TD365
.W65
1980
United States
Environmental Protection
Agency
                             Water Planning Division
                             Wp-hmuto^ DC 20460
Water
                                          September 1980
OOOD80100
               Draft
               WQM Needs Assessment
               FY 80-84

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The material contained in this draft publication is being given circulation



to provide oooortum'ty for review and comment.  All statements, conclusions,



and/or recommendations contained here are preliminary draft and do not



necessarily reflect the policies of the U.S. Government or the Environmental



Protection Agency.   Comments should be forwarded to the Environmental Protection



Agency, Water Planning Division (WH-554), 401 M St., S.W., Washington, D.C. 20460



by September 30, 1980.  This material will be revised as necessary to respond to



comments.

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                                TABLE OF CONTENTS


                                                                               PAGE

Chapter I
     INTRODUCTION

     A.   Background	   2

     B.   Methodology	   7


Chapter II
     SUMMARY

     A.   Summary of WQM Agency Projections	  10

     B.   Observations and Impl ications	  18


Chapter III
     MUNICIPAL FACILITY PLANNING AND MANAGEMENT

     A.   Overview	  30

     B.   Construction Grants Management	  32

     C.   O&M/Training	  35

     D.   Facility Planning	  37


Chapter IV
     INDUSTRIAL AND MUNICIPAL SOURCE CONTROL

     A.   Overview	  41

     B.   NPDES	  45

     C.   Pretreatment	  54

     D.   Monitoring

          1.    Overview	  58

          2.    Equipment	  61

          3.    Compl iance	  64

          4.    Intensive Surveys	  67

     E.   Dredge and Fill  Programs	  69

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                                                                              PAGE

Chapter V
     NONPOINT SOURCE PLANNING AND ADMINISTRATION

     A.   Overview	   73

     B.   Rural

          1.    Overview	   84

          2.    Agriculture	   86

          3.    Silviculture	   91

          4.    Noncoal  Mining	   96

     C.   Urban

          1.    Overview	  101

          2.    Urban Runoff	  1 03

          3.    Construction Runoff	  106

     D.   Ground Water

          1.    Overview	  Ill

          2.    Onlot Disposal	  116

          3.    Residual s	  1 21

          4.    Ground Water Management	  1 24


Chapter VI
     OTHER WQM PROGRAMS

     A.   Overview	  1 30

     B.   Ambient Monitoring	  1 32

     C.   Water Quality Standards	  134

     D.   TMDL/WLA	  1 36

     E.   Emergency Response	  1 39

     F.   Other State Programs	  142


Chapter VII
     CLEAN LAKES	  "143

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                                                                              PAGE

Chapter VIII
     INTERSTATE AGENCIES	  145
Appendix A.  Statewide Projections.

Appendix B.  Statistical Analysis..
 *The Appendices may be obtained by writing or calling:

                    The Environmental Protection Agency
                    Water Planning Division (WH-554)
                    401 M Street, SW
                    Washington, DC   20460
                    (202/426-2474 or FTS/426-2474)
                                      in

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      CHAPTER I
     INTRODUCTION
SECTION A - BACKGROUND



SECTION B - METHODOLOGY

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                               SECTION A

                               BACKGROUND
The Water Quality Management Needs Assessment was undertaken to
identify the fiscal  and manpower resources required by State, Interstate,
and Areawide Agencies to protect water quality and achieve the goals of
the Clean Water Act (CWA).  This report presents the results of that
Assessment.  It is based on conservative estimates of activities
supported under Sections 106, 208 and 314 which these Agencies believe
necessary over the next 4 years to implement the Act.  The Report is
the culmination of a cooperative effort between EPA Water Program
Offices, EPA Regional Offices, all States, and Interstate and Areawide
Agencies.

To carry out the ambitious and far-reaching goals set by the Congress
in the Clean Water Act (CWA) of 1972 and reaffirmed in 1977, many
specific objectives must be accomplished.  The Nation has committed
an investment measured in tens of billions of dollars to control
municipal and industrial discharges into waterways.  More is being
invested every day by taxpayers, corporations, and consumers.  Wise
application of that investment to achieve its intended purposes
requires thousands of decisions by Federal, State, Interstate,
Areawide and local agencies, and the public.  Most of the national
investment in water pollution control goes to industrial and muncipal
treatment facilities.  A very small portion of those funds go to
management of those activities.

The activities covered in the Assessment with the exception of
wastewater treatment plant planning and construction under Sections
201 and 205(g), constitute virtually all State, Areawide, and
Interstate Agency (referred to in this Report as WQM Agencies)
participation in the CWA.  They comprise what is termed the Water
Quality Management (WQM) program funded Federally under Sections
106, 208, and 314.

Activities funded by Section 106 form the core of the WQM program.
106 funds are used together with State funds to administer the State
water program, primarily for planning, monitoring, construction
grants management, the National Pollutant Discharge Elimination
System (NPDES) for permit issuance and enforcement, municipal
operations and maintenance, and emergency response.  On an
aggregate basis, States have historically contributed twice as much
as the Federal government to activities under Section 106 (See Table 1-1
and Figure 1-1).  The static funding level of recent years has sub-
stantially affected the covered activities and is a primary focus
of this Report.

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                  FIGURE 1-1
HISTORICAL CONTRIBUTION TO 106 FUNDED PROGAMS
                   TOTAL
                          FEDERAL 106
                          APPROPRIATION
                   75    76    77

                  FISCAL YEAR
                   TABLE 1-1

           HISTORIC FUNDING  (FY 72-80)

                  ($ millions)
FY
72
73
74
75
76
77
78
79
80
(106) appropriated
15.0
20.0
40.0
48.5
50.0
50.0
52.4
52.4
48.7
(208) appro
_._-
50.0
100.0
150.0
53.0
15.0
69.0
32.0
37.5

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Assessment results are particularly important under the 1977 amend-
ments to the Act which expanded on requirements for the control  of
toxics through Best Available Technology (BAT), conventional pollutants
through Best Conventional Technology (BCT)  and municipal  facility
compliance.  This new phase is more complex and will  substantially
affect many WQM programs, including industrial and municipal source
control and monitoring.  The resource implications of this expansion
are also a primary focus of this Report.

The 1977 Amendments to the Act provided for delegation of responsibility
for construction grants management under Section 205(g).   By FY  81,
approximately $60 million in Federal funds  will be available annually
for such activities.  As with NPDES, the 205(g) delegation usually
requires expansion of the existing State program to obtain approval.
Section 205(g) delegation has reduced but not eliminated  the need for
WQM funding for construction grants management due to the magnitude  of
support required to administer the delegation  (See below).

Section 208 of the CWA supports planning or program development  at
the State and Areawide levels.  The plans developed under 208 in-
creasingly set the context for future water pollution control.   The
emphasis since FY 80, under the WQM strategy, has been on nonpoint
source control, particularly filling the major gaps in 208 plans
developing a technical information base for program development  nationally,
and building financial capability to administer programs.

Activities under Sections 106 and 208 are supplemented by the Clean
Lakes program under Section 314, which provides matching  grants  to
identify and control pollution of fresh water lakes.   These grants
can cover planning as well as structural and nonstructural controls.
The 314 program and associated projections  are discussed  separately
in Chapter VII.  Throughout the Report, except if otherwise stated,
the term WQM covers only WQM Agency activities supported  by 208  and  106.

State pollution control agencies play a vital and indispensible
role in achieving the goals of the CWA.  Congress recognized this
when it emphasized delegation to States of responsibility for
carrying out the NPDES, dredge and fill programs, and construction
grants management programs.  The activities under WQM are generally
managed by the States.  In keeping with Congressional intent, delegated
and non-delegated States have developed programs to administer the
complex and broad requirements of the Act.

Together with Areawide Agencies, State total contributions to the WQM
program have risen substantially now exceeding Federal support by
approximately $40 million (Table II-l).  The rising level of contri-
bution reflects in part the expansion of CWA requirements and increased
State delegations.  As this occurred and Federal funding  has remained
static or declined, implementation of the CWA has become  increasingly
dependent upon continuing that level of support at a minimum.  The
future Federal funding outlook for 106 and 208 are provided in Tables
1-2 and 1-3.

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To provide information on funding needs expeditiously for the budgetary
process, the Report is being issued in preliminary draft  form at  this
time.  It will also be used by EPA and States in the current initiative
to restructure the water program and develop a long-term  water
strategy through the 1990 construction grants strategy and the 106
management initiative coordinated by the Office of Water  and Waste
Management.  This initiative is proceeding on the basis of Congressional
direction, and the increasingly significant need to stretch scarce
Federal and State resources.

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                                   TABLE  1-2

                         STATE  106 TARGETS FOR  FY 81

       BASED  ON TOTAL  APPROPRIATION OF $48.73 MILLION  ($ MILLIONS)
REGION 1
TOTAL
3.74
               REGION  2
                REGION  3
            REGION 4
5.43
                                           SRBC   0.08  ORSANCO  0.33
6.10
9.48
            REGION 5
CT
ME
MA
NH
RI
VT
NEIWPCC

0.75
0.54
1.16
0.33
0.51
0.24
0.22

NJ
MY
PR
VI
ISC



1.33
2.68
0.79
0.36
0.26



DE
DC
MD
PA
VA
WV
DRBC
INCOPOT
0.41
0.41
0.82
2.18
1.23
0.62
0.22
0.14
AL
FL
GA
KY
MS
NC
SC
TN
1.30
1.26
1.52
0.72
0.73
1.80
0.97
0.88
IL
IN
MI
MN
OH
Ml


1.82
1.02
1.74
0.91
1.86
1.38


8.74
REGION 6
TOTAL     4.16
               REGION  7
                   2.64
                REGION  8
            REGION 9
                    1.68
                 4.38
            REGION 10
AR
LA
NM
OK
TX


0
0
0
0
1


.72
.82
.28
.54
.80


IA
KS
MO
NE



0
0
0
0



.71
.51
.86
.56



CO
MT
ND
SD
UT
WY

0.46
0.33
0.21
0.22
0.30
0.16

AZ
CA
HI
NV
AS
GU
*TT
0.40
2.87
0.34
0.17
0.08
0.36
0.16
AK
ID
CR
WA



0.15
0.38
0.80
1.04



                 2.37
GRAND  TOTAL  — 48.73

Note:  Columns  may not  sum exactly due to rounding error
       * includes Northern Mariana Islands
  REGION 1

   1.5
                                 TABLE  1-3

        REGIONAL 208 TARGETS FOR EY 81 BASED ON TOTAL APPROPRIATION OF $34.0 MILLION*

                                (* MILLIONS)



  REGION 2   REGION 3   REGION 4   REGION 5   REGION 6   REGION 7    REGION 8  REGION 9

    3.0       2.8       4.7      5.5      3.8      1.9       2.2       3.7
                                                      REGION 10

                                                        2.9
  TOTAL: 32.0
  * $2 million may be held at Headquarters for
   NURP funding during FY 81

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                               SECTION B

                              METHODOLOGY
Since the Assessment was the first Agency attempt to project WQM
needs no methodology existed.  The Assessment evolved on a
trial and error basis.

The guidance used to complete the Assessment for WQM Agencies was
developed in close coordination with States, Interstate Agencies,
the Association of State and Interstate Water Pollution Control
Administrators, and the EPA Regional Offices.  Areawide Agencies
participated through the National Association of Regional  Councils.
In designing the format for collecting information, careful  con-
sideration was given to the need for National uniformity and
consistency.  The guidance divided WQM activities into 41  categories
or sub-categories to correspond as closely as possible to  the
organization of water programs and legal  requirements.  Since the
information was not solicited to revise the 106 allocation formula,
programmatic CWA objectives rather than the extent of pollution
were the primary consideration in organizing the Assessment.  In
each category, total fiscal needs (i.e.,  combined State/local and
Federal share) and staffing requirements  were solicited.  In the
summary, the guidance solicited the projected source of those funds
(i.e., State/local and CWA Sections 106,  208 or 314.)

Drafts of the guidance for the Assessment were tested in pilot States
and an Interstate Agency and distributed  for review and comment.
The guidance was then refined and issued  to EPA Regional Offices.
Since the purpose of the Assessment was to document State, Interstate,
and Areawide Agency understanding of needs (i.e., not EPA's  prediction),
EPA also nationally proceeded on a separate track to estimate needs (see
below) to provide some basis of comparison.

The Assessment guidance was designed for  completion by EPA Regional
Offices in consultation with WQM Agencies.  States and Interstate
Agencies in particular showed a high degree of interest in the
Assessment and took an active role.  Whenever possible, Regions
relied on existing information such as Section 305(b) reports,
State strategies, and State/EPA Agreements.  Projections for State
and Areawide Agencies were incorporated into one statewide submittal.
All submittals received WQM Agency concurrence.

The Assessment covered FY 79-80 to document past activities  and  funding
levels.  Needs were projected for FY 81-84.  Ideal  or "cadi 1 lac"
programs were avoided as unrealistic and  the ability to staff up and
manage projected growth was considered a  limiting factor.  Narrative
descriptions of program direction, activities, and expected  outputs
were requested.

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Completed submissions were reviewed in EPA headquarters to assure
that the information was properly categorized, the addition was correct
and the activities projected were eligible under WQM.   In some instances,
it was necessary to make adjustments in submittals for one or more of
those reasons.  WQM Agency projections were reviewed for consistency
by comparison with one another (See Appendix B)  and analyzed.  Statewide
projections as adjusted, appear in Appendix A.  Interstate Agencies
are covered in Chapter VIII.

In the analysis, the categories used to solicit information were
reformated to correspond more closely to environmental and program
objectives.  The distribution portrays the direction of the
water program and program interrelationships well.  This Report is
organized according to this reformating into discussions on facility
planning and management, industrial and municipal  control, nonpoint
sources, and other activities.

In addition to the effort to project needs from the WQM Agency
perspective, in select program areas EPA also estimated needs to
provide some perspective on WQM Agency projections.  Coverage was
limited by the availability of information, resources  and time.  NPDES,
monitoring, pretreatment and some nonpoint sources were covered. The
Agency focused on areas which were evolving under new program require-
ments.  Estimates were developed by using indicators for the extent
of the problem, identifying typical activities for solving the problem,
assigning costs to the activities, and estimating national needs.  For
the most part, EPA estimates were developed strictly on the basis of
existing policy, regulations and CWA deadlines, without accounting for
individual WQM Agency characteristics.  The comparison of WQM Agency
projections and EPA estimates proved more useful for indicating
differences in approach or program direction than in evaluating
validity of costs projected.  In large part this is because no EPA
water program strategy (other than that for nonpoint sources) existed
on which to project needs.
                                     8

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                  CHAPTER II
                   SUMMARY
SECTION A - SUMMARY OF WQM AGENCY PROJECTIONS



SECTION B - OBSERVATIONS AND IMPLICATIONS

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                               SECTION A

                   SUMMARY OF WQM AGENCY PROJECTIONS
WQM Agencies project that an increase of 40% or $85 million above
FY 80 total WQM Agency/Federal  funding levels will  be required to
manage implementation of the CWA annually by FY 84  (Table II-l).   This
level of funding, being constant from FY 81-84, appears reasonable
over the long term if there are no major adjustments or changes in
program direction.  However, WQM Agencies indicate  uniformly that
current and projected funding will be inadequate to meet minimum  require-
ments within the time frame of the Act.   This is reflected by the 2:1
increase noted in the first available budget year,  FY 81.  While  the
Federal share increases substantially in FY 81, the State share has
risen steadily.
Table II-l:  Total WQM Needs ($000,000)
FY79*
Federal Share**
State & Areawide Share
TOTAL
84
86
171
.4
.6
.0
FY80*
86
126
213
.2
.8
.0
FY81
178
116
294
.0
.0
.0
FY82
181
110
291
.0
.5
.5
FY83
180
113
293
.0
.5
.5
FY84
177.0
118.5
295.5
*Note that it appears some FY 79 planned expeditures previously
 estimated by States in 106 supported programs actually
 occurred in FY 80.  A considerable amount of FY 79 appropriated
 208 funds apparently were indicated as used in FY 80.

** 208 and 106
State and Areawide contributions have increased substantially over
the past decade, while in recent years Federal  support under 106  and
208 has remained fairly static (Table 1-1).   States in the Assessment
project a declining level of contribution reflecting trends in State
legislative action and is not limited to WQM.   The 106 program, where
States collectively contribute twice as much as the Federal  government,
illustrates the relationship of WQM Agency to Federal  funding and the
impact of static support (Figure 1-1).  One State submittal  portrays this:
                                    10

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               "The highest level of Federal funding
               for the 106 program was in Fiscal year
               1976 and 1977 ....  Despite increasing
               costs due to inflation, the 106 grant
               has been generally decreasing since
               1977....  Over the four year time period
               from FY 77 to FY 80, therefore, a total
               of 90 positions were lost to the pro-
               gram.  During this same time period,
               there were increasing program responsi-
               bilities as a result of the 1977 amend-
               ments to the Clean Water Act.  The
               Department's Water Quality Program
               would have kept pace with inflation
               if 106 funding levels had kept pace
               with inflation to support increasing
               costs.  The 5-year Needs Assessment
               for the 106 program included in this
               document reflects an increase of 100
               positions through FY 84."

Projections indicate that the State ability to administer the Act is
severely strained as requirements increase and funding remains constant.
States indicate these new requirements cannot be met without increased
Federal support.

Effects are limited to the 106 supported programs, most importantly
implementation of CWA requirements for industrial  and municipal  control.
This is in contrast to the matching programs (i.e., Clean Lakes  and 208)
where WQM Agencies project increasing needs and therefore an  increasing
level of State/local support.   As the above quote indicates, although
WQM Agencies projected program growth to administer increased requirements
of the Act, they may contemplate more efficient programs because pro-
jections barely offset past inflation.  As States recognized in  the
Assessment:

               "The Division's budget has increased
               nearly 10 fold  since 1971 and additional
               expansion is extremely difficult to
               justify when Federal  support is con-
               tinuing to decline.  The Division
               feels the Needs Assessment is very
               important and represents a positive
               step towards achieving the national
               goals ... (the  State)   Legislature is
               becoming increasingly resistant to
               "being blackmailed" into supporting
               Federal  programs."
                                    11

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               "The amount of State general funds
               used as a match has remained static for
               the past several years creating a
               dependency on Federal funds .... Changes
               in Federal funding levels will  signifi-
               cantly affect the State staffing levels.
               With a fiscally conservative legislature,
               relief of any Federal short falls
               would be difficult with the possibility
               that delegations might be returned to EPA."

               "(The State) will remain fairly dependent
               upon Federal funding to continue in
               the Water Quality Management Program.
               The level of ... participation  will be
               directly proportional to available 106
               208, and 314 funds."

Within the projected Federal share, WQM Agencies indicate a 140%
or $69.5 million increase in Section 106 support and a 50% or $20
million increase in Section 208 support will  be needed by FY 84
(Table II-2).
             Federal WQM Contributions Need by WQM Agencies According To
Table II-2:  Funding Category ($000,000)*

106
208
FY79**
52.5
32.0
FY80**
48.7
37.5
FY81
108.0
70.0
FY82
108.0
73.0
FY83
111.5
68.5
FY84
118.0
59.0
Authorized
CWA Levels
100
150
 *For Clean Lakes -- See Chapter VII.
**Appropriated


Tables II-l & 2 represent projections in constant FY 80 dollars.  When
an inflation factor of 8.5% is considered, the Assessment for 106
and 208 supported programs results are substantially affected (Figures
II-l, 2, & 3).  This perspective must be kept in mind throughout the
Report because elsewhere all projections appear in FY 80 dollars.  All
projections have been rounded off to the nearest half million (Figures
II-l, 2, & 3).
                                     12

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                                   FIGURE 11-1
                             WQM AGENCY PROJECTED
                            CONTRIBUTION WITH INFLATION
                          100
                           FY80
                                 FY81
                                       FY82
                                             FY83
                                   FIGURE II-2
                              WQM AGENCY PROJECTED
                           FEDERAL 106/208 FUNDING NEEDS
                          250
                           50 -
                           FY80
                                 FY81
                                       FY82
                                             FY83
                                                  FY84
                                   FIGURE II-3
                           TOTAL WQM AGENCY PROJECTED
                      NEEDS WITH INFLATION (FEDERAL/STATE/LOCAL)
                          500
                        Z 300
                        O
                          200
                           FY80
                                       FY82
                                             FY83
Although  in  the  aggregate, WQM Agency projections may  appear large,
program strength at the individual Agency level  is moderate con-
sidering  the program expansion anticipated under the CWA requirements.
For example,  States project a total WQM staff  increase by FY 84 of approx-
imately 35%  above FY 80 levels.  The growth rate is somewhat higher for
dollars because  of the immediate need to offset  past inflation in
order to  retain  existing capabilities and non-staff related expenditures
such as monitoring, equipment, building, and contract  services.  Staff
salaries  in  some States are currently too low  to maintain trained
staff and career ladders (although some of these States  projected
at these  low levels.)   More sophisticated programs will  be required
in the future with the emphasis on toxics.

The effort to get needs in constant dollars reflecting the costs of
materials and services in FY 80 was largely successful.   However,
some States  felt that  programmed increases in  salaries and other
factors imposed  burdens that should be recognized separately from
inflation because of State legislative requirements.   In  those instances,
these considerations were reflected in some projections.   In a limited
number of cases,  inflation was included.
                                      13

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As Table II-2 indicates, there are only marginal increases in 106 needs
after FY 81, indicating that States offset past inflation, programmed
improvements for the CWA and staff up for the long term in FY 81 (see
page 12).  As previously discussed, projections corresponded closely to
levels necessary to compensate for erosion from past static funding
levels which implied increased efficiency to address additional  CWA
needs.  Projections for FY 81 were overly ambitious when the ability to
staff up, manage, and synchronize development of program elements is
considered.  The growth is more likely to be phased in through FY 84.
For these reasons the Report focuses on FY 84 as the more representative
of needs and directions.  To the extent that needs are not met as projected,
development will slip into FY 85 and beyond.

State contributions to WQM reflected in this Assessment are higher than
previously estimated.  This  is primarily due to contributions of State
agencies to water quality which have not been directly supported by
Section 106 or 208 funds.  This is not suprising because water quality
is a broad-based concern.  A continued effort in the future to identify
these activities is desirable to get a more accurate picture of progress
toward implementing the Act.

Projected needs for 208 funding indicate continuing planning
activity and the desire to use Section 208 rather than 106 funds for
that purpose.  The majority  of this 208 funding projected is for non-
point sources.  208 needs decline in FY 83-84, reflecting the shift
for WQM in nonpoint sources  from planning to program development and
administration (the latter of which is ineligible for 208 funding).
However, the increase in funding over the period of the Assessment
indicates a willingness in this area to increase State/local support.
208 funding needs projected  by WQM Agencies are higher than necessary
for the nonpoint source planning and program development identified
in the Assessment (which requires a 25% match).   This  indicates  a
desire to use 208 funds also for general  and point source planning
(e.g., monitoring,  waste load allocations).   Needs discussed in  this
Report (except Clean Lakes)  were projected for WQM Agencies irrespective
of the ultimate funding source.   The unavailability of 208 funding,
should current plans to phase out 208 be completed, would merely trans-
fer the Federal  source for those pollution control  needs from Section
208 to 106 or other sources  (314).
                                      14

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As Table II-3 indicates, all functional areas undergo growth.  However,
there is wide diversity in the rate of growth, indicating where
emphasis is shifting in WQM to accommodate new requirements and  shifting
priorities (Figures II-4&5).  2/3 of the total growth in WQM needs
between FY 80 and 84 is due to toxics and other industrial and municipal
control.  The majority of the total growth (56%) is related specifically
to the new requirements of the Act (e.g., BAT for toxics, BCT for
conventional  pollutants, the municipal strategy under 301(i), pretreatment,
and associated monitoring).  Greater priority is given to this
aspect of the program by FY 84 when it constitutes 41% of the program
as compared to 35% in FY 80.  As one State explained:
               "Since the passage of the Clean
               Water Act of 1977, emphasis has
               shifted to the control of toxics,
               pretreatment requirements for POTWS
               and the incorporation of BAT and
               BCT 1 imitations ..."
                FY80
                                 FIGURE 11-4
                             TOTAL WQM AGENCY
                             PROJECTED NEEDS
                          MUNICIPAL
                          FACILITY
                          PLANNING
                      AND MANAGEMENT
                             01%)
 INDUSTRIAL AND
 MUNICIPAL CONTROL
     (44%)
            FIGURE 11-5
PERCENTAGE OF TOTAL WQM AGENCY
    PROJECTED GROWTH: FY80-84
   INDUSTRIAL AND
   MUNICIPAL CONTROL
   (68%)
                                     15

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    Growth  is  more moderate  in other program areas.  General  and point
    source  planning, ambient monitoring,  and other aspects  of Category  IV  in
    Table  11-3 maintain  their share of the  program, accounting for 14%  of
    the  growth and 16% of  the total program.  Both facility planning and
    management and nonpoint  source planning and administration undergo
    growth  in  WQM, but constitute a smaller share of the  program by 84.
    this does  not reflect  a  decrease of  activity in these areas, but is due
    to other factors.

     In  facility  planning and management  States  are  assuming  the  205(g)
    delegation.   However,  the responsibilities  under  the delegation  of
    205(g)  are taking  more resources  than  obtainable  under 205(g).   There-
    fore, the Assessment indicates  support  from WQM (i.e., 106  and State
    resources) will  continue to  be  necessary  (see  Chapter III,  Section B).
    The  net effect  of  the 205(g)  delegation is  a more  moderate  growth  rate
    in  WQM needs  for municipal facility  planning and  management.  The
    development  in  this  area is  further  diminished  by  some reliance  by
    State and Areawide agencies  on  201  funding  for  facility  planning.
    Nonpoint sources programs, as previously  discussed, become  less
    resource intensive for WQM as the  implementation  stage is reached
    during the period  of the Assessment.  This  probably reflects  a
    reliance on  State/local  and  other  Federal agency  support  for
    administration.   Federal 208  support can  be in  effect "seed"  money.
              TABLE 1 1-3

TOTAL WQM NEEDS FOR FY 80 & 84 ($ MILLION)
                                                                 *
CATEGORY                                    FY80                  FY84                   GROWTH

1.  Municipal Facility Planning & Management       $24.5 (lit)            29.5 (9%)                20%

   •  Facility Planning
   •  Construction Grants Management
   •  O&M/Training

2.  Industrial & Munciipal Source Control         $94.5 (44%)           $153.5 (51%)              62%

      NPDES
      Pretreatrnent
      Monitoring
      404
      Other State Point Source Permit Programs

3.  Nonpoint Source Planning & Administration      $62.0 (29%)            $72.0 (24%)              16%

4.  Other                                   $34.5 (16%)            $47.0 (16%)              36%

   •  Ambient Monitoring
   •  General 5 Point Source Planning
   •  Emergency Response
   •  Miscellaneous
TOTAL                                      216.0                 302.0                   40%

*Clean Lakes  not Included (See Chapter VII)
 Percentage of total program is indicated
  for FY 80  & 34
                                            16

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Analysis of WQM Agency  projections  indicates  that the data are statistically
valid using normative techniques  (see  Appendix B).   Point source, municipal
and other data are consistent  across  the States when compared to factors such
as population, land area,  population  density, and number of point sources.
Nonpoint source data is also well  related when significant relationships
(acres forested for silviculture)  were observed.  As a general conclusion, the
data are consistent.  Analysis indicates States are operating on a common
scenario of increasing  demands, constant or decreasing revenue, no expectation
of sufficent funds availability to  satisfy the requirements of the CWA, and a
reluctance or inability to fully  estimate funding and personnel needs until
regulations and policy  are more clear.
                                    FIGURE II-5A
                            TOTAL WQM PROGRAM NEEDS
                                    PROJECTED
            330
            300 —
             FY79
FY80
                     MUNICIPAL
                  FACILITY PLANNING
                  AND MANAGEMENT
                                   FY81
                                               FY82
                                                         FY83
                                            FY84
             OTHER
NON POINT SOURCE
 PLANNING AND
 ADMINISTRATION
                                       17

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                               SECTION B

                     OBSERVATIONS AND IMPLICATIONS
There are some observations and implications which can be made from
the results of the Assessment for programs supported by 106  and 208.
They are based on WQM Agency submissions,  follow-up conversations,
EPA policy and expectations, and funding outlooks.  Observations are
made in the aggregate and may not apply to all  Agencies in every
instance.  They do however, provide a sense of  the national  picture.
Further examination may be appropriate to  refine them.

Overview -- Increasing responsibilities, inflation, and the  uncertain
funding outlook are severely straining the ability to implement the
CWA.  There are several alternatives for addressing the problem:
increased funding, more cost-effective use of available resources,
strategic planning, priorities, and a combination of these approaches.
Different aspects of this problem are discussed below.  These  include:
State primacy, inflation, increasing responsibilities under  the Act,
effects of 205(g), State/EPA consensus, and coordinated grants
management.

State Primacy — Assessment results confirm the States leadership
role in achieving the goals of the CWA.  Their  continued support and
participation cannot be taken for granted  and is the paramount future
concern.

The State water program is the backbone of the  CWA.  States  have
expanded their water program to administer the  complex and broad
requirements of the CWA.  In many cases this was done in part  to
receive 205(g) delegation and the NPDES program approval. State
contributions exceed Federal support levels and are far in excess of
the minimum resources required by law (Table II-4).  As the  water program
has expanded and Federal funding has remained static, implementation
of the CWA has become increasingly dependent upon the maintenance
of that level of State support.  Unfortunately, State contributions
are falling as State legislatures experience budgetary difficulty
and increasing demands from other areas for the limited revenue
base.  These legislatures are increasingly less inclined to  support
what is perceived as a Federal program.  This is a particularly
serious problem because the downward trend is in the 106 supported
programs (e.g., NPDES, pretreatment, monitoring, and O&M).  As one
State observed:

          "It is anticipated that no significant amounts
          of States funds will be provided to implement
          the increased requirements of the Federal
          program."
                                    18

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Alabama                   S
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawan
Idaho
II1 inoi s                     1 ,7b7 .24J                ', , r'jir id
Indiana                      382,100                '.Jashin-iton
Iowa                         131,170                West Vi f; im,i
Kansas                       329,481                ..isccrisin
Kentucky                      346,474                ,jyoi':in:j
Louisiana                     417,571                District of
Maine                        366,696                Columbia
Maryland                                            uuai.
Massachusetts                                       Puetto  Riro
Michigan                      94'', 142                Virgin  Islands
Minnesota                     693,117                Delaware Piver
Mississippi                   150,104                basin Co,*'] ssi on
Missouri                      236,888                Interstate Corinssio'1
Montana                       59,783                on the  Poto"iac River Basin
Nebraska                       96,883                Interstate Sanitation
Nevada                        35,249                Conn, i s'-ioi
New Hanpshire                 493,386                'ievi fn'jl ind hitprstate
New Jersey                    679,034                ,'/atcr Pollution Control
New Mexico                    173,358,                Coi.ir.ission
New York                     4,b39,236                Onio Riv^r Valle/ '.,'ater
North Carolina                 534,009                sanitation Commission
 The declining  State  contribution,  the relatively low  Federal  funding
 level,  inflation, and growing responsibilities  under  the CWA  are
 severely straining States  abilities to  participate in  the program.
 States  are becoming  less able partners  in the WQM program simply
 because due to funding constraints, they  increasingly  lack the
 technical  and  administrative resources  to cooperate effectively with
 EPA.  This instability is  where the program can  least  afford  it
 (i.e., minimum  requirements  of the  Act).   One submission acknowledged
 the effect of  this trend:

            "After this fiscal  year  if the  funding level
             is  not increased (the State) will be  forced
             to  reduce  its programs  and return delegated
             functions  to EPA."
                                            19

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In this situation there are several options if the strain is not relieved.
All of these options affect the efficiency of the program and require
that EPA increasingly administer the program which in effect, shifts
the burden:

     •  Amend delegations to assume fewer responsibilities over a
        longer period of time.

