide funding actions has
Improved significantly over the last 2 years. Michigan uses the PPL to manage
the construction grants program as in the other states, but there appears to
be room for improvement in other Michigan water quality programs' use of the
PPL as a management tool. Although Ohio makes good use of the PPL as a manage-
ment tool, this fiscal year the extremely late submission of the PPL has caused
problems in the decisionmaking process for all water quality programs.
As needs are identified through applications from municipalities, permits and
enforcement activities, and water quality management planning; projects to
address these needs are subjected to the States' priority system ranking
processes. The State priority systems rank projects based on water quality,
public health, and other factors permitted by the regulations. Since future
growth and some need categories are ineligible for funding, some newly emerging
needs will not be fundable.
All Region V States update priority list information on a regular basis, some
more frequently than others. Significant updating occurs after submission of
Information by applicants during the public participation process and at the
time applications are completed. Region V reviews the priority lists for
accuracy when they are submitted for acceptance as well as when projects are
certified for grant award.
Qualitative Measure (B): Have Regions/States demonstrated that grant dollars
are going to priority projects with high WQ/PH ranking established at the
start of the fiscal year (page A-52)?
Grants in Region V are only awarded for projects in the funding range on the
State PPL's or to contingency projects reached through established State bypass
procedures. This ensures the funding of priority projects since the priority
system rankings are based on WQ/PH. Facilities plans, prepared as prerequisite
1
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to grant award, document public health problems, and waste load allocation
reports, prepared to establish effluent limits and to review water quality
standards, document biological and chemical water quality impairments.
Either one (the facilities plan) or both of these documents are available
before a grant 1s awarded to demonstrate appropriate use of grant dollars.
In nest of the States enforcement and construction grants staff coordinate
enforcement actions being considered or ongoing for those communities which
will or have received construction grants. Discussions among the staff occur
concerning planning, design, and construction schedules and timing of potential
grants.
Qualitative Measure (C); Do priority projects funded in (B) above correlate
with priority waterbodies identified in the Water Quality Standards, Planning,
and Assessment section of OWAS (page A-52)?
Although all the States coordinate the priority waterbody and construction
grants priority list processes, only Illinois and Ohio have reported that
priority waterbody maps have been prepared to show the location of PPL projects.
For the Region V work plan, each quarter numbers of construction grants projects
completed and in compliance with NPDES effluent limits on priority waterbodies
are determined to reflect water quality improvements. Numbers of completed
pipe or small system projects are used as indicators of public health improve-
ments. In addition, numbers of new awards on priority waterbodies are used as
indicators of projected water quality/public health Improvement.
Regional Contact: John R. Kelley, Chief, Program Management Section, 353-2123.
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-_
MID YEAR REPORT
OBJECTIVE:
ACTIVITY 1:
Ensure.51nandal/Techn1cal Program Management (A-53)
Translate National Guidance Into Mechanisms for Oversight.
Qualitative Measure (A) are sludge management projects being
Implemented 1n a manner consistent with existing Agency
Guidance?
A direct response to this Inquiry would be Yes! We have
Initiated a self evaluation questionnaire which 1s being
utilized as a means of monitoring sludge management project
activities within each State. Thus far, 1n FY'85, three States
have completed the questionnaire and two more are 1n the process of
providing responses to the questionnaire. The entire monitoring
process should be completed by June.
The questionnaire was developed so as to clearly indicate whether
or not sludge projects are being Implemented consistent with
existing Agency Guidance. Preliminary results to date indicate
an affirmative response to the implementation and consistency
aspects of this Qualitative Measure. Pertaining to the States
which have thus far been monitored we can say with some confidence:
- The States do monitor and track compliance by POTW's with
appropriate guidance and regulations.
_ State sludge management programs are applicable to all projects
regardless of the source of funding.
_ The States within the Region do use EPA guidance and Federal
regulations.
- Some of the States are gradually becoming aware of the problems
associated with the land application sludge disposal practice
within proximity to urbanized areas. Remedial actions are just
now being considered.
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- SLUDGE MANAGEMENT - MID YEAR REPORT
OBJECTIVE: Ensure Financial/Technical Program Management (A-53)
ACTIVITY 2: Adopt Programs to Meet Requirements of the Regulations
QUALITATIVE MEASURE (A): Are the States developing sludge management programs
which embody and enforce EPA regulations and guidance (Page A-53).
- Do the States plan to improve their current sludge management programs
to embody and enforce EPA regulations and guidance?
Region V has several waste treatment facilities which have reached or
exceeded their capacity to store or properly dispose of the residual
product (sludge) resulting from the wastewater treatment process.
Neither the Region nor the several States can positively state that we
have a firm handle on each and every location which may be experiencing
sludge management problems. Accordingly, the Region has initiated
action with each of the States to ensure that an inventory of each
sewage sludge generator and sludge disposal facility will be available.
This inventory is ongoing and is scheduled for completion as a part of
the FY 1986 Work Plan activities. This inventory will be a major part
of each State's sludge management improvement program.
While each delegated State's sludge management program will be actively
monitored and evaluated during FY 1985, the Region has noted that in
virtually all of the States a lack of resources at the State level has
resulted in slow advancement in the improvement of each State's sludge
management program. In addition, and without exception, each State
is awaiting the promulgation of new EPA sludge management regulations
and guidance. Each State is reluctant at this juncture to expend
resources toward the improvement of their current program in view of
the imminent promulgation of new State program requirements. (See
State by State assessment.)
- Which States have an inventory of sewage sludge generators and sludge
disposal facilities?
This qualitative measure was originally set forth in February 1985 as
a part of the FY 1986 Work Plan objectives, activities and performance
measures. It has been duly noted and will be accomplished during
FY 1986.
Our FY 1985 monitoring and evaluation activities indicate that some of
the States have accomplished significant Inventorying as a part of their
pretreatment program and despite limited resources, the States will be
providing follow-up toward the expansion of this Inventory program.
-------
Identify the agencies In the States that have sludge management
responsibilities.
This qualitative measure has been Included in the broader spectrum of
our FY 1985 monitoring and evaluation activities. Each State has been
requested to "provide an organizational chart or description clearly
defining areas of sludge management program responsibility and those
within the organization who will administer the sludge management
program".
The several States which have been monitored thus far in FY 1985 have
Indicated that agencies within that State which have sludge management
responsibilities can be Identified, and we should have this information
available by the end of June 1985.
A State by State assessment of their activities to improve their
current sludge management programs.
Illinois
During the early portion of FY 1985, Illinois upgraded and distributed
to local agencies, two key sludge management guidance documents. Both
of these publications encourage and promote municipal sludge disposal
systems which provide for the beneficial use of sludge. The State sludge
coordinator is highly competent and continues to show an active interest
in Improving the State's sludge management performance, as evidenced by
his attendance and active participation in the National sludge coordinators
conference which dealt primary with the development of new regulations
and guidance as well as continuing improvement in current sludge manage-
ment programs. Illinois has developed a wait-and-see position concerning
any plans for the improvement of current programs, depending upon the
requirements of the new State program regulations„.
Indiana
The Indiana State Board of Health refined their sludge management program
1n FY 1984 and in the early part of FY 1985. This refinement took place
in order to deal with the complexities Involved in several sources of
contaminated sludge discovered during the contaminated sludge inventory.
The Indiana sludge program continues to be hampered by staffing problems,
however these are being resolved slowly and there has been improvement
1n their current sludge management program.
Michigan
The State sludge coordinator, represented MDNR on the National Sludge
State Program Regulation Task Force and has been active 1n the formulation
of National policy. Action leading to any alteration or Improvement in
the Michigan current sludge management has been placed on hold, as the
State prepares to receive the new Federal State Program and Technical
Regulation and guidelines. The State sludge coordinator believes that
Michigan's current sludge program can be adopted to meet the new
Federal Program - only time will tell.
5
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Minnesota
During the first half of FY 1985 the Minnesota Pollution Control
Agency continued to be in the forefront of States encouraging the
beneficial uses of sludge. Monitoring data indicates that MPCA is
currently Improving their sludge management program to the point
where over 90 percent of the sludge material produced within the
State is disposed of through land application. In addition, MPCA is
planning improvements to the guidance document "Recommendations for
the Application of Municipal Wastewater Sludges on Land", and is
providing quality assistance to local municipalities.
Ohio
The Ohio sludge management program continues to be hampered by
fragmentation. The majority of project specific implementation
activity is disseminated to the several District Offices as well as
administrated by the Ohio Air, Land, and Wastewater Operating
Divisions. There is little likelihood that changes will take place
within the Ohio sludge management program pending the promulgation of
the Federal sludge program regulations. Improvement activity has
given way to a cautious wait-and-see position.
Wisconsin
The Wisconsin sludge management program continues to be a positive and
effective force in the implementation of practices throughout the
State toward the beneficial uses of sludge. The State sludge coordinator
1s active and involved in the preparation of the new Federal sludge
program regulations and has contributed significantly toward asserting
the States viewpoints as the preparation of the new regulations went
forth. WDNR is currently hiring new staff with which to implement
Improvements not only within the current State program, but also to
place into effect the new Federal sludge program regulations, when
promulgated.
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ACTIVITY 3: Manage the Program to Ensure Priority Legislative Requirements
are Effectively Implemented.
Qualitative Measure (A-l): Is the Region/delegated State management approach
achieving maximum utilization of I/A set-aside (page A-53)?