     •  Return delegations.

     •  Do not seek full delegation of CWA responsibilities.

Inflation — The Assessment demonstrates the serious, continuing
deterioration in existing WQM Agency program activities due to
inflation.  Without additional funds States indicate they will be
unable to assume the new responsibilities under the CWA.

As a result of persistent inflation and static funding, States have
been forced to curtail  existing program activities at the same time
that Congress and EPA are requiring significant new program activities
and expenditures.  Section 205(g) delegation has increased funds
available, but State program expansion required for delegation exceeds
the available 205(g) resources.

The programs which appear to be most affected are NPDES and mon-
itoring, which also receive the majority of the funds.  In cutting
back, States are increasingly prioritizing among CWA requirements.
These cutbacks are particularly detrimental to new initiatives such
as pretreatment, toxic BAT requirements, and 208 plan implement-
ation.  Not only must these new initiatives compete for resources,
but they also depend heavily upon maintaining existing capabilities.
At the same time that the CWA encourages delegation, inflation is
causing States to contemplate return of NPDES programs and 205(g)
delegations.  Submissions candidly discussed the problem:

          "Inflation and automatic personnel salary
          adjustments have resulted in fewer reviews
          of the new construction plans received;
          operational permits renewed; NPDES permits
          certified; EIS's reviewed; notice of
          violations written; enforcement conferences
          conducted; dischargers monitored; samples
          analyzed, and less data assimilated because
          of a decrease in manpower."

          "Our 106 staffing will have to be decreased
          in FY 1980 if the 106 grant remains con-
          sistant or decreases.  This may preclude
          our ability to be delegated the NPDES
          program ... if our 106 grant does not
          increase, we will have to cut 50% of 106
                                      20

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          Staffing  by  1984  - approximately 15 technical
          positions.   This  staff  cut would absolutely
          prohibit  us  from  operating NPDES; would
          require us to  "bare  bones" (answer the tele-
          phone)  in operating  and maintenance; and
          practically  eliminate sampling of ambient
          and  point sources."
          "The State has been able to keep pace with
          inflation by some increased State funding
          and program adjustments and keeping levels
          of activities below desirable objectives.
          Implementation and planning in new program
          areas has reached its limits . . . continued
          current levels of funding from Federal
          sources will obviously impact the ability to
          implement planning, develop new initiatives,
          and maintain the established base of current
          activities on fixed Federal  funds."

          "Current funding levels with an appropriate
          inflationary increase would be sufficient
          to continue operation of ongoing programs,
          but would absolutely prohibit the expansions
          mandated by the Clean Water Act."

          "To maintain existing programs, it is obvious
          that funding levels will  have to increase
          10 to 20 percent per year."

Increasing Demands on Limited .Resources -- The Assessment demonstrates
that water program responsibilities far exceed available resources.
Increased funding, program adjustments, and improved operations are
several options for assuring the viability of the CWA goals under
these constraints.

The Assessment indicates the new CWA requirements and other WQM
needs will conservatively require a $85 million increase in total  funding
above FY 80 levels by FY 84.  Even  at that level, WQM Agencies will have
substantial  slippage in meeting CWA deadlines.   They appear hesitant
to project the full  impact of requirements because all regulations
have not been issued and the funding outlook appears poor at the
State, local  and national  levels.

The increasing demands become critical  under existing funding levels.
The problem is not new to the program.   In the past, for example,  EPA
has emphasized major dischargers in NPDES because of resource con-
straints and has directed 208 funding to nonpoint sources.   Now
increasing NPDES requirements and the static WQM funding level have
simply led to more rapid deterioration in the situation.  States have
individually tried to make program  adjustments  (e.g., improved manage-
                                     21

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ment, priority trade-offs) to cope with demands.  However, further,
broader action will be necessary.  Strategic planning, priorities,
and more cost-effective or expeditious approaches are alternatives
for administering the program under fiscal  constraints.   Consensus  is
desirable among WQM Agencies and EPA on the appropriate  long term
action.

          "If existing funding levels continue for FY 81-
          84, the CWQD will have to drastically cut back
          staff and therefore the number of activities
          it can properly handle.  No new programs would
          be established unless existing efforts are
          diminished.  The CWQD will also begin looking
          at dropping federally mandated activities."

Major Effect of Toxics — Projections recognize that the toxic
requirements of the CWA will have major effects on the WQM program.

Toxics control will have substantial impacts on resource require-
ments and the structure of the WQM program.  WQM Agencies must gear
up to control toxics and get a better understanding of the problems.
New program direction and increased sophistication will  be required
to implement BAT and pretreatment, conduct necessary support
monitoring, and develop further necessary water quality based controls,
Approximately 1/2 of the growth in needs between FY 80 and 84 can be
attributed to toxics.

          "The Board will not initiate a program to
          look for and to permit existing municipal
          and industrial dischargers that are not
          already permitted . . . Toxic pollutant
          activities . . . will increase significantly
          during the next five years.  This should
          have the following impacts . . . Enforcement
          action will increase in the toxic areas and
          decrease with regard to conventional
          pollutants . . . The Division . . .will
          need to shift emphasis from analyzing for
          conventional pollutants to toxic pollutants."

Toxics requirements cut across all aspects of the WQM program.
Strategic planning and improved program operation are desirable
for effective achievement of toxic aspects of the program for several
reasons which are discussed in detail elsewhere in this  chapter.

     t  Program needs exceed the funding likely to be available.

     •  The CWA objectives are ambitious for the time frame.

     •  Covered activities are interrelated and should be closely
        coordinated and synchronized in planning and implementation
        (e.g., enforcement, lab equipment, and monitoring).
                                      22

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     0  There appears to be a lack of consensus among States and EPA
        on the approach to toxics which has substantial impacts on
        timing and resource requirements.

CWA Dead!ine — WQM Agency projections indicate there will be substantial
delay in meeting CWA deadlines for municipal and industrial control.
This suggests immediate consideration of alternatives to assure
attainment.

Although WQM Agencies were requested to project needs, their sen-
sitivity to the funding outlook  and other factors resulted in
conservative projections.  WQM Agency forecasts fall short of the level
necessary to meet statutory deadlines (pretreatment, NPDES) and States
confirm that this is indeed the  case.  In the likely event that the
initially large infusion of resources WQM Agencies  projected for FY
81 does not occur, there will be additional delay as activities projected
to meet CWA requirements in the  Assessment extend into FY 85 and beyond.

Industrial  and municipal sources., as well  as State water programSjare
affected by this slippage.  The Act is very clear on responsibi-
lities of sources.  Confusion or delay breeds economic uncertainty.
Business and communities, as well as the water program benefit from
stability and long-range planning.  States observed:

          "It should be noted that an attempt (in the
          assessment) has been made to keep cost pro-
          jections at a reasonable or minimum level  to
          accomplish regulatory requirements.  Some
          expansion can be noted in new program areas,
          however, on-going programs are relatively
          static along with new initiatives because of
          the current outlook for additional funding
          . . . future development has been kept to a
          minimum .  . .  Fixed funding will  not even
          maintain the status quo."

          "Any delay in implementing an investment
          decision substantially increases the degree
          of uncertainty.  An NPDES program that is
          not functioning smoothly clearly delays
          investment decisions . . . Inflation is a
          direct and easily recognizable cost which
          results .  . ."

The problem becomes  more critical at existing funding levels  (as
witnessed by current NPDES permit backlogs).  Without changes  in
approach to implementing the CWA which accommodate the funding out-
look, WQM Agency projections indicate it  will  be virtually impossible
                                      23

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to meet CWA deadlines.  States individually are trying to cope with
the situation through improved management and innovative approaches.
However, the opportunities are limited under existing policy and
regulations.  Several options exist nationally for meeting CWA require-
ments at minimum cost:  national  strategic planning, priorities,
cost-effective alternatives to the existing approach, and State
flexibility to apply streamlined, innovative techniques.  If these
measures, within available funding, are not sufficient to meet
deadlines, adjustments in the Act may warrant consideration.

205(g) is not the answer — 205(g) delegation has not offset the
increasing demands on the 106 program as had been anticipated.

The availability of 205(g) funds  has been used to argue that a cut in
or deletion of Section 106 funds  would not damage the States water
program.  The CWA of 1977 made up to 2% of a State's construction
grant allotment (or $400,000 - whichever is greater) available for
the administration of the construction grant program ana auoweu
this amount to be increased to cover the costs of administering
the NPDES, 404 dredged and fill,  and 208 programs.  In theory, this
would increase the funds available to States in two ways:  negotiation
and award of 205(g) would free-up 106 and State resources for use
in other activities; and 205(g) funds could be used for other WQM
ournoses.

The Assessment conclusively demonstrates that this is not the case
for two reasons.  First, data indicates a large number of States have
been unable to or do not think it is possible to carry out the fully
delegated construction grants management program with the resources
available under the delegation.  There will be a need to supplement
205(g) funds with 106 and States  resources.  One option to minimize
this is reexamination of 205(g) delegation requirements.  Secondly,
inflation has been so pervasive that "freed-up" 106 and States
resources are simply absorbed without any nationally appreciable
increase in program activities.  One State observed:

          "The term freed-up 106  funds is a joke.  Even
          with the assumption of 205(g) delegation, this
          agency foresees a $50,000 short fall this fiscal
          year."

205(g) has kept the growth in facility planning and management
aspects of the WQM program modest.  However, the continuation of
these activities as major WQM funding needs (in addition to the
availability of 205(g), 201, and other funding) raises issues on
the extent of those needs under the Act, appropriateness of funding
sources, and priority for those needs in WQM.
                                       24

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Consensus -- Projections indicate there is inadequate consensus
among States and EPA on program direction, strategy, and expectations.
This undercuts the ability to effectively achieve CWA objectives and
administer the water program.

States viewed as a whole, and EPA are taking different approaches
to the water program which impact timing, program direction, and
resource requirements.  This leads to substantial problems because
it undercuts the ability to effectively administer the water
program and, affects (sometimes dramatically) timing, program
structure, and resource requirements.  It is particularly evident
in the NPDES and monitoring programs, where EPA estimates of needs
and priorities varied widely from WQM Agency projections.  There
were corresponding substantial differences in program structure
and direction (e.g., water quality vs. minimum technology approach).
Within the EPA water program itseit, tnere may be inadequate consensus
on objectives and priorities as witnessed by the lack of a water
strategy.

The diversity of approaches and needs among  WQM  agencies  leads  to
priorities which are not as clear or as  consistent as desirable under
the Act.   Some WQM agencies indicate no  activitiy in critical  program
areas.   Although, within statistically acceptable norms  (see Appendix B),
there is a wide variability in costs among States and no  mutual  State
and EPA understanding of appropriate resource levels to  allocate among
priority activities.   In part,  this is due to uncertainty about the
effect of toxics and further EPA regulations on  the program.  Consequently,
within the program elements there is more consistency,  than  for the
program as a whole.   Statistical  analysis confirms this  confusion and
lack of strategy.

EPA estimates reflect a water quality standards based and a minimum
technology based approach to water pollution, particularly in
monitoring and planning.  This results in higher EPA estimates.  The
opposite occurs in NPDES where States are emphasizing technology based
approaches and cooperative,rather than enforcement techniques to
secure compliance with industrial and municipal  requirements.  EPA
estimates, emphasizing enforcement are substantially lower than State
projections.  Each approach has its advantages and disadvantages which
merit further consideration.  One State discussed this:
          "With increasing emphasis on pollution
          control  and authority delegated under the
          NPDES program, the Water Quality Bureau
          has moved from a service agency to one
          oriented to regulation and enforcement.
          This has been a rather difficult tran-
          sition for the Bureau, the permittees
          and for municipalities and will never
          be entirely completed.  The construction
                                     25

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            grants  program requires  a  continued
            assistance attitude toward municipal
            officials and their problems  whereas  the
            enforcement program requires  these same
            officials be subjected to  litigation.  All
            too  often, causes (of) delay  compliance
            are  found to lie within  the Bureau or
            EPA  review process, this significantly
            weakens the enforcement  stature."

 Since some flexibility is necessary  to  accommodate diversity,  a  mutual
 WQM Agency/EPA understanding of water program objectives and priorities
 in the 1980's  would enhance attainability  of the CWA, lead to  a
 unified program direction and strengthen the WQM Agency/EPA partnership.

 Coordinated Grants  Management -- Projected WQM  needs can be minimized
 and more effectively satisfied through  coordinating grants management.
 Future needs for  a  comprehensive strategy, priorities and improved
 program operations  depend upon this  ability.

 106  and  208 needs identified by  WQM Agencies  are  not the only  source
 of  funding  for many  of  the  needs projected by the Assessment (Table
 II-2)    Section 201, 205(g),  and 314  of the  CWA,  RCRA,  SDWA and other
 Federal  sources, and the  private sector are  alternative sources and
 S   ^T,™  Appropriate  (See  Table  II-5).  A joint  undertaking  by
 EPA  and  WQM Agencies is desirable to  take advantage  of  the  funding
 overlaps.   Such action  is particularly important  when demands  exceed
 available resources.  In the water  program, there  should be  a  common-
 ality  of approach, strategy  and  priorities  for which these  funding
 sources  have different roles and  responsibilities.   Coordinated grants
management,  based  on that commonality can promote strategic  priorities
document progress  and accomplishments, and  enhance program operation  '
                                    TABLE 11-5

                           POTENTIAL FUNDING SOURCES


                                                       PERMITS   USER  STATE/LOCAL
 ACTIVITY                106    208    201    205 igi* *  JH    104    105   FEES   CHARGES  FUNDING   OTHER
 FACILITY PLANNING AND MANAGEMENT
 • FaciUty Planning
 • Construction Grants
    Management
 • O&M/Trammg
 INDUSTRIAL AND MUNICIPAL
  REGULATION
 • NPDES Related

 • Pretreatment
 • Monitoring
 • 401

 • Othei State Point Source
    Permit Programs
 NON POINT SOURCES
 • Planning
 • Administration
 OTHER
 • Ambient Monitoring
 • General and Point Source
    Planning
 • Emergency Response
                                        26

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Stable program -- Projections  indicate WQM Agencies perceive no change
in direction for the WQM  program.

WQM Agencies project no changes  in direction for the water program.
They focus  on meeting the immediate deadlines of the CWA which as  indicated
here, is a  considerable venture.  Resources are directed towards
meeting the minimum technology requirements under the Act (e.g., NPDES,
pretreatrnent, municipal compliance, and BMPs).  Any changes in program
direction for WQM Agencies  (e.g., water quality standards based point
and nonpoint source control) will have major effects on program structure
and resource requirements.

Nonpoint sources — Nonpoint sources continue to be a major program
element under the projections  but remain an emerging area.  Nonpoint
source control appears to be a cost-effective approach for WQM,
particularly the Federal  government, to pollution abatement.

WQM Agencies continue their commitment to nonpoint source control.
They are at various stages of development which is expected because
nonpoint source control is an  emerging area of WQM.  Projections
indicate that substantial  development can be accomplished with a
relatively moderate growth in  Federal resources.  Results indicate WQM
Agencies foresee the immediate but limited need to satisfy major
planning needs.  As this  occurs, there is a shift in FY 80-84 for WQM
from planning to less resource intensive program administration.  As
implementation escalates WQM needs decline  and  nonpoint  source  control
becomes  a very good  investment  of the Federal  WQM  dollars  due  in
part  to  the following:

     •   Nonpoint  sources are responsible  for  1/2  of  the  pollution,

     •   program is  at  early stages of development  and  therefore
        amenable  to  substantial progress  in control  and  management,

     *  nonpoint source control  receives substantial support from
        other sources such as other Federal  agencies (USDA), permit
        fees, local  government,  and non-water quality related State
        programs (e.g., Soil and Conservation programs).  WQM is,
        in effect, "seed  money"  for nonpoint  source in control  in
        contrast to industrial  and municipal  control where the
        WQM is the primary support.

In spite of the progress  indicated, projections do not correspond as
well  as they should to the known extent of nonpoint source pollution.
The gap between the extent of the problem and projections  is partially
the result of the preceived lack of resources to address nonpoint
sources  and the emerging  nature  of the program.   This tendency is
also seen elsewhere in Assessment (See below).   The WQM baseline
strategy is evidence in the Assessment by a consistent WQM Agency
direction.  Continuation  of this emphasis should increase  State and
local  nonpoint source control,  expedite control,  and minimize costs.
                                     27

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Extent of Pollution -- Projections reflect EPA and CWA priorities
but to a much lesser degree, the extent of pollution.

Projections correspond strongly to measures of human activity (e.g.,
population, number of pollution sources) and CWA requirements.  This
results in statistically valid projections and indicates WQM Agencies
are consistent in their approach and outlook.  They are responsive
to past experience and priorities (e.g., deadlines for minimum controls).

Emerging problems or the extent of pollution was not a major factor in
projecting needs.  Therefore, more varibility in Assessment results and
higher needs would be expected based on the extent of pollution.  This
is a particularly important factor to consider in preventing future
problems (e.g., impacts of energy development).  The conservative
approach taken by WQM Agencies and the existing fiscal constraints are
major reasons for that limited coverage.  A shift in program focus from
a minimum technology to a more problemmatic approach will  affect needs.

Municipal  needs — Projected growth is directed primarily towards
industrial  sources and toxics.  Municipal  compliance for conventional
pollutants may not be receiving adequate attention.

Industrial  and municipal dischargers are both major sources of water
pollution, but pose quite different dangers to water quality.  Over
50% of the municipal sources are in noncompliance with the CWA and are
causing substantial problems with conventional pollutants.  WQM
Agencies recognize the need to address this problem in their projections
for NPDES, operations and maintenance, and training, but appear to
place the majority of the emphasis on industrial sources.   The
appropriateness of this emphasis should be assessed in the development
of the water strategy for the 1980's.
                                     28

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             Chapter III



MUNICIPAL FACILITIES PLANNING AND MANAGEMENT


    Section A - Overview

    Section B - Construction
                Grants Management

    Section C - O&M/Training

    Section D - Facility Planning
                       29

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                                   Section A

                                   OVERVIEW
This Chapter includes WQM activities relating to the planning, design, construction
and operation of sewage treatment works.  These activities specifically include
facility planning, construction grants management, operation and maintenance
(O&M) and training.  They are eligible for Federal funding under 201, 205(g),
106, 208, and other Sections of the Act.  Needs projected here (i.e., UQM
under 106 and 208) are limited to those activities States feel they cannot
fund from other sources (e.g., 201 and 205(g) (see Table III-l)).


Table III-l:  Total State Projected Needs for Municipal  Planning and Management*

                                 FY79    FY80    FY81     FY82    FY83    FY84
Construction
Grants Management
Facility Planning
O&M/Training
17.5
3.5
6.5
13.0
4.5
7.0
10.0
7.5
9.5
10.0
8.0
10.5
9.5
7.5
11.0
9.5
7.5
11.5
TOTAL                            27.5    24.5    27.0    28.5    28.0    28.5


  *Some administration costs are not included ($000,000).  See Table II-3.


Proper operation, maintenance, and construction of sewage treatment plants  are
an environmental priority for States and EPA.  These needs undergo moderate
growth between FY 80 and 84 going from $24.5 to$28.5 million (20% growth).
This is due to the increasing use of 205(g) funds for construction grants
management and 201 for facility planning.  The 205(g) delegation, however,
does not supply sufficient funding to fully support construction grants management
in delegated States.  The decrease in construction grants management needs  due
to 205(g) is more than offset by the increase in O&M/Training and facility
planning (see Figure III-l).

There are many demands on WQM funds and many program overlaps among Sections
201, 205(g), 208, 106, 105, and 109 of the Act.  A coordinated funding strategy
for meeting these needs should be a paramount consideration.  Since proper
plant operation involves FJPDES and monitoring, those programs are also affected.
                                       30

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                       Figure  III-l

Total WQM  Agency Projected Needs  for Municipal  Facilities
                  Planning and  Management

                            FY80
                                                       FACILITY
                                                       PLANNING
                                                         17%
                      CQf*STRyCTtQN GRANTS
                          MANAQfME
                          •  "  54% '
                            FY84
                                                       FACILITY
                                                      PLANNING
                                                        (26%)
                             31

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                                   Section B

                        CONSTRUCTION GRANTS MANAGEMENT
Conclusions
     •    Management of the construction grants program will continue to be a
          priority WQM activity throughout the FY 81-84 period.  Although the
          number of Section 205(g) delegations and grant awards will increase
          during this period, the States indicate a continued need of over $10
          nil lion in State and 106 Federal funds to successfully manage the
          Statewide construction grants program.

     «    States are confused about the WQM role in construction grants management
          and the eligibilities under 205(g) delegations.


Background

Since the passage of P.L. 95-2T7, grant awards under Section 205(g) of the CHA
have been available for States' use in management of the construction grants
program.  The States are expected to be delegated increased responsibility to
administer construction grants under delegation and to meet those costs with
205(g) funds.

The States have met the costs of administering the construction grants program
with State and Section 106 funds since implementation of the CWA in 1972.
These activities have included:  design and implementation of the project list
and associated priority criteria; coordination with NPDES in permit development
and enforcement—as well as Hater Quality Standards development; preliminary
conferences for steps 1 and 2; review of Section 201 facility plans, environmental
assessments; construction oversight; O&M manual review; public participation;
administrative review of applications; processing of grants offers, amendments
and payment; resolution of audit problems; maintaining a grants tracking
system; responding to Federal EPA and State legislative information requests;
and activities not directly related to the Section 201 construction grants
program—such as industrial facilities management.

With receipt of a 205(g) delegation, State agencies become primarily responsible
for the performance and quality of these activities, while EPA assumes an
oversight role.  Historically, the States have used 15% to 20% of their combined
State and Section 106 resources to administer the construction grants program.
The availability of Section 205(g) funds was expected to ultimately reduce the
need for States to use any 106 funds in the administration of the construction
grants program.


State Projections

The Needs Assessment information yields a mixed, somewhat confusing picture
and a continuing need for 106 funds (Table III-2).  The confusing results from
the availability of Section 205(g) funds and the varying ways in which they
are utilized by the States.
                                       32

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Table III-2:   Total State Projected WQM Needs in Construction Grants
	      Management, FY 79-84 ($000,000)	

                                 FY79    FY80    FY81     FY82    FY83    FY84
Total States Needs
Total Staff Years
7.5
683
13.0
485
10.0
400
10.0
381
9.5
377
9.5
375
The need for WQM funds diminished as 205(g) funds become available in FY 80
and FY 81.  State projections for the FY 81-84 period, however, level off in
FY 81  and remain fairly constant through FY 84.

In FY 84, when virtually all the 205(g) delegations are expected,  there is a
small  increase (see Appendix A for precise amount) in the need for Section 106
and State funds.   This is presumably to supplement the Section 205(g) resources
devoted to administration of completely delegated construction grants management
programs.

While at first surprising, this continued demand on WQM and 106 can be explained
by examining the patterns of need indicated by various States.

     e    22% of the States (11) exhibited the common expectations concerning
          205(g)  delegation.  Following the receipt of a 205(g) delegation,
          the need for State and Section 106 resources declined to zero and
          remain at no need for the entire period covered by the Assessment.
          Thus, for example, a State negotiated  and received a 205(g) delegation
          and grant award in FY 80 and indicated no need for State and Section
          106 resources in FY 81 and beyond.

     0    42% of the States (21) indicated a continued need for WQM funds
          subsequent to receipt of a Section 205(g) delegation.  Of these, 16
          indicate no decrease or an actual increase in the need for Section 106
          and State resources.  This group exhibits 2 patterns of  projected
          need:

                    The demand for State and Section 106 funds decrease to
                    zero for one or two fiscal years and then is reasserted as
                    a more complete phase-in of  205(g) activities  occur.

                    The demand for State and Section 106 funds remain the same
                    or increases as the 205(g) delegation is phased in.

     0    28% of the States (4) indicate that no 205(g) delegation is expected.
                                       33

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     t    4 States, indicated no need for Section 106 and State funds from
          FY 79-84.  The results are summarized below:


Table III-3:   Patterns of 205(g) Use in Relation to WQM Need	

          205(g) Award/   205(g) Award/   205(g) Award/   No 205(g)   No Need
          No WQM Need     Decreased l.'QM   Increased WQM   Award       FY 79-84
                          Need            Need            Expected
Number
of States     11               5               16            14
Analysis

These patterns of need suggest some possible conclusions.  The amount of funds
available under 205(g) may be inadequate to support State activities as EPA
begins to measure State performance against the delegation agreement require-
ments.  This could mean that the 2% or $400,000 set aside is too low or
unrealistic given EPA's expectations.  Since 205(g) funds are intended to pay
100% of the actual State administrative costs, EPA's expectations may be too
high given the amount of money available.  This is particularly important
because projected funding under 205(g) is expected to exceed $60 million by
FY 81.
Another possible explanation is that some of the activities projected as
needs in construction grants management are or appear to be ineligible for
funding under Section 205(g).  Thus, 205(g) funds may be adequate or available
but not used because of uncertainty as to their eligibility.  There appears to
be little consistency in State interpretation.  30 States for example, indicate
a continued need for UQM funds to perform non-201 related functions which are
an integral part of the State municipal facilities construction program.  In
some cases, 205(g) is expected to pay for these activities; in others, it is
not.

The overall impact of Section 205(g) funds on the demand for UQM State and
Section 106 needs does not indicate any real savings decrease in WQM dollars
needed over time.  This fact results from a combination of factors, the most
significant being the real reduction in program support due to inflation.  The
States recognize this problem:

          "...106 funds will continue to be needed in this area due to
          continued development of design standards and construction
          permits for non-grant projects, agricultural projects and
          industrial projects."

          "The term 'freed-up1 106 funds is a joke.  Even with the
          assumption of 205(g) delegation, this agency foresees a
          S50,000 shortfall  this fiscal year  (FY 80)."

          "There are no plans at present for assuming 205(g)
          delegation.  In  the event 205(g) delegation is accepted,
          106 funds will be  used to offset program cost increase
          due to inflation."

                                      34

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                                   Section C

       OPERATION AND MAINTENANCE OF HASTE TREATMENT FACILITIES; TRAINING
Conclusions
          States want to improve the priority of operations and maintenance
          (O&M) and training programs in recognition of the serious, pervasive
          municipal noncornpl iance problems caused by inadequate O&M and training,

          Substantial progress can be made toward improving POTW's performance
          by implementing the Composite Correction Program (CCP) and other
          measures.
Background

Increased efforts to solve municipal sewage problems were made with passage of
Public Law 92-500 in 1972 (under Title II, Section 201).  Since then, many
billions of dollars under Section 201 of the CWA have been spent on construction
of waste treatment facilities.  Subsequent efforts have been made to provide
guidance through regulations and EPA policy to insure the best O&M procedures.

In spite of these efforts, it is estimated that only about 1/2 of all publically-
owned treatment works (POTWs) are meeting their design standards for biochemical
oxygen demand (BOD) reduction and suspended solids (SS) removal.  This has
lead to substantial noncompliance which is due in part to low funding, inadequate
staff and operation procedures, poor maintenance, and inappropriate plant
design.

An Evaluation of Operation arid Maintenance Factors Limiting Biological Hastewater
Treatment Plant Performance, released in July 1979 by EPA, listed the following
persistent POTW problems in decreasing order of severity:

     1)    Inadequacy of operator application of treatment concepts and testing
          to process control.

     2)    Infiltration/Inflow - resulting in periods of severe hydraulic
          overloading, and dilution of the influent wastewater so that both
          suspended and fixed biological  systems are loaded to less than
          optimal values.

     3)    Inadequate Process Control Testing Procedures.

     4)    Ineffective O&M manual instructions.

     5)    Inadequate industrial loading process.

     6)    Inadequate training.

     7)    Inadequate hydraulic loading process.

     8)    Inadequate understanding treatment process.
                                       35

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     9)   The lack of controllability evident in the inability to adequately
          measure and control flow streams such as return sludge flow and
          trickling filter recirculation rates.

    10)   Inadequate sludge handling facilities and the inability to measure
          and control the volume of waste sludge.


State Projections

In combatting these municipal operation problems,  States show substantial
growth in needs through FY 84.  Actual  State needs are indicated below.   The
program projected in WQM, however, continues to be modest.


Table III-4:   Total State Projected Municipal  O&M/Training Needs, FY 79-84

 ($000,000)	FY79    FY80    FY81     FY82    FY83    FY84

Operation and
Maintenance
Training
4.
2.
0
5
4.
3.
0
0
5
4
.5
.0
6.
4.
0
5
6.
4.
5
5
7.0
4.5
TOTALS                            6.5     7.0     9.5    10.5    11.0    11.5


Projections indicate that the program basically stabilizes in FY 82 - FY 84.
Thus, States appear satisfied with this level effort in WQM.   States do not
indicate a strong attention to operator training in relation  to O&M inspections,
audits, etc.  States project a higher than average growth rate for the program,
indicating the underfunded nature of this program.


Analysis

EPA statistically analyzed the States'  projected needs, in order to evaluate
their validity.  This was done by comparing States' needs in  FY 84.  The cost
of the projected program was divided by the population for each State and
found to be valid and within an order of magnitude.