The States of Illinois, Minnesota, Ohio and Wisconsin did not lose any FY 84
I/A set-aside. These States anticipate obligation of all FY 85 I/A set-aside
funds.
Indiana lost a significant portion of the FY 84 alternative set-aside due to
the funding of a large number of conventional projects listed at the upper
portion of the State Project Priority List (PPL). The State has modified its
priority system to allow funding of more rural I/A projects and has stepped
up efforts to promote the use of I/A projects which will minimize if not
eliminate any loss of FY 85 I/A set-aside.
The State of Michigan did not lose any FY 84 I/A set-aside, but anticipates
losing a minimum amount of set-aside for FY 85. Although it encourages the
use of I/A technologies by way of obligating all of its small community set-
aside funds (projects are at least 50 percent Innovative or alternative)
and as part of facilities planning reviews, assuring the consideration of I/A
alternatives, the State does not have provisions in the project priority
system to advance I/A projects listed on the PPL nor does it make any special
efforts to ensure obligation of all I/A funds. The issue, from the State of
Michigan's point of view, is related to an inconsistency in objectives between
obligating all I/A funds and directing CG funds to the highest priority environ-
mental needs. As such, the State recommends the legislative and regulatory
provisions be changed to expand the small community set-aside concept, and
eliminate the I/A set-aside. Under the State-recommended plan, the 20 percent
bonus for I/A components would still apply, and would be an incentive for com-
munities to assure I/A alternatives are considered in the facilities planning
process.
Qualitative Measure (A-2): What criteria does the Region utilize to ensure
consistent, high quality designations of I/A technology (page A-53)?
Subsequent to the August 20, 1984 GAO Report on innovative technology desig-
nations, the Region has taken steps to ensure that project files are complete
and clearly document Innovative (and alternative) technology designations.
These steps include - (1) expansion of the Innovative (and alternative) tech-
nology reviews and designation memoranda to include either the discussion of
or reference to all applicable innovative technology criteria, technological
risk assessment, detailed description of the proposed technology, State
agency recommendation, and documents reviewed; (2) coordination with EPA/WERL
1n terms of either their review or analysis of the specific proposed tech-
nology by means of telephone conversations or written memoranda; (3) Increase
1n the number of precertlficatlon reviews and documentation of this Region's
positions taken on projects which are controversial in terms of National,
Regional, or State perspective; (4) with respect to those States where dele-
gation agreements for I/A technology reviews have been formalized, Initiation
-------
of oversight/program management and periodic reviews of State-reviewed inno-
vative (and alternative) technology designations to ensure that those States
can benefit from current national and regional guidance on applications of
specific technologies; and (5) regular involvement of first, second (and
other, 1f appropriate,) management levels in finalizing any Innovative (and
alternative) technology designations.
8
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ACTIVITY 3
Qualitative Measure (B-l): (From the FY 84 Annual Value Engineering Summary
Report - per Headquarters instructions)
VE Recommendations VE Recommendations Implemented
State in Millions of $ in Millions of $ _J
IL 8.5 2.1
IN 11.9 . 5.0
MI 13.9 -2<--"'5.2
MN 2.6 ' 0.6
OH 21.3 11.1
HI 20.3 2.3
TOTAL 78.5 ' 26.3 Average 33.5
In the current delegation agreements with the States in the Region, the States
have not been asked to report what percentage of VE recommendations were im-
plemented for the annual report to EPA Headquarters; the delegation agreements
will need to be modified to include same.
Qualitative Measure (B-2):
The VE program has been delegated to each State in the Region except Indiana.
VE training was provided to the State of Indiana in December 1984. The con-
sensus is that delegation of the VE program to Indiana will take place during
the third quarter of FY 85. This decision will be made after an evaluation
of Indiana's efforts in reviewing two additional VE reports.
To date, there have been no VE studies reviewed during FY 85. Tracking of
those projects needing VE studies for FY 85 awards is being done by the States.
No problems are anticipated to prevent meeting the Regional obligations pro-
jections.
The Region has scheduled a performance evaluation 6f the Wisconsin VE program
this August, since Wisconsin has the lowest percentage of VE recommendations
implemented of all the states. The intent is to ensure that the state is
making sufficient efforts to maximize project cost savings on each VE project,
and to highlight any potential obstacles to a successful VE program in the State.
Based on the information from the Annual Value Engineering Summary Report,
only 5 of the 18 projects that had VE studies, had two or more VE workshops
completed. Although the scope of the VE effort depends on the size and
complexity of the facilities, the EPA guidance anticipates that two VE studies
are normally performed on $10 million projects. This may be an emerging
trend in the Region, which could effect the success of the VE program in the
future. The Region is concerned with this situation and will have discussions
with the States to examine the situations and take action as necessary.
-------
ACTIVITY 3: Manage the Program to Ensure Priority Legislative Requirements
are Effectively Implemented.
Qualitative Measure (C-l): Have the Region and States taken steps to ensure
that grantees have established programs to perform the 1-year certification
on projects funded after December 29, 1981 (page A-54)?
The Region tracks initiation of operation (N7) and project perfor-
mance certification (KA) dates for projects on the GICS system. All
Region V States have been notified that the$e-#ata elements must be
kept current and updated regularly. For most Region V States, target
dates for N7 and KA are established and included in the schedules
negotiated with applicants prior to grant award. Upon grant award, -
these dates are entered into GICS. The States then monitor the dates
to make sure that the .grantee is following its schedule. Regio'n'V
employs a quarterly exception report as a basis for follow-up contacts
with States to assure that overdue events are investigated and corrected
by timely State action.
Regionally, in FY 85, the Municipal Engineering Section (MES) is perform-
ing a Special Evaluation Project (SEP) on the project performance certi-
fication requirements. Through the SEP, it is intended to: (1) ascertain
whether the legislative requirements are being implemented and (2) begin
an assessment of the effects of the new requirement. The information and
knowledge acquired by the various State agencies will be shared and dis-
seminated so that Regional improvements can be instituted in this program
area. A mid-year SEP report (copy attached), prepared by the MES, pro-
vides greater detail not only on some of the items presented here but also
on other aspects of the project performance certification process.
Generally, prior to grant award, grantees are notified by Region V States
that they must comply with the project performance certification require-
ments. Proposed A/E subagreements are reviewed hy the States to assure
that appropriate training, performance evaluation and certification sup-
port services are included. The States review.Final Plans of Operation
to determine that project performance certification activities are duely
integrated into project schedules. COE and State project inspectors
ascertain and report these activities as they occur.
Grantees that received grants prior to the promulgation of program regu-
lations that established the specific performance certification services
requirements were contacted by States, informed of the requirements and
are being assisted to establish programs to perform the 1-year certifi-
cation activities. This activity, ongoing since 1983, is now complete
in all Region V States excepting Indiana and Michigan.
The Table on the following page presents a statistical summary of certi-
fication program status in Region V. Five affirmative certifications
have been received. No non-affirmative certifications have been reported
to date.
10
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KUOtLI rtKrUK,,MnLt LtKIIUCAlIUN
MID-YEAR STATISTICAL SUMMARY
IL
IN
MI
MN
OH
WI
TOTAL
nts awarded ..
fiscal year
82/09/30
83/09/30
84/09/30
Present
•ks 1n 1st Year Operation
-get (Estimated at Oo / Ql)
Qo
Ql
02
Q3
04
'ks 1n 1st Year Operation
ual
Qo
Ql
Q2
* Certified
-get •Cumulative
;t1mated at Qo / Ql)
Qo
Ql
Q2
Q3
04
•ks CeHfled
ual - Cumulative
Qo
Ql
Q2
tlflcatlons Overdue
Qo
Ql
02
I: Oo « 09/31/84
17
61
46
2
126
(21/12)
13
(39/29)
28
(50/38)
1 36
(64/55)
53
(80/68)
65
5
6
20
(2/1)
1
(2/2)
2
(2/2)
4
(8/8)
10
(16/12)
13
0
1
1
1
1
1
9
21
16
0
46
(1/2)
1
(1/3)
1
(3/5)
4
(8/5)
13
(8/5)
16
1
1
2
(0/0)
0
(0/0)
0
(0/0)
0
(1/1)
1
(1/2)
1
0
0
0
0
0
0
6
21
27
0
54
(7/3). .-
6 '
(11/7)
8
(12/8)
10
(16/14)
16
(18/18)
20
2
4
6
(0/0)
0
(0/0)
2
(0/0)
. 2
(2/2)
4
(3/3)
6
0
0
0
1
2
2
6
30
27
2
65
^3/2)
0
(10/9)
4
(11/11)
7
(15/13)
9
(20/19)
17
0
0
4
.(1/0)
0
(1/0)
0
(1/0)
• 0
(1/0)
0
(6/2)
0
0
0
0
0
0
0
26
22
34
3
82
(3/3)
2
(6/6)
5
(6/6)
5
(13/13)
13
(21/20)
28
0
3
4
(1/2)
2
(1/2)
2
(V2)
2
(3/3)
3
(4/3)
3
1
1
1
1
1
1
9
11
16
6
42
(6/6)
6
(17/17)
12 -
,07/17)
14
(19/19)
18
(21/20)
19
2
2
4
(2/2)
2
(3/3)
3
(4/5)
5
(5/6)
6
(5/6)
6
2
3
3
0
0
2
73
166
166
ID
415
(41/28)
28
(84/71)
58
(99/95)
76
(135/119)
122
(168/150)
165
10
16
40
(4/5)
6
(7/7)
9
(8/9)
13
(20/20)
24
(35/28)
29
3
5
5
4
4
7
Ql • 12/31/84
Q2 • 3/31/85
lOa
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Qualitative Measure (C-2): What strategies or programs have been developed
by the Region and Spates to address non-affirmative certification?