Traditionally, this area has been funded under Section 106.  EPA stresses the
availability of other funding sources,  such as Sections 205,  201, 109(b), 105,
and 104.  Use of these alternate funding sources would free up Section 106
funding for other areas.  Further coordination among grants programs would
enhance funding.

Programs outside WQM may be involved in O&M/Training.  Those  programs, although
not covered by the Assessment, should be considered in determining the full
extent of needs.  Sufficient information is not available under the Assessment
to evaluate the full extent of present support to O&M/Training and the total
needs outlook beyond UQM.

Improvements in Agency policy and guidance procedures, plant management/design,
incentives for O&M/Training, and integrated EPA management of the overlapping
programs are desirable, as envisioned by the Composite Correction Program
discussed in the 1979 study.

                                       36

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                                   Section D

                          MUNICIPAL FACILITY PLANNING
Conclusion

WQM Agencies foresee difficulty in relying on 201 and 205(g) funding to meet
facility planning needs.  Further consideration should be given to these
problems in developing the water program strategy for the 1980's.


Background

Municipal waste treatment problems exist in every State.  Many of the problems
lend themselves to straightforward solutions, via EPA's construction grants
program, through secondary treatment facilities.  Sometimes, however, municipal
waste treatment problems are complex and require additional  planning before
construction can proceed.  WQM Agencies must ensure that water quality standards,
total maximum daily loads, waste load allocations, population/economic projections
and financial arrangements are sound.  They consider point/nonpoint source
control  tradeoffs, innovative or alternative technologies, and alternative
approaches such as water conservation.

In the first round of 208 grants, many State and Areawide Agencies successfully
addressed municipal waste treatment problems, identifying service areas,
making population disaggregations, and identifying necessary levels of treatment.
Often, however, where advanced waste treatment (AWT) appeared to be necessary
for the solution to a problem, further planning was required to confirm the
need.  To assist with development of State processes for municipal facility
planning, EPA is funding about 15 AWT olanning and review projects with FY 79-
208 grants.

EPA, recognizing the costs and energy requirements of publically-owned treatment
works providing treatment greater than secondary, has taken  several steps to
insure that such facilities are only Federally funded when based upon technically
adequate effluent limitations.  Reduced WQM funding in fiscal year appropriations
and increasing demands lead to several  policy adjustments.  With limited
exceptions, AWT planning in FY 80 and beyond is not eligible for 208 funding
(see Chapter VI, Section D).   Instead,  201  and 205(g) policies have been
expanded to meet facility needs.

With respect to 208 funding for regular plan updates, EPA believes almost all
of the necessary population projections, service area delineations, and waste
load and flow projections are in  place, by virtue of the initial 208 planning
effort EPA funded between FY 74 and 79 and current disaggregations under the
Cost-Effectiveness Guidelines.  Where construction grants are involved, popu-
lation projections are an eligible Step I cost and are easily incorporated
into existing 208 plans under the WQM regulations.
                                       37

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TD365
.W65
1980
United States
Environmental Protection
Agency
                             Water Planning Division
                             Wp-hmuto^ DC 20460
Water
                                          September 1980
OOOD80100
               Draft
               WQM Needs Assessment
               FY 80-84

-------
The material contained in this draft publication is being given circulation



to provide oooortum'ty for review and comment.  All statements, conclusions,



and/or recommendations contained here are preliminary draft and do not



necessarily reflect the policies of the U.S. Government or the Environmental



Protection Agency.   Comments should be forwarded to the Environmental Protection



Agency, Water Planning Division (WH-554), 401 M St., S.W., Washington, D.C. 20460



by September 30, 1980.  This material will be revised as necessary to respond to



comments.

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                                TABLE OF CONTENTS


                                                                               PAGE

Chapter I
     INTRODUCTION

     A.   Background	   2

     B.   Methodology	   7


Chapter II
     SUMMARY

     A.   Summary of WQM Agency Projections	  10

     B.   Observations and Impl ications	  18


Chapter III
     MUNICIPAL FACILITY PLANNING AND MANAGEMENT

     A.   Overview	  30

     B.   Construction Grants Management	  32

     C.   O&M/Training	  35

     D.   Facility Planning	  37


Chapter IV
     INDUSTRIAL AND MUNICIPAL SOURCE CONTROL

     A.   Overview	  41

     B.   NPDES	  45

     C.   Pretreatment	  54

     D.   Monitoring

          1.    Overview	  58

          2.    Equipment	  61

          3.    Compl iance	  64

          4.    Intensive Surveys	  67

     E.   Dredge and Fill  Programs	  69

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                                                                              PAGE

Chapter V
     NONPOINT SOURCE PLANNING AND ADMINISTRATION

     A.   Overview	   73

     B.   Rural

          1.    Overview	   84

          2.    Agriculture	   86

          3.    Silviculture	   91

          4.    Noncoal  Mining	   96

     C.   Urban

          1.    Overview	  101

          2.    Urban Runoff	  1 03

          3.    Construction Runoff	  106

     D.   Ground Water

          1.    Overview	  Ill

          2.    Onlot Disposal	  116

          3.    Residual s	  1 21

          4.    Ground Water Management	  1 24


Chapter VI
     OTHER WQM PROGRAMS

     A.   Overview	  1 30

     B.   Ambient Monitoring	  1 32

     C.   Water Quality Standards	  134

     D.   TMDL/WLA	  1 36

     E.   Emergency Response	  1 39

     F.   Other State Programs	  142


Chapter VII
     CLEAN LAKES	  "143

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                                                                              PAGE

Chapter VIII
     INTERSTATE AGENCIES	  145
Appendix A.  Statewide Projections.

Appendix B.  Statistical Analysis..
 *The Appendices may be obtained by writing or calling:

                    The Environmental Protection Agency
                    Water Planning Division (WH-554)
                    401 M Street, SW
                    Washington, DC   20460
                    (202/426-2474 or FTS/426-2474)
                                      in

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      CHAPTER I
     INTRODUCTION
SECTION A - BACKGROUND



SECTION B - METHODOLOGY

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                               SECTION A

                               BACKGROUND
The Water Quality Management Needs Assessment was undertaken to
identify the fiscal  and manpower resources required by State, Interstate,
and Areawide Agencies to protect water quality and achieve the goals of
the Clean Water Act (CWA).  This report presents the results of that
Assessment.  It is based on conservative estimates of activities
supported under Sections 106, 208 and 314 which these Agencies believe
necessary over the next 4 years to implement the Act.  The Report is
the culmination of a cooperative effort between EPA Water Program
Offices, EPA Regional Offices, all States, and Interstate and Areawide
Agencies.

To carry out the ambitious and far-reaching goals set by the Congress
in the Clean Water Act (CWA) of 1972 and reaffirmed in 1977, many
specific objectives must be accomplished.  The Nation has committed
an investment measured in tens of billions of dollars to control
municipal and industrial discharges into waterways.  More is being
invested every day by taxpayers, corporations, and consumers.  Wise
application of that investment to achieve its intended purposes
requires thousands of decisions by Federal, State, Interstate,
Areawide and local agencies, and the public.  Most of the national
investment in water pollution control goes to industrial and muncipal
treatment facilities.  A very small portion of those funds go to
management of those activities.

The activities covered in the Assessment with the exception of
wastewater treatment plant planning and construction under Sections
201 and 205(g), constitute virtually all State, Areawide, and
Interstate Agency (referred to in this Report as WQM Agencies)
participation in the CWA.  They comprise what is termed the Water
Quality Management (WQM) program funded Federally under Sections
106, 208, and 314.

Activities funded by Section 106 form the core of the WQM program.
106 funds are used together with State funds to administer the State
water program, primarily for planning, monitoring, construction
grants management, the National Pollutant Discharge Elimination
System (NPDES) for permit issuance and enforcement, municipal
operations and maintenance, and emergency response.  On an
aggregate basis, States have historically contributed twice as much
as the Federal government to activities under Section 106 (See Table 1-1
and Figure 1-1).  The static funding level of recent years has sub-
stantially affected the covered activities and is a primary focus
of this Report.

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                  FIGURE 1-1
HISTORICAL CONTRIBUTION TO 106 FUNDED PROGAMS
                   TOTAL
                          FEDERAL 106
                          APPROPRIATION
                   75    76    77

                  FISCAL YEAR
                   TABLE 1-1

           HISTORIC FUNDING  (FY 72-80)

                  ($ millions)
FY
72
73
74
75
76
77
78
79
80
(106) appropriated
15.0
20.0
40.0
48.5
50.0
50.0
52.4
52.4
48.7
(208) appro
_._-
50.0
100.0
150.0
53.0
15.0
69.0
32.0
37.5

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Assessment results are particularly important under the 1977 amend-
ments to the Act which expanded on requirements for the control  of
toxics through Best Available Technology (BAT), conventional pollutants
through Best Conventional Technology (BCT)  and municipal  facility
compliance.  This new phase is more complex and will  substantially
affect many WQM programs, including industrial and municipal source
control and monitoring.  The resource implications of this expansion
are also a primary focus of this Report.

The 1977 Amendments to the Act provided for delegation of responsibility
for construction grants management under Section 205(g).   By FY  81,
approximately $60 million in Federal funds  will be available annually
for such activities.  As with NPDES, the 205(g) delegation usually
requires expansion of the existing State program to obtain approval.
Section 205(g) delegation has reduced but not eliminated  the need for
WQM funding for construction grants management due to the magnitude  of
support required to administer the delegation  (See below).

Section 208 of the CWA supports planning or program development  at
the State and Areawide levels.  The plans developed under 208 in-
creasingly set the context for future water pollution control.   The
emphasis since FY 80, under the WQM strategy, has been on nonpoint
source control, particularly filling the major gaps in 208 plans
developing a technical information base for program development  nationally,
and building financial capability to administer programs.

Activities under Sections 106 and 208 are supplemented by the Clean
Lakes program under Section 314, which provides matching  grants  to
identify and control pollution of fresh water lakes.   These grants
can cover planning as well as structural and nonstructural controls.
The 314 program and associated projections  are discussed  separately
in Chapter VII.  Throughout the Report, except if otherwise stated,
the term WQM covers only WQM Agency activities supported  by 208  and  106.

State pollution control agencies play a vital and indispensible
role in achieving the goals of the CWA.  Congress recognized this
when it emphasized delegation to States of responsibility for
carrying out the NPDES, dredge and fill programs, and construction
grants management programs.  The activities under WQM are generally
managed by the States.  In keeping with Congressional intent, delegated
and non-delegated States have developed programs to administer the
complex and broad requirements of the Act.

Together with Areawide Agencies, State total contributions to the WQM
program have risen substantially now exceeding Federal support by
approximately $40 million (Table II-l).  The rising level of contri-
bution reflects in part the expansion of CWA requirements and increased
State delegations.  As this occurred and Federal funding  has remained
static or declined, implementation of the CWA has become  increasingly
dependent upon continuing that level of support at a minimum.  The
future Federal funding outlook for 106 and 208 are provided in Tables
1-2 and 1-3.

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To provide information on funding needs expeditiously for the budgetary
process, the Report is being issued in preliminary draft  form at  this
time.  It will also be used by EPA and States in the current initiative
to restructure the water program and develop a long-term  water
strategy through the 1990 construction grants strategy and the 106
management initiative coordinated by the Office of Water  and Waste
Management.  This initiative is proceeding on the basis of Congressional
direction, and the increasingly significant need to stretch scarce
Federal and State resources.

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                                   TABLE  1-2

                         STATE  106 TARGETS FOR  FY 81

       BASED  ON TOTAL  APPROPRIATION OF $48.73 MILLION  ($ MILLIONS)
REGION 1
TOTAL
3.74
               REGION  2
                REGION  3
            REGION 4
5.43
                                           SRBC   0.08  ORSANCO  0.33
6.10
9.48
            REGION 5
CT
ME
MA
NH
RI
VT
NEIWPCC

0.75
0.54
1.16
0.33
0.51
0.24
0.22

NJ
MY
PR
VI
ISC



1.33
2.68
0.79
0.36
0.26



DE
DC
MD
PA
VA
WV
DRBC
INCOPOT
0.41
0.41
0.82
2.18
1.23
0.62
0.22
0.14
AL
FL
GA
KY
MS
NC
SC
TN
1.30
1.26
1.52
0.72
0.73
1.80
0.97
0.88
IL
IN
MI
MN
OH
Ml


1.82
1.02
1.74
0.91
1.86
1.38


8.74
REGION 6
TOTAL     4.16
               REGION  7
                   2.64
                REGION  8
            REGION 9
                    1.68
                 4.38
            REGION 10
AR
LA
NM
OK
TX


0
0
0
0
1


.72
.82
.28
.54
.80


IA
KS
MO
NE



0
0
0
0



.71
.51
.86
.56



CO
MT
ND
SD
UT
WY

0.46
0.33
0.21
0.22
0.30
0.16

AZ
CA
HI
NV
AS
GU
*TT
0.40
2.87
0.34
0.17
0.08
0.36
0.16
AK
ID
CR
WA



0.15
0.38
0.80
1.04



                 2.37
GRAND  TOTAL  — 48.73

Note:  Columns  may not  sum exactly due to rounding error
       * includes Northern Mariana Islands
  REGION 1

   1.5
                                 TABLE  1-3

        REGIONAL 208 TARGETS FOR EY 81 BASED ON TOTAL APPROPRIATION OF $34.0 MILLION*

                                (* MILLIONS)



  REGION 2   REGION 3   REGION 4   REGION 5   REGION 6   REGION 7    REGION 8  REGION 9

    3.0       2.8       4.7      5.5      3.8      1.9       2.2       3.7
                                                      REGION 10

                                                        2.9
  TOTAL: 32.0
  * $2 million may be held at Headquarters for
   NURP funding during FY 81

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                               SECTION B

                              METHODOLOGY
Since the Assessment was the first Agency attempt to project WQM
needs no methodology existed.  The Assessment evolved on a
trial and error basis.

The guidance used to complete the Assessment for WQM Agencies was
developed in close coordination with States, Interstate Agencies,
the Association of State and Interstate Water Pollution Control
Administrators, and the EPA Regional Offices.  Areawide Agencies
participated through the National Association of Regional  Councils.
In designing the format for collecting information, careful  con-
sideration was given to the need for National uniformity and
consistency.  The guidance divided WQM activities into 41  categories
or sub-categories to correspond as closely as possible to  the
organization of water programs and legal  requirements.  Since the
information was not solicited to revise the 106 allocation formula,
programmatic CWA objectives rather than the extent of pollution
were the primary consideration in organizing the Assessment.  In
each category, total fiscal needs (i.e.,  combined State/local and
Federal share) and staffing requirements  were solicited.  In the
summary, the guidance solicited the projected source of those funds
(i.e., State/local and CWA Sections 106,  208 or 314.)

Drafts of the guidance for the Assessment were tested in pilot States
and an Interstate Agency and distributed  for review and comment.
The guidance was then refined and issued  to EPA Regional Offices.
Since the purpose of the Assessment was to document State, Interstate,
and Areawide Agency understanding of needs (i.e., not EPA's  prediction),
EPA also nationally proceeded on a separate track to estimate needs (see
below) to provide some basis of comparison.

The Assessment guidance was designed for  completion by EPA Regional
Offices in consultation with WQM Agencies.  States and Interstate
Agencies in particular showed a high degree of interest in the
Assessment and took an active role.  Whenever possible, Regions
relied on existing information such as Section 305(b) reports,
State strategies, and State/EPA Agreements.  Projections for State
and Areawide Agencies were incorporated into one statewide submittal.
All submittals received WQM Agency concurrence.

The Assessment covered FY 79-80 to document past activities  and  funding
levels.  Needs were projected for FY 81-84.  Ideal  or "cadi 1 lac"
programs were avoided as unrealistic and  the ability to staff up and
manage projected growth was considered a  limiting factor.  Narrative
descriptions of program direction, activities, and expected  outputs
were requested.

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Completed submissions were reviewed in EPA headquarters to assure
that the information was properly categorized, the addition was correct
and the activities projected were eligible under WQM.   In some instances,
it was necessary to make adjustments in submittals for one or more of
those reasons.  WQM Agency projections were reviewed for consistency
by comparison with one another (See Appendix B)  and analyzed.  Statewide
projections as adjusted, appear in Appendix A.  Interstate Agencies
are covered in Chapter VIII.

In the analysis, the categories used to solicit information were
reformated to correspond more closely to environmental and program
objectives.  The distribution portrays the direction of the
water program and program interrelationships well.  This Report is
organized according to this reformating into discussions on facility
planning and management, industrial and municipal  control, nonpoint
sources, and other activities.

In addition to the effort to project needs from the WQM Agency
perspective, in select program areas EPA also estimated needs to
provide some perspective on WQM Agency projections.  Coverage was
limited by the availability of information, resources  and time.  NPDES,
monitoring, pretreatment and some nonpoint sources were covered. The
Agency focused on areas which were evolving under new program require-
ments.  Estimates were developed by using indicators for the extent
of the problem, identifying typical activities for solving the problem,
assigning costs to the activities, and estimating national needs.  For
the most part, EPA estimates were developed strictly on the basis of
existing policy, regulations and CWA deadlines, without accounting for
individual WQM Agency characteristics.  The comparison of WQM Agency
projections and EPA estimates proved more useful for indicating
differences in approach or program direction than in evaluating
validity of costs projected.  In large part this is because no EPA
water program strategy (other than that for nonpoint sources) existed
on which to project needs.
                                     8

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                  CHAPTER II
                   SUMMARY
SECTION A - SUMMARY OF WQM AGENCY PROJECTIONS



SECTION B - OBSERVATIONS AND IMPLICATIONS

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                               SECTION A

                   SUMMARY OF WQM AGENCY PROJECTIONS
WQM Agencies project that an increase of 40% or $85 million above
FY 80 total WQM Agency/Federal  funding levels will  be required to
manage implementation of the CWA annually by FY 84  (Table II-l).   This
level of funding, being constant from FY 81-84, appears reasonable
over the long term if there are no major adjustments or changes in
program direction.  However, WQM Agencies indicate  uniformly that
current and projected funding will be inadequate to meet minimum  require-
ments within the time frame of the Act.   This is reflected by the 2:1
increase noted in the first available budget year,  FY 81.  While  the
Federal share increases substantially in FY 81, the State share has
risen steadily.
Table II-l:  Total WQM Needs ($000,000)
FY79*
Federal Share**
State & Areawide Share
TOTAL
84
86
171
.4
.6
.0
FY80*
86
126
213
.2
.8
.0
FY81
178
116
294
.0
.0
.0
FY82
181
110
291
.0
.5
.5
FY83
180
113
293
.0
.5
.5
FY84
177.0
118.5
295.5
*Note that it appears some FY 79 planned expeditures previously
 estimated by States in 106 supported programs actually
 occurred in FY 80.  A considerable amount of FY 79 appropriated
 208 funds apparently were indicated as used in FY 80.

** 208 and 106
State and Areawide contributions have increased substantially over
the past decade, while in recent years Federal  support under 106  and
208 has remained fairly static (Table 1-1).   States in the Assessment
project a declining level of contribution reflecting trends in State
legislative action and is not limited to WQM.   The 106 program, where
States collectively contribute twice as much as the Federal  government,
illustrates the relationship of WQM Agency to Federal  funding and the
impact of static support (Figure 1-1).  One State submittal  portrays this:
                                    10

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               "The highest level of Federal funding
               for the 106 program was in Fiscal year
               1976 and 1977 ....  Despite increasing
               costs due to inflation, the 106 grant
               has been generally decreasing since
               1977....  Over the four year time period
               from FY 77 to FY 80, therefore, a total
               of 90 positions were lost to the pro-
               gram.  During this same time period,
               there were increasing program responsi-
               bilities as a result of the 1977 amend-
               ments to the Clean Water Act.  The
               Department's Water Quality Program
               would have kept pace with inflation
               if 106 funding levels had kept pace
               with inflation to support increasing
               costs.  The 5-year Needs Assessment
               for the 106 program included in this
               document reflects an increase of 100
               positions through FY 84."

Projections indicate that the State ability to administer the Act is
severely strained as requirements increase and funding remains constant.
States indicate these new requirements cannot be met without increased
Federal support.

Effects are limited to the 106 supported programs, most importantly
implementation of CWA requirements for industrial  and municipal  control.
This is in contrast to the matching programs (i.e., Clean Lakes  and 208)
where WQM Agencies project increasing needs and therefore an  increasing
level of State/local support.   As the above quote indicates, although
WQM Agencies projected program growth to administer increased requirements
of the Act, they may contemplate more efficient programs because pro-
jections barely offset past inflation.  As States recognized in  the
Assessment:

               "The Division's budget has increased
               nearly 10 fold  since 1971 and additional
               expansion is extremely difficult to
               justify when Federal  support is con-
               tinuing to decline.  The Division
               feels the Needs Assessment is very
               important and represents a positive
               step towards achieving the national
               goals ... (the  State)   Legislature is
               becoming increasingly resistant to
               "being blackmailed" into supporting
               Federal  programs."
                                    11

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               "The amount of State general funds
               used as a match has remained static for
               the past several years creating a
               dependency on Federal funds .... Changes
               in Federal funding levels will  signifi-
               cantly affect the State staffing levels.
               With a fiscally conservative legislature,
               relief of any Federal short falls
               would be difficult with the possibility
               that delegations might be returned to EPA."

               "(The State) will remain fairly dependent
               upon Federal funding to continue in
               the Water Quality Management Program.
               The level of ... participation  will be
               directly proportional to available 106
               208, and 314 funds."

Within the projected Federal share, WQM Agencies indicate a 140%
or $69.5 million increase in Section 106 support and a 50% or $20
million increase in Section 208 support will  be needed by FY 84
(Table II-2).
             Federal WQM Contributions Need by WQM Agencies According To
Table II-2:  Funding Category ($000,000)*

106
208
FY79**
52.5
32.0
FY80**
48.7
37.5
FY81
108.0
70.0
FY82
108.0
73.0
FY83
111.5
68.5
FY84
118.0
59.0
Authorized
CWA Levels
100
150
 *For Clean Lakes -- See Chapter VII.
**Appropriated


Tables II-l & 2 represent projections in constant FY 80 dollars.  When
an inflation factor of 8.5% is considered, the Assessment for 106
and 208 supported programs results are substantially affected (Figures
II-l, 2, & 3).  This perspective must be kept in mind throughout the
Report because elsewhere all projections appear in FY 80 dollars.  All
projections have been rounded off to the nearest half million (Figures
II-l, 2, & 3).
                                     12

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                                   FIGURE 11-1
                             WQM AGENCY PROJECTED
                            CONTRIBUTION WITH INFLATION
                          100
                           FY80
                                 FY81
                                       FY82
                                             FY83
                                   FIGURE II-2
                              WQM AGENCY PROJECTED
                           FEDERAL 106/208 FUNDING NEEDS
                          250
                           50 -
                           FY80
                                 FY81
                                       FY82
                                             FY83
                                                  FY84
                                   FIGURE II-3
                           TOTAL WQM AGENCY PROJECTED
                      NEEDS WITH INFLATION (FEDERAL/STATE/LOCAL)
                          500
                        Z 300
                        O
                          200
                           FY80
                                       FY82
                                             FY83
Although  in  the  aggregate, WQM Agency projections may  appear large,
program strength at the individual Agency level  is moderate con-
sidering  the program expansion anticipated under the CWA requirements.
For example,  States project a total WQM staff  increase by FY 84 of approx-
imately 35%  above FY 80 levels.  The growth rate is somewhat higher for
dollars because  of the immediate need to offset  past inflation in
order to  retain  existing capabilities and non-staff related expenditures
such as monitoring, equipment, building, and contract  services.  Staff
salaries  in  some States are currently too low  to maintain trained
staff and career ladders (although some of these States  projected
at these  low levels.)   More sophisticated programs will  be required
in the future with the emphasis on toxics.

The effort to get needs in constant dollars reflecting the costs of
materials and services in FY 80 was largely successful.   However,
some States  felt that  programmed increases in  salaries and other
factors imposed  burdens that should be recognized separately from
inflation because of State legislative requirements.   In  those instances,
these considerations were reflected in some projections.   In a limited
number of cases,  inflation was included.
                                      13

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As Table II-2 indicates, there are only marginal increases in 106 needs
after FY 81, indicating that States offset past inflation, programmed
improvements for the CWA and staff up for the long term in FY 81 (see
page 12).  As previously discussed, projections corresponded closely to
levels necessary to compensate for erosion from past static funding
levels which implied increased efficiency to address additional  CWA
needs.  Projections for FY 81 were overly ambitious when the ability to
staff up, manage, and synchronize development of program elements is
considered.  The growth is more likely to be phased in through FY 84.
For these reasons the Report focuses on FY 84 as the more representative
of needs and directions.  To the extent that needs are not met as projected,
development will slip into FY 85 and beyond.

State contributions to WQM reflected in this Assessment are higher than
previously estimated.  This  is primarily due to contributions of State
agencies to water quality which have not been directly supported by
Section 106 or 208 funds.  This is not suprising because water quality
is a broad-based concern.  A continued effort in the future to identify
these activities is desirable to get a more accurate picture of progress
toward implementing the Act.

Projected needs for 208 funding indicate continuing planning
activity and the desire to use Section 208 rather than 106 funds for
that purpose.  The majority  of this 208 funding projected is for non-
point sources.  208 needs decline in FY 83-84, reflecting the shift
for WQM in nonpoint sources  from planning to program development and
administration (the latter of which is ineligible for 208 funding).
However, the increase in funding over the period of the Assessment
indicates a willingness in this area to increase State/local support.
208 funding needs projected  by WQM Agencies are higher than necessary
for the nonpoint source planning and program development identified
in the Assessment (which requires a 25% match).   This  indicates  a
desire to use 208 funds also for general  and point source planning
(e.g., monitoring,  waste load allocations).   Needs discussed in  this
Report (except Clean Lakes)  were projected for WQM Agencies irrespective
of the ultimate funding source.   The unavailability of 208 funding,
should current plans to phase out 208 be completed, would merely trans-
fer the Federal  source for those pollution control  needs from Section
208 to 106 or other sources  (314).
                                      14

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As Table II-3 indicates, all functional areas undergo growth.  However,
there is wide diversity in the rate of growth, indicating where
emphasis is shifting in WQM to accommodate new requirements and  shifting
priorities (Figures II-4&5).  2/3 of the total growth in WQM needs
between FY 80 and 84 is due to toxics and other industrial and municipal
control.  The majority of the total growth (56%) is related specifically
to the new requirements of the Act (e.g., BAT for toxics, BCT for
conventional  pollutants, the municipal strategy under 301(i), pretreatment,
and associated monitoring).  Greater priority is given to this
aspect of the program by FY 84 when it constitutes 41% of the program
as compared to 35% in FY 80.  As one State explained:
               "Since the passage of the Clean
               Water Act of 1977, emphasis has
               shifted to the control of toxics,
               pretreatment requirements for POTWS
               and the incorporation of BAT and
               BCT 1 imitations ..."
                FY80
                                 FIGURE 11-4
                             TOTAL WQM AGENCY
                             PROJECTED NEEDS
                          MUNICIPAL
                          FACILITY
                          PLANNING
                      AND MANAGEMENT
                             01%)
 INDUSTRIAL AND
 MUNICIPAL CONTROL
     (44%)
            FIGURE 11-5
PERCENTAGE OF TOTAL WQM AGENCY
    PROJECTED GROWTH: FY80-84
   INDUSTRIAL AND
   MUNICIPAL CONTROL
   (68%)
                                     15

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    Growth  is  more moderate  in other program areas.  General  and point
    source  planning, ambient monitoring,  and other aspects  of Category  IV  in
    Table  11-3 maintain  their share of the  program, accounting for 14%  of
    the  growth and 16% of  the total program.  Both facility planning and
    management and nonpoint  source planning and administration undergo
    growth  in  WQM, but constitute a smaller share of the  program by 84.
    this does  not reflect  a  decrease of  activity in these areas, but is due
    to other factors.

     In  facility  planning and management  States  are  assuming  the  205(g)
    delegation.   However,  the responsibilities  under  the delegation  of
    205(g)  are taking  more resources  than  obtainable  under 205(g).   There-
    fore, the Assessment indicates  support  from WQM (i.e., 106  and State
    resources) will  continue to  be  necessary  (see  Chapter III,  Section B).
    The  net effect  of  the 205(g)  delegation is  a more  moderate  growth  rate
    in  WQM needs  for municipal facility  planning and  management.  The
    development  in  this  area is  further  diminished  by  some reliance  by
    State and Areawide agencies  on  201  funding  for  facility  planning.
    Nonpoint sources programs, as previously  discussed, become  less
    resource intensive for WQM as the  implementation  stage is reached
    during the period  of the Assessment.  This  probably reflects  a
    reliance on  State/local  and  other  Federal agency  support  for
    administration.   Federal 208  support can  be in  effect "seed"  money.
              TABLE 1 1-3

TOTAL WQM NEEDS FOR FY 80 & 84 ($ MILLION)
                                                                 *
CATEGORY                                    FY80                  FY84                   GROWTH

1.  Municipal Facility Planning & Management       $24.5 (lit)            29.5 (9%)                20%

   •  Facility Planning
   •  Construction Grants Management
   •  O&M/Training

2.  Industrial & Munciipal Source Control         $94.5 (44%)           $153.5 (51%)              62%

      NPDES
      Pretreatrnent
      Monitoring
      404
      Other State Point Source Permit Programs

3.  Nonpoint Source Planning & Administration      $62.0 (29%)            $72.0 (24%)              16%

4.  Other                                   $34.5 (16%)            $47.0 (16%)              36%

   •  Ambient Monitoring
   •  General 5 Point Source Planning
   •  Emergency Response
   •  Miscellaneous
TOTAL                                      216.0                 302.0                   40%

*Clean Lakes  not Included (See Chapter VII)
 Percentage of total program is indicated
  for FY 80  & 34
                                            16

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Analysis of WQM Agency  projections  indicates  that the data are statistically
valid using normative techniques  (see  Appendix B).   Point source, municipal
and other data are consistent  across  the States when compared to factors such
as population, land area,  population  density, and number of point sources.
Nonpoint source data is also well  related when significant relationships
(acres forested for silviculture)  were observed.  As a general conclusion, the
data are consistent.  Analysis indicates States are operating on a common
scenario of increasing  demands, constant or decreasing revenue, no expectation
of sufficent funds availability to  satisfy the requirements of the CWA, and a
reluctance or inability to fully  estimate funding and personnel needs until
regulations and policy  are more clear.
                                    FIGURE II-5A
                            TOTAL WQM PROGRAM NEEDS
                                    PROJECTED
            330
            300 —
             FY79
FY80
                     MUNICIPAL
                  FACILITY PLANNING
                  AND MANAGEMENT
                                   FY81
                                               FY82
                                                         FY83
                                            FY84
             OTHER
NON POINT SOURCE
 PLANNING AND
 ADMINISTRATION
                                       17

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                               SECTION B

                     OBSERVATIONS AND IMPLICATIONS
There are some observations and implications which can be made from
the results of the Assessment for programs supported by 106  and 208.
They are based on WQM Agency submissions,  follow-up conversations,
EPA policy and expectations, and funding outlooks.  Observations are
made in the aggregate and may not apply to all  Agencies in every
instance.  They do however, provide a sense of  the national  picture.
Further examination may be appropriate to  refine them.