Currently, Minnesota and Illinois have written procedures and strate-
gies in place to deal with this issue. Wisconsin and Ohio have draft
strategies, Michigan and Indiana are in the process of assembling a
strategy to deal with the certification process, including non-affirma-
tive certifications.
Generally, the State strategies that have been submitted to the Region
provide that prior to grant award, the grantees are notified by the
state that they must comply with the project^er-formance certification
requirements. This entails the state establishing project performance
standards, to be agreed to by the grantee, as well as reviewing proposed
A/E contracts (generally with the prime A/E) for services to be performed
in conjunction with the certification. Generally, project performance
standards are established during plan and specification review.*"'?erform-
ance standards are documented by individual States: (See SEP mid-year
report for details).
Grant agreements incorporate schedules that identify target dates of
initiation of operation and certification. Target dates are verified by
States during Final Plan of Operation review and at the point of 90 per-
cent project completion. Grantees are required to report the actual date
of initiation of operation in writing and the actual date is confirmed
by COE/State inspectors.
During the construction period on the project, the COE/State inspectors
keep the central offices of the states informed on the progress of the
construction and, accordingly, the projects status with respect to its
schedule.
Region V States enter initiation of operation (N7) and certification (KA)
dates in GICS, monitor grantees schedule compliance and update GICS data
as appropriate. The Region employs a quarterly exception report for
management purposes.
«
A couple of the states have indicated that they and/or the COE will be
taking an active role in assisting the grantee during the 1-year certifi-
cation period. This assistance would take the form of special inspections,
meetings with the grantee, etc.
Grantee compliance with discharge-related performance standards is monitored
by State review of discharge monitoring reports. State strategies provide
for coordination of grant administration and compliance/enforcement actions
if significant non-compliance occurs for a prolonged period after initia-
tion of operation.
To date, the Region has had five affirmative certifications and no non-
affirmative certifications. However, the states have indicated through
their strategies that should a non-affirmative certification be issued, the
11
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grantee will be required (pursuant to 40 CFR 35.2218) to submit a cor-
rective action report as well as a schedule for undertaking the correc-
tive action necessary to bring the project into compliance. In general,
these items are required by the states at the time of the nonaffirmative
certification itself (1 year after initiation of operation), although
Minnesota, in its current guidelines, provides the grantee an additional
30 days.
All of the states (with the exception of Indiana) have indicated that
once a corrective action report and schedul£lTave been submitted to the
state by the grantee, further coordination will be undertaken with the
states' compliance and/or enforcement staff to ensure consistency with
compliance schedules and enforcement actions.
lla
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FY 85 Mid-Year Report
on the
Special Evaluation Project
on
Project Performance Certification Requirements
A. Introduction
1. Background
The 1-year project performance certification (PPC) requirement was
added to the requirements of the construction grants program through
section 204(d) of the Clean Water Act on December 29, 1981. Any
Step 3 or Step 2+3 grant award made on or after this date 1s subject
to the PPC requirement. The goal of the PPC requirement 1s to assure
that Federally funded treatment works are meeting, and will continue
to meet, design specifications and effluent limitations at the end
of the first year of operation.
2. Purpose
The FY 85 Special Evaluation Project (SEP) on PPC requirements has a
twofold purpose: (1) To ascertain whether this legislative require-
ment 1s being implemented, and (2) To begin an assessment of the ef-
fects of the new requirement. The Information and knowledge acquired
by the various State agencies will be shared and disseminated, so
that Regional Improvements can be instituted 1n this program area.
3. Scope of Effort on SEP
The first focus of this SEP has been to collect and analyze quantita-
tive program data on municipal treatment projects that are subject
to PPC requirements. At the beginning of FY 85, the'universe of
projects affected by this requirement was Identified. Since then, an
ongoing attempt has been made to get the States to update this universe
of projects 1n the Grants Information and Control System (GICS).
The second focus on PPC's has been to obtain some qualitative data on
the various aspects of this legislative requirement. Towards this end,
a questionnaire was developed and sent to the States and the COE,
requesting Information on those projects that are, or are targeted to
be. In operation at the present time and scheduled for performance
certification by or before the end of FY 85. The SEP report on PPC's
covers this class of projects. At the present time, the States of
Wisconsin, Indiana, and Minnesota have returned their questionnaires.
An on-s1te visit was made to obtain the requested Information from
the State of Illinois.
12
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Although the questionnaire covers all aspects of the project performance
certification requirements, this report will focus on only the services to
be performed by the A/E (or through force account) during the 1-year period
and the establishment of the performance standards. This is because only
five of the 21 projects in our universe (for which questionnaires were filled
out) have completed the 1-year certification period and, as such, an analysis
of the data relating to the certification process itself would be inappropri-
ate at this time. However, an analysis of the complete project performance
certification system will be done at the end of FY 85 when the projects in our
universe will have all completed the 1-year certification process.
B. Findings
1. Procedures followed on .projects in SEP universe (State-by-State)
a) Project Performance Period Services
Indiana
Currently, Indiana has only one certified project. This is a sewer rehabili-
tation project. The A/E did not have project performance period services
included in his original contract, nor was an amendment to include these
services processed. There was no dollar amount involved in the project per-
formance period services. Essentially, the A/E certified to the grantee that
the work was performed in accordance with design specifications and that it
was complete. No start-up services were provided.
Wisconsin
Wisconsin has five projects that are in operation at the present time and are
either certified or targeted to be certified by the end of FY 85. Three of
these five projects have been certified. None of the certified projects had
project performance period services included in either the original A/E con-
tract or contract amendments, although one of the projects had a statement
in their certification that some project performance period services had been
performed. Of the two remaining projects, one had start-up services lumped
together with project performance period services as start-up services and
incorporated by an amendment to the original A/E contract. The other was
performing project performance period services by force account. In general,
most of these projects did not appear to have had project performance period
services, although since most of these projects were sewer projects, only
minimal services would have been required.
Minnesota
Minnesota has three projects that fall into the universe of projects examined
for this SEP. All of these projects have project performance period services
incorporated by amendments to the original contracts. The services are being
performed by the prime Step 3 A/E for two of the projects. Services for the
third project are being done by force account. The scope of the services was
similar for all three projects, and consisted of the following: (1) Orient
13
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and train staff, (2) optimization of treatment facilities, (3) revise 0AM
manual, (4) direct operation of project to assure performance standards are
met, and (5) provide an evaluation report at the end of the 1-year performance
period. It appears that start-up services were also provided for these projects,
and that these services were similar to the project performance period services.
mino1s
Illinois has 12 projects that fall Into the universe of projects examined for
this SEP. Four of these projects did not have project performance period
services, although one of these four did have start-up services. All four of
these projects Involved sewer work. The remaining eight projects all had
project performance period services Incorporated either 1n the original A/E
contract, or thru an amendment to the A/E contract. The project performance
period services were performed by the prime Step 3 A/E (except for one case
of force account being used). Most of these projects also had start-up
services. The start-up services generally Included operation and maintenance
type duties while the project performance period services Included a follow-up
Inspection 1 year after initiation of operation and the preparation of a report
on the ability of the project to meet Its performance standards.
b) Performance Standards
Indiana
The single project 1n Indiana which is Included in our project universe had
Its project performance standard formally Incorporated into the grant through
the plan and specification approval letter. Accordingly, the standards are
Identified 1n the plans and specifications and also the I/I report. These
standards were expressed 1n terms of sewer tests.
Wisconsin
Out of the five projects 1n Wisconsin which fall 1n our project universe,
two have had standards formally Incorporated Into the grant (both having been
approved verbally). Others will be formalized through some type of letter
agreement. The project performance standards to which the grantees will certify
are generally identified 1n the "Report on the Examination of Plans and Speci-
fications." The standards are or will address such things as: (1) WWTP discharge
In terms of effluent limits at design year flows and loadings, (2) sewer separa-
tion 1n terms of flow, or (3) sewer construction in terms of sewer tests.
Minnesota
As noted previously, Minnesota has three projects which fall within our project
universe. Although the project performance standards have yet to be formally
Incorporated Into the grants (e.g. through the award letter, plan and specifi-
cation approval letter, etc.), the State has indicated that 1t will be doing so
by Issuing plan and specification amended approval letters. These standards
will reference NPDES permits for treatment plant construction and State Disposal
14
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Permits for septic tank and drain field construction. The standards will
address such things as: (1) WWTP discharge 1n terms of effluent limits at
design year flows and loadings, (2) treatment process equipment 1n terms of
equipment performance specifications and tests, or 3) stabilization pond
construction In terms of groundwater protection and non-degradation at
Initial year flows and loads.