Overview -- Increasing responsibilities, inflation, and the  uncertain
funding outlook are severely straining the ability to implement the
CWA.  There are several alternatives for addressing the problem:
increased funding, more cost-effective use of available resources,
strategic planning, priorities, and a combination of these approaches.
Different aspects of this problem are discussed below.  These  include:
State primacy, inflation, increasing responsibilities under  the Act,
effects of 205(g), State/EPA consensus, and coordinated grants
management.

State Primacy — Assessment results confirm the States leadership
role in achieving the goals of the CWA.  Their  continued support and
participation cannot be taken for granted  and is the paramount future
concern.

The State water program is the backbone of the  CWA.  States  have
expanded their water program to administer the  complex and broad
requirements of the CWA.  In many cases this was done in part  to
receive 205(g) delegation and the NPDES program approval. State
contributions exceed Federal support levels and are far in excess of
the minimum resources required by law (Table II-4).  As the  water program
has expanded and Federal funding has remained static, implementation
of the CWA has become increasingly dependent upon the maintenance
of that level of State support.  Unfortunately, State contributions
are falling as State legislatures experience budgetary difficulty
and increasing demands from other areas for the limited revenue
base.  These legislatures are increasingly less inclined to  support
what is perceived as a Federal program.  This is a particularly
serious problem because the downward trend is in the 106 supported
programs (e.g., NPDES, pretreatment, monitoring, and O&M).  As one
State observed:

          "It is anticipated that no significant amounts
          of States funds will be provided to implement
          the increased requirements of the Federal
          program."
                                    18

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Alabama                   S
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawan
Idaho
II1 inoi s                     1 ,7b7 .24J                ', , r'jir id
Indiana                      382,100                '.Jashin-iton
Iowa                         131,170                West Vi f; im,i
Kansas                       329,481                ..isccrisin
Kentucky                      346,474                ,jyoi':in:j
Louisiana                     417,571                District of
Maine                        366,696                Columbia
Maryland                                            uuai.
Massachusetts                                       Puetto  Riro
Michigan                      94'', 142                Virgin  Islands
Minnesota                     693,117                Delaware Piver
Mississippi                   150,104                basin Co,*'] ssi on
Missouri                      236,888                Interstate Corinssio'1
Montana                       59,783                on the  Poto"iac River Basin
Nebraska                       96,883                Interstate Sanitation
Nevada                        35,249                Conn, i s'-ioi
New Hanpshire                 493,386                'ievi fn'jl ind hitprstate
New Jersey                    679,034                ,'/atcr Pollution Control
New Mexico                    173,358,                Coi.ir.ission
New York                     4,b39,236                Onio Riv^r Valle/ '.,'ater
North Carolina                 534,009                sanitation Commission
 The declining  State  contribution,  the relatively low  Federal  funding
 level,  inflation, and growing responsibilities  under  the CWA  are
 severely straining States  abilities to  participate in  the program.
 States  are becoming  less able partners  in the WQM program simply
 because due to funding constraints, they  increasingly  lack the
 technical  and  administrative resources  to cooperate effectively with
 EPA.  This instability is  where the program can  least  afford  it
 (i.e., minimum  requirements  of the  Act).   One submission acknowledged
 the effect of  this trend:

            "After this fiscal  year  if the  funding level
             is  not increased (the State) will be  forced
             to  reduce  its programs  and return delegated
             functions  to EPA."
                                            19

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In this situation there are several options if the strain is not relieved.
All of these options affect the efficiency of the program and require
that EPA increasingly administer the program which in effect, shifts
the burden:

     •  Amend delegations to assume fewer responsibilities over a
        longer period of time.

     •  Return delegations.

     •  Do not seek full delegation of CWA responsibilities.

Inflation — The Assessment demonstrates the serious, continuing
deterioration in existing WQM Agency program activities due to
inflation.  Without additional funds States indicate they will be
unable to assume the new responsibilities under the CWA.

As a result of persistent inflation and static funding, States have
been forced to curtail  existing program activities at the same time
that Congress and EPA are requiring significant new program activities
and expenditures.  Section 205(g) delegation has increased funds
available, but State program expansion required for delegation exceeds
the available 205(g) resources.

The programs which appear to be most affected are NPDES and mon-
itoring, which also receive the majority of the funds.  In cutting
back, States are increasingly prioritizing among CWA requirements.
These cutbacks are particularly detrimental to new initiatives such
as pretreatment, toxic BAT requirements, and 208 plan implement-
ation.  Not only must these new initiatives compete for resources,
but they also depend heavily upon maintaining existing capabilities.
At the same time that the CWA encourages delegation, inflation is
causing States to contemplate return of NPDES programs and 205(g)
delegations.  Submissions candidly discussed the problem:

          "Inflation and automatic personnel salary
          adjustments have resulted in fewer reviews
          of the new construction plans received;
          operational permits renewed; NPDES permits
          certified; EIS's reviewed; notice of
          violations written; enforcement conferences
          conducted; dischargers monitored; samples
          analyzed, and less data assimilated because
          of a decrease in manpower."

          "Our 106 staffing will have to be decreased
          in FY 1980 if the 106 grant remains con-
          sistant or decreases.  This may preclude
          our ability to be delegated the NPDES
          program ... if our 106 grant does not
          increase, we will have to cut 50% of 106
                                      20

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          Staffing  by  1984  - approximately 15 technical
          positions.   This  staff  cut would absolutely
          prohibit  us  from  operating NPDES; would
          require us to  "bare  bones" (answer the tele-
          phone)  in operating  and maintenance; and
          practically  eliminate sampling of ambient
          and  point sources."
          "The State has been able to keep pace with
          inflation by some increased State funding
          and program adjustments and keeping levels
          of activities below desirable objectives.
          Implementation and planning in new program
          areas has reached its limits . . . continued
          current levels of funding from Federal
          sources will obviously impact the ability to
          implement planning, develop new initiatives,
          and maintain the established base of current
          activities on fixed Federal  funds."

          "Current funding levels with an appropriate
          inflationary increase would be sufficient
          to continue operation of ongoing programs,
          but would absolutely prohibit the expansions
          mandated by the Clean Water Act."

          "To maintain existing programs, it is obvious
          that funding levels will  have to increase
          10 to 20 percent per year."

Increasing Demands on Limited .Resources -- The Assessment demonstrates
that water program responsibilities far exceed available resources.
Increased funding, program adjustments, and improved operations are
several options for assuring the viability of the CWA goals under
these constraints.

The Assessment indicates the new CWA requirements and other WQM
needs will conservatively require a $85 million increase in total  funding
above FY 80 levels by FY 84.  Even  at that level, WQM Agencies will have
substantial  slippage in meeting CWA deadlines.   They appear hesitant
to project the full  impact of requirements because all regulations
have not been issued and the funding outlook appears poor at the
State, local  and national  levels.

The increasing demands become critical  under existing funding levels.
The problem is not new to the program.   In the past, for example,  EPA
has emphasized major dischargers in NPDES because of resource con-
straints and has directed 208 funding to nonpoint sources.   Now
increasing NPDES requirements and the static WQM funding level have
simply led to more rapid deterioration in the situation.  States have
individually tried to make program  adjustments  (e.g., improved manage-
                                     21

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ment, priority trade-offs) to cope with demands.  However, further,
broader action will be necessary.  Strategic planning, priorities,
and more cost-effective or expeditious approaches are alternatives
for administering the program under fiscal  constraints.   Consensus  is
desirable among WQM Agencies and EPA on the appropriate  long term
action.

          "If existing funding levels continue for FY 81-
          84, the CWQD will have to drastically cut back
          staff and therefore the number of activities
          it can properly handle.  No new programs would
          be established unless existing efforts are
          diminished.  The CWQD will also begin looking
          at dropping federally mandated activities."

Major Effect of Toxics — Projections recognize that the toxic
requirements of the CWA will have major effects on the WQM program.

Toxics control will have substantial impacts on resource require-
ments and the structure of the WQM program.  WQM Agencies must gear
up to control toxics and get a better understanding of the problems.
New program direction and increased sophistication will  be required
to implement BAT and pretreatment, conduct necessary support
monitoring, and develop further necessary water quality based controls,
Approximately 1/2 of the growth in needs between FY 80 and 84 can be
attributed to toxics.

          "The Board will not initiate a program to
          look for and to permit existing municipal
          and industrial dischargers that are not
          already permitted . . . Toxic pollutant
          activities . . . will increase significantly
          during the next five years.  This should
          have the following impacts . . . Enforcement
          action will increase in the toxic areas and
          decrease with regard to conventional
          pollutants . . . The Division . . .will
          need to shift emphasis from analyzing for
          conventional pollutants to toxic pollutants."

Toxics requirements cut across all aspects of the WQM program.
Strategic planning and improved program operation are desirable
for effective achievement of toxic aspects of the program for several
reasons which are discussed in detail elsewhere in this  chapter.

     t  Program needs exceed the funding likely to be available.

     •  The CWA objectives are ambitious for the time frame.

     •  Covered activities are interrelated and should be closely
        coordinated and synchronized in planning and implementation
        (e.g., enforcement, lab equipment, and monitoring).
                                      22

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     0  There appears to be a lack of consensus among States and EPA
        on the approach to toxics which has substantial impacts on
        timing and resource requirements.

CWA Dead!ine — WQM Agency projections indicate there will be substantial
delay in meeting CWA deadlines for municipal and industrial control.
This suggests immediate consideration of alternatives to assure
attainment.

Although WQM Agencies were requested to project needs, their sen-
sitivity to the funding outlook  and other factors resulted in
conservative projections.  WQM Agency forecasts fall short of the level
necessary to meet statutory deadlines (pretreatment, NPDES) and States
confirm that this is indeed the  case.  In the likely event that the
initially large infusion of resources WQM Agencies  projected for FY
81 does not occur, there will be additional delay as activities projected
to meet CWA requirements in the  Assessment extend into FY 85 and beyond.

Industrial  and municipal sources., as well  as State water programSjare
affected by this slippage.  The Act is very clear on responsibi-
lities of sources.  Confusion or delay breeds economic uncertainty.
Business and communities, as well as the water program benefit from
stability and long-range planning.  States observed:

          "It should be noted that an attempt (in the
          assessment) has been made to keep cost pro-
          jections at a reasonable or minimum level  to
          accomplish regulatory requirements.  Some
          expansion can be noted in new program areas,
          however, on-going programs are relatively
          static along with new initiatives because of
          the current outlook for additional funding
          . . . future development has been kept to a
          minimum .  . .  Fixed funding will  not even
          maintain the status quo."

          "Any delay in implementing an investment
          decision substantially increases the degree
          of uncertainty.  An NPDES program that is
          not functioning smoothly clearly delays
          investment decisions . . . Inflation is a
          direct and easily recognizable cost which
          results .  . ."

The problem becomes  more critical at existing funding levels  (as
witnessed by current NPDES permit backlogs).  Without changes  in
approach to implementing the CWA which accommodate the funding out-
look, WQM Agency projections indicate it  will  be virtually impossible
                                      23

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to meet CWA deadlines.  States individually are trying to cope with
the situation through improved management and innovative approaches.
However, the opportunities are limited under existing policy and
regulations.  Several options exist nationally for meeting CWA require-
ments at minimum cost:  national  strategic planning, priorities,
cost-effective alternatives to the existing approach, and State
flexibility to apply streamlined, innovative techniques.  If these
measures, within available funding, are not sufficient to meet
deadlines, adjustments in the Act may warrant consideration.

205(g) is not the answer — 205(g) delegation has not offset the
increasing demands on the 106 program as had been anticipated.

The availability of 205(g) funds  has been used to argue that a cut in
or deletion of Section 106 funds  would not damage the States water
program.  The CWA of 1977 made up to 2% of a State's construction
grant allotment (or $400,000 - whichever is greater) available for
the administration of the construction grant program ana auoweu
this amount to be increased to cover the costs of administering
the NPDES, 404 dredged and fill,  and 208 programs.  In theory, this
would increase the funds available to States in two ways:  negotiation
and award of 205(g) would free-up 106 and State resources for use
in other activities; and 205(g) funds could be used for other WQM
ournoses.

The Assessment conclusively demonstrates that this is not the case
for two reasons.  First, data indicates a large number of States have
been unable to or do not think it is possible to carry out the fully
delegated construction grants management program with the resources
available under the delegation.  There will be a need to supplement
205(g) funds with 106 and States  resources.  One option to minimize
this is reexamination of 205(g) delegation requirements.  Secondly,
inflation has been so pervasive that "freed-up" 106 and States
resources are simply absorbed without any nationally appreciable
increase in program activities.  One State observed:

          "The term freed-up 106  funds is a joke.  Even
          with the assumption of 205(g) delegation, this
          agency foresees a $50,000 short fall this fiscal
          year."

205(g) has kept the growth in facility planning and management
aspects of the WQM program modest.  However, the continuation of
these activities as major WQM funding needs (in addition to the
availability of 205(g), 201, and other funding) raises issues on
the extent of those needs under the Act, appropriateness of funding
sources, and priority for those needs in WQM.
                                       24

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Consensus -- Projections indicate there is inadequate consensus
among States and EPA on program direction, strategy, and expectations.
This undercuts the ability to effectively achieve CWA objectives and
administer the water program.

States viewed as a whole, and EPA are taking different approaches
to the water program which impact timing, program direction, and
resource requirements.  This leads to substantial problems because
it undercuts the ability to effectively administer the water
program and, affects (sometimes dramatically) timing, program
structure, and resource requirements.  It is particularly evident
in the NPDES and monitoring programs, where EPA estimates of needs
and priorities varied widely from WQM Agency projections.  There
were corresponding substantial differences in program structure
and direction (e.g., water quality vs. minimum technology approach).
Within the EPA water program itseit, tnere may be inadequate consensus
on objectives and priorities as witnessed by the lack of a water
strategy.

The diversity of approaches and needs among  WQM  agencies  leads  to
priorities which are not as clear or as  consistent as desirable under
the Act.   Some WQM agencies indicate no  activitiy in critical  program
areas.   Although, within statistically acceptable norms  (see Appendix B),
there is a wide variability in costs among States and no  mutual  State
and EPA understanding of appropriate resource levels to  allocate among
priority activities.   In part,  this is due to uncertainty about the
effect of toxics and further EPA regulations on  the program.  Consequently,
within the program elements there is more consistency,  than  for the
program as a whole.   Statistical  analysis confirms this  confusion and
lack of strategy.

EPA estimates reflect a water quality standards based and a minimum
technology based approach to water pollution, particularly in
monitoring and planning.  This results in higher EPA estimates.  The
opposite occurs in NPDES where States are emphasizing technology based
approaches and cooperative,rather than enforcement techniques to
secure compliance with industrial and municipal  requirements.  EPA
estimates, emphasizing enforcement are substantially lower than State
projections.  Each approach has its advantages and disadvantages which
merit further consideration.  One State discussed this:
          "With increasing emphasis on pollution
          control  and authority delegated under the
          NPDES program, the Water Quality Bureau
          has moved from a service agency to one
          oriented to regulation and enforcement.
          This has been a rather difficult tran-
          sition for the Bureau, the permittees
          and for municipalities and will never
          be entirely completed.  The construction
                                     25

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            grants  program requires  a  continued
            assistance attitude toward municipal
            officials and their problems  whereas  the
            enforcement program requires  these same
            officials be subjected to  litigation.  All
            too  often, causes (of) delay  compliance
            are  found to lie within  the Bureau or
            EPA  review process, this significantly
            weakens the enforcement  stature."

 Since some flexibility is necessary  to  accommodate diversity,  a  mutual
 WQM Agency/EPA understanding of water program objectives and priorities
 in the 1980's  would enhance attainability  of the CWA, lead to  a
 unified program direction and strengthen the WQM Agency/EPA partnership.

 Coordinated Grants  Management -- Projected WQM  needs can be minimized
 and more effectively satisfied through  coordinating grants management.
 Future needs for  a  comprehensive strategy, priorities and improved
 program operations  depend upon this  ability.

 106  and  208 needs identified by  WQM Agencies  are  not the only  source
 of  funding  for many  of  the  needs projected by the Assessment (Table
 II-2)    Section 201, 205(g),  and 314  of the  CWA,  RCRA,  SDWA and other
 Federal  sources, and the  private sector are  alternative sources and
 S   ^T,™  Appropriate  (See  Table  II-5).  A joint  undertaking  by
 EPA  and  WQM Agencies is desirable to  take advantage  of  the  funding
 overlaps.   Such action  is particularly important  when demands  exceed
 available resources.  In the water  program, there  should be  a  common-
 ality  of approach, strategy  and  priorities  for which these  funding
 sources  have different roles and  responsibilities.   Coordinated grants
management,  based  on that commonality can promote strategic  priorities
document progress  and accomplishments, and  enhance program operation  '
                                    TABLE 11-5

                           POTENTIAL FUNDING SOURCES


                                                       PERMITS   USER  STATE/LOCAL
 ACTIVITY                106    208    201    205 igi* *  JH    104    105   FEES   CHARGES  FUNDING   OTHER
 FACILITY PLANNING AND MANAGEMENT
 • FaciUty Planning
 • Construction Grants
    Management
 • O&M/Trammg
 INDUSTRIAL AND MUNICIPAL
  REGULATION
 • NPDES Related

 • Pretreatment
 • Monitoring
 • 401

 • Othei State Point Source
    Permit Programs
 NON POINT SOURCES
 • Planning
 • Administration
 OTHER
 • Ambient Monitoring
 • General and Point Source
    Planning
 • Emergency Response
                                        26

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Stable program -- Projections  indicate WQM Agencies perceive no change
in direction for the WQM  program.

WQM Agencies project no changes  in direction for the water program.
They focus  on meeting the immediate deadlines of the CWA which as  indicated
here, is a  considerable venture.  Resources are directed towards
meeting the minimum technology requirements under the Act (e.g., NPDES,
pretreatrnent, municipal compliance, and BMPs).  Any changes in program
direction for WQM Agencies  (e.g., water quality standards based point
and nonpoint source control) will have major effects on program structure
and resource requirements.

Nonpoint sources — Nonpoint sources continue to be a major program
element under the projections  but remain an emerging area.  Nonpoint
source control appears to be a cost-effective approach for WQM,
particularly the Federal  government, to pollution abatement.

WQM Agencies continue their commitment to nonpoint source control.
They are at various stages of development which is expected because
nonpoint source control is an  emerging area of WQM.  Projections
indicate that substantial  development can be accomplished with a
relatively moderate growth in  Federal resources.  Results indicate WQM
Agencies foresee the immediate but limited need to satisfy major
planning needs.  As this  occurs, there is a shift in FY 80-84 for WQM
from planning to less resource intensive program administration.  As
implementation escalates WQM needs decline  and  nonpoint  source  control
becomes  a very good  investment  of the Federal  WQM  dollars  due  in
part  to  the following:

     •   Nonpoint  sources are responsible  for  1/2  of  the  pollution,

     •   program is  at  early stages of development  and  therefore
        amenable  to  substantial progress  in control  and  management,

     *  nonpoint source control  receives substantial support from
        other sources such as other Federal  agencies (USDA), permit
        fees, local  government,  and non-water quality related State
        programs (e.g., Soil and Conservation programs).  WQM is,
        in effect, "seed  money"  for nonpoint  source in control  in
        contrast to industrial  and municipal  control where the
        WQM is the primary support.

In spite of the progress  indicated, projections do not correspond as
well  as they should to the known extent of nonpoint source pollution.
The gap between the extent of the problem and projections  is partially
the result of the preceived lack of resources to address nonpoint
sources  and the emerging  nature  of the program.   This tendency is
also seen elsewhere in Assessment (See below).   The WQM baseline
strategy is evidence in the Assessment by a consistent WQM Agency
direction.  Continuation  of this emphasis should increase  State and
local  nonpoint source control,  expedite control,  and minimize costs.
                                     27

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Extent of Pollution -- Projections reflect EPA and CWA priorities
but to a much lesser degree, the extent of pollution.

Projections correspond strongly to measures of human activity (e.g.,
population, number of pollution sources) and CWA requirements.  This
results in statistically valid projections and indicates WQM Agencies
are consistent in their approach and outlook.  They are responsive
to past experience and priorities (e.g., deadlines for minimum controls).

Emerging problems or the extent of pollution was not a major factor in
projecting needs.  Therefore, more varibility in Assessment results and
higher needs would be expected based on the extent of pollution.  This
is a particularly important factor to consider in preventing future
problems (e.g., impacts of energy development).  The conservative
approach taken by WQM Agencies and the existing fiscal constraints are
major reasons for that limited coverage.  A shift in program focus from
a minimum technology to a more problemmatic approach will  affect needs.

Municipal  needs — Projected growth is directed primarily towards
industrial  sources and toxics.  Municipal  compliance for conventional
pollutants may not be receiving adequate attention.

Industrial  and municipal dischargers are both major sources of water
pollution, but pose quite different dangers to water quality.  Over
50% of the municipal sources are in noncompliance with the CWA and are
causing substantial problems with conventional pollutants.  WQM
Agencies recognize the need to address this problem in their projections
for NPDES, operations and maintenance, and training, but appear to
place the majority of the emphasis on industrial sources.   The
appropriateness of this emphasis should be assessed in the development
of the water strategy for the 1980's.
                                     28

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             Chapter III



MUNICIPAL FACILITIES PLANNING AND MANAGEMENT


    Section A - Overview

    Section B - Construction
                Grants Management

    Section C - O&M/Training

    Section D - Facility Planning
                       29

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                                   Section A

                                   OVERVIEW
This Chapter includes WQM activities relating to the planning, design, construction
and operation of sewage treatment works.  These activities specifically include
facility planning, construction grants management, operation and maintenance
(O&M) and training.  They are eligible for Federal funding under 201, 205(g),
106, 208, and other Sections of the Act.  Needs projected here (i.e., UQM
under 106 and 208) are limited to those activities States feel they cannot
fund from other sources (e.g., 201 and 205(g) (see Table III-l)).


Table III-l:  Total State Projected Needs for Municipal  Planning and Management*

                                 FY79    FY80    FY81     FY82    FY83    FY84
Construction
Grants Management
Facility Planning
O&M/Training
17.5
3.5
6.5
13.0
4.5
7.0
10.0
7.5
9.5
10.0
8.0
10.5
9.5
7.5
11.0
9.5
7.5
11.5
TOTAL                            27.5    24.5    27.0    28.5    28.0    28.5


  *Some administration costs are not included ($000,000).  See Table II-3.


Proper operation, maintenance, and construction of sewage treatment plants  are
an environmental priority for States and EPA.  These needs undergo moderate
growth between FY 80 and 84 going from $24.5 to$28.5 million (20% growth).
This is due to the increasing use of 205(g) funds for construction grants
management and 201 for facility planning.  The 205(g) delegation, however,
does not supply sufficient funding to fully support construction grants management
in delegated States.  The decrease in construction grants management needs  due
to 205(g) is more than offset by the increase in O&M/Training and facility
planning (see Figure III-l).

There are many demands on WQM funds and many program overlaps among Sections
201, 205(g), 208, 106, 105, and 109 of the Act.  A coordinated funding strategy
for meeting these needs should be a paramount consideration.  Since proper
plant operation involves FJPDES and monitoring, those programs are also affected.
                                       30

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                       Figure  III-l

Total WQM  Agency Projected Needs  for Municipal  Facilities
                  Planning and  Management

                            FY80
                                                       FACILITY
                                                       PLANNING
                                                         17%
                      CQf*STRyCTtQN GRANTS
                          MANAQfME
                          •  "  54% '
                            FY84
                                                       FACILITY
                                                      PLANNING
                                                        (26%)
                             31

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                                   Section B

                        CONSTRUCTION GRANTS MANAGEMENT
Conclusions
     •    Management of the construction grants program will continue to be a
          priority WQM activity throughout the FY 81-84 period.  Although the
          number of Section 205(g) delegations and grant awards will increase
          during this period, the States indicate a continued need of over $10
          nil lion in State and 106 Federal funds to successfully manage the
          Statewide construction grants program.

     «    States are confused about the WQM role in construction grants management
          and the eligibilities under 205(g) delegations.


Background

Since the passage of P.L. 95-2T7, grant awards under Section 205(g) of the CHA
have been available for States' use in management of the construction grants
program.  The States are expected to be delegated increased responsibility to
administer construction grants under delegation and to meet those costs with
205(g) funds.

The States have met the costs of administering the construction grants program
with State and Section 106 funds since implementation of the CWA in 1972.
These activities have included:  design and implementation of the project list
and associated priority criteria; coordination with NPDES in permit development
and enforcement—as well as Hater Quality Standards development; preliminary
conferences for steps 1 and 2; review of Section 201 facility plans, environmental
assessments; construction oversight; O&M manual review; public participation;
administrative review of applications; processing of grants offers, amendments
and payment; resolution of audit problems; maintaining a grants tracking
system; responding to Federal EPA and State legislative information requests;
and activities not directly related to the Section 201 construction grants
program—such as industrial facilities management.

With receipt of a 205(g) delegation, State agencies become primarily responsible
for the performance and quality of these activities, while EPA assumes an
oversight role.  Historically, the States have used 15% to 20% of their combined
State and Section 106 resources to administer the construction grants program.
The availability of Section 205(g) funds was expected to ultimately reduce the
need for States to use any 106 funds in the administration of the construction
grants program.


State Projections

The Needs Assessment information yields a mixed, somewhat confusing picture
and a continuing need for 106 funds (Table III-2).  The confusing results from
the availability of Section 205(g) funds and the varying ways in which they
are utilized by the States.
                                       32

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Table III-2:   Total State Projected WQM Needs in Construction Grants
	      Management, FY 79-84 ($000,000)	

                                 FY79    FY80    FY81     FY82    FY83    FY84
Total States Needs
Total Staff Years
7.5
683
13.0
485
10.0
400
10.0
381
9.5
377
9.5
375
The need for WQM funds diminished as 205(g) funds become available in FY 80
and FY 81.  State projections for the FY 81-84 period, however, level off in
FY 81  and remain fairly constant through FY 84.

In FY 84, when virtually all the 205(g) delegations are expected,  there is a
small  increase (see Appendix A for precise amount) in the need for Section 106
and State funds.   This is presumably to supplement the Section 205(g) resources
devoted to administration of completely delegated construction grants management
programs.

While at first surprising, this continued demand on WQM and 106 can be explained
by examining the patterns of need indicated by various States.

     e    22% of the States (11) exhibited the common expectations concerning
          205(g)  delegation.  Following the receipt of a 205(g) delegation,
          the need for State and Section 106 resources declined to zero and
          remain at no need for the entire period covered by the Assessment.
          Thus, for example, a State negotiated  and received a 205(g) delegation
          and grant award in FY 80 and indicated no need for State and Section
          106 resources in FY 81 and beyond.

     0    42% of the States (21) indicated a continued need for WQM funds
          subsequent to receipt of a Section 205(g) delegation.  Of these, 16
          indicate no decrease or an actual increase in the need for Section 106
          and State resources.  This group exhibits 2 patterns of  projected
          need:

                    The demand for State and Section 106 funds decrease to
                    zero for one or two fiscal years and then is reasserted as
                    a more complete phase-in of  205(g) activities  occur.

                    The demand for State and Section 106 funds remain the same
                    or increases as the 205(g) delegation is phased in.

     0    28% of the States (4) indicate that no 205(g) delegation is expected.
                                       33

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     t    4 States, indicated no need for Section 106 and State funds from
          FY 79-84.  The results are summarized below:


Table III-3:   Patterns of 205(g) Use in Relation to WQM Need	

          205(g) Award/   205(g) Award/   205(g) Award/   No 205(g)   No Need
          No WQM Need     Decreased l.'QM   Increased WQM   Award       FY 79-84
                          Need            Need            Expected
Number
of States     11               5               16            14
Analysis

These patterns of need suggest some possible conclusions.  The amount of funds
available under 205(g) may be inadequate to support State activities as EPA
begins to measure State performance against the delegation agreement require-
ments.  This could mean that the 2% or $400,000 set aside is too low or
unrealistic given EPA's expectations.  Since 205(g) funds are intended to pay
100% of the actual State administrative costs, EPA's expectations may be too
high given the amount of money available.  This is particularly important
because projected funding under 205(g) is expected to exceed $60 million by
FY 81.
Another possible explanation is that some of the activities projected as
needs in construction grants management are or appear to be ineligible for
funding under Section 205(g).  Thus, 205(g) funds may be adequate or available
but not used because of uncertainty as to their eligibility.  There appears to
be little consistency in State interpretation.  30 States for example, indicate
a continued need for UQM funds to perform non-201 related functions which are
an integral part of the State municipal facilities construction program.  In
some cases, 205(g) is expected to pay for these activities; in others, it is
not.

The overall impact of Section 205(g) funds on the demand for UQM State and
Section 106 needs does not indicate any real savings decrease in WQM dollars
needed over time.  This fact results from a combination of factors, the most
significant being the real reduction in program support due to inflation.  The
States recognize this problem:

          "...106 funds will continue to be needed in this area due to
          continued development of design standards and construction
          permits for non-grant projects, agricultural projects and
          industrial projects."

          "The term 'freed-up1 106 funds is a joke.  Even with the
          assumption of 205(g) delegation, this agency foresees a
          S50,000 shortfall  this fiscal year  (FY 80)."

          "There are no plans at present for assuming 205(g)
          delegation.  In  the event 205(g) delegation is accepted,
          106 funds will be  used to offset program cost increase
          due to inflation."

                                      34

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                                   Section C

       OPERATION AND MAINTENANCE OF HASTE TREATMENT FACILITIES; TRAINING
Conclusions
          States want to improve the priority of operations and maintenance
          (O&M) and training programs in recognition of the serious, pervasive
          municipal noncornpl iance problems caused by inadequate O&M and training,

          Substantial progress can be made toward improving POTW's performance
          by implementing the Composite Correction Program (CCP) and other
          measures.
Background

Increased efforts to solve municipal sewage problems were made with passage of
Public Law 92-500 in 1972 (under Title II, Section 201).  Since then, many
billions of dollars under Section 201 of the CWA have been spent on construction
of waste treatment facilities.  Subsequent efforts have been made to provide
guidance through regulations and EPA policy to insure the best O&M procedures.

In spite of these efforts, it is estimated that only about 1/2 of all publically-
owned treatment works (POTWs) are meeting their design standards for biochemical
oxygen demand (BOD) reduction and suspended solids (SS) removal.  This has
lead to substantial noncompliance which is due in part to low funding, inadequate
staff and operation procedures, poor maintenance, and inappropriate plant
design.

An Evaluation of Operation arid Maintenance Factors Limiting Biological Hastewater
Treatment Plant Performance, released in July 1979 by EPA, listed the following
persistent POTW problems in decreasing order of severity:

     1)    Inadequacy of operator application of treatment concepts and testing
          to process control.

     2)    Infiltration/Inflow - resulting in periods of severe hydraulic
          overloading, and dilution of the influent wastewater so that both
          suspended and fixed biological  systems are loaded to less than
          optimal values.

     3)    Inadequate Process Control Testing Procedures.

     4)    Ineffective O&M manual instructions.

     5)    Inadequate industrial loading process.

     6)    Inadequate training.

     7)    Inadequate hydraulic loading process.

     8)    Inadequate understanding treatment process.
                                       35

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     9)   The lack of controllability evident in the inability to adequately
          measure and control flow streams such as return sludge flow and
          trickling filter recirculation rates.

    10)   Inadequate sludge handling facilities and the inability to measure
          and control the volume of waste sludge.


State Projections

In combatting these municipal operation problems,  States show substantial
growth in needs through FY 84.  Actual  State needs are indicated below.   The
program projected in WQM, however, continues to be modest.


Table III-4:   Total State Projected Municipal  O&M/Training Needs, FY 79-84

 ($000,000)	FY79    FY80    FY81     FY82    FY83    FY84

Operation and
Maintenance
Training
4.
2.
0
5
4.
3.
0
0
5
4
.5
.0
6.
4.
0
5
6.
4.
5
5
7.0
4.5
TOTALS                            6.5     7.0     9.5    10.5    11.0    11.5


Projections indicate that the program basically stabilizes in FY 82 - FY 84.
Thus, States appear satisfied with this level effort in WQM.   States do not
indicate a strong attention to operator training in relation  to O&M inspections,
audits, etc.  States project a higher than average growth rate for the program,
indicating the underfunded nature of this program.


Analysis

EPA statistically analyzed the States'  projected needs, in order to evaluate
their validity.  This was done by comparing States' needs in  FY 84.  The cost
of the projected program was divided by the population for each State and
found to be valid and within an order of magnitude.

Traditionally, this area has been funded under Section 106.  EPA stresses the
availability of other funding sources,  such as Sections 205,  201, 109(b), 105,
and 104.  Use of these alternate funding sources would free up Section 106
funding for other areas.  Further coordination among grants programs would
enhance funding.

Programs outside WQM may be involved in O&M/Training.  Those  programs, although
not covered by the Assessment, should be considered in determining the full
extent of needs.  Sufficient information is not available under the Assessment
to evaluate the full extent of present support to O&M/Training and the total
needs outlook beyond UQM.

Improvements in Agency policy and guidance procedures, plant management/design,
incentives for O&M/Training, and integrated EPA management of the overlapping
programs are desirable, as envisioned by the Composite Correction Program
discussed in the 1979 study.

                                       36

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                                   Section D

                          MUNICIPAL FACILITY PLANNING
Conclusion

WQM Agencies foresee difficulty in relying on 201 and 205(g) funding to meet
facility planning needs.  Further consideration should be given to these
problems in developing the water program strategy for the 1980's.


Background

Municipal waste treatment problems exist in every State.  Many of the problems
lend themselves to straightforward solutions, via EPA's construction grants
program, through secondary treatment facilities.  Sometimes, however, municipal
waste treatment problems are complex and require additional  planning before
construction can proceed.  WQM Agencies must ensure that water quality standards,
total maximum daily loads, waste load allocations, population/economic projections
and financial arrangements are sound.  They consider point/nonpoint source
control  tradeoffs, innovative or alternative technologies, and alternative
approaches such as water conservation.

In the first round of 208 grants, many State and Areawide Agencies successfully
addressed municipal waste treatment problems, identifying service areas,
making population disaggregations, and identifying necessary levels of treatment.
Often, however, where advanced waste treatment (AWT) appeared to be necessary
for the solution to a problem, further planning was required to confirm the
need.  To assist with development of State processes for municipal facility
planning, EPA is funding about 15 AWT olanning and review projects with FY 79-
208 grants.

EPA, recognizing the costs and energy requirements of publically-owned treatment
works providing treatment greater than secondary, has taken  several steps to
insure that such facilities are only Federally funded when based upon technically
adequate effluent limitations.  Reduced WQM funding in fiscal year appropriations
and increasing demands lead to several  policy adjustments.  With limited
exceptions, AWT planning in FY 80 and beyond is not eligible for 208 funding
(see Chapter VI, Section D).   Instead,  201  and 205(g) policies have been
expanded to meet facility needs.

With respect to 208 funding for regular plan updates, EPA believes almost all
of the necessary population projections, service area delineations, and waste
load and flow projections are in  place, by virtue of the initial 208 planning
effort EPA funded between FY 74 and 79 and current disaggregations under the
Cost-Effectiveness Guidelines.  Where construction grants are involved, popu-
lation projections are an eligible Step I cost and are easily incorporated
into existing 208 plans under the WQM regulations.
                                       37

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The future role of the WQM program is to work with the States on overall
management programs, assist with the development of State or local regulatory
programs and help local communities avoid both the water quality problems
associated with failing systems and financial burdens which frequently accom-
pany "sewer-and-treat" solutions.  EPA will work with WQM Agencies to:

                    identify where WLAs are most needed

                    identify appropriate Federal and other funds available to
                    do needed work, with particular emphasis on 201 and
                    205(g) funds

                    assist 1'iQM agencies in obtaining these funds (e.g., pass-
                    through)


WQM Agency Projections

Needs were projected for facility planning where 201 or 205(g) funds would not
be available.  Waste load allocations were projected separately (see Chapter VI
Section D).  Results appear in Table III-5.  Projections indicate WQM Agencies
foresee substantial, continuing needs for WQM support to facility planning.
This is particularly true for areawide agencies.  The growth in this area
(74%) between FY 80-84 is higher than the average indicating the underfunded
nature of the activities in WQM perceived at the State and local level.  WQM
agencies discussed the following activities (from most to least frequently
cited).

          population projections and disaggregations

          treatment needs

          general, comprehensive facility planning

          service area delineations

          facility plan updates

          coordination with 201 planning

          land use considerations

          designation of management agencies

          onlot disposal


Table III-5:  WQM Agency Projected Municipal Facility Planning Needs ($000,000)

	FY79    FY80    FY81    FY82    FY83    FY84

Total Needs                    3.5     4.0     7.5     7.5     7.5     7.5
                                       38

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In FY 84, 15 States had needs in excess of $100,000.  3 States exceeded $500,000.
Of the 15 States projecting no needs, 7 specifically referenced the policy to
use 201 and 205(g) funds for facility planning.  As the projections indicate,
WQM Agencies in most States believe that 201 and 205(g) funds are not available
to meet all facility planning needs.  They cited the following reasons for
continued WQM involvement:  WQM Agencies are believed ineligible to receive
201 grants; 201 funds are inadequate to meet identified needs; low 201 priority
for activities cited; and the desirability for an areawide, or regional,
rather than 201 management agency focus.


Analysis

WQM Agency projections indicate a considerable lag in understanding or implementing
EPA policy on 201 and 205(g) funding of facility planning needs.  The wide
variability among WQM Agencies resource projections suggests varying degrees
of success in applying the policy.  Although the agencies covered in the
Assessment may not be directly eligible for 201 funding, pass-through funding
mechanisms are available and have been used in other aspects of EPA programs at
the State and local level (e.g., Air).

Virtually all of the needs indicated are eligible for 201 or 205(g) funding
and have traditionally been 201 agency activities.  Reasons cited by WQM
Agencies for continuing needs for WQM support should receive further study in
the development of the 1990 and WQM strategies.  Further consideration should
be given to impediments to implementing the 201 and 205(g) funding policy and
meeting facility planning needs.  Expanded 201 grantee eligibility may be
appropriate if existing mechanisms (i.e., pass-through) are too cumbersome.

The Assessment confirms the impetus behind the limitation of WQM funding in
this area (i.e., nonpoint source planning and expanding NPDES and monitoring
needs).  The WQM Agency perception of 201 funding, is too limited to meet
their needs, is disturbing in that 201 and 205(g) funding, which focuses on a
limited aspect of the water program, far exceeds UQM levels.  In spite of this,
further examination of needs may indicate, as a last resort, that adjustments
in WQM policies are desirable.
                                       39

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              Chapter IV


INDUSTRIAL AND MUNICIPAL SOURCE CONTROL
     Section A - Overview

     Section B - MPDES

     Section C - Pretreatment

     Section D - Monitoring
                 Part 1  - Overview
                 Part 2  - Equipment
                 Part 3  - Compliance
                 Part 4  - Intensive Surveys

     Section E - Dredge  & Fill  Programs
                    40

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                                SECTION  A

                     INDUSTRIAL  AND  MUNICIPAL  CONTROL

                                 Overview
This chapter includes activities  designed  to  improve water quality
through control of  industrial  and municipal  sources.  As Figure IV-1
and Tables IV-1 and 2 indicate, industrial  and  municipal  sources are
major sources of pollution  problems.   This  chapter covers:

     •  The NPDES program for  municipal  and  industrial  point sources
        under Section 402,

     •  pretreatment at the  State level  under Section 307,

     •  dredge and fill programs  under Sections 404 and 208(b),

     •  monitoring  in support  of  these programs specifically compliance
        monitoring, intensive  surveys,  and  laboratory equipment and
        facilities, and

     •  other point source  permit programs  established  under State law.

For NPDES and 404, projections  include the  State administration of the
NPDES program, program development  to  assume  delegation,  certification
of permits under Section 401,  and support  to  the Federal  government
in administering the program where  delegation has not occurred.  The
latter activity can be particularly substantial  because the Federal
government has limited resources  and  relies  on  State assistance.

                                   FIGURE 'V-I
                    BASINS AFFECTED* BY INDUSTRIAL DISCHARGES
       * In whole or in part


       Note. Affected basins are shaded
                                      41

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                                "ABLE  IV-1



                       30!NT  SOURCES  OF  ?OLLUTION
         Percentage of Sasins  Af^ectec*  jy  'yoe  of JQint Source




Regi on
        of basins) _ Indus'.'" al _ Mumci pal



Northeast (40)                          95                         95



Southeast (47)                          74                         91



Great Lakes (41)                        30                         95



North Sentra1  ''35)                      74                         35




Soutn Central  (30)                      70                        '.00



Southwest (22}                          23                         54




Northwest (221                          55                         73




Island (9)



  "oral   (246
                                  TABLE  IV-Z




                       EFFECTS OF POINT SOURCES OF POLLUTION
Percentage of Basir

.Number of basins!
Northeast 140)
Southeast |47i
Great Lakes |41)
North Central (35)
South Central 130)
Southwest !22)
Northwest [221
Islands (9)
Total (246)


33
1 1
24
1 1
3
5
0
33
15


93
77
80
89
73
50
08
89
78

depletion
93
89
35
80
87
36
55
78
79
is Affected'


78
70
7 1
74
33
41
55
56
69
bv Type of Pollution Problem fro

souos
70
26
44
23
30
'4
23
33
35

solids
13
9
27
20
30
23
5
1 i
1 7


1 5
1 7
24
14
0
5
5
0
1 4
m Point Sources


35
6
34
0
13
5
0
44
16


58
26
51
57
43
9
5
22
38


43
28
59
^3
7

4
1 1
28
1 In whole or in part
 Tab1e  IV-3:Tota1  Neeas  -n Iieust'-'al S Municipal Control ($000,000)



                         FY  30FV34
                                    42

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 Within this category, States maintain the same emphasis  collectively for
 NPDES, pretreatment and monitoring support while increasing  emphasis
 in 404 as States assume delegation (Table IV-3).  For actual  projections,
 see Table IV-4B.  As resources become increasingly scarce and  responsi-
 bilities increase the emphasis devoted to other State permit  programs
 progressively wanes.  By FY 84, NPDES, pretreatment, and monitoring
 support constitute 41% of the WQM program (Table IV-4A).


                      WQM Agency ?rojac"ea Needs:  Industrial and Municipal
               IV-4At  Control - "e^t-onsMo to Total J--ogram	
                               68%
Industrial and municipal  control,  in  total,  constitutes the majority
(51% by FY 84) of  the  WQM program  and over 2/3 of the total growth
projected under the Assessment  (Table IV-4A  and Figure II-5A).   This
growth is primarily due to  the  increased  activity and level of
sophistication required by  the  Act  for toxic problem identification
and control as well as a  general upgrading of the program in the
NPDES, pretreatment and monitoring.   The  Assessment  indicates the
toxic identification and  control,  in  particular,  will  have the
largest impact on  the water program.   These  program  areas represent
the most demanding and comprehensive  areas of the CWA.   55% of  the
projected total growth in needs between FY 80 and 84 is attributable
to the NPDES, pretreatment,  and monitoring support programs.  81%
of the growth in this chapter is attributable to  these  activities
(See Figure IV-1 ).
                                   FIGURE IV-1
                   DISTRIBUTION OF GROWTH IN INDUSTRIAL AND
                           MUNICIPAL CONTROL FY 80-84
                                                           •OTHER 9%
                                                          NPDES
                                                           41%
                                      43

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Needs associated with the NPDES, pretreatment, and monitoring support
services are likely to exceed the resources available even under the most
optimistic funding outlook.  Increased strategic planning, program manage-
ment, and priorities are options for more cost-effective, expeditious
achievement of the Act.  Without such action, there appears to be
little likelihood that CWA deadlines will be met; at existing
resource levels, it appears from the States perspective to be
virtually impossible.

The activities covered are very interrelated.  Close coordination
between different aspects of NPDES, pretreatment, and monitoring
support services are desirable to synchronize activities and expedite
the program.  For example, inadequate toxic analytic capability
can preclude toxic control.  A better consensus among WQM Agencies
and EPA on resource allocations for these activities is desirable
for smooth program operation.
               Total  WQM Agency Projected Needs:   Industrial  and
 Table IV-4B:   Municipal  Control  ($000,000)

NPDES
Pretreatment
Monitoring Equipment
Facil ities
Compliance Monitoring
Intensive Surveys
Dredged and Fill
Other State Permit
FY79
29.0
1.0
6.0
10.5
6.5
.5
16.5
FY80
36.5
4.0
8.5
12.0
8.0
1.0
19.0
FY81
56.0
8.0
30.5
15.5
12.5
3.0
26.5
FY82
53.0
9.0
16.5
18.5
13.0
5.0
24.5
FY83
57.5
9.5
11.5
20.0
14.0
7.0
24.0
FY84
60.0
10.0
11.0
21.0
14.0
7.0
24.0
  Programs

   TOTAL                 70.0     89.0     152     139.5    143.5     147.0

 *Some administration is not factored in (See Table 11-3).
                                      44

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                                  SECTION B

                            NPDES PERMIT PROGRAM
Conclusion

The NPDES program is being substantially affected by recent CWA initiatives.
WQM Agencies project over a 60% increase in needs for administering the NPDES
permit program over the next five years.  This increase is primarily a direct
result of the incorporation Federal requirements regarding the control of
toxic pollutants (e.g., BAT, municipal compliance and the initiation of
pretreatment programs).  The States maintain that their ability to comply with
these provisions will be dependent upon increased Federal support.


Background

The Clean Water Act generally prohibits the discharge of pollutants into
waters of the United States, except when dischargers have obtained permits.
This requirement is implemented for the most part through the National Pol-
lutant Discharge Elimination System (NPDES) permit program under Section 402
and 401 of the Act.  The NPDES program controls discharges from industries and
from publicly owned treatment works (POTWs) and, thus, is a primary vehicle
for reducing and eliminating both conventional and toxic discharges into
waters of the United States.

Section 402(b) authorizes State and Interstate Agencies to administer the
NPDES permit program instead of EPA.   The Clean Uater Act of 1977 emphasized
this provision by adding the following language to Section 101(b) of the Act:

          "It is the policy of Congress that the State ...implement
          the permit program under Section 402... of this act."

33 States now administer the program and the remaining States work with EPA in
administering the program.

The following Sections describe the NPDES oermit program in greater detail and
set forth the total State funding needs for these programs.  As discussed
below, the basic elements of the program are:   permit issuance, compliance
evaluation, and enforcementJ
 1
  A number of other programs discussed elsewhere in the report also involve
the NPDES permit program.   (See water quality standards, wasteload allocations
compliance monitoring, and pretreatment.)
                                     45

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State Projections
Summary -- The increase in NPDES needs can be attributed most specifically
to the Federal initiative to control toxic discharges and achieve municipal
compliance.  States indicate the incorporation of BAT guidelines (or in
the alternative the more resource intensive Best Engineering Judgment)  to
promote this effort will have a significant effect on NPDES program costs.
Widening scope of these program activities will  necessitate the thorough
evaluation of the raw materials and production processes used by the
industrial facility and products manufactured, as several States observed:


          "Since the beginning of the permit program, the
          scope . . . has increased from . . . conventional
          ... to toxic pollutants.  This is resulting
          in additional time being needed to properly and
          thoroughly investigate and review each permit
          application and facility prior to permit pre-
          paration.  For industrial facilities,  this means
          thoroughly evaluating the raw materials used,
          the production process and products made and
          determining the appropriate controls that
          need to be applied on the facility discharge(s)
          in the NPDES permits.  With the more stringent
          effluent controls being proposed by the EPA
          through (BAT, BCT, and BMP guidelines) and other
          toxic and State imposed effluent controls, more
          time will be needed . . . from the evaluation/
          permit preparation phase to the discussions/negoti-
          ations/public hearings to permit issuance phases.
          Therefore, additional staff will be needed."


          "Preparation of new five year permits  incorporating
          implementation schedules for achieving toxic BAT
          permit limitations will require extensive negotiations
          with the applicants, thus significantly increasing
          the time to prepare each major permit."

Revisions of existing permits will be required in order to include
the applicable toxic effluent limitations as they are determined.
Essentially, the States have indicated the need  to not only upgrade
their existing program, but also to expand them  in order to address
these new program requirements.  A large percentage of States also
attributed their increased needs to BCT, municipal compliance,
increased coverage of minor discharges, and inclusion of pretreatment
requirements in NPDES permits.
                                       46

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Table IV-5:  Total State NPDES Program Needs, FY 79-84 ($000,000)

                       FY79    FY80    FY81    FY82     FY83    FY84
Permit Issuance
Compl iance
Evaluation
Enforcement
TOTAL
11.5
11.5

6.0
29.0
16.5
13.0

7.0
36.5
21.5
25.5

9.5
56.0
22.5
19.0

11.5
53.0
23.5
20.0

14.0
57.5
24.5
20.5

15.0
60.0
14 States indicated the desire to assume NPDES authority in FY 81-84.
When the needs of present NPDES States are compared to those States
indicating the desire to assume "delegation", the latter had a faster
rate of growth.  This was primarily because of the need to gear up
programs to receive EPA approval and implement CWA requirements.
While it might have been expected that States anticipating assumption
of NPDES during the period covered by the Assessment would have been
responsible for a significant portion of the increase, this is not the
case.  Instead, 80% of the increase occurs in States which have already
assumed the program.  This suggests new requirements and general program
improvement are the major reason for NPDES growth.

By FY 84, new NPDES States permit administration costs are comparable
to those of the present NPDES States but their compliance evaluation
and enforcement costs are substantially lower.  This suggests that
needs for these States in FY 85 and beyond will  be higher than
FY 84.  Under State projections, needs for the 4 non-NPDES States
by FY 84 are negligible ($.5M.)

Permit issuance -- Permit Issuance includes processing permit applications,
developing effluent limitations and schedules of compliance in draft
permits, conducting public hearings and issuing final  permits.  The States
also process permit modification and, depending on the type of variance,
can grant, deny or recommend EPA approval.

States which do not administer the NPDES program also participate in the
program.  Under Section 401, non-NPDES States review Federal permits to assure
compliance with effluent guidelines, water quality standards and other require-
ments of State and Federal law.  Some States jointly develop permit conditions
with EPA for inclusion in EPA NPDES permits.  The needs projected here include
costs for developing capability to receive NPDES permitting authority.


Almost all  of the States had increased needs for Permit Issuance.
About 2/3 of the States specifically referenced  that they will  need
additional  resources for permitting of toxic discharges and municipal
compliance under 301(i).  States also indicated  that there will  be
additional  costs for energy facility related permits.   Some States
noted that permit backlogs of varying degree and increased coverage
for minors influenced projections.
                                      47

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          "At the time of delegation there were an estimated
          6,400 point-source dischargers . . . 1,950 of
          these had received NPDES permits, and an additional
          1,500 of these had pending NPDES applications,
          prior to delegation.  This meant that some 2,900
          potential dischargers had not applied for an NPDES
          permit at the time of delegation ... of the estimated
          6,400 dischargers in (the State) only about 400
          of these had been designated major by EPA prior
          to delegation.  (The State is) experiencing
          a severe NPDES permit-processing backlog problem
          . . . the total number of permit applications
          on-hand has steadily increased since early 1979.
          The percent of these applications over 120 days
          has also increased from 16% in May 1979 to 62%
          in November 1979.  The number of permits issued
          per month has also increased as permit processing
          staff have become more familiar with the procedural
          and technical aspects of the program."

          "Significant backlogs in our Permit process are
          developing due to:  permit issuance for new
          dischargers; permit reissuance for expired
          permits and for municipalities required to
          implement pretreatment programs; pre-existing
          backlogs which developed in 1977 because of
          mass expiration of permits; and time delays
          arising from two-party preparation, review
          and issuance of permits".

Compliance Evaluation — State programs for determining compliance
with permits include arrangements for review of self-monitoring
information provided by permittees and procedures for determining
compliance that are independent of information developed by permittees.
States maintain a comprehensive inventory of all sources covered
by permits, conduct initial screening to identify violations, and
conduct substantive technical  evaluations to determine the appropriate
responses.  States also have programs for periodic inspection of
facilities of dischargers.  Non NPDES States generally conduct some of
these activities to assist EPA.

The States attributed the increase in compliance evaluation needs
to a number of different factors.  Increased emphasis on toxic
pollutants and the anticipated promulgation of BAT guidelines will
intensify the activities related to the review and assessment of
permittee performance.  In addition, many States expressed plans to
increase the focus on municipal compliance under 301(i), the number
of compliance evaluations, inspections per discharger per year, and
improve automated data processing capabilities.  Finally, States noted
that the development of pretreatment programs will substantially
increase the scope of the compliance evaluation activities.
                                       48

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Enforcement — State programs must have procedures to enable the
Agency to sue to enjoin threatened or continuing violations of
permit conditions and to obtain civil and criminal penalities.
States use a variety of techniques to bring sources into compliance,
including warning letters, administrative orders, civil actions,
and injunctions.  "Non-delegated" States assist EPA with administration.

The estimation of enforcement needs over the next five years appeared
more difficult for the States since they could not foresee how many
permittees will violate the conditions of their permits or what
measures will be necessary to bring the violators into compliance.
Hov/ever, they have identified a number of factors which can be
expected to increase enforcement costs.  Once again, the growing
emphasis on toxic pollutants (i.e., the inclusion of BAT provisions
in permits) will increase the expense and intricacy of the program
activities.  "Delegated" States must use enforcement to meet their
new responsibilities.  The initiation of pretreatment programs will
necessitate further legal involvement by the States.  Unlike the needs
projected for compliance evaluation and permit administration, which
demonstrate negligible growth rates for the latter part of the Assess-
ment period, enforcement costs show a substantially higher growth rate
throughout the five years.

In some States, enforcement activities are conducted in part by
Agencies such as the Attorney General's Office that do not have
substantial Clean Water Act responsibilities.  Needs for these
Agencies were not always included; therefore, the Enforcement needs
set forth here may be somewhat understated.  Hov/ever, funding may
come from non-HQM sources.
Analysis

Estimates of State needs for the NPDES program were made by EPA on a
national basis (See Methodology).  The assumptions made in developing
these estimates come from an understanding of the approaches the
Federal government uses to implement the permit program.  For example,
it was assumed that comprehensive State permit programs were in
existence before 1980 and no new program development costs were
included.  In addition, no new State delegations were costed in the
overall program estimate.

The national  costs were* based upon numbers of outstanding permits
from the computer printouts of 1/3/79 and 3/26/79 in the relevant
grouping of permit types:  municipal major, municipal minor,
industrial  primary major and minor, and industrial secondary major
and minor.   It was assumed that minimum overall management was
required and that expiring permits would be reissued promptly.  In
all cases,  wherever feasible, available EPA manpower models were
employed.
                                       49

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             EPA Estimations of State NPDES Needs Based on Available
Table IV-6:  EPA Manpower Modelling ($000,000)

Permit Issuance
Compliance
Enforcement
TOTAL
FY80
8.0
4.5
13.5
26.0
FY81
10.0
4.5
14.0
28.5
FY82
8.5
4.5
14.0
27.0
FY83
.5
5.0
14.0
19.5
FY84
4.5
5.0
14.5
24.0
Projected permit issuance costs were developed on the basis of the
number of existing major and minor permits and their expiration dates.
A modest growth rate of 100 new permits per year was added to this
estimate to project the cost of anticipated growth.  The methodology
follows the documentation of the ZBB process for the determination of the
Regional Workloads of 1979, 1980, and 1981.  It was assumed that
State work years equalled that of the Regional offices and that
the bulk of the municipal reissues will be accomplished by 1980.
The industrial reissues are related to the BAT and BCT Promulgation
dates, and assuming only small delays, these regulations should be
completed by FY 1981.  In order to meet statutory deadlines for
permit compliance, high rates of State activity were therefore
assumed for FY 81 and FY 82.  The only activity projected for the
non-NPDES States in permit issuance were certification under 401(a).

Projected annual compliance evaluation costs including compliance
reviews and inspections were based on the "Justification for Regional
Workloads, Water Enforcement Division, FY 1981" and estimated for
both NPDES delegated and nondelegated States.  The basis of costing
for these activities is the number of outstanding permits in the
municipal and industrial categories.  In several cases a specific
target for the year or percent of permits to be considered for the
activity was applied.  For the NPDES States, it has been assumed
that they would supply 80% of the workload with the EPA region
responsible for the remaining 20%.  In the case of the non-NPDES
States, lower State workloads were assumed.  Emphasis was placed
only on the major permits with no costs allocated for the minor
permits.

Projected annual enforcement costs were based upon the activities and
workload estimates in the Justification for Regional  Workloads, Water
Enforcement Division, FY 81."  In each case, the basis of costing has
been developed from statistical analysis of past EPA Regional  frequencies
of the activities and do not reflect individual State levels of activities.
Enforcement activities in the non-NPDES States are more limited than in the
NPDES States.   Consequently, a diminished role, sufficient to keep the State
informed of possible cases, was assumed.  As in the previous section on
compliance evaluation, one annual cost estimate for all the activities in
both NPDES and non-NPDES States was produced.  A separate estimate of new
growth for both compliance evaluation and enforcement were developed.
                                     50

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The State and  EPA approaches to estimating NPDES needs were very
different.   The States have their  actual past experience in the
activities  to  use as a base line whereas the Federal models were
developed from an examination of previous EPA Regional activities
based upon  the number of outstanding permits.  Consequently, the
comparisons are more significant in the ratios among the different
activities  which make up the NPDES Permit Program than in absolute
cost estimates.  A comparison of needs from the two perspectives
(Figure IV-2)  demonstrates the relationship among the three activities
of Permit Issuance, Compliance Evaluation, and Enforcement from the
perspectives,  Federal and State.
                           FIGURE IV-2
         COMPARISON OF STATE AND EPA
                 NPDES PROJECTIONS
                                                             PERMIT
                                                             ISSUANCE
                                                        I	k COMPLIANCE
                                                        I	1 EVALUATION
                                                             ENFORCEMENT
          FY80
FY81
FY82
FY83
FY84
EPA projections are substantially lower than State projections for
permit  issuance and compliance.  The difference  is not surprising,
for until this Assessment,  no concerted effort had been made
nationally to identify State costs.  EPA has manpower models for the
agency,  but not for the State program.  State projections, as pre-
viously  discussed, are statistically valid,  and  for that reason
should  be given substantial consideration.
                                     51

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Projections indicate little consensus between States and EPA on
timing, approach, management, prioritization, or needs.   The gap
between State and EPA perception as well as existing and needed
funding levels is so large that achievement of CWA requirements
may be in jeopardy.

A comparison of EPA estimates and State projections leads to the
conclusion that States will be unable to meet CWA deadlines. (Since
confirmed by follow up).  They project continuing incremental
increases in needs for permit issuance which bear no relationship
to the deadlines of the Act for reissuance.  EPA projections for
permit issuance, on the other hand, assume adherence to  those dead-
lines and, therefore, are very low in FY 83.  The States' hesitancy
to fully project the impact of toxics and their assumption of a
limited funding outlook is partially responsible for this slippage.
Further inquiries should be made into State assumptions  and the
significance of the difference.

The higher State projections indicate the NPDES program  and toxics,
in particular, may be much more resource intensive than  EPA assumed.
This raises substantial programmatic and managerial  issues.  The
EPA assumption of similar costs for conventional-and toxic pollutant
coverage appears to be incorrect at the State level.  If BAT guidelines
are unavailable, permitting may be made resource intensive under Best
Engineering Judgment.  Also States emphasize permit issuance and
compliance more than enforcement in NPDES while EPA relies heavily on
enforcement.  States appear to be expanding coverage to  include more
minor permittees also, which EPA methodology did not cover.