Illinois
Illinois has 12 projects which fall Into our project universe, seven of which
Involve sewer rehabilitation. For most of these projects, the project per-
formance standards are formally made a part of the grant In two ways. First,
they are Included 1n the State Priority Certification or an amended certifi-
cation as an Item reading something such as: "Applicable project performance
standards for the useful life of the project are as follows:." The schedule
1n the certification also includes project performance certification activi-
ties. The second way that the standards are made a part of the grant is
through the "Resolution Regarding Project Performance Standards" which is sub-
mitted by the grantee. This resolution, although somewhat generic 1n nature,
can be easily adopted to fit the particulars of a project. The general reso-
lution gives load limits based on design average and maximum flows, and effluent
limits as identified in the NPDES permit (for WWTP's). and/or states (for sewer
rehabilitation projects) that "Under design conditions, there shall be no
overflows, surcharges, or basement backups associated with the separate sani-
tary collection system." In most cases, the resolution was submitted after
the project was under construction, based upon letters from the State detailing
project performance certification requirements and requesting that the grantee
submit any applicable Items not yet submitted.
2. Comparison with Currently Established Procedures
Indiana
Indiana does not yet have any written guidelines with respect to project per-
formance certification procedures. Accordingly, no comparison with the above
findings can be made.
Wisconsin
The WDNR has just recently (October 1984) developed guidelines regarding project
performance procedures in the form of a Project Performance Certification sec-
tion to Its Procedures Manual, although the section has not yet been finalized.
This section contains, 1n part, guidelines with respect to A/E services to be
performed during the 1-year period and also a proposed resolution regarding the
project performance standards which will Identify the standards agreed to by
the State and the grantee. Since only two of the five projects have work yet
to be completed and since these projects are slgnficantly Into the 1-year per-
formance period, any eventual f1nalizat1on of the Project Performance Certifica-
tion section will have a minimal Impact with respect to the areas covered by
this report (especially with regard to the A/E services to be performed during
the 1-year period). Accordingly, a direct comparison of the findings, as noted
1n Part B above, with the proposed section 1s Inappropriate.
15
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M1nnesota
In viewing our findings on the projects, within our project universe, with
respect to the MPCA's June 1984 Performance Certification Guidelines, 1t
appears that the findings are In accordance with criteria established In the
guidelines. The scope of services Included 1n the A/E contracts, with respect
to the project performance certification requirements, are as suggested in the
guidelines and are either being performed by the prime Step 3 A/E (as suggested)
or through force account. In addition, even though the performance standards
have not yet been formally Incorporated Into the grants, the guidelines do not
give a time frame for the formalIzatlon.
Illinois
In the Spring of 1983, the IEPA developed project performance certification
guidelines. A comparison of the above findings with the guidelines shows that
while there were minor variations in the projects reviewed, the procedures
established by the State to Implement this legislative requirement were gen-
erally followed. The project performance period services contained in the A/E
contracts were generally as suggested 1n the guidelines and most of the project
files contained a "Resolution Regarding Project Performance Standards." A
major reason for the lack of subject Items 1n some projects appears to be the
age of the projects with respect to the time at which the State guidelines were
developed. All of the newer grants require project performance period services
to be Included 1n the A/E contract submitted with the grant application and also
require the Resolution to be submitted with the grant application.
C. Conclusion
Even though there is some variation among the projects 1n our project uni-
verse, with regard to the services performed during the project performance
certification period and to the establishment of project performance stand-
ards, there appears to be a trend toward a greater uniformity with regard
to these Items on the newer projects. Many of the projects which did not
Include project performance period services or Included only some services,
were either older projects which were completed or substantially under way
before guidance was issued, or were sewer rehabilitation projects which
Inherently required less services to meet the project performance certifi-
cation requirements. Currently, however, those states which have developed
guidelines on performance certification have, in general, Included, as sug-
gested services, those Hems Identified 1n 40 CFR 33.2218(b) (with some
explanation of what these Items entail). As with the services, the vari-
ation with regard to the establishment and formal1zation of performance
standards on those projects in our universe appears to be the result of the
age of the projects with respect to the time of the development of the guide-
lines by the various states. Since the Implementation of Its guidelines,
however, IEPA has required that a resolution, establishing the standards, be
16
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included in the grant application. A similar type of resolution is also
being proposed by the WDNR (as a part of its guidelines) for inclusion in
the grant application. OEPA is proposing, as part of their guidelines,
to mail letters to prospective grantees proposing performance standards
to be accepted by the grantee (in its proposed form or revised through
negotiations with OEPA) prior to the grant award. We feel that these
are good procedures with respect to the establishment of the performance
standards and encourage all of the states to, in some way, ensure that the
standards are established prior to grant award. By doing so, it makes
the grantee (and the A/E) aware, at a time when adjustments can easily
be made, of what is required of them during the certification process. In
general, it also appears that the standards which have been established
are appropriate for the projects.
17
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ACTIVITY 4 QUALITATIVE MEASURE A
The Region will conduct annual reviews of all States to see how those
States have Implemented the Financial and Management Capability Policy
(F/KCP) and whether projects are technologically appropriate. The Region
Is actively participating in a national Internal control review (ICR) to
assess State compliance with the F/MCP. This activity will be concluded
1n the third quarter.
Of the appropriate technology reviews conducted to date in Illinois,
Michigan* and Ohio we have concluded that, in general, those States have
performed in an acceptable manner. Based on staff contacts it 1s our under-
standing that all States have implemented the F/MCP to one extent or another.
In addition to the above we have -
0 Participated in the development of both the Policy and its
Implementation procedures.
0 Provided detailed guidance in context of concept and checklists
to our States.
0 Specifically incorporated financial and management capability
review concerns into the overall facilities planning review
conducted as part of the delegation reviews.
0 Provided technical assistance, co-sponsored workshops, and
actively encouraged low cost technologies Including flow reduction
and water conservation as alternatives to capital construction.
The above was discussed in some detail during the HQ ICR review of the
Region.
18
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ACTIVITY 4;
Qualitative Measure (B): How does the Region/State screen projects for
potential problems, Including Inappropriate technology? What follow-up
Is provided on problem projects so Identified? What types of problems
appear to be recurring 1n terms of financial capability and appropriate
technology and what measures are being applied to other projects to avoid
similar situations 1n the future (A-55)?
Technologies that have been Identified as potentially not being able
to meet project performance expectations are candidates for analysis
as a special Evaluation Project (SEP). The SEP objectives are to
analyze the nature, scope, Impact and causes of failure as well as
addressing Implications for future projects as well as corrective
measures at existing Installations. Reports have been completed on
ultra-violet disinfection as well as land treatment of wastewater
systems. Reports are currently being prepared addressing vacuum
assisted sludge drying beds, alternative conveyance systems, and swirl
concentrators.
The UXB printouts were sent to each State on 12/14/84. While there
has been little reaction from the States to this latest printout,
the Region, on 2/26/85, responded to HQ 1n a lengthy memo discussing
the limitations of the UXB printout. Subsequent discussions with
several States have confirmed the uselessness of the printouts.
Reviews conducted by the Region of delegated State reviews of facil-
ity plans have generally concluded that appropriate technologies
are being selected. However, there will always be some projects 1n
which the cost-effective solution is financially unimplementable,
I.e., there are some problems for which there are no good solutions.
19
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ACTIVITY 6: Evaluate Delegated CSO Projects
There have been no CSO projects proposed for funding under
Section 201(n)(1) to date. To our knowledge none are being
proposed for the balance of the fiscal year.
20
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OBJECTIVE: ENSURE EFFECTIVE CONSTRUCTION AND PREVENT BACKLOGS.
ACTIVITY 1: ELIMINATE BACKLOGS AND MANAGE GRANTS EFFICIENCY.
SUBACTIVITY 1: OVERALL PROGRAM MANAGEMENT.
Qualitative Measure A. Do Regions/States have an effective strategy for
managing projects (all steps) from grant award to closeout.
A major objective of the construction grants program was and is to assist in
achieving municipal compliance. Accordingly, with the issuance of the National
Municipal Policy (NMP) and the later media management emphasis on pretreatment,
the Region overtly managed Step 1 grants to mesh the major objective with
those initiatives and encouraged the States correspondingly. This was reflected
in the Region's March 1984 strategy for completing Step 1 and 2 grants, and
provided to Headquarters with last year's mid-year evaluation.
Based on the NMP, increased emphasis has been focused on managing Step 2+3 and
Step 3 projects to and through construction. The Region and States have always
tracked projects from grant award to construction. The COE has generally been
responsible to monitor progress to physical completion or initiation of opera-
tion at which time the environmental results of the construction begin to
pay off. At that point, the project is tracked by the Water Quality Branch,
Compliance Section to ensure that effluent limits are met. The Region is
currently developing a protocol whereby enforcement actions can be utilized
at any time after grant award to and through construction until at least
initiation of operation to get municipal dischargers subject to final effluent
limits as soon as possible.
Management of administrative completions continues to be one of the most
resource intensive management efforts in the Region. After the tremendous push
last fiscal year to meet and exceed the commitment, everyone (Region, State and
COE), took a deep breath to address other activities which were set aside.
The result was a low first quarter accomplishment.
By mid-November, lists of projects and responsibilities for getting actions
accomplished were back in high gear and all parties (Region, State and COE) are
making progress to complete the 31 projects missed in the first two months of
the Fiscal Year. Actual second quarter accomplishments (44) more than doubled
those in the first quarter and it is anticipated the first quarter shortfall
will be substantally reduced in the third quarter. The Region, States and
COE are cautiously optimistic of meeting the end-of-year projections.
The ideas and management concepts which came from the February 1984 workshop are
working, but the activity is extremely resource intensive. •
21
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Qualitative Measure (J). Do the Regions/States take aggressive action
in identifying and resolving problems on delayed projects (all steps)?
The Region reviews the GICS reports on"a bi-weekly, weekly and monthly basis.
Region V Program Managers utilize GICS to work with the states who work with
grantees and engineers to resolve problems. The Regional role is in context
of persuasion, technical assistance, negotiation, overview, etc. The
following are major efforts and accomplishments by Region V States:
IL - The State requires grantees to schedule projects to be under
construction within 9 months. The State contacts grantees at
6 months if construction has not been initiated. Projects
that are not moving forward are considered for possible termi-
nation if swift action is not taken. The COE performs pre-
final construction inspections of projects to determine if pro-
jects conform to schedule. IEPA conducts final inspections to
ensure compliance with effluent limits and sets firm dates for
resolution of deficiencies. The COE and IEPA are emphasizing
to grantees/engineer's the importance of construction schedule
and permit schedules.
The IEPA has initiated aggressive effort to move the remaining
Step i and Step 2 projects to completion. The State projects
that the number of active Step 1 projects will be reduced to 80-
90 by the end of FY 1985. It is expected that only two Step 2
projects will remain active at the end of this fiscal year.
The IEPA is closely monitoring the Step 2+3 projects to ensure
that grantees complete the design portion of the project and
submit approvable plans and specifications to the State. The
IEPA routinely contacts grantees to ensure adherence to project
schedules.
IN - The State has established additional codes to help them monitor
Step 4 grant projects through the completion of P A S. This
procedure has reduced project backlogs. The State also issues
compliance orders consistent with the grant schedule which allows
enforcement actions (as appropriate) when projects get off
shedule during construction. The State has employed a strategy
to address physical completion of Step 1 grants. To date, the
strategy has resulted in completions being ahead of projections.
During the remainder of the year, the State will be concentrating
on municipalities with priority numbers greater than 150 with
active Step 1 grants. The resulting completions and terminations
should result in EPA exceeding projections for the year.
MI - The State and the COE monitor grantee adherence to project
schedules. The MDNR reviews projects and must approve or dis-
approve any significant revisions. Costs for administrative
completion will be addressed during the 1 year performance
period. The State 1s now more actively tracking and pursuing
the completion of Step 142 projects.
MN - The State has 125 Step 1 and 4 Step 2 projects which will not
be physically completed at the end of FY '86.
22
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MN (cont.)
The State has had problems moving projects from design stage to
construction stage. The State acquired a computer in January 1985
and through Jts use has found an improvement in tracking and pro-
gress toward completion.
WI - The State is developing an appropriate tracking mechanism to ensure
quality management of the grant programs. EPA works closely with
the State on a monthly basis to identify and resolve problems
which delay projects. The State's field inspectors visit each pro-
ject under construction at least once a quarter and more fre-
quently during critical states of construction. The State had
assigned one staff person, full-time, to develop and implement a
series of recommendations that deal with construction management
in an attempt to keep projects on schedule.
During the first half of FY 1985, Wisconsin has initiated steps to
identify those Step 1 and Step 2 projects that could be physically
completed during FY 1985. The Bureau of Water Grants (BWG) is work-
ing closely with the Bureau of Wastewater Management to commence the
termination process on Step 1 projects where a no action alternative
was chosen. BWG staff are administratively completing Step 1 and Step
2 projects where the Step 3 project was not Federally funded. WDNR
hopes to administratively complete many of the projects this fiscal
year so that the amount to be tracked in FY 1986 will be small.
OH - The State is proposing a requirement which will direct grantees
to advertise equipment contracts by the time the projects are
75% complete and to finalize the price of small, non-bid items,
no later than 6 months prior to the scheduled date of initiation
of operation. In addition, grant construction costs will be
finalized between initiation of operation and certification. The
State is making a concerted effort to both physically and adminis-
tratively complete as many Step 1 and Step 2 projects as possible.
To accomplish this, OEPA will no longer consider Step 1 and Step
2 grant increase requests, except when phase 1 pre-treatment amend-
ment requests are dated prior to May 1, 1984, and/or when other
amendment requests were received prior to January 1, 1985.
Qualitative Measure K. What actions are the Region taking to ensure that
projects are completed in a timely manner?
Headquarters did a special evaluation of this activity. Our April 2, 1985
response to Headquarter's draft report addresses this subject fully.
23
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GUBACrivm II: Preconstruction Lag
Quantitative Measure (a): Percent of projects (by dollar) in preconstruetion
lag (page A-57)*:
Mid-Year Mid-Year
Target (10% Actual
of Annual (Dollar
Allotment) Amount)
State in Dollars in Lag
Percent
Achieved
bid-Year End-Year
Target (10% Projection
of Annual (Dollar
Allotment) Amount)
In Dollars In Lag
Percent
Expected
see MR 15 and MR 5
Total
SimACTIVITY III: Step 1 and Step 2 Completions
Quantitative Measure (d-1): Number of active Step 1 projects physically completed
or terminated during fiscal year (page A-58):
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Cami tment Actual Achieved Cairo!tment Projection Expected
SEE MR 11 and MR 5
Total
Qualitative Measure (I): Is there a strategy, with time based goals, for
completing Step 1 and Step 2 projects (page A-58)?
See sub activity I, Qualitative Measure A
SUBACTIvrrY IV: Physical Completions
Quantitative Measures (e): Number of Step 3, Step 2+3 and PL 84-660 physical
completions and terminations (page A-58):
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Cowni tment Actual Achieved Carol tment Projection Expected
SEE MR 12 and MR 5
24
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SUBWCTIvm Vi Administrative Collet ions
Quantitative Measures (f): Number of Step 3, Step 2+3 and PL 84-660 admini-
strative completions (page A-58):
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Ccrenitraent Actual Achieved Comitiient Projection iboected
- See MR 13 and MR 5
fetal
Quantitative Heasure (h): Number of administrative completion backlogs
eliminated (page A-59):
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Catmitment Actual Achieved Commitment Projection Expected
- See MR 16 and MR 5
Total
25
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SUBACTIVrry VI: Close outs
Quantitative Measure (g): Nuwber of Step 3, Step 2+3 and PL 84-660 closeouts
(pageA-59):
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Cannitnent Actual Achieved Cannitnent Projection Expected
_ See MR 9
Total
Quantitative Measure (i); Number of closeout backlogs eliminated (page A-59)
Mid-Year Mid-Year Percent End-Year End-Year Percent
State Conmitroent Actual Achieved Conraitnent Projection Expected
See MR 17
Qualitative Question (M): What actions are the Region taking to ensure
that projects are closed out in a timely manner (page A-59)?
The Grants and Finance Branch has the following policy and operating
procedure to ensure that projects are closed in a timely manner.
1. The Grants Management Section has assigned a Grants Assistant
to coordinate the closeout activities including, (a) identification
and location of project files, (b) review of file and supporting
financial documents, (c) preparation of appropriate letters and
(d) maintenance and update of GICS.
2. It is our policy to closeout those projects identified by DIG as
not requiring audit no later than the quarter following the notification
by DIG.
3. Those projects that have been audited are closed out no later than
the quarter following the final determination.
For projects in category 2 or 3 the closeout will usually occur during
the quarter in which the decision is made if it is within the first half
of the quarter. This, of course, assumes availability of the project
file.
26
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SUB&CTIVITY VII: Unliquidated Obligations
Quantitative Measure (b): Percent reduction of unliquidated obligations
in • negotiated group of "•low moving" projects (page A-57):
Estimated Estimated
Mid-Year Mid-Year Estimated End-Year End-Year
Beginning Mid-Year Dollar Percent End-Year Dollar Percent
Project FY 85 ULB FY 85 ULB Reduction Reduction FY 85 ULB Reduction Reduction
See MR 2 and MR 8
fetal
Qualitative Measure (B): Have the Region/States developed profiles of slow
moving/fast moving projects (page A-57)? .
See MR 2
Qualitative Measure (C): Have the Regions and States managed the program to
reduce the total of unnecessary unliquidated balances in slew moving projects
(page A-57)?
See MR 2
Qualitative Measure (D): Are construction schedules in the grant agreement
being achieved (page A-57)?
See sub activity I Overall Program Management
27
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SUBACTIVITY VIII: Contractor Claims
Qualitative Measure (L): What actions have the Regions and States taken
to manage a claims reduction program?
The timely resolution of claims in the construction grants program has been
a concern in Region V for sometime. The resolution of claims was assigned,
in the past, to staff members on a case-by-case basis. For sometime, it
has been apparent to Region V management that this was not satisfactory and
that a long time solution was needed. Also, the number of claims was in-
creasing to the point that a person would have to be hired full time to
handle claims exclusively. In September 1984, an environmental engineer
(Claims Specialist) was hired to provide technical and engineering assistance
and advice to Division staff, state and local government officials and con-
sulting engineers regarding construction claims management, construction
contract administration and construction procurement activities.
Every quarter beginning March 1983, the COE, as requested by Region V, has
been reporting claims activity for all assigned projects in each state.
The COE reports list the grant number, the grantee, the claimant, nature
of claim, amount and status of claim (Potential, Active or Settled). From
these COE reports, a summary is compiled by Region V. The summary lists
the number of claims outstanding in each state and the dollar amount of the
claim. A second summary analyzes the type of claim, frequency, and distribu-
tion in each state. Changes from quarter to quarter are tracked. The latest
EPA reports summarizing the claims activity in Region V are attached and
captioned, "Classification of Claims" and "Summary of Region V Claims." It is
anticipated in the future, that the claims activity summaries will be expanded
to include more meaningful data for determining the effectiveness of the claims
management program.