The State approach appears to be directed toward cooperative achieve-
ment of compliance through working with sources, technical assistance,
and negotiation.  This increases costs for permit issuance and
compliance but should minimize enforcement needs.  As one State observed:

          "With increasing emphasis on pollution control
          and authority delegated under the NPDES program,
          the Water Quality Bureau has moved from a service
          agency to one oriented to regulation and enforce-
          ment.  This has been a rather difficult transition
          for the Bureau, the permittees and for munici-
          palities and will never be entirely completed.
          The construction grants program requires a
          continued assistance attitude toward municipal
          officials and their problems whereas the enforce-
          ment program requires these same officials be
          subjected to litigation.  All too often, causes
          for delayed compliance are found to lie within the
          Bureau or EPA review process, this significantly
          weakens the enforcement stature."
                                     52

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Under the State approach, permit issuance could be delayed if adequate
funds are not available.  This could increase the number of enforce-
ment actions in the future.  A careful  matching of strategy, program
activities and needed funds is necessary to ensure a timely meeting
of goals without increased litigation.   States could benefit from
Federal  technical  and financial assistance to expedite the program
and meet deadlines.

Finally, comparison of State projections with the funding outlook
indicates there will be very substantial slippage in deadlines unless
the WQM program can accommodate the deadlines through cost and time
savings by program adjustments.  This appears necessary even at the
higher resources levels projected.   To  the extent that requirements
can not be satisfied at existing funding levels, States indicate the
Federal  government must supply the  support.  This increased support is
not anticipated from State legislatures.  To the extent that States and
EPA cannot meet demands within the  resources available, adjustments in
the Act may warrant consideration.
                                     53

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                               SECTION C

                              PRETREATMENT
Conclusion

States do not anticipate the availability of sufficient funds to
implement pretreatment programs and meet CWA deadlines.  Many flexible
approaches illustrate options for implementing the program more
cost-effectively.
Background

Industrial wastes which enter a municipal treatment plant (POTW)
can interfere with its operation, pass through into receiving waters,
and contaminate the sewage sludge.  To reduce these pollution risks, a
national pretreatment policy including general discharge prohibitions
and specific industrial standards has been established in accordance
with the Act.  This complicated program requires the involvement of
States and local governments to protect the public health and environment
as well as the billion dollar investment in municipal  treatment works.

As in the NPDES permit program, there is the opportunity arid indeed the
encouragement for States to develop and implement pretreatment programs.
The NPDES-delegated States were required to submit programs by the end
of March 1980; non-delegated States are also in various stages of
program development.  These programs include activities to plan and
implement pretreatment requirements at the State level, review the local
community roles and programs, organize a compliance evaluation system,
and develop enforcement procedures for both communities and industrial
users.  In addition, States generally will assume responsibility for the
smaller communities' programs.  It is the addition of the local level of
government with its responsibilities which adds to the complexity and
magnitude of the total State pretreatment program.

The scope of pretreatment can be contrasted to the NPDES program by
comparing the increased number of industrial dischargers to be regulated,
the shorter period of time for accomplishing compliance and the more
complex pattern of regulation and authority.  This new program can be
anticipated to control between 30 - 50,000 industries within a 4-year
period as opposed-to 10,000 major industries within a 12-year period
for the NPDES program.  Consequently, it can be easily understood when
States project that a doubling of resources will be required to accomplish
this new program.
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State Projections

The State pretreatment needs are summarized below:



Table IV-7:  Total State Projected Needs for Pretreatment (FY 79-84)

	FY79   FY80   FY81   FY82   FY83   FY84

Total Needs ($000,000)        1.0    4.0    8.0    9.0    9.5   10.0
The annual increases between FY 1979 and FY 1982 reflect the State
response to EPA's deadline for the development of State pretreatment
programs.  By FY 1982 most States indicate that programs will have been
developed and State activities will become primarily administrative.
Most States indicate needs level off once they are assured that local
pretreatment programs are operating and meet EPA standards.

The State submissions on pretreatment programs generally anticipate
a significant increase in funding to develop and implement programs.
Many have not yet inventoried their POTWs and industrial users (Ills) to
determine exact numbers to be impacted by the requirements.  Those that
have completed the inventory requirements especially recognize the need
for staff increases.  Highly industrialized States in particular will
need significant additions.  Both New York and Illinois have pointed to
this.

States under resource restrictions are seeking to minimize costs.  Several
States such as Ohio and Tennessee with respected pretreatment programs
in some cities have indicated they will ask these cities to assist other
communities in program development.  Others such as Kansas have announced
procedures to limit the number of industries that will  be controlled,
by, for example, excluding industries whose waste loads are primarily
biological.  Several other States with older pretreatment programs have
developed combined NPDES and pretreatment permit programs.  Connecticut
and Vermont, for instance, issue pretreatment permits comparable to
their point source permits.  Nebraska anticipates a similar organization
and Alabama has already permitted many of its industries on POTWs.  All
of these techniques may point the way to cost savings.


Analysis

EPA has estimated national costs for State pretreatment programs in
a manner similar to that used to estimate the costs of the NPDES program.
                                      55

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Based upon existing information, including the State guidance documents,*
numbers of POTWs and  Ills have been estimated along with required program
activities at the State level.  These responsibilities can be converted
to costs on the basis of applicable manpower loadings for the number of
POTWs and Ills in each State for both locally and State run programs.
This procedure has resulted in the following projections:


Table IV-8:  Total EPA Estimated Pretreatment Needs (FY 80-84)

	FY80   FY81    FY82   FY83   FY84

Total Needs ($000,000)       9.0    13.0    18.5   15.0   15.0


These estimates include four sets of activities which make up each
State pretreatment program:

     1.  Program Organization for 1979, 1980, and 1981.

     2.  Review of POTW Program Elements for 1980, 1981 and 1982.

     3.  Compliance for each year including 1981, 1982, 1983 and 1984.

     4.  Enforcement for each year including 1982, 1983 and 1984.

In the case of non-NPDES States, judgments based upon earlier permitting
assumptions have been used which provide for minimal States activity
with maximum Regional  responsibility.

The  comparison of State projections for pretreatment to EPA estimates
demonstrates two different approaches:  the States are evaluating a
total program responsive to monetary constraints, whereas EPA is evaluating
specific program activities with assumed, although conservative, manpower
loadings.  It would appear from the low State projections that  the States
will have difficulty  in meeting 1984 deadlines for implementing  pretreatment
programs for industries.   Indeed, many States have said as much:

           "(The State)  is  developing a pretreatment program
          but does not  have the resources to duly implement
          a program as  required by 40 CFR 403 which is massive
          in its commitment.  The State incorporates a minimum
          level reasonable approach to implementation."

           "The program  submitted underestimates  program
          administration costs.  These costs will increase
          for FY 81-84  due to an increase in the time  required."
  ^Example:   Guidance  for NPDES  States  on  Implementation of  General  Pretreatment
   Regulations  by  OWE,  1979.
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          "Program emphasis for pretreatment and toxics
          activities will be accomplished within resource
          limitations provided that those activities
          do not detract significantly from the ongoing
          responsibilities of processing permits.  This
          level of resources is less than tV- minimum
          identified by EPA, but is believed to be
          reasonable in view of the funding constraints."

States may have also underestimated costs based on overly optomistic
assumptions about local  program adequacy:

          "While the needs indicate the cost of the
          program will decline significantly after the
          third year, this w'll probably not happen.  The
          projections are based upon increased numbers
          of 'facilities' developing and operating their
          own  programs.   Expense and politics will
          interfere especially without significant federal
          support by way of grants.  Considerable
          financial support even at the State level will
          be necessary for the success of this planned
          program."

Since the pretreatment program is new and ambitious and the time frame for
program development and  industrial  compliance in short under the Act,
States could benefit substantially from EPA program assistance in
carrying out CWA requirements.   Pretreatment, as a new program, will
require careful nurturing to assure that it receives adequate resources.
Needs in existing programs outlined elsewhere in the Assessment are
such that a tradeoff in  favor of pretreatment without substantial
increase in funding is very unlikely.

Increasing requirements  and limited resources suggest consideration
by States and EPA of a pretreatment strategy.  Improved program
operation and funding priorities are two options.  Other funding
sources including Sections 201  and 205(g) should be considered and
may be more appropriate  for both the State and local  program needs.
This would avoid diverting WQM from other priority needs and still
maintain the pretreatment program requirements-
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                               SECTION D

                          MONITORING - PART 1

                                Overview

In reformating the categories used to solicit Assessment  information
for analysis, monitoring appears in two chapters.   With  the  exception
of ambient (See Chapter VI, Section B), all  monitoring is covered
here.  This split obscures the full impact of monitoring  on  the  WQM
program and the relationship among covered activities.  To put
monitoring in perspective, an overview is provided here.

WQM agencies project an increase of 53% in monitoring needs  between
FY 80 and 84.  The total cost of the monitoring needs indicates  it  is
one of the most expensive activities and will remain  so  due  to the
costly, sophisticated equipment and trained personnel  required for
toxics.  Monitoring is exceeded only by the NPDES  program in size
and by FY 84 constitutes 22% of the program.

As indicated in Figure IV-3, the significant increase in  equipment
costs that occur in FY 81 is largely responsible for  the  substantial
cost of the monitoring program in that year.  The  large  percentage
growth represents the intention to respond to equipment  needs as
quickly as possible.  Of the three types of monitoring,  intensive
surveys experiences the greatest one-year percentage  increase from
FY 80 to FY 81.  It is during this period that ambient monitoring
needs fall below those for compliance monitoring,  suggesting a
possible tradeoff in which the WQM Agencies have decided  to  build up
their intensive survey program while deemphasizing ambient monitoring.
The compliance monitoring needs show a more steady rate  of growth
through FY 84.  This is unlike most of the other water quality
programs, which tend to remain static toward the end  of  the  period
covered by the Assessment.  It appears that the States will  continue
to place greater emphasis on this facet of their monitoring  program
(Figure IV-3).
                                 FIGURE IV-3

                      WQM AGENCIES PROJECTED
                      TOTAL MONITORING NEEDS
 $ MILLIONS
    70M r-
    60M


    50M


    40M


    30M
    20 M
    10M
                   COMPLIANCE MONITORING
                   AMBIENT MONITORING
                   INTENSIVE SURVEYS
                   EQUIPMENT
                   TOTAL MONITORING COST
                  I
I
      FY79 FY80 FY81 FY82 FY83 FY84
                                      58

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                                       FIGURE IV-4

                              WQM AGENCY PROJECTED
                              TOTAL MONITORING NEEDS
                               (EXCLUDING  EQUIPMENT)
$ MILLIONS
   60M


   50M  -



   40M  —



   30M  -
        +


   20M  -



   10M
COMPLIANCE MONITORING
AMBIENT MONITORING
INTENSIVE SURVEYS
TOTAL MONITORING COST (EXCLUDING EQUIPMENT)
      FY79  FY80  FY81  FY82  FY83  FY84
   Figure IV-4  illustrates  the  State's total monitoring needs when
   their equipment  costs  have been excluded.  There is no longer a
   steep increase from  FY 80 to 81 nor a decrease from FY 81 to 84.
   Instead,  ambient and compliance monitoring, and intensive surveys
   combine to form  a total  monitoring program which grows steadily after
   a more pronounced increase from FY 80 to FY 81.
   Figure IV-5 compares the WQM Agency projections  of monitoring program
   needs with EPA estimates.  They are substantially different.  Among
   program elements WQM Agencies and EPA appear  to  take  very different
   approaches.  This raises an issue as to whether  WQM Agencies and EPA
   are consistent in program objectives, directions and  priorities.
   The most significant difference in the projections exists between the
   respective equipment projections while the  ambient monitoring estimates
   are very close.  Also, EPA estimates for intensive surveys exceed WQM
   Agencies projections indicating a more water  quality  based program
   than States anticipate.  WQM Agencies projections for compliance
   monitoring costs are also much lower than EPA estimates.
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                       FIGURE IV-5
  MONITORING COMPARISION OF STATE AND EPA ESTIMATES
$90
$80
$70
$60
$50
$40
$30
$20
$10
                                                 COMPLIANCE
                                                 MONITORING
           FY80
                          FY81
                                         FY84
                      FIGURE IV-6
       PRIORITIES OF WQM AGENCY PROJECTIONS
                                            AMBIENT
                                           MONITORING
                                              31 %


                                             FY80
                        AMBIENT
                       MONITORING
                          20%
                                                                     AMBIENT
                                                                    MONITORING
                                                                       27%
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                          MONITORING - PART 2

              Monitoring Equipment and Facilities Services
Conclusions

•    Toxic analytic capability is crucial to the continued development of
     State programs designed to monitor and control industrial and municipal
     point sources.  A large capital investment totaling over $30 million
     in new equipment, such as sophisticated mass spectrometers and gas
     chromatographs, will be necessary for some States to effectively
     monitor for toxics.

•    While the most important influence on demands for new equipment
     indicated by the States is the need for toxic monitoring capacity,
     there are other forces projected to increase costs, such as increased
     workloads and the need for sophisticated State data management systems.

•    The normal operation costs of laboratory, maintenance of equipment,
     supplies, and replacement constitute a substantial continuing need
     (approximately $10 million).


Background

This part covers laboratory equipment and facilities for CWA programs.  These
services are used to analyze samples from fixed stations, intensive surveys,
and compliance monitoring.  Personnel are covered separately under
monitoring activity categories (i.e., ambient, compliance and intensive).

Equipment needs have been segregated in the Assessment because of their
importance to the statutory requirements and regulatory programs.  An
effective water quality program is dependent upon the information
provided by the monitoring activities,  which in turn, are contingent on
the availability of the proper equipment.  Effective permit issuance
and permittee compliance rely on an understanding of information related
to water quality gained from monitoring.  Very specialized and sophisticated
equipment will be needed to accomplish  this.

Examples of the equipment projected as  needed by the States include
automated gas chromatographs (approximately $50,000 each), mass spectrom-
eters (approximately $200,000 each) and atomic absorption units (approx-
imately $40,000 each)  for the analysis  of toxic pollutants or inductively
coupled argon plasma units (approximately $100,000 - $140,000 each)
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for very high volume metals analysis, and infrared-ultraviolet
spectrophotometers (approximately $100,000 each) for the analysis of
organic materials.  The great expense of these instruments is compounded
by the need to hire personnel possessing the high level of technical
expertise required to operate the equipment.  Hov/ever, the time saved
by this equipment and the quality of the analysis provided by it should
ultimately lead to cost savings.

Often associated with the procurement of new analytic equipment, there
are facility changes including adequate safety for handling
"high hazard" samples (e.g., "clean rooms"), additional cooling and
more even power supplies.  States also noted that greater laboratory
productivity will necessitate sophisticated data processing equipment.
These items must be added to the continued requirement for storage
refrigerators, ovens, balances, glassware, and reagents needed in
routine operations.
State Projections

The following table reflects total equipment needs projected by the
States.
             Total State Projected Monitoring Equipment and Facility
Table IV-9:  Needs (FY 79-84)

Total Needs ($000,
FY79
,000) 6.0
FY80
8.5
FY81
30.5
FY82
16.5
FY83
11.5
FY84
11.0
The States contend that their monitoring capability has not kept
pace with the increased concern being directed toward toxic pollutants.
Their monitoring activities will not provide all of the information
needed for regulatory and management decisions until laboratory capabilities
are improved with the addition of suitable equipment:

          "Equipment needs are largely dictated by the
          analytical workload, complexity of analysis
          and diversity of samples for toxic pollutants.
          The greatest impact on our laboratory will be
          in the area of analysis for toxic organic
          pollutants-  The replacement of existing equip-
          ment with modern instrumentation capable of
          automated sampling and data handling is
          essential."
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          "In coordination with and support of National
          Pollutant Discharge Elimination System (NPDES)
          compliance monitoring, the recent Environmental
          Protection Agency promulgation of priority-
          pollutant criteria necessitates more
          sophisticated analytical equipment."

The substantial increase in projected needs for FY 81 indicates the States
desire to increase their in-house capability as soon and as completely
as possible.  This is particularly true of the 5 States  (Kentucky,
Michigan, New Jersey, Oklahoma, and West Virginia) projecting 66% of
the total FY 81 equipment needs.  Much of the cost in FY 83-84 is attri-
butable to the normal operation cost of laboratories and equipment
replacement.

Analysis

3 State submissions projected no needs for equipment purchases probably
due to procedural  difficulties associated with procuring this equipment
with Federal funding or projecting needs where many agencies or con-
sultants are involved.  Some others projected what appeared to be
abnormally low costs to maintain (or contract for) laboratories and equip-
ment.  The net result is that these projections may underestimate equipment
needs.  However, this may be partially offset by unidentified reliance on USGS.


Laboratory equipment needs actually projected by the States exceed EPA
estimates by a wide margin (see Figure IV-5).  This indicates uncertainty
exists between States and EPA regarding future program direction and the
strategy to meet those needs.  While EPA has formulated  a specific strategy
in this area, "Option 7", it appears that States are unaware or disagree
with this Agency approach of sharing facilities.

The substantial  costs of routine purchases of glassware  and reagents
were not specifically estimated by EPA, adding to the difference in
estimates.   There are also other factors which may have contributed
to this difference, such as the pricing discrepancies among States,
but further study will be necessary to accurately identify them.

The emphasis placed on toxics in the WQM program will require an
early build up of toxic analytic capability as a prerequisite to
program operations.  States and EPA should give careful consideration
to a cost-effective program and grants strategy for meeting those
needs and preceed promptly to implement.
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                          MONITORING - PART 3

                         Compliance Monitoring
Conclusions

•  The resources necessary to maintain the States' compliance monitoring
   programs will continue to increase as those programs supported by
   compliance monitoring, such as NPDES enforcement and compliance
   evaluation, and pretreatment, expand to meet new requirements.
   States identified an increase of 67% from FY 80 to FY 84.

•  A major factor to which this growth can be attributed is the mounting
   concern being directed toward toxic pollutants.  States cited
   increased compliance monitoring needs based on the adoption of
   toxic substance standards, the initiation of bioassay monitoring
   to detect toxicity, and an increase in the number of compliance
   sampling inspections.

Background

Compliance monitoring involves water quality sampling and analysis
to determine discharge compliance with pretreatment requirements and
effluent limitations in NPDES permits.  It includes sample collection
and handling, laboratory analysis, and report development.  Compliance
monitoring is performed by "delegated" and "non-delegated" States.
The partnership between EPA and non-NPDES States is becoming increasingly
important as resources become more scarce.  The Agency must depend on
the information gathered through these State's compliance monitoring
activities to support EPA's enforcement program.  This reliance on
non-delegated States underscores the importance of compliance monitoring
programs to all States in their effort to perform the regulatory activities
prescribed by the Act.  To a limited degree Areawide Agencies also
conduct such monitoring.

HQM Agency Projections

The following table shows the total WQM Agency projections for operating
the compliance monitoring program.

Table IV-10:  Total WQM Agency Projections for Compliance Monitoring (FY 79-84)

	FY79	FY80	FY81     FY82      FY83	FY84

Total Needs         10.5       12.0       15.5     18.5     20.0       21.0
 ($000,000)
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Every Statewide submittal but one projected needs for the period covered.
42 identified an increase in needs while 2 States projected a decrease.
4 States cited needs which remained stable from FY 80-84.  Unlike many
of the other program needs which showed a leveling off or decrease
of costs in the later years, the compliance monitoring costs increase
throughout this period.  This indicates that WQM Agencies perceive
compliance monitoring to be of growing importance (e.g., BAT) or very
underfunded.

WQM Agencies cited a number of factors responsible for the yearly
increases in needs.  Foremost among these was the high priority
currently being given the detection of toxic pollutants.  Almost
3/4 of the submittals attributed at least part of the increase in needs
to this growing concern.  Emphasis on toxic monitoring will require
the expansion and retooling of existing compliance monitoring programs.
Many WQM Agencies also indicated plans to initiate bioassay monitoring
which is organism-dependent and can be an accurate measurement of
toxicity.

The expansion of WQM Agency programs to cover the increased requirements
of the Clean Water Act will also lead to an increase in their compliance
monitoring workload.  Periodic inspections and samplings of POTWs and
industries will  be necessary to assure compliance with the NPDES and
pretreatment programs.  Influential  factors cited by a number of Agencies
include increases in the number of compliance sampling inspections
(especially of minor discharges) and increases in the number and complexity
of the parameters specified in new and modified permits.

Analysis

Detailed analysis of the projected compliance monitoring costs provides
some important observations.

EPA estimates of total compliance monitoring needs were much higher than
WQM Agency projections (See Figure IV-5).  There are a number of reasons
which can account for this difference which merit further consideration.
WQM Agencies and EPA appear to differ in their strategy and approach.
Agencies indicate uncertainty about  EPA policy and direction.  In
addition, EPA assumed an increase in the rate of permitted dischargers
monitored from 48% in FY 80 to 75% in FY 84.  This increased workload
would lead to an increase in needs.   Hov/ever, in assuming that 75% of
the major dischargers would be monitored once yearly by FY 84, EPA
may have over-stated the need.  It appears that a more realistic rate
may be somewhere below that percentage.

While WQM Agencies recognize toxic needs, they may not perceive the workload
to be as great as EPA estimates.   Another possibility is that the
States underestimated the increase in the workload time or resource
intensity required to contend with toxics which is a trend seen elswhere
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in the Assessment.  States may have also relied on more non-sampling
methods of compliance monitoring or have higher productivity rates.
Higher EPA projections may reflect more reliance enforcement to secure
compliance than States projected in the NPDES program (See Section B).

A mutual  State/EPA understanding of compliance monitoring needs should
be reached and implemented at the Regional  and State level.  EPA and
WQM Agencies could benefit from a long term program and funding
strategy.  Funding adequate to satisfy all  these needs is unlikely.
Priorities and more cost-effective approaches may be necessary.  There
are also alternatives to Federal support including user charges and
increased reliance on self monitoring which merit consideration.
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                             MONITORING - PART 4

                             Intensive Surveys
Conclusions
     WQM Agencies increase emphasis on intensive surveys over the period
     of the Assessment.  Program needs are projected to grow over 75^
     with the increase in emphasis primarily directed toward developing
     a better understanding of water quality problems.  WQM Agencies
     are becoming more aware of the utility of intensive surveys in
     identifying problems, expanding the information base to include
     additional  parameters, indepth analysis and develop point source
     controls.  This is in contrast to their past reliance on fixed
     station monitoring.

     The States intend to increase their intensive surveys as a device
     for detecting general nonpoint source problems.  This type of
     intensive survey is  more sophisticated in that it involves more
     intricate,  time-varying sampling techniques.
Background

Intensive surveys perform a variety of essential services such as
developing instream data for determining cause and effect relationships
between sources and pollution, providing detailed information concerning
point-nonpoint source relationships, determining toxic problems, and
developing total maximum daily loads and waste load allocations.  The
information is used primarily in general and point source planning (see
Chapter VI, Section C & D) and triggers development of specific nonpoint
source control programs.  For nonpoint sources, this chapter includes
only surveys to identify the specific category (e.g., agriculture vs.
onlot or municipal facilities) which is causing a problem.  Subsequent
surveys are covered in Chapter V.

In the past few years and over the period of the Assessment, WQM Agencies
indicated a shift from ambient monitoring in favor of intensive surveys.
WQM Agency Projections

Table IV-11 reflects the total WQM needs for conducting intensive surveys
WQM Agencies project the largest growth in FY 81, indicating the general
inadequacy of the existing program or the increasing awareness of toxics.
Moderate program development is projected beyond FY 81.  The apparent
desire to increase priority of the program and rely more heavily on
intensive surveys can be attributed to a number of factors, one of which
is the shift in environmental  concern from conventional to toxic and
hazardous waste problems.
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In order to deal with these priority problems, WQM Agencies project
the need to increase toxic substance surveys.  These surveys are
geared to identifying and understanding problems at this point in
time rather than developing specific controls (such as wasteload
allocations) for point and nonpoint sources.  70% of the increase
in needs from FY 80-84 is for this general purpose type of intensive
survey.  By FY 84,this type constitutes 60% of the program's total
needs.  Intensive surveys for the development of total maximum daily
loads and waste load allocations (e.g., AWT/AST reviews) increase
53% over the period of the Assessment but decline in priority.

WQM Agencies also discussed the need to obtain information necessary
for including toxics criteria in the water quality standards.  They
project a need to initiate strong nonpoint source surveillance programs
to obtain nonpoint source background data and identify land areas
where best management practices (BMPs) are needed.  Cause and effect
studies will be performed to identify relationships between nonpoint
source pollution and water quality standards violations.

Every submittal identified intensive survey needs for the period covering
FY 80 to FY 84.  40 projected increasing needs, while 4 showed decreases.
Another 4 submittals identified needs that remained stable.

Table IV-11:  Total WQM Agency Projected Needs for Instensive Surveys

	FY79    FY80    FY81    FY82    FY83    FY84

Total Needs ($000,000)  6.5      8.0     12.5    13.0    14.0    14.0
Analysis

EPA's estimates for intensive surveys far exceed State projections (See
Figure IV-5).  This is primarily because the Agency assumed a greater
number of intensive surveys would be made than States indicate.  This
tended to place a higher EPA emphasis on intensive surveys and water
quality based planning than WQM Agencies gave.  Although WQM Agencies
indicated that there will be some program shift from fixed station
(i.e., ambient) monitoring to intensive surveys, this shift of emphasis
will not be to the degree evidenced in EPA estimates.  The Agency's
estimates, therefore, represent a more significant commitment to
information drawn from this source for program development and operation.
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                               SECTION E

                 PROGRAMS FOR DREDGED AND FILL MATERIAL
Conclusions

•    States want to assume delegation of 404 programs.

t    Substantial increases in resources will be necessary to
     delegate 404 programs.

•    There appears to be substantial State confusion over program
     requirements and EPA expectations.

Background

Section 404  of  the CWA established  a permit  program for control of
discharges of dredged or fill material.  Activities regulated  under  this
program include the filling  and alternation  of wetlands, the disposal of
dredged spoil into waters  of  the United States, and the construction of
structures in these waters.   This program  is now administered -by the
Corps of  Engineers.  The 1977 amendments to  the Clean Water Act authorize
approved  States to administer this  permit  program for certain waters
within the State  (commonly referred to as  a  404 delegation) and to
regulate  certain  of these  activities through statewi-de 208 regulatory
programs  under  208(b)(4)(B).  The amendments emphasized the importance
of these  provisions by adding the following  language to Section 101(b)
of the Act:

           "It is  the policy  of Congress that the States
           ...implement the programs under... Section 404
           of this Act."

State 404  programs must issue permits  that will assure compliance with
EPA guidelines, coordinate with EPA and other States in the issuance of
these permits,  and take enforcement actions  to abate permit violations.
State Projections

States currently have a low level of 404 activitity which focuses on
certifying permits issued by the Corps as being consistent with State
law.  This is required under Section 401 of the Act.  By FY 84, 18
States project assumption of the 404 program.  This, of course, results
in a dramatic increase in resource needs.  By  FY 84, delegation (and 208
(b)(4)) is projected to require 6.5 million dollars.  The remainder is
attributable to certification in non-delegated States (see Table IV-12).
Of the 18 States projecting 404 programs, 6 also costed statewide dredge
and fill regulatory programs under Section 208(b)(4).
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Table IV-12:  Total State Projected Needs for Dredge & Fill Programs, FY 79-84

	FY79     FY80	FY81      FY82      FY83     FY84

Total State Needs         .5     1.0        3.0       5.0       7.0      7.0
 ($000,000)

For those States (28) not indicating the desire to assume delegation,
there are negligible increases in needs.  The average cost per State
projecting assumption delegation in FY 81-84 is approximately $360,000
in each year.  However, there is substantial variation among the States
on costs for administering the 404 permit program.  This can be
attributed, at least in part, to several factors.

No State is now administering the permit program; thus, there is less
experience and precedent and more likely to be confusion.  This is
compounded by the fact that the geographic scope of 404 jurisdiction is
not the same as that of the Corps program.  404 regulations and the
definition of exemptions from permit requirements were recently issued
by EPA.  Both Corps and State experience is therefore of limited value
in determining the extent of the program needed.  Programs may also be
heavily dependent upon State circumstances, such as the wetlands which
may lead to high variability.

Projections for assumption of the delegation heavily emphasized
permitting rather than compliance and enforcement.  This phenomenon,
also seen in the NPDES Program for new delegations indicates that by
FY 84 States will have not fully phased in all aspects of the program.
Therefore, needs are likely to increase beyond FY 84, particularly
in compliance and enforcement, which in FY 84 are very minimal
costs per State.

The number of States desiring delegation is subject to change.
Assumption of the program will be dependent upon resource
availability.  For example, some States indicated that increased
Federal funding would be necessary to assume the program.  As with
pretreatment, this program is new.  Needs are substantial enough in
existing WQM programs that State tradeoffs in favor of 404 assumption
are unlikely.  Assumption is more probable if accompained by increases
in resources.  Final 404 regulations for State program operations,
once promulgated by EPA, will clarify the associated resource needs
for States.  In addition, State legislation may be necessary before
assumption of the delegation and may not be feasible in all instances.

Analysis

States are ambitious about assuming the delegation.  The outlook
will be directly dependent upon resource availability.  Although
there is variability among States, an average cost of $360,000 does
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not appear unreasonable.  More weight, however,  should be given  to
compliance/enforcement.   The variability indicates substantial
confusion over program requirements.   State projections may be  low.
Certification costs may be underestimated since  some States indicated
no costs and activity is underway.  Assessment Projections generally
reflect the needs of the State agencies primarily responsible for
administration of CWA programs, and may not include activities  of
other State agencies that work with the Corps of Engineers in
administering the 404 program.

If priority is placed on State assumption of the 404 program, specific
attention should be given to the associated resource requirements.
Policy should be set in full recognition of needs in other programs
and tradeoffs among WQM program objectives within the available
resources.  Continued and increased attention to specifying EPA  policy
will  lead to more consistent State programs and  more cost effective
use of resources.
                                    71

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                 Chapter V
NONPOINT SOURCE PLANNING AND ADMINISTRATION
   Section A - Overview

   Section B - Rural
               Part 1
               Part 2
               Part 3
               Part 4
         Overview
         Agriculture
         Silviculture
         Noncoal  Mining
   Section C -
   Section D -
Urban
Part 1  - Overview
Part 2 - Urban Runoff
Part 3 - Construction Runoff

Around Hater
Part 1  - Overview
Part 2 - Onlot Disposal
Part 3 - Residuals
Part 4 - Ground Hater Management
                    72

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                 NONPOINT SOURCE PLANNING AND ADMINISTRATION

                                  Section A

                                  Overview
Nonpoint sources of pollution are often a significant problem, affecting 87%
of the nations water basins (Table V-l).  WQM Agencies agree that these
sources should be controlled and are willing to assume that responsibility.
This is particularly important because nonpoint sources comprise about one-
half of the pollution problem.  The goal of the WQM program for nonpoint
sources is to assist State and local agencies, and the public in developing a
decision-making process for solving pollution problems and meeting the water
quality goals of the act.  To accomplish this goal, EPA awarded grants under
Section 208 of the Clean Water Act  (CWA) totalling approximately $370 million
to State, interstate, and areawide  agencies.


                                   Table V-l

                           NONPOINT SOURCES OF POLLUTION
Percentage of Basins Affected* by
Region
(Number of basins)
Northeast (40)
Southeast (47)
Great Lakes (41)
North Central (35)
South Central (30)
Southwest (22)
Northwest (22)
Islands (9)
Total (246)
Urban runoff

70
57
54
54
50
23
23
67
52
Construction

15
2
7
6
0
0
23
67
9
Hydrologic
modification
20
21
2
3
23
18
23
22
15
Silviculture

10
30
15
6
13
5
27
0
15
Type of Nonpoint Source
Mining

20
15
41
40
53
36
23
0
30
Agriculture

55
62
59
89
87
73
55
78
68
Solid Waste
disposal
35
9
15
9
13
0
9
22
14
Individual
disposal
63
40
39
29
40
35
32
89
43
"In whole or part.
 Since the  passage of the  Clean  Water Act  in  1972,  EPA has  made substantial
 progress toward meeting  the goals of the  Act.   Initial  State and areawide 208
 plans have laid the groundwork  for continuing  efforts in water quality manage-
 ment   Of  the 225 agencies which received grants  in FY 74-76 to prepare initial
 plans, 175 have State certification and 142  have  EPA approval  as of April 1,  1980,
 Mow that most initial  planning is completed,  EPA, States and areawide agencies
 are beginning to implement the decisions through:  Section 201  construction
 grants, Section 106'State program grants (e.g., the NPDES permit program), the
 Section 205(g) construction management assistance program,
 tation-oriented programs.
and other imolemen-
                                          73

-------
 Since there  are still  gaps  in  the  plans,  especially  for  nonpoint  source
 controls,  EPA  will  continue to use the  208  grant  program to  fill  important
 gaps  and  to  augment the  existing point  source  control  framework with  an
 equally complete nonpoint  source framework.   For  FY  80 and beyond,  EPA
 introduced national  208  funding priorities  through the WQM strategy and
 208 funding  priorities (available  from  the  Water  Planning Division).
 They  are  based on an analysis  of the  important gaps  in the initial
 plans and  the  ability of EPA and other  Federal  and State programs to
 address them.

 The  national  priorities  for 208 grants  are  nonpoint  source problems,  with  the
 greatest  emphasis on urban  storm runoff,  agriculture,  and ground  water  contam-
 ination.   In addition, EPA  will to address  the persistent problem of  a  lack of
 financial  and  managerial techniques to  implement  approved 208 plans.   EPA  has
 developed  specific strategies  for  ground  water and agriculture and  is developing
 a small alternative wastewater systems  strategy (all  available from the  Water
 Planning  Division).   Since  conditions vary  from one  location to  another,
 priorities must be tailored to local  circumstances.   The WQM program  supports
 local nonpoint source priorities which  differ from the national  priorities  if
 they  will  lead to implementation and  have a major impact on  water quality.

 In the Assessment, projections were requested for the following  categories:
 agriculuture,  silviculture, urban  runoff, noncoal  mining, ground  water,  onlot
 disposal,  construction runoff  and  residuals.  This Chapter organizes  these
 areas into three sections:   urban  (urban  and construction runoff);  rural
 (agriculture,  silviculture, and noncoal mining);  and ground  water (onlot,
 residuals, and ground water management).  There are  interrelationships  and
 overlaps  among the sections which  should  be kept  in  mind when reviewing  this
 chapter.
States were requested to divide needs into three activity categories.   Problem
assessment includes development of inventories and projections, development
and evaluation of best management practices and other program effectiveness.
Program development includes development of legal, financial, administrative
capability and the management structure to implement solutions.  Program
administration includes ongoing program administration and management,  educa-
tion, training and technical assistance associated with implementing solutions,
Federal eligibility for program administration under WQM is limited to  106
funding.   Section 208 can support only planning.  Therefore,  under implemen-
tation, this Assessment covers only State administration needs and any  State
anticipated pass-through to local governments for completing  State delegated
tasks.

In addition to the areas covered here, States identified miscellaneous  needs
such as open space/recreational planning and hydro-modification.   These needs
are modest and account for less than 2% of total MPS needs.

States projected a continued commitment to nonpoint source control.  Nonpoint
sources account for 29% of the total program in FY 80 and 24% in  FY 84.  The
program is exceeded only by point source control in size.  Between FY  80-84,
total resource needs increase by $10.0 million or 16% (Tables II-3 and  V-2).
                                        74

-------
Growth is moderate  because  fiscal  needs peak in FY 82 as the program shifts
from planning  toward  less costly program administration.  Projections  indicate
most States are  at  the  program development stage in many problem
the period of  the Assessment,  the nonpoint source program shifts
~i-,*,~-,-.,,-, 4-~  -.A^i^i^+^^-i-irm  ,.,u-;^u accounts for 20% of needs in
                                                                  areas.  Over
                                                                  markedly from
planning to administration which  accounts  for 20% of needs in FY 80 and 60% in
FY 84 (Figure V-l).  This is  due  in  part ot the contributions of other funding
sources to administration of  nonpoint  source control programs such as other
Federal Agencies (USDA), permit fees,  local government, and non-water quality
related State programs  (e.g.,  Soil and Conservation Service).  As with other
aspects of WQM  (except  Clean  Lakes), this  Report does not cover actual structural
and nonstructural  implementation  in  the field.
                                       Figure V-1
                      Total Nonpoint Source Needs by Activity Category
  45
  40
  35
  30
  25
  15
  10
                                                               Program Administration
                                                                    Problem Assessment
                                                                   Program Development
  FY79
                  FY80
                                  FY81
                                                   FY82
                                                                  FY83
FY84
The distribution of total needs  among  urban,  ground water and rural program
areas becomes relatively stable  after  FY  81  reaching 25%, 41%, and 34% respec-
tively by FY 84 (Figure V-2).  Uncertainty over continued Federal commitment
to nonpoint source control  is  reflected  by a  very limited number of States
which assumed continued funding  at  less  than  or equal  to existing levels.
This perspective, inconistent  with  Assessment's objectives, obscures needs
slightly and is seen  in other  aspects  of  this Report.   Figure V-3 indicates
the portion these areas share  of the  total  needs projected.
                                          75

-------
                                                 Figure V-2
                                          Distribution of Nonpoint
                                             Source Projections
                        FY 1979
                                                                               FY 1980
          Non-Coal
           Mining
             2%
                                                                                                   Construction
                                                                                                       4%
                                        Non-Coal
                                         Mining
                                           3%
FY 1981
                                                         FY 1982
                                      Residuals
                                         4%
Non-Coal
 Mining
  3%
                                   Non-Coal
                                    Mining
                       FY 1983
                                                                               FY 1984
    Non-Coal
     Mining
      4%
                                    Non-Coal
                                     Mining
                                      4%
                                                     76

-------
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-------
Projections  indicated a stable program with moderate shifts  in  resources  among
source  categories (Figure V-4).  The most notable development  is  the  growth in
agriculture  between FY 79 and 84.  This appears to  indicate  voluntary,  cost-
sharing  programs, are more resource intensive than  regulatory  and other non-
point source control  programs.  During FY 81-84, there  is  continued growth in
construction runoff programs.  Ground water, silviculture, residual waste
control,  and onlot increase but peak before FY 84.  Projections  for urban
runoff  decrease substantially after FY 81.
                                       Figure V-4
                                   Total WOM Needs for
                                Nonpoint Source Categories
   22
   20
   18
   16
   14
       Silviculture
                Non-Coal Mining
         I    I    I    I    I
                                         Construction
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   FY 79 FY 80 FY 81 FY 82 FY 83 FY 84

               Rural
FY 79 FY 80 FY 81 FY 82 FY 83 FY 84

          Urban
FY 79 FY 80 FY 81 FY 82 FY 83 FY 84

       Ground Water
National prototype projects, whose  objective is to reduce WQM Agency costs and
expedite program development,  are not reflected in WQM Agency projections
beyond FY 81.  These prototype projects should help Agencies achieve objectives
at reduced costs.  The WQM Agency lack of project orientation may be due to
postponements of projects until  after FY 84 when staffing is more adequate and
problems better defined, a shift from areawide to State program management,
acknowledgement of inadequate  resources at the State and local level to cover
such projects, reliance on national  prototype projects, or incomplete strategies
and uncertainty at this time about  specifically which projects should be
undertaken FY 81-84.  Further  examination of the relationship of National
prototype projects and technology transfer to /Jgh Agency projections and cost-
effective achievement of nonpoint source control is desirable.
                                          78

-------
Several major conclusions can  be made  from the projections:

     o    There is general  State and a^eawide consensus with the national
          strategy.  Projections  confirm  the appropriateness of priorities and
          the national program  di;ec,ti')n.   >n the near term, Agencies focus on
          filling major gaps  'n plans.   rrnphasis  gradually shifts toward
          implementing planning output'-  .;;;'•  building institutional program
          capability.  Ptojprtions  in-1!'.-5 "e  .-.a I  this strategy, with adequate
          funding will, in'!e^r!,  lpa<'  lo  kip1 emer'tat-ion of State/local nonpoint
          source control.   .'", thi:  •-•.'".>--.  i---^  federal WQM role and associated
          costs diminish.

          Projections  indicate  incr easinc;  awareness  and commitment to nonpoint
          source pollution contra"'.   Sjhs f.diitial  progress can be made with
          moderate  increase^  i?i 'edfiv;  c. emr-i tii.pM4 .   "lonpoint source pollution
          control is one cT thp r>\-/ or "niv  /---as where increased water
          quality benefits can  be a '.Move'!  ii  c'ea easing costs to WQM and the
          Federal government.   If. cinpear^  to  bo  a cost-effective approach to
          water pollution control fo,  .ffjM  winch  stresses support from other
          sources and State,  local  -,rr< ,-ir;.--^n  sp-ctor involvement.  WQM is in
                 "seed nionev,1
          Nonpoint source control  i-  ^ r;iaio>"  cnnuonent of the 1JQM program.
          However, perceptional  pfoblesus  persist.   This is an emerging program
          area.   Projections, as a  remit  .k  nui  correspond as well  as they
          should to the extent of  the  proi UTI  (e.g.,  around water contamination),
          Program develoupcnt bevon'1  'hat  projei.-t  is  necessary to get adequate
          programs in place to control priority  problems.   Continued emphasis
          on prototype projects  anc  t^hnolmy  transfer as put forth in the
          HQM strat-:qv' v/i 1 1  mii'imi^  ros"-  ai.d  expedite controls.

          Creative use of ruin "QM  resources can  reduce 208 needs.  Some of the
          needs  identified could be met by  increased,  but selective reliance
          on Section 104 and 10^ of  the Act. for  funding.   Both Sections support
          research and development  and can  reduce  demands  for 208 funds.
          Further examination of tfpse f.inrlinq mechanisms  and their relationship
          to HQM needs ^KHI!'.! be undertaken.

          Staffing is of paramont  iriportance  because  availability of qualified
          personnel may be  a limiting  fcctor  in  nonpoint  source control,
          particularly in new or r^pidr,  expanding  areas  such as ground water.
          Long  range program arv1 " + Tffi!i'i  --trTtegies  can  minimize this problem
          and expedite nonp'iJ!''1  i,r\i><.'-- -.o'l:,) nl .   Joint study by EPA and States
          should be unde^tak^c un''0!  c^..ti'-!.  l^'l (n )('^) to  assure adequate
          staff  aval lahi 1 i rv tr- I'ret v/a^er  poMution  control  needs.
                                         79

-------
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    Section B



      RURAL








Part 1  - Overview



Part 2  - Agriculture



Part 3  - Silviculture



Part 4  - Noncoal  Mining
        83

-------
                             RURAL  NONPOINT  SOURCES

                                   Part  I

                                 Overview
This section covers projections  for  the  following  problem areas:   agriculture,
silviculture, and noncoal mining.  WQM Agency projections indicate rural
nonpoint source categories  have  more WQM funding  needs  than urban or ground
water.  By FY 84, rural categories constitute 41%  of  the nonpoint source
program compared to 29% in  FY  79 and 25% in  FY 80  (Figure V-5).  Agricultural
program needs are responsible  for most of the growth.   Projections indicate
that WQM Agencies are  in  the process of  shifting  from planning to administration
of programs (Figure V-6).
   21



   18



   15

U)
c
-i  12
    6


    3


    0
   FY
                                       Figure V-5
                         Total Rural Nonpoint Source Control Needs
                                   by Activity Category
     79
FY80
                                   FY81
                                FY82
                                                                  FY 83
                                                                                  FY84
WQM project a doubling of programs  over  the  five-year  period from 1980-1984 in
the area of silviculture; an  increase  of 42% from  1980-1984 in the area of
noncoal mining; a 100% increase  in  agriculture from  1980-1984.  WQM estimate
Rural nonpoint source needs to be:
Table V-3:   Total WQM Projected  Rural  Nonpoint Source  Needs, FY 79-84 ($000,000

Noncoal Mining
Silviculture
Agriculture
TOTAL

FY 79
1.0
2.0
9.0
12.0

FY 80
2.0
2.5
10.0
14.5

FY 8.1
2.5
6.0
19.5
28.0
84
FY 82
2.5
5.5
19.5
27.5

FY 83
2.5
5.5
19.5
27.5

FY 84
2.5
5.5
20.0
28.0


-------
The Table above projects  a  program growth from FY 79 to  FY  84  of  134% in rural
nonpoint source programs.   A growth of 91% is projected  from FY  80 to FY 84.
The percentage for administration of implementation programs in  FY 84 in rural
nonpoint source programs  is projected by WQM Agencies as:

                                      FY 84

                    Agriculture    -    63% administration

                    Silviculture   -    78% administration

                    Noncoal  Mining -    53% administration
                                       Figure V-6
                       Shift in Priority of Rural Nonpoint Source Control

                                          FY80
       Non-Coal
        Mining
         2%
                                         85

-------
                                        Part 2

                                      AGRICULTURE
Conclusions
          WQM Agencies have projected  their greatest  resource  needs  for nonpoint
          sources in agriculture.  WQM Agencies  project  the  need  to  double the
          size of their 1980 agriculture  programs.

          The majority of WQM Agencies are projecting  nonregulatory  programs.
          EPA projects a more limited  role  for WQM  than  the  WQM  Agencies
          projected in agricultural NPS pollution control.
Background

For the purposes of this Assessment, agriculture  is  defined  as  runoff and
seepage from agricultural activities which  cause  surface  and ground water
pollution.  Agricultural activities are  the most  widespread  cause  of nonpoint
source pollution problems, affecting over two-thirds  of the  river  basins  in
the country.  The regions most affected  by  agricultural nonpoint source
pollution are the North Central, South Central, Southwest and Island regions.
Agricultural pollution can come from runoff,  ground  water percolation or
irrigation return flows.

Agriculture contributes over  half of the total man-made sediment load which
often carries with it other water pollutants,  such as animal  wastes, chemical
fertilizers, insecticides, and herbicides.  In some  irrigated areas, salt
contamination has reduced crop yields on 25%  of the  land  and degraded surface
and ground water quality.  Nitrate contamination  of  ground water in irrigated
areas has also been documented in many parts  of the  country.
                                       Figure V-7
                    Basins Affected* by Pollution from Agricultural Activities
       * In whole or in part


       Note: Affected basins are shaded
                                          86

-------
Good farm management works toward maintaining soil  productivity of the land.
Agricultural  BMPs, such as conservation tillage,  crop rotation, terracing,
integrated pest management, nutrient management,  and reduced water use help
protect water quality.  EPA is working in concert with the USDA to select,
fund, and manage projects to assist farmers in implementing BMPs where problems
are identified through 208 WQM plans.

EPA is involved with several cooperative efforts  with USDA regarding agricultural
nonpoint source control.  BMPs for agriculture may need some further investigation,
but the basic need is for technical and financial assistance to ensure their
implementation.

EPA with USDA has initiated a Model Implementation Program (MIP) in seven
agricultural  areas to evaluate BMPs, determine farmer attitudes, and document
costs.  In addition, 22 Agricultural Conservation Program (ACP) special  water
quality studies are underway.  EPA is also participating in the Experimental
Rural Clean Water Program (RCWP) which provides cost-share funds to farmers
for implementing certain BMPs consistently with WQM plans.  These BMPs must be
concurred on by EPA as essential for abatement of agricultural water pollution.


EPA has outlined its future strategy (obtainable  from the Water Planning
Division, EPA) for the control of nonpoint source pollution from agricultural
lands.  The following activities are EPA priorities:

     1)   The development of State plans for agriculture (this includes
          identification and prioritization of critical problem areas; selection
          of appropriate BMPs; designation of management agencies; and development
          of operational programs).  Many States  already have certified  and
          approved agricultural elements of their WQM plans.

     2)   Monitoring and evaluation (M&E) (this includes determination of
          cause-effect relationships between activities, pollutants and  impact
          on water quality; evaluation of BMP effectiveness; and determination
          of the degree of control necessary to meet standards).

     3)   Implementation of control programs (this includes State initiatives
          in securing implementation of BMPs by farmers, i.e., incentives,
          regulations, education, etc.).


WQM Agency Projections

WQM Agencies in 48 States projected needs for agricultural nonpoint source
pollution.  For FY 81-84, WQM Agencies anticipate a total  need of $78.5  million
to identify problems and develop and administer programs.   Table V-4 gives the
total dollar and staff year needs for agriculture.


TableV-4:  Total WQM Projected Agricultural Needs, FY 1979-84 ($000,000)

                         FY 79    FY 80    FY 81     FY 82     FY 83    FY 84

Total Funding Needs       9.0      10.0     19.5      19.5      19.5     20.0

Total Staff Years        160       235     462      483      474      509
                                        87

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The WQM Agency needs double from FY 80 and then level off in the following
years.  This increase coincides with the initiation of RCWP projects.  From
FY 80-84, Agriculture constitutes an increasingly larger share of the program.
(see Figure V-2 and 6).   2 State programs increase from FY 80 to 84, 14
decrease and 3 remain the same.  Of those that increase, 19 increase by more
than 100%.  For FY 84, the size of the programs range from $5,500 to $5 million,
The average program is $319,000 and 11 staff years.  As program administration
becomes a larger share of the program, staff increases particularly to provide
technical assistance.

The projected needs for each activity category (i.e., problem assessment
program  development, and program administration) are shown in Figure V-7.
Both  problem assessment and program development needs peak in FY 81 and
then  decline slowly.  Administration  needs, however, increase sharply
from  FY 80  to FY 81 and continue to rise in the following years.  In
FY 80, the  major activity in State programs is problem assessment.  By
FY 84, the  major WQM activity will be administration of implementation
programs, composing 63% of program activities.  Most States are already
involved  in administering implementation programs.   21 States indicate
implementation needs in 1979,  13 more in FY 80; 6  in FY 81; and 2 in
subsequent  years.
Most  States expect  to have nonregulatory agriculture programs.  Many of these
States mentioned the intent or  interest  in developing incentive programs.  4
States identified programs with  regulatory and nonregulatory elements.  3
States project regulatory programs.   In  describing their projected  programs,
States mentioned the following  activities  (in order  from most to least cited):

          Technical assistance,  public education

          Assessment, monitoring and  evaluation

          RCWP involvement

          Implementation of  BMPs

          Overall  coordination,  oversight  of  agriculture  program

           Identification of  appropriate  BMPs
                                         88

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                                     Figure V-8
                   Total Agricultural Control Needs by Activity Category
  12


  11


  10


   9
c
g

1  6
c

<*  5


   4


   3


   2


   1


   0
   FY
                                              Program Administration
                                              Problem Assessment
                                              Program Development
     79
FY80
                                   FY81
FY82
                                                FY83
FY 84
Analysis

States and EPA share the similar  priorities,  as  reflected in the similarity
between States' projected activities  and  the  EPA agriculture strategy; however,
the 106/208 program needs which States  have projected  are higher than EPA
estimates.
Several reasons exist for why  the
needs in agriculture:
                    Agencies projected more substantial HQM
     1)   WQM Agencies may project  a  larger  role  for WQM in their
          agricultural program  than EPA which  is  placing reliance more on
          other program assistance  (e.g.,  USDA).

     2)   States projected development and ongoing  maintenance of an agricultural
          program geared to protection of  water quality.  Needs did not have a
          more limited project  focus  which EPA strategy  addresses.

     3)   WQM-eligible activities are major  elements of  their future programs.
          Nonregulatory, cost-sharing, BMP-implementation programs appear to
          be the direction in which agriculture programs are moving.  These
          programs will require such  WQM activities as technical  assistance,
          public education, problem assessment, and program oversight, and
          evaluation.

     4)   Nonregulatory programs are  usually not  as self-supporting, as
          regulatory permit programs.  Consequently, they require greater
          support at either the State or Federal  level.
                                         89

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     5)   Since many actors are involved at all levels, a State-level program
          is probably necessary to coordinate, manage, and evaluate the various
          efforts.

     6)   Increasing food supply and other demands will increase pressure for
          greater production, which may also increase the potential for pollution-
          causing activity on agricultural lands.

     7)   Agriculture is widely recognized by States as a major nonpoint
          source pollution problem area and has recently received national
          emphasis and impetus through the WQM strategy, MIP, and RCWP, and
          the Resource Conservation Act under USDA.

Though the needs for control of nonpoint source pollution from agriculture
will undoubtedly be high over the next 5 years, EPA foresees a more limited
WQM role than the WQM Agencies are projecting.  EPA plans to use the USDA
programs for much of the local technical assistance and public education
through RCWP, MIP, and ACP.  Under 208, EPA will supplement those efforts for
monitoring and evaluation.  EPA has promoted the concept that WQM Agencies
should support their ongoing agriculture program, allowing Federal money to be
available for special demonstration projects in critical problem areas.
However, the WQM Agencies are not projecting WQM needs for project support but
for program support.


An EPA study of resources needed (man years and dollars ) to make State
programs operational  and self sustaining will  be completed shortly.  The
impact of this study on WQM Agencies projections should be examined at that
time.   From a National  perspective, EPA emphasizes for WQM:   assessment;
overall coordination and oversight of the agricultural  program; and the
provision of technical  assistance, BMP identification and implementation,
monitoring and evaluation and WQM participation in prioritizing and imple-
menting special projects to address specific water quality problems.   EPA has
also supported the reauthorization of Section  208(j) and the experimental RCWP
to provide more implementation funds for prioritized projects and is  investi-
gating alternative Federal  financing methods (e.g., special  201 grants) to
solve identified agricultural  problems.
                                         go

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                                  Part 3

                               SILVICULTURE
Conclusions
          WQM Agencies project the need to double the WQM silviculture
          program by FY 84.  WQM Agencies believe a substantial  increase
          in resources will be necessary for administration of implementation
          programs, and project 78% of their 1984 silviculture program
          to be allocated to such administration.
     •    A nonregulatory approach will be taken by 75% of the
          Agencies, though many WQM Agencies plan to evaluate and revise
          their programs, if this type of control is found to be ineffective,

     «    Though problem assessment and program development needs decrease
          after 1981, WQM Agencies foresee a continued need for these
          activities.

     •    The WQM Agencies and EPA project similar future program emphases:
          administration of BMP implementation programs, training and
          technical assistance, problem assessment, and program evaluation.


Background

Silvicultural activities, such as timber harvesting, can cause water
quality problems.   The primary problem, sedimentation, results from land
erosion.  Other contaminants associated with silviculture are inorganic
matter, nutrients, introduced chemicals, and high stream temperatures.
Though Silvicultural activities are not widespread contributors to
nonpoint source pollution, they can be locally significant.  There is a
clear need to maintain high-quality waters in forested regions, especially
since these watersheds are use for spawning and are the source for many
of our municipal water supplies.  (See  Figure V-9).

The WQM Agenices regulate Silvicultural activities through regulatory or
nonregulatory programs.   Both programs promote the implementation of (1)
Best Management Practices (BMPs)  to decrease or arrest sediment loading
in ongoing activities and (2) mitigative measures to correct existing
problems.   Both programs usually include problem identification and
assessment activities and BMP identification and testing.

The more developed regulatory programs are found along the West Coast
and were established through the  passage of Forest Practice Acts.  Other
regulatory programs manage forest activities through sediment control
laws, as in Pennsylvania and Maryland, or harvest permit requirements,
as in New Hampshire.  These programs usually include such activities as
the review of harvest plans, administration of permits, compliance
evaluation, and enforcement.
                                     91

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                                       Figure V-9
                               Basins Affected* by Pollution
                                from Silvicultural Activities
* In whole or in part

Note: Affected basins are shaded


Most WQM Agency programs are nonregulatory  and  range  from  the general  guide-
line programs found in Wyoming and  Illinois to  extensive educational  programs
with detailed BMP recommendations found  in  Florida, Georgia,  and Alabama.
These programs include such activities as the establishment of institutional
arrangements, technical assistance  to loggers,  operators and  landowners,
incentives, public education, and training  courses.

WQM policy has been to use the existing  delivery  systems and  technical expertise
of the Forest Service (FS) and State agencies to  implement its silvicultural
water quality program.  The Forest  Service  and  EPA  first entered into a Coopera-
tive Agreement in 1976 and recently reemphasized  this cooperation through  a
Statement of Intent signed February 1979.   The  EPA/FS agreement emphasizes a
coordinated planning process for the State  water  quality and  forestry plans,
the development of a national training package  on water quality management
principles and the implementation and evaluation  of BMPs through existing
Federal, State or local programs.


WQM Agency Projections

WQM Agencies in 36 States  reported  needs in silviculture nonpoint source
control programs. This is  a 5 State increase over the 31 receiving funds in
FY 79-80.  21 States see their program needs increasing over the next 5 years,
11 decreasing and 3 staying the same.  Of those 21  which increase, 8 increase
by more than 100%.

The WQM Agencies  needs for each fiscal year appear  in Table V-5.

                                          92

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Table V-5:  Total WQM Projected Silvicultural Needs, FY 1979-84 ($000,000)

                         FY 79    FY 80    FY 81    FY 82    FY 83    FY 84

Total Funding Needs       2.0      2.5      6.0      5.5      5.5      5.5

Total Staff Years        51       67      132      128      127      120
The projected program doubles in size over the five-year period from FY 80 to
84.  In FY 80, the average silviculture program statewide cost $76,000 or
supported approximately 2 staff people.  In FY 84, it is projected to cost
$150,000 and support approximately 4 staff.  The program predicted for FY 84
will be 78% program administration, 17% problem assessment, and 5% program
development (Figure V-lu).All but 4 States with programs reported implementation
occurring by FY 81.  21 States are currently implementing all  or part of their
programs, and 11 more will begin implementation in FY 81.  Most WQM Agencies
predict that as their programs phase from planning to implementation, some
needs will continue for problem assessment and program development in order to
evaluate and improve their program effectiveness.

26 States projected nonregulatory programs and 10  regulatory.   Most predicted
continuing this type of control, but planned to evaluate and revise their
programs if it proved necessary.  The regulatory programs occur in the Northeast
and the West Coast.


The WQM Agencies reported needs for the following  activities (in order
from the most to the least frequently cited need):

          Problem  identification and assessment

          BMP implementation and evaluation

          Training and technical assistance

          Pub!ic education

          Coordination with State and Federal forestry program

          Evaluation of implementation programs

          Regulatory activities, such as compliance monitoring, enforcement,
          and permit administration.
                                        93

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                                      Figure V-10
                              Total Silvicultural Control Needs
                                    by Activity Category
6


5


4


3


2


1


0
FY79
                    FY80
                                FY81
FY82
                                                                   FY 83
                                                                                  FY84
 Analysis

 The greatest need expressed by the WQM Agencies is funding for nonregulatory
 programs to identify and assess problems, administer implementation programs,
 and evaluate BMPs and train and assist loggers, operators, and landowners.
 The EPA WQM Strategy emphasizes these same program elements and includes the
 additional  objective of further integration of water quality and forestry
 management programs.  The WQM strategy for 208 has a project-orientation which
 promotes the development of these program elements through prototype projects.
 The projects'  findings are then transferred to the WQM Agencies with similar
 problems.

The WQM Agencies' projections do not appear to incorporate this project
orientation.  Their needs are based upon:  building the technical and insti-
tutional capabilities for managing and administering a control program.  Since
the EPA project orientation is very recent in silviculture (two projects have
just submitted workplans and had funding approved), the impact of this strategy
on WQM Agency needs have yet to be determined.  EPA believes that the impact
will be less than in other problem areas because the technological/institu-
tional base and the prioritity areas for pollution control are relatively well
known in silviculture.  The problems which lie ahead for WQM Agencies are:
implementing the control programs, evaluating those controls, and improving
their control capability.

EPA statistically analyzed the WQM Agencies' projected needs, in order to
evaluate their validity.  This was done by comparing VJQM Agency needs in
FY 84.  The cost of the projected statewide program was divided by the number
of acres of land with silvicultural activity for each State.  EPA found the
WQM Agencies' data statewide to be consistent with other States.  They cluster
within an order of magnitude, spending from .3 to 3 cents per acre per program.
Out of 36 States, 27 fall within this range, 3 fall below and 6 above.  Of
those 9 States, all but 4 explain the discrepancy:

     1)   One State with a well-developed regulatory program included in its
          cost projection the entire cost of administering its permit program.
          Though this is an eligible need under 106, most of the States with
          regulatory programs did not choose to include it in their projections,
          So, this State's needs are Higher than the other States' needs.
                                           94

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     2)   A State which projected a minimal program came out above the maximum.
          It has few areas with silvicultural activity, so its cost/acre was
          higher.  However, its projected cost is the minimum required to
          adequately administer a control program.

     3)   2 States above the maximum gave detailed documentation for their
          projections.  Their programs are more ambitious and comprehensive
          than the norm and therefore, more costly.

     4)   A State over the maximum included in its calculations all lab and
          field monitoring personnel.  This was contrary to directions, and so
          placed its needs higher than those of other States.
On the basis of the information supplied to EPA, it is felt that one State
overestimated its needs and 3 States underestimated their needs.
                                        95

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                                      Part 4

                                  MONCOAL MINING
Conclusions
          Noncoal mining remains a low K'QM priority for most WQM Agencies  and
          a high priority for a few.
              Agencies project a noncoal  program for FY 84 which  will  cost 42%
          more than the FY 80 program.

     •    Hhile needs for administration of implementation programs  increase,
          they do not become as dominant an activity as'they do in other NPS
          problem areas.