The OEPA in late 1984 requested assistance from Region V in claims manage-
ment training from Region V. To achieve this goal, a 1-day Regional Claims
Training Seminar was conducted on February 26, 1985, in Columbus, to approxi-
mately 44 attendees from the Region's COE and State offices. Region V pre-
pared a course outline, solicited participation from two COE district offices
(Detroit and Huntington) and asked OEPA to host the Regional Seminar. The
attendees were instructed in field activities, contract language and theories
of recoveries, meritorious claims and eligibility reviews.
EPA Headquarters reports that the Claims Guidance pamphlet has been approved
and will be printed in April for nationwide distribution. Two drafts of the
guidance have already been distributed. The COE and States in Region V have
been contacted and 850 copies have been requested and will serve the Region's
Initial needs.
In October 1984, Headquarters established a national policy to administratively
complete grants notwithstanding any unresolved claims. With this intent in
mind, a Gary Sanitary District grant with an unresolved claim is under review.
It is hoped that a procedure will be established as a result of this review
and that the national policy can be implemented in Region V.
28
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The annual COE/State Evaluation Plan this year will Include the random sam-
pling of grantees' B/C comments and responses and the outstanding claims,
1f any. The purpose will be to determine the Implementation or lack of
Implementation of COE B/C comments and responses correlated to the claims
outstanding.
Region V 1s serving with Headquarters 1n a new organization known as the
Deep Foundations Construction Industry Roundtable. The eminent group of
people from throughout the U.S. and allied with the construction Industry,
»eets every three months 1n Chicago. The organization's long range goal is
to resolve construction claims via the inclusion of a mediation clause in
contracts.
REGIONAL CONCERNS
Region V 1s aware that the number of claims and the dollar amount of those
claims 1s Increasing and as such represents a potentially significant financial
Impact on the construction grants program.
Construction contracts recommending arbitration for disputes 1s another
growing concern 1n the Region. The decisions from arbitration are 1n most
cases, awarded without adequate documentation and Information relating to the
claim costs requested and the costs awarded.
29
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SUBACTIVITY IX; CHE's and PMC's
Quantitative Measure (c): Number of full-extended CME's:
State
IL
IN
MI
MN
OH
WI
Mid-Year
Commitment
0
1
0
2
2
0
Mid-Year
Actual
0
1
0
2
2
0 '
Percent
Achieved
100%
100%
100%
100%
100%
100%
End-Year
Commitment
2
2
2
2
3
1
End-Year
Projection
2
2
2
2
3
1
Percent
Expected
100%
100%
100%
100%
100%
100%
Total 5 5100%1212100%
All CME's in the region are being performed under the direction of a team
leader who is a technical specialist in the grant program with over 15 years
of grant program experience. To date 11 CME's have been conducted. Other
members of the team are represented by the COE and our Financial Management
Branch.
The COE conducts PMC's in Region V. Some States may also attend PMC's but
they do not have the primary responsibility to conduct PMC's (except for
Wisconsin in the non-Milwaukee area). The training and expertise of the PMC
team members varies from COE District to COE District, but as a whole, the
expertise and training of the team members is of a high quality, so that well-
structured and beneficial PMC's are conducted in Region V.
All CME's are conducted in accordance with the guidance provided in the
September 1983, Construction Management Evaluation and Project Management
Conference Manual. All findings during the conduct of the CME are discussed
during the CME exit briefing. All data are then assembled into a draft report
and submitted to the grantee, etc., for comments prior to issuing as a final
report. Once the text has been agreed upon, it is issued as a final. The
report is then Issued with a 30-day response as to what actions will be taken
by the grantee to the action items in the report. These action items are
followed up by all parties involved with the project, i.e., USEPA, COE and
States. Very favorable results have been achieved.
Approximately 120 grantee opinion surveys on PMC's and inspections were sent
out, received and tabulated from 5 out of the 6 Region V States (Illinois,
Michigan, Ohio, Wisconsin, and Minnesota). The overall consensus, by the
grantees, is that PMC's are a very valuable exercise, and that they are defin-
itely a help to grantees in the Construction Grants Program.
32
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The only time that a PMC would not be conducted on a Step 3 or Step 2+3
project, would be 1f the grantee has already had a PMC conducted (I.e.,
previous grant), or 1f the grantee has been 1n the grants program pre-
viously but had not had a PMC, 1n which case a reduced scope PMC would be
conducted.
During the conduct of a CME all program matters are discussed and outlined
to the grantee. In most CME's, the grantees are doing an acceptable manage-
ment of the related construction activities, but are lax on the awareness of
needing to: set up a property management system, prepare for the 1-year
operating certification, provide a complete record master file for audit
upon completion of the project, etc. These CME's have been very helpful for
all grantees to obtain this Information. The CME also provides grantees with
a contact person on the various areas of the program.
To date we have conducted'only one CME for which a PMC was held. There was
evidence that the PMC was helpful to the grantee In organizing its records
system. The grantee was also much more familiar with program matters relating
to Its responsibilities.
Regional Contact
Arwin W. Hothan - Technical Specialist (Team Leader) - phone 312-886-0270
Regional Concerns/Issues
The performance expectation 1n the FY 86 guidance is to conduct 24 CME's in
the Region. This is twice the number being performed in FY 85 which is
pretty much a full time job for the experienced team leader. At the present
the CME's are averaging approximately 23 man-days to complete. Our ability
to commit to perform at the expectation level 1n FY 86 is very questionable.
33
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OBJECTIVES: Ensure Effective Construction and Prevent Back Logs (Continued)
ACTIVITY 2: Establish State/Regional Grant Appeal Resolution Procedures and
Tracking Systems to Monitor States
Each State 1n the Region has a system (although not all are final) for dealing
with requests for review of decisions. In all cases, managers are Involved
that were not privy to all the details when the original decision was made. In
one State, a three-member management team takes a fresh look at all the facts
and renders a final decision. In another, the supervisor of the staff person
who made the original decision does a thorough review and prepares the final
decision. In all cases, the State tracks the requests and generally Issues a
final decision within 45 days.
When a request for review of a State decision 1s received by USEPA, 1t 1s
entered on a log maintained by the Municipal Facilities Branch (MFB). The log
1s updated monthly. The Branch Chief 1s the Disputes Decision Official and
takes an active Interest 1n the resolution of the dispute. Making a final
decision has been taking several months because grantees seldom present a
complete request the first time.
Requests for review of dispute decisions are handled in accordance with Region
Procedures involving the Office of Regional Counsel and the dispute decision
official operating program Division Director's Office, and as necessary, the
Deputy Regional Administrator. In addition, the MFB has been providing an
increasingly greater level of effort on technical and programmatic Issues sur-
faced 1n audit reports where the Chief of the Grants and Financial Management
Branch is the designated dispute decision offical on audit decisions.
Resolutions of disputes at EPA are presently taking more time than desirable.
Additional emphasis 1s being placed on setting deadlines for grantee submissions
and for making the final decision based on best available information.
ISSUE:
Reconsiderations require a very significant expenditure of resources for the
State and for the Region (the program office and Regional Counsel). For
grantees, the costs of requesting a re-determination are very limited, and the
potential benefits 1n some cases are very great. Some requests for consider-
ation have little merit and involve attempts to maximize Federal participation
1n public works expenditures. This situation creates a significant resource
drain, with limited program benefits. A regulatory mechanism to discourage
"frivolous" reconsideration requests may be desirable.
34
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ACTIVITY 3: Oversee the Corps IAG to see that Workplan Commitments are
Achieved.
Quantitative Measure (a): Percent of Corps Ut11ilzat1on vs; Target:
The Corps outputs, expenditures and FTE's are within i 10% of target except
as follows:
NCD (North Central Division)
There is a 16% shortfall in B/C reviews, because Minnesota (St. Paul
District) did not meet their mid-year projection. They are expected to
clear up their present backlog and meet their end-of-year projection.
There 1s a 46% shortfall in PMC's. This is due to Michigan, (Detroit
District) Minnesota, and Wisconsin (St. Paul District) falling short of
their mid-year projections. Not enough new grants were awarded in the
first two quarters to meet the PMC mid-year projection. A PMC has,
however, been performed for each new construction start.
There is a 37% shortfall in administrative closeouts. This is due to
both Wisconsin (St. Paul District) and Illinois (Chicago District) not
meeting their mid-year projection. In both States, constrution related
problems have delayed the completion of several projects. In Illinois,
the Corps also needs to receive several final payment documents from the
the State, before administratively closing out several projects. Wisconsin
expects to meet its end-of-year projection.
On-site presence has been exceeded by 22%. This is due to Illinois (Chicago
District) underestimating their on-site presence needs.
ORD (Ohio River Division)
There 1s a 31% shortfall in B/C reviews, due to Ohio (Huntington District)
not meeting their mid-year projection. This is due to the fact that the
Corps did not receive as many plans and specifications for review as they
had anticipated. There 1s no backlog at this time.
Qualitative Measure (A-l): Is the Region overseeing the Corps IAG to ensure
that negotiated resource and output commitments are met?
The review mechanism that the Region employs to ensure the quality of nego-
tiated outputs consists of annual Monitoring and Evaluation Workplans,
which outline and describe the methodology and criteria to be used in the
monitoring and evaluation of key program areas. Outputs are evaluated
after-the-fact generally and Improvements are made where necessary on future
products. Routine communications also track quality and program management.