Background

Runoff or drainage from active or inactive mining sites can result in  pollution
of surface and ground water.  Sedimentation, heavy metals, and acid  and alkaline
mine drainage are the most serious and  common forms of water pollution associated
with mining.

Mineral commodities extracted and processed in the States include mineral
fuels, such as uranium; metallic minerals, such as iron,  copper,  lead, or
zinc; and nonmetallic minerals, such as sand and gravel,  clay and quarried
stones.  Recent statistics published by the U.S. Bureau of Mines  show  21,000
currently active mines, of which 15,200 are noncoal.

Consistent and detailed water quality information in relation to  mining is not
available nationally.  One reason for this is the diversity of mineral industrial
operations and the large number of different pollutants associated with mining.
For example, in Colorado 32 mineral commodities, which would be expected to
generate at a minimum 13 water pollutants, are related to the State's  mining
industry.

Water quality problems may also be created by inactive or abandoned  mines.  In
a national assessment of the problem, EPA found over 1,200 kilometers  of
streams and rivers adversely affected by past noncoal mining.  The metal
mining industry contributes most to this pollution, the principal metals being
gold, copper, silver, lead, zinc, and mercury.  On a statewide basis,  pollution
from inactive mines is usually not assigned a high priority; however,  on a
localized basis, it can be a severe problem.  80% of the water pollution from
inactive noncoal mines occurs in 4 areas:  California, Idaho-Montana,  Colorado,
and Missouri.

With the enactment of the Surface Mining Control and Reclamation  Act of 1977,
a comprehensive program to deal with the adverse environmental effects from
abandoned, active, and future coal mines was established.  Since  then, EPA has
focussed its attention on the control of nonpoint source pollution associated
with noncoal mining.
                                         96

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States can regulate active mining through various mechanisms.  For instance,
through Section 304(e) of the Act, the NPDES program can regulate mining
activities which generate toxic or hazardous nonpoint source pollution.  The
permits may require procedural or minor-construction BMPs.  States may also
have a separate regulatory program for mining.  For example, Pennsylvania
administers a comprehensive program with runoff control  regulations oriented
toward eliminating all uncontrolled drainage from mine sites and associated
areas.

Pollution from abandoned mines is usually controlled through reclamation
programs designed to abate surface and ground water pollution and perform
other restoration work.  However, implementation of such programs is often
stagnated by lack of funding for restoration work; different ownership of
surface and mineral rights causing questions of responsibility; inadequate
abatement technology; chances of claims being revived; and cost-effectiveness
of programs.

The WQM program has funded problem identification, regulation development, and
evaluation and improvement of existing programs related to noncoal mining.  It
has a low funding priority, but where water quality impacts are severe, problems
known, and solutions feasible, the current WQM policy is to finance development
of solutions.


WQM Agency Projections

WQM Agencies in 30 States requested needs in noncoal control programs.  22
used WQM funding in FY 79-80.  The total needs in dollars and staff years for
each fiscal year appear in Table V-6 .

Table V-6 :  Total HQM State Projected Noncoal Mining Needs, FY 1979-84 ($000,000)
Total Funding Heeds
Total Staff Years)
FY
1.
20
79
0
FY
2.
45
80
0
FY 81
2.5
61
FY
2
66
82
.5
FY
2.
65
83
5
FY
2.
64
84
5
The total dollar needs increase by 42% from FY 80 to 84 and staff needs by
30%.  19 States projected their needs increasing between FY 80 and 84, and 16
of those States project their needs increasing by over 100%.  6 States expect
decreasing needs, and 5 State programs remain the same.

As the WQM Agencies approach FY 84, emphasis shifts from planning into
administration.  The years in which States begin implementation activities
range from FY 79 to 84.  8 States indicate implementation occurring in FY 79
and 5 in FY 80.  4 States project initial  implementation needs in FY 81,  4 in
FY 82, 2 in FY 83, and 2 in FY 84.  Implementation increases from 14% of  the
States'  programs in FY 80 to 53% in FY 84  (See Figure V-ll). Problem assessment
decreases from 67% in FY 80 to 31% in FY 84, while program development remains
fairly constant.
                                         97

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The WQM Agencies described more HQM  needs  in  controlling  pollution  from
inactive or abandoned mining  sites than  active  sites.   In 21  States WQM
Agencies indicated the following needs for control  of  inactive  or abandoned
mining sites (from most to least mentioned):

          BMP implementation/reclamation activities

          Problem identification

          BMP development

          Prioritization of sites

In 10 States WQM Agenices indicated  the  following  needs  for the control of
active mining:

          Problem identification

          Institutional arrangements

          Administration of permit programs

          BMP implementation
                                      Figure V-11
                              Total Non-Coal Mining Needs
                                  by Activity Category
   0
   FY79
FY80
                                  FY 81             FY 82

                                         98
FY83
FY84

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Analysis

The range of needs requested by WQM Agencies statewide varied widely for
noncoal, from $3,000 annually to $609,000 annually.  It appears as though
mining is a low WQM priority in most States, and a high priority for a few.
Some States with identified severe problems are not requesting 106/208 dollars.
Support for their pollution control for noncoal mining may come from other
sources such as the Rural Abandoned Mines Program and the Surface Mining Act
or they may not be addressing the problem.  The role of WQM and its relation-
ship to other funding sources for pollution abatement should be further
examined.

EPA statistically analyzed projected needs in States.  UQM Agency needs
statewide were compared to each other for the year FY 84.  Using the variable
of acres utilized for noncoal mining between 1930 and 1971 by statewide data
was found to be consistent.  Out of 30 States, 25 fell within a range of
magnitude, i.e., projected between $.38 and $3.80 per acre of mined land for
a control program.   Of the other 5, 2 fell below the minimum and 3 above the
maximum.  One State above the maximum provided adequate explanation of its
needs, which includes administering both an abandoned mines program and an
active mines program,  "lot enough information is provided to explain the other
4 States' projections.
                                        99

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    Section C



      URBAN





Part 1  - Overview



Part 2  - Urban Runoff



Part 3  - Construction Runoff
       100

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                               URBAN NONPOINT SOURCES

                                      Part 1

                                     Overview
This Section covers projections for the following problem areas:  urban
runoff and construction runoff.  Both of these nonpoint source problems are
experienced primarily in urbanizing areas and therefore are covered jointly.
Projections in this area were the most difficult to interpret because of the
marked decline in urban runoff needs projected.   EPA believes that this
indicates uncertainty about the program after the National prototype projects
are completed, rather than an actual anticipated decline in priority.  Meeds
in this area should be reexamined as prototype projects are completed.
 Table V-7:   Total WQM Agency projected Urban Nonpoint source Needs, FY 79-84

              ($000,000)          FY79    FY80    FY81    FY82    FY83    FY84
Urban Runoff
Construction Runoff
7.
2.
5
0
17.
2.
0
5
19.
6.
5
5
15.
6.
5
5
13
6
.0
.0
11.0
7.5
 TOTAL
9.5
19.5
26.0
22.0
19.0
18.5
 Figure V-13  illustrates the  shifts  in  priority  urban  program  areas  undergone
 over the duration of the Assessment.   In  FY  80, these areas constituted  36« of
 the nonpoint source programs  in WQM.   By  FY  84, projections account  for  25% of
 the total nonpoint source needs.  As urban runoff prototype projects  are
 completed, needs for problem  assessment drop rapidly  and  and  program  adminis-
 tration becomes a much more  significant part of the program.  Administration
 was allocated 8% of the resources in FY 79;  by  FY 84, it  is 1/2  of  the urban
 program.  Thus as in other nonpoint source areas, needs peak  before  FY 84  as
 the focus shifts from planning for WQM to less  resource intensive program
 administration.  The decline  in the later years of the Assessment represents a
 shift in the type of activity, rather  than a decline  in activity.
                                         101

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                                              Figure V-12
                                   Total Urban Source Control Needs
                                          by Activity Category
  18
  15
                                                         Problem Assessment
   12
V)
c
g
=  9

c

   6
              Program Development
                                     Program Administration
   0
  FY79
                      FY80
                                          FY81
                                                              FY82
                                                                                 FY83
FY84
                                              Figure V-13
                                Shift in Priority of Urban  Source Control
                       FY79
                                                                            FY80
            Non-Coal
             Mining
              2%
                                                                                           Construction
                                                                                               4%
                        FY81
                                   Residuals
                                     4%
Non-Coal
 Mining
  3%
                                                      Non-Coal
                                                       Mining
                                                   102

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                                        Part 2

                                    URBAN RUNOFF
Conclusions
     •    There is confusion about the extent of urban runoff problems and
          control  needs.

     0    This confirms the need for the National Urban Runoff Program prototype
          projects under the WQM Strategy.  As those projects are completed,
          EPA and States should reassess needs and program direction.

     •    State projected needs to combat urban runoff pollution show continuing
          decreases through FY 84.  However, costs for administration of
          implementation programs continue to grow thru FY 84 and projections
          demonstrate a shift for WQM from planning to administration.


Background

Pollution from urban runoff is much more serious than previously realized.
The problem is more concentrated in the highly metropolitan Northeast region
than the rest of the country.  It is a primary cause of water quality degrad-
ation in populated areas.   Nationwide, it is estimated that over 50% of the
river basins are affected by urban runoff.

Rainfall runoff in urbanized areas flush out large quantities of pollutants
that eventually reach receiving waters.  There are-many pollutants involved
that may cause degradation of surface and qroundwater quality.  Some of these
include:  silt; organic debris; heavy metals, such as lead; grease and oil; and
pesticides, such as Toxaphene and Servin.  As point source controls on industrial
and municipal dischargers take effect, urban runoff, if uncontrolled, increases
because of the growth of urban areas.

States and local  governments address urban storm water under Sections 208(b)(2)(c)
and 201(c), which require programs to control all point and nonpoint sources
of pollution to the extent feasible.  Costs for treatment of urban storm water
can be extremely high, so pollution control efforts focus on less costly
nonstructural controls, such as street sweeping, catch-basin cleaning, runoff
detention basins,  and erosion control.  The preventive approach to stormwater
pollution is an indirect one.  The more direct approach would be to capture
the sewer discharge through interceptors and then to treat the effluent at a
plant designed for thjs purpose.   This approach can be costly.

A number of uncertainties hamper the development of effective control programs.
Not enough is known about:   (1) the sources of pollutants; (2) transport mech-
anisms from these  sources to receiving waters; (3) the cost and effectiveness
of control measures; (4) the relative impact of urban storm water on water
quality, as opposed to other pollution problems; and (5) the relative costs
and benefits of urban runoff pollution control.   In the National  Urban Runoff
Program, EPA is funding planning  agencies to fill these information gaps and
resolve uncertainties over the scope and impact of the problem.
                                        103

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    Agency Projections

WQM Agency projections  are  indicated  in  the  following  table:

TableV-8:  Total WQM Agency Projected Needs  for Urban  Runoff, FY 79-84 ($000,000)
                               FY79      FY80     1981      FY82     FY83     FY84
Total [leeds

Number of States
  providing costs
             7.5     17.0     19.5      15.5      13.0      11.0
            37
39
44
45
41
41
The highest year for  Problem  Assessment  needs  is  FY80.   The highest year for
orogram development is  FY82.   Administration of implementation programs
continues to grow  in  need  through  FY84,  demonstrating  a  shift in NQM needs
from planning to administration  (see  Figure V-14).  However, the shift is more
gradual than for other  nonpoint  sources  in  that problem  assessment continues
to be a large program element.   Costs  may be somewhat  overstated.  In problem
assessment, activities  identified  by  the WQM Agencies  frequently included
water quality assessments  and stream  surveys to determine water quality
impacts and define areas for  further  study.  Data and  methodologies developed
through the National  Urban Runoff  program should  result  in cost savings for
planning in these  areas.

The costs for administering urban  storm  water  programs will be borne primarily
by local governments, whose administrative  costs  are generally not covered in
this Assessment.   Although in some instances,  administration costs appear to
include local government activities.   Adequate means to  ensure the continuation
of the controls must  be provided,  otherwise the controls may become ineffective
or even exacerbate runoff  pollution.
                                       Figure V-14
                        Total Urban Runoff Needs by Activity Category
   14

   13

   12

   11

   10

   9

   8

   7

   6

   5

   4

   3

   2

   1

   0

   FY79
                                     Problem Assessment
                         Program Development
FY80
                FY 81
           FY82
          Program Administration



                   I

                 FY83
                                                               FY84
                                          104

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Analysis

Planning needs drop dramatically between FY 81  and 82, indicating uncertainty
over the program after prototype and other special projects.  It is not
sufficient that planning activities cease with  the initiation of a preferred
storm water management program (see Figure V-13).

Urban runoff's percentage of the total need steadily decreases over the period
of the assessment.   This is not typical of nonpoint source programs.   Further
examination of urban runoff needs, particularly as prototype projects are
completed, is desirable to confirm or elaborate on these needs.   Projections
and the program instability indicates that there is probably confusion or
uncertainty about the extent of the problem and the future and feasibility of
urban runoff control.  It is precisely for these and other reasons that the
National Urban Runoff Program was instituted.   More will  be known as  those
projects are completed.
                                        105

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                                       Part 3

                               CONSTRUCTION RUNOFF
Conclusions
     •    Construction runoff programs are currently inadequate.   Further
          action is needed to institute the necessary programs.   Projections
          support continued development of those programs into FY 84.   The
          most effective construction runoff programs appear to  be regulatory.


Background

Construction runoff includes all forms of water pollution caused  by sediment
originating at construction sites, and other water contaminants  transported
along with sediment.  Construction runoff causes substantial water quality
problems.  About 5% of the tons of sediment reaching U.S. waterways each year
are from land undergoing highway construction or land development.  Although
runoff from construction sites constitutes a small percentage of  the total
national sediment load, its impact on the environment is increased by  its high
concentration in urban watersheds with increasing populations.  Construction
can also increase the existing rate of sediment runoff and represents  over
half of the sediment load carried by streams draining small  watersheds under
development.

Figure V-15 shows a ranking of States in order of problem severity.  Each
State's  priority rating is a product of the State's sediment yield/mi^, as
reported by the Soil Conservation Service  (SCS), and the Construction Activity
Indicator  (CAI), and a weighted combination of indices of single and multiunit
housing  starts, other private investment in constuction and public (govern-
ment) investments in construction.  As Figure V-17 indicates, priority States
are concentrated East of the Mississippi and in the Panhandle.

Regulatory programs to control  construction runoff have been gradually increasing
in number in the U.S.  since 1967, when Montgomery County, Maryland instituted
the first mandatory control program.  Since then, over 40 States, Territories,
and numerous local  jurisdictions have instituted programs.  Early State
programs predated the CWA, and were funded largely from State and local revenues
and permit fees which helped cover the cost of local  regulatory  programs.

The most effective construction runoff control  programs are regulatory as
opposed to voluntary.   The main reason for this is that land development is
generally a transitory phenomenon.  The developer usually sells  the land soon
after it is developed.  This leaves the developer with little incentive to
consider the long term impacts of construction practices on the  soil or on the
area.  Construction is also more amenable to regulatory action than other
nonpoint pollution sources.  Its geographic concentration makes  inspection and
enforcement less difficult than for problems like agriculture or silviculture.
                                        106

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                                        Figure V-15
                  Priority Ranking for Severity of Construction Runoff Problems
      *. Washington, D.C
      2. New Jersey
      3. Louisiana
      4 Maryland
      5. Indiana
      6. Tennessee
      7. Mississippi
      8. Texas
      9. Alabama
      10 Oklahoma
      11. Kentucky
      12 Ohio
      13. Virginia
      14. Illinois
      15. California
      16. North Carolina
17  Iowa
18. Arkansas
19  Missouri
20. Connecticut
21. Rhode Island
22  Colorado
23  Florida
24. South Carolina
25. Massachusetts
26. Georgia
27. New York
28. Delaware
29. Pennsylvania
30. West Virginia
31. Michigan
32  Washington
33. Utah
34. New Mexico
35. New Hampshire
36. Wisconsin
37. Arizona
38. Oregon
39. Minnesota
40 Vermont
41. Idaho
42 Nebraska
43. South Dakota
44. Kansas
45. Montana
46 Wyoming
47 Maine
48. North Dakota
     "Unranked: Alaska, Hawaii, Nevada
Typically, a regulatory program involves  close cooperation of officials at
State  and local  levels of government, along  with private developers.   In all
State  programs,  the localities  are either empowered or  required  to  run local
programs.   The State directly  regulates private industry onlv where there is
no  local  program.   Oversight over local programs, and technical  advice to
local  officials  are responsibilities of either a state  water quality  manage-
ment agency or the  State soil  conservation districts.   Typically, regulation
and erosion control  for State,  Federal, and  local government construction act-
ivities  is also  the responsibility of the State water quality management
agency.   Sometimes  the State K/QM agency will  delegate authority  for regulating
Federal  agency's  projects to that agency.
With  the exception  of funding  under Section  208, the  Federal role  has been
largely advisory.   EPA has worked closely  with States  and conservation dis-
tricts  to provide guidance in  all phases of  program development, from problem
identification through BMP development and the drafting  of regulatory legis-
lation, to the development of  an implementation structure for the  program.
                                            107

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Although Federal money has not historically  played  a  crucial  role  in  supporting
these programs, there are two factors  that indicate need  for  a  continued
Federal support:

     (A)  Geographical Coverage - The  construction  runoff problem  is  present
          in all 50 States and the  District  of  Columbia and has been  noted
          as a priority problem nationally.   40 States and Territories  cur-
          rently have programs to deal with  the problem.   Only  10  States have a
          well established implementation program.  Some  States with  severe
          problems have no regulatory  programs.

     (B)  Program Deficiencies - Evidence in  a  National Association of
          Conservation Districts study of 6  State programs, among  other
          studies, has indicated that  the effectiveness of State programs has
          been limited by a  lack of  inspectors.  When combined  with the lack
          of adequate State  programs,  this would seem to  indicate  that  availa-
          bility of financial resources  is a  major  limiting factor in reducing
          construction runoff.
WQM Agency Projections

Tablev-9; Total HQM Projected Needs for  Construction  Runoff  Control,  FY  79-84
Total State Needs
  ($000,000)
                         FY  79
         2.0
                 FY 80
  2.5
          FY 81
6.5
        FY 82
6.5
        FY 83
6.0
        FY 84
7.5
Figure V-16shows decreases  in  the  HQM  costs  for  Problem  Assessment and Program
Management through FY 84.  Cost for administering  implementation  programs
increases through FY 84.   This  indicates  that with  sustained funding, States
can shift from the planning stage to  implementation of  solutions.
                                     Figure V-16
                         Total Construction Runoff Control Needs
                                 by Activity Category
                                                                   Program Administration
  0
  FY 79
FY80
FY 81             FY 82

        108
                                                FY 83
                                                                FY84

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Construction runoff is unique among nonpoint source control  needs  in  that  it
is the only area to consistently project an increasing larger  portion  of the
total needs (Figure  V-2). This may indicate the problem  is  particularly
underfunded at the present in relationship to the control  needs.
Analysis

EPA estimates needs to be higher than State projections.  However,  the  State
projections represent substantial progress in what  is perceived  by  States  and
EPA as an area with inadequate control.

Although  all  States have  construction  runoff  problems,  there are some States
which  consider  the  problem  to  be  too  small or geographically isolated to
warrant regulation. States  have  been  slow in  developing construction runoff
programs,  but are making  incremental  progress and  recognize the  need.

In order  of  priority, EPA estimates 32  priority States  need programs (Figure  V-17)
Those States  projecting needs forecast a  slower  rate of  development  than EPA
believes desirable and feasible.  Estimating  costs  based on  select  States  with
adequate programs and phasing in program  development and administration  for
the priority  32 States over the period of the Assessment, EPA  estimates  the
following needs.

Table V-1C:EPA Estimated Total Construction Runoff  Control  Needs, FY  81-84
Total State Needs
  ($000,000)
                                         FY 81
6.0
          FY 82
6.0
        FY 83
5.5
        FY 84
12.0
The fluctuations in estimates is due to the phased development of  programs  and
the increased focus by FY 84 on implementation.
                                      Figure V-17
                        Priority States for Construction Runoff Control
                                         109

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         Section D



       GROUND WATER






Part 1  - Overview



Part 2  - Onlot Disposal



Part 3  - Residuals



Part 4  - Ground Water Management
            110

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                                     GROUND WATER

                                       Overview
Conclusions
     •     States  are continuing the priority established  for  ground  water in
           the  WQM strategy.   Ground water programs comprise about  one  third of
           the  NPS program by FY 84.  States indicate a relatively  stable
           priority for the program from FY 81-84.

     •     Projections confirm the need to further develop State  capability
           to administer ground water programs.   States project an  increase
           in needs peaking in FY 83.  However,  further progress  is needed
           beyond  that projected.

     0     Projections support continuing the emphasis and direction  taken for
           ground  water in the WQM strategy.  States indicate  the need  to fill
           planning gaps is most apparent in the next several years.  As  States
           move towards FY 84, increased emphasis is given to  implementing
           these planning  outputs.   Program administration comprises  the  major
           portion of the  ground water program by FY 84.  As this shift occurs,
           costs to the ilQM program in ground water decrease.

Background

Preservation of ground water quality is a growing national concern.  Approxi-
mately 48% of  the population depends on ground  water for drinking water.
                                      Figure V-18
                        Nationwide Dependence on Groundwater for
                             Public and Private Drinking Water
      Hawaii
       "(Note Data for Arizona is not available)
                                                 Legend
                                                 |  | 0-24%

                                                 |§il 26-50%

                                                 ^| 51-75%

                                                 ^H 76-100%
                                         111

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In 18 States, at least 50% of the population uses ground water basins  which
are contaminated.  10 States have 50% or more of their basins  contaminated.
19 States have 25-50% of basins contaminated.  Ground water furnishes  80% of
the water used in rural areas for domestic and stock-watering  uses.   Excluding
water used to generate hydroelectric power, approximately 20%  of the water
used by the nation is ground water.

The nation is becoming more dependent upon ground water.  Ground water use is
increasing at twice the rate of total water use.  Generally, ground  water is
of good quality; however, it is easily contaminated,  and, because of its  slow
recharge rate, is extremely difficult to clean up.  Therefore, it is critical
that ground water that is now high quality be protected from contamination.
EPA, the States, and local government are becoming increasingly aware  of
pollution problems.   Because of the importance of the resource, its  vulner-
ability, our national dependence on it, and the severity of contamination,
States and EPA (in the V'QM Strategy) are placing a high priority on  ground
water protection.  To manage EPA programs covering ground water effectively
and to maximize ground water protection, EPA is developing a comprehensive,
integrated ground water strategy.

Sources of ground water problems can be grouped into  four categories:   leachate
from septic tanks and cesspools, land disposal of residual  wastes, nondisposal
activities, and ground water depletion, including salt water intrusion.   Three
major pieces of Federal legislation impact State ground water  programs:   the
Clean Water Act, Safe Drinking Water Act (SDWA), and  Resource  Conservation and
Recovery Act (RCRA).  In assessing HQM ground water needs, it  is important to
understand the CWA relationship to RCRA^and SDWA.

The Clean Water Act addresses, in part, ground water  contamination from
municipal and industrial point and nonpoint sources.   WQM covers primarily
design of State programs and the development of nonpoint source controls.  WQM
encourages the coordination and integration of all ground water protection
programs.  Historically, Section 106 funds have not been available for ground
water.  Ground water activities are primarily funded  under Section 208 which
is increasing emphasis on ground water primarily through prototype projects.
These prototype projects will lead to cost savings over the long term  by
avoiding duolication in planning as well as saving time and money by providing
reliable information adaptable to problems in other locations.  Most monitoring
has been done by LISGS.

Under the Safe Drinking Water Act, EPA is responsible for drinking water
standards, treatment technologies for public drinking water systems; under-
ground injection requirements; survey of pits, oonds  and lagoons; and  sole
source aquifer designation.  RCRA covers land disposal of municipal  waste;
solid waste disposal facilities; generation, transport, storage, treatment,
and disposal of hazardous waste; and the open dump survey.

State agencies involved with ground water operate under diverse laws and
institutional arrangements  (see Figure V-19).  Some States use general pollu-
tion control  laws to protect ground water, while others have specific  laws to
address different activities.  Many agencies are involved.  Most States do not
regulate all  sources of contamination in every area.   For any  particular
activity or source,  the specific approach and the resources available to
implement  the program differ considerably from State to Stadte.  For the  most
part, there is a lack of  conjunctive management of surface and ground water
for quality and quantity.  While there  is a growing State interest in ground
water management, available resources, data, expertise are extremely limited.
                                        112

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DRAFT


1. Monitoring
II. Problem Assessment
Solution Development
III. Implementation
• Operating programs
i.e. permitting
• BMPs
• Construction/
Abatement
IV. Enforcement
V Evaluation of
Management
ISSUES
SOURC
*
Mon
Estai1 SPraV
Facil
1 Delega
To De\
Prograi
2 Landf!lllmcJatlon
SIA, Rftagement
3 208 Loi
for Ha;
Operate
Jisoosal
Propose
Will Prc
for Abd
Few Enfi
Initiated
Current Bewage
311 Autf-
Propose<
N
1 Stale f)t|0ns
2 New H
and Si
3 Techni
Rehahi
Mining
Wastes
No Monitoring
Requirements
Coal Mining
OSM- Develop Regulatory
Program for Coal Mining
208 Program Develops BMPs
and Control Programs for
Non-Coal Mining
OSM- Inventory of Abandoned
Mines
NPDES for Point Source Disposal
BMPs - for Non-Point Source
Disposal
Permits--OSM Consolidated
With NPDES for Coal Mining
Operations
NPDES -Point Source Controls
Enforcement Under PL 95-87
for Coal Mining
Limited State Enforcement Under
State Laws
None
1 BMP Implementation
2 Technical Capabihtv for
Controlling Abandoned Mines

Other
Monitoring
SDWA - Public Drinking Supplies
USGS — Quantity and Aquifer
Characteristics
Well Drillers - Quantity Data
Other Data Sources
SCS Soil Maps
UIC Aquifer Maps
Research
EPA-- Ada Lab
USDA- 1 3 Millions Dollars
Year
OWRT-1 Million Dollars
Year
Comprehensive Ground water
Programs Beiny Developed
Under 208 in a Few States
1424(el Program - Designation
of Sole Source Aquifers Which
Requires EIS on Federally
Assisted Projects Located in
Recharge Zones


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Over the period of the Assessment, Groji.^. v-a^r 'ui'ows the general  trend
seen in nonpoint sources of shifting fr- t h- planning to program administ-
ration (see  Figure V-20).   Ground water Joc-^ases in priority constituting
1/3 of the nonpoint source control program in FY d4.   ihis decline nay
reflect absence of special  projects in vJQr, Agency projections.  FY 79-
80 includes such projects  (see  Figure V-21).

Most State ground water programs  are  in  early stages of development.  EPA
believes further development  is needed by FY 84 beyond that projected because
of the costly  nature  of the problem and  immediate need to build expertise.
State and areawide needs may  have been underrepresented, however, because of
other Agency involvement which may  not be incorporated.  The  problem of  resource
and staff constraints  is compounded by Federal de legation of  new program
responsibilities to the States, which will cause fierce competition for  the
diminishing resources.  Table V-ll  gives  the total funding needs for ground
water.


Fable V-11:  Total '.-JQM Agency Ground Water Needs for JfJQM_,_fY_79::8£ J
                              F Y79     Y8      Y S     FY82    F Y83     Y84
Gnlol Disposal                 7.5    10.5    11.5    11.5    11.0    11.0

Residuals                      3,5     4.0     3.U     3.5     4.5     4.0

Ground Water Management        5.5     8.0    10.0    10.0    10.0     8.5
TOTAL                         16.5    22.5    2^.5    25.0    25.5    23.5
This report covers only ground water as it relates to the Clean Water Act
under MQM in Sections 106 and 208 of the CWA.  Activities eligible under the
other programs such as RCRA, SDWA, and the Surface Mining Act are excluded.
This Chapter covers onlot disposal, residuals, and general ground water manage-
ment.  Other CWA oollution sources contaminating ground water (e.g., industrial
discharges, agriculture, spills, and noncoal mining) are covered elsewhere in
this Report (See Table of Contents).
                                         114

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                                            Figure V-20
                            Total Ground Water Source Control Needs
                                       by Activity Category
15
1?
                                                                              Program Administration
                                                                               Problem Assessment
                                                                              Program Development
 0
FY 79
                   FY80
                                      FY81
FY82
FY83
FY84
                                           Figure V-21
                         Shift in Priority of Ground Water Source Control
                    FY79
                                                                        FY84
       Non-Coal
       Mining
          2O/
          /o
                                                   Non-Coal
                                                    Mining
                                                      4%
                                              115

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                                        Part 2

                                    ONLOT DISPOSAL
Conclusions
          After a  substantial  increase  in  program size in FY 79 and 80, the
          States'  program  needs  stabilize  into FY 84.

          The magnitude  of the requests  varies widely  from State to State,
          indicating  that  some States projected needs  in WQM for their entire
          onlot control  program  and  others for only certain activities, such
          as evaluation  and  improvements in the existing program.

          The States' major  needs  involve  evaluating,  revising, and adminis-
          tering regulatory  programs.
Background

For the purposes of  this Assessment,  onlot disposal  or small  flow systems is
defined as small wastewater  disposal  systems  that are used for the treatment
of home generated wastes.

Failing septic  tanks  and cesspools  are  the most frequently reported sources of
ground water contamination.   In  1970,  it was  estimated that between 20 and 32
million households disposed  of their  sewage in privies, cesspools and septic
tank systems.   Onlot  systems annually discharge over 2 trillion gallons of
wastewater to the subsurface.  Although the percent of newly constructed homes
using onlot systems  is  decreasing  each  year in relation to those using sewers,
the total number of  onlot  systems  is  increasing by 500,000 per year(Figure v-22),
                                       Figure V-22
                  Basins Affected* by Pollution from Individual Disposal Systems
     * In whole or m part

      Note: Affected basins are shaded
                                          116

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Malfunctioning systems can cause wastewater to back up into the home, rise to
the  surface in the form of surface breakout or short circuit and move directly
into ground water.  Even a properly functioning system will add dissolved
solids to the ground water.  Where insufficient treatment of wastewater occurs,
bacteria, viruses, degradable organic compounds, synthetic detergents and
chlorides may contaminate ground water.  Of these, the greatest hazards are
bacteria and nitrates.  Systems fail for a number of reasons including  faulty
siting, design or construction or inadequate maintenance,  (e.g., periodic
pumping