Although all Corps outputs effect the Region's ability to meet Us commit-
ments to a certain extent, the most critical Corps outputs 1n this context
are final Inspections, (leading to physical completions) and administrative
35
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closeouts (leading to administrative completions). Each of these Corps activ-
ities must be completed before further State actions can be taken. In terms
of final Inspections, the Corps essentially met Its projections, but a short-
fall was experienced 1n administrative closeouts. Although, the shortfall
was due to circumstances beyond the COE's control, 1t did effect the Region's
ability to meet Its mid-year projection for administrative completions.
Regional Contact: John Kelley, Chief, Program Management Section, 353-2123.
36
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Mid-Year Evaluation of Region V Water Program
JIONAL DIRECTIONS: IMPROVE STATE/REGIONAL PROGRAM MANAGEMENT
rriYITY 1: COMPLETE DELEGATION OF THE CONSTRUCTION GRANTS PROGRAM TO THE
STATES
ialys1s:
Progress toward 100% delegation In Region V has been good. Five of the
six States are almost entirely delegated. Only assorted delegations
Involving bid protest appeals, engineering performance certifications,
AT reviews, and audit resolution remain to be completed 1n these States,
and the majority of these delegations are scheduled for the second half
of FY 85. Indiana 1s running behind the other five States, simply because
CG program delegation was not feasible until September 1983. The current
schedule for Indiana calls for tasks to be delegated through FY 1986.
There are two possible obstacles to continued delegation 1n Indiana. The
first 1s a potential reorganization 1n State government that would establish
a new State environmental agency. (Pollution control programs are now
In the Indiana State Board of Health.) The second problem Involves a
continuing Inability on the part of the State to fund Its share of the
the State water pollution control program supported by the 106 grant.
These potential oblstacles will be monitored closely 1n the coming months
1n an attempt to keep the delegation process on schedule.
An area on which the Region will be focusing 1n the second half of FY
1985 Is the updating of Delegation Agreements. In four States (Illinois,
Michigan, Ohio, and Wisconsin) the Agreements are being fundamentally
revised. The structure will be changed to make the Agreements more
concise and more flexible, and procedures manuals will be used to back
up the Agreements and provide the necessary details on program Implementa-
tion. These efforts will result In fully updated documents that reflect
current policies, procedures, and regulations. It Is expected that this
work will be completed 1n all of the four States by the end of the
fiscal year.
In Minnesota the bulk of the Delegation Agreement has been formally
updated, or revisions have been negotiated and are In final form. The
Indiana Agreement Is essentially current.
GICS 1s used extensively by the Region 1n the management of the grants
program. Computer runs regularly provide data on project activity and
project status, pre-construction lags, and physical and administrative
completions. GICS Is used to varying degrees by the States. To Increase
States' awareness of GICS Region V conducts regularly-scheduled conference
calls during which program performance, based to a large extent on GICS
reports, 1s discussed. Copies of GICS reports are forwarded to the
States, when appropriate, both to point out data problems and to show the
various reports that are available. Region V encourages the States to
participate 1n national GICS activities, and has helped to create new
data elements and coding documents and Input screens for the States.
37
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-2-
Key strengths 1n the Region are the State GICS Coordinators, who are
responsible for the day-to-day operation of the system and who for the
nost part pay strict attention to data quality. Data quality 1s of
critical Importance to the Region. Region V's comprehensive data quality
Improvement efforts Include the use of exception reports, designed by
Regional and Headquarters staff, to audit data elements not now on the
CGP 0060 report. The Region has developed a GICS monitoring and evaluation
workplan, to overview of the States' entry of data and utilization of the
system. Training to the States Is provided 1n conjunction with the overview
efforts. This Initiative has Improved data quality In two States and 1s
expected to do so In all States evaluated.
The GICS error rate 1n Region V has consistently remained below 5%. In
fact, the Region's standard for data quality based on the CGP 0060 report
has been reduced from 5% to 3%. The rates for the Region V States as of
the end of March are as follows:
IL
IN
MI
MN
OH
HI
REGION v
1.98%
1.991
.78%
.95%
.03%
.06%
.94%
One problem with respect to GICS utilization Is the Inability of some
States to expedltlously purchase equipment, e.g., a high speed printer or
a CRT, that would enhance the timeliness and usefulness of the system.
CTIVITY 2: IMPLEMENT THE AGENCY POLICY ON DELEGATION AND OVERSIGHT FOR
THE CONSTRUCTION GRANTS PROGRAM
nalysls:
The Agency policy on delegation and oversight 1s fully Implemented 1n all
of the Region V States, and has been effective 1n assessing program
performance and drawing attention to areas where Improvement Is needed.
The overview system either has been Incorporated, or very soon will be
formally Incorporated, Into each of the State Delegation Agreements.
A description of the Regional planning and overview system, which served
as a model for use In the Delegation Agreements, Is attached. Plans
for overview were developed for each of the States for FY 1985.
Region V also has an effective program for overview of the Corps of
Engineers. The Region monitors the workpian accomplishments of both CoE
Divisions on a monthly basis. Monthly bills are also analyzed and checked.
Any questions, Issues, or problems with the monthly bills and/or workplan
accomplishments are Identified and discussed with appropriate CoE Division
personnel. CoE Monitoring and Evaluation Horkplans are developed on an
annual basis, and evaluations are conducted and feedback Is provided to
38
-------
-3-
the CoE for overall program Improvement. In FY 84 the Region evaluated
Corps (and State) efforts related to PMCs, Inspections, change orders,
and contractor claims. In FY 1985 the Region 1s conducting a follow-up
survey of grantees to elicit feedback on the quality of CoE activities.
In addition, the Region 1s conducting a program evaluation 1n the area of
B/C reviews. Corps overview efforts are closely coordinated with other
•onltorlng and evaluation activities undertaken by the Region.
39
-------
REGION V
SYSTEM FOR OVERVIEW OF STATE ADHINISTRATION
OF THE CONSTRUCTION GRANTS PROGRAM
Purpose
IISEPA Region V and the (State agency) are responsible for water program
Management consistent with the goals and objectives of the Clean Water
Act. Fach year water pollution control programs will be planned and
•anaged to achieve progress towards these goals. Monitoring and evaluation
are the Agencies' tools for Measuring what actually occurs as a result
• of program activities. The purpose of this document 1s to describe the
Monitoring and evaluation principles and activities that will be used to
assess the work performed and the environmental results of the activities
carried out under the State Management Assistance Program Delegation
Agreement In the Management of the construction grants program (CGP).
II. Activities
Monitoring and evaluation activities will be directed toward assessing
the total CGP program. This Includes measuring State and Corps of Engineers
performance of delegated tasks as well as the overall progress being
Made toward program and management objectives with a focus on environmental
results. Monitoring and evaluation will also assess work performed by
Region V, or the appropriateness of USEPA policies. Monitoring and
evaluation will include tracking the performance of activities, but
will emphasize the extent to which Important program and management
objectives are achieved. The work will Include qualitative and quantitative
considerations. A detailed presentation of the principles and procedures to be
used by the Region for monitoring and evaluation can be found 1n the
Region v Water 01 vision Monitoring and Evaluation Guidebook (June 1982).
The Monitoring and evaluation activities will change from year to
year as the program 1s carried out. Priorities will change over time,
and management and environmental objectives may change as well. Monitoring
and evaluation will reflect these changes. Also, as the State becomes
Increasingly proficient at performing the tasks outlined In the nelegatlon
Agreement, oversight of these activities will be adjusted. Detailed
procedural reviews that would be appropriate Immediately after the State
begins to perform a task may very well not be appropriate, or may need
to be done less frequently after the State has demonstrated Its performance
capability. Monitoring and evaluation will generally shift from detailed
reviews toward more general assessments of program results as delegation
Matures.
The State and USEPA will negotiate the specific monitoring and evaluation
activities on an annual basis, reflecting the current objectives and
priorities and the stage of delegation. The resulting overview program
will fulfill 40 CFR 35.3075 which requires that an annual plan for overview
be developed. The planning of Monitoring and evaluation activities 1s
an Integral part of the overall program planning and budgeting cycle: the
sequence of events 1s described below. Months are provided for general
perspective, but are subject to national and regional planning schedules
developed on an annual basis.
40
-------
A. EPA Headquarters transmits guidance to EPA Regional Offices. This
guidance Includes national objectives and priorities as veil as estimated
allotments for program grants. This will usually take place 1n
January or February, after the President has proposed the national
budget.
B. In March Region V proposes objectives and priorities, performance measures,
•nd key activities for the upcoming year and meets with the State 1n April
to discuss the proposal. Agreements are documented as necessary 1n
the State-specific guidance. The performance Measures will address
Information needed:
1. for fiscal tracking;
?. for the EPA national accountability systems;
3. to track the performance of key activities Identified by Region V
and the State:
4. to measure progress toward program and management objectives: and
5. to measure Regional performance.
C. The State submits a draft water pollution control program plan and
?05 (g) budget, reflecting the agreements reached 1n June. This program
plan will fulfill the requirement for a work program. Included in
Subpart A Part 35 and the requirement for developing annual outputs
Included 1n Subpart J Part 35.
n. The State and USFPA conduct discussions to resolve program planning
Issues and to agree on annual outputs, monitoring Information needs,
and key questions to be addressed through in-depth evaluations in July
and August.
E. In August the State submits a final program plan and budget which 1s
reviewed and approved by the Region.
F. Agreement 1s reached on the plan for overview, Including monitoring
plans and general descriptions of evaluation projects, and Regional
and State team leaders, as appropriate, are selected for evaluation
projects 1n September.
fi. Program activities are carried out as planned. Program monitoring is
conducted to track activities and measure progress toward objectives.
In-depth evaluations are planned and carried out, coordinating with
program monitoring activities where appropriate. At least one on-sitp
• performance evaluation will be conducted annually as required 1n
Subpart J.
41
-------
M. Feedback on the findings and conclusions of Monitoring and evaluation activities
will be provided to acknowledge effective performance and to suggest program
Improvements*where necessary.
In addition to the Monitoring and evaluation performed by USEPA and
the State, work performed by other offices or individuals may provide
useful feedback to Region V or the State. Audits performed by the
Office of the Inspector General and reports prepared by the General
Accounting Office are two examples of possible sources of Information.
Findings such as these, once verified, will be considered in the assessment
of program performance to the extent appropriate.
This policy meets the requirements for a system for EPA overview
pursuant to 40 CFR 3b.3010 (c)(7).
42
-------
ACTIVITY 2: Manage Program To Meet Outlay Projections.
Quantitative Measure (a): % of cumulative net outlays to connitment (p. A-61)
Mid-Year Percent End-of-Year Percent
State Commitment Actual Achieved Ccronitnent Projection Expected
See MR 2 and MR 7
Regional
Total
43
-------
ACTIVITY 3: Manage program to meet Obligation Projections
Quantitative Measure (a): Percent of cumulative gross obligations to commitment
(pageA-€l).
Mid-Year Mid-Year Percent End-Year bid-Year Percent
State Conreitroent Actual Achieved Comnitnent Projection Expected
See MR 2 and MR 6
Total
44
-------
Qualitative Measure (A-2): What are net obligations on a State-by State,
source-by-source, quarter-by-quarter basis (page A-61).
:ate/Source
Carryover
Talmadge/Nunn
FY 84
FY 85
Totals
Carryover
Talmadge/Nunn
FY 84
FY 85
Total
Carryover
Talmadge/Nunn
FY 84
FY 85
Total
Carryover
Talmadge/Nunn
FY 84
FY 85
Total
Carryover
Talmadge/Nunn
FY 84
FY 85
Total
Carryover
Talmadge/Nunn
FY 84
FY 85
Total
Mid-Year
Project'n
(6)
10
20
~H
.3
--
4.8
S7T
— —
—
--
17.0
TO
„
--
5.5
4.5
TO
2.0
--
7.7
0
977
„
--
.8
62.7
5375
Mld-Yr. Percent
Actual Achieved
(5.7)
--
14.5
25.1
1379 141
(1.2)
--
. 6.3
1.4
675 127
(2.3)
--
1.6
5.0
~O 25
(.3)
--
4.6
18.1
"217? 224
(9.4)
—
3.6
10.1
~O 44
(3.8)
--
4.4
47.5
78TT 76
Original
End-of-Yr.
Project'n
(10)
—
14.5
95.0
W3
2.7
--
55.1
5.5
6373
__
—
2.5
92.0
"9175
_ _
--
5.5
30.5
3670
(4.0)
--
12.0
128.1
T3T7T
__
--
.8
66.1
6679
Current
End-of-Yr.
Project'n
(10)
—
21.8
95.0
1TJO
(3.7)
--
43.1
5.5
44.9
(4.0)
—
5.0
92.0
"93TTJ
(.6)
- -
8.9
30.5
3878
(12.0)
•
14.9
128.1
131.0
(4.0)
— —
10.1
66.1
72T2
Percent
Expected
107
71
98
108
96
TOTAL
T7O
TT575
108
"581
Regional Contacts:
Ray Maraslgan, Chief, Finance & Accounting Section; 886-7510
Richard C. Walker, Financial Management Officer, Region V; 353-2040
45
-------
FY 85
MID-YEAR EVALUATION OF REGION V WATER PROGRAMS
National Objective; Improve Performance of Completed Facilities
Activity: Improve Facilities Performance
Regional Analysis:
Qualitative Measure (A-l): Are States effectively Implementing on-site
training and technical assistance programs for bringing small facilities into
improved compliance?
Qualitative Measure (A-2): Are States conducting annual on-site O&M reviews?
Overall the six Region V States are doing a good job of implementing on-site
operator training. The FY 85 work plans were developed by each State to address
the national guidance. State-by-State summaries are:
Illinois
Illinois conducts regular on-site 04M reviews of completed facilities. Utilizing
the EPA Form 7500-5, they have completed 52 inspections thus far in FY 85, with
their commitment being 55 inspections. These were completed at major municipal-
ities, mostly on PWB's.
Illinois also has a substantial program for inspection of minor municipal WWTP's,
construction grant compliance inspections, and operational assistance.
Overall, Illinois has an effective O&M program.
Indiana
Indiana conducts regular on-site O&M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have completed 13 inspections so far in FY 85, with the
commitment being 15 inspections. These were completed at major municipalities,
mostly on PWB's.
Indiana also has a substantial program for inspection of minor municipal WWTP's,
and operational assistance. The construction grant compliance inspection pro-
gram shows minimal activity, but the Corp of Engineers performs additional
inspections.
Overall, Indiana has an effective 04M program.
Michigan
Michigan conducts regular on-site 04M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have completed 14 inspections so far in FY 85, with the
commitment being 15 inspections. These were completed at major facilities,
mostly on PWB's.
-------
Michigan also conducts inspections at minor municipalities, a few construc-
tion grant compliance inspections, and operational assistance. A short-coming
of the Michigan program is that most of their field inspection resources are
used for 24-hours sampling surveys with little or no evaluation of the O&M
of the plant surveyed.
Michigan should devote more resources to O&M inspections, with less resources
for 24-hr, sampling surveys.
Minnesota
Minnesota conducts regular on-site O&M reviews of completed facilities.
Utilizing EPA Form 7500-5, they have met their commitment of 25 inspections
at major municipalities, mostly on PWB's (thru second quarter FY 85).
Minnesota also has a substantial program for inspection of minor municipal
WWTP's, construction grant compliance inspections, and operationaV'assistance.
Overall, Minnesota has an effective O&M program.
Ohio
Ohio conducts regular on-site O&M reviews of completed facilities. Utilizing
EPA Form 7500-5, they have met their commitment of 50 inspections at major
municipalities, mostly on PWB's (thru second quarter FY 85).
Ohio also has a substantial program for inspection of minor municipal WWTP's,
and operational assistance. The construction grant compliance inspection
program shows minimal activity, but the Corps of Engineers conducts additional
inspections.
Overall, Ohio has an effective O&M program.
Wisconsin
Wisconsin conducts regular on-site O&M reviews of completed facilities, but
they refuse to use EPA Form 7500-5. Utilizing narrative reports with EPA
Form 3560-3, they have met their commitment for 25 inspections thus far in
FY 85, mostly major facilities on PWB's.
Wisconsin also has a substantial program for inspection of minor municipal
WWTP's, construction grant compliance inspections, and operational assistance.
Wisconsin is the only State in the Region to make commitments for intensive
operational assistance studies. They have exceeded their commitments for
6 such studies thus far in FY 85.
Overall, Wisconsin has an effective O&M program.
-------
Qualitative Measure (A-3). In regard to operator training. Are the Regions/
coordinating the operator training, technical assistance, construction grants.
permits and enforcement program?
The Regional 04M program consists of three separate parts located in the
Municipal Facilities Branch and Water Quality Branch of the Water Division
and in the Environmental Monitoring Section in the Environmental Services
Division. The work activities are coordinated through the Chief of the
Water Quality Branch, who implements the Regional Operations and Maintenance
Procedures established in May 1983. This memorandum delineates the specific
responsibilities for all involved programs (Construction Grants, Permits,
Compliance, Great Lakes National Program Office and Environmental Services
Division). The Region solicits nominations for 0AM awards from each State
in October of each year. From these submissions a panel at EPA, Region .V
reviews projects in three size categories (small plant < 2.0 mgd; medium
plant > 2.0 to < 20 mgd;.large plant > 20 mgd), with two types of ^treatment
(secondary and advanced) under each, for a total of six Regional categories.
The results of the review become recommendations for awards presented to
the Regional Administrator. This FY, the awards will be presented during
May and June 1986. Region V is currently the only Region in EPA to have
a municipal wastewater treatment plant O&M award program.
The Regional office makes operating training grants to the State agencies
in order to enhance the activities funded by either the States (109(b)
funds) and/or USEPA (Section 106 funds). The grants awarded under Section
104(g)(l) to the State during FY 84 and FY 85 are summarized on the table
below. The Section 104 grants have been used as supplemental funding to the
States to augment Sections 106 and 205(g) activities. This has happened due
to the delayed availability of funds over the past several years. The
Regional coordinator of the technical portion of the O&M awards is located
in the Compliance Section in the Water Quality Branch. The coordinator is
assisted by the Planning and Standards Section in the preparation of grant
awards.
•During FY 85 the following resource distributions were made by the States.
IL IN MI ' MN OH WI
WY
Section 106 $1000
WY
Section 205 (g) $1000
Section 104(g)(l) WY
(FY 84 funds) $1000
10.6
599.6
6.0
242.4
1.2
75.0
1.75
49.9
0
0
1
75.0
0
0
0
0
±
75.0
4
20.90
3
154.0
1
50.0
265
11.6
0
0
+
50.0
0
0
4.92
245.0
+
50.0
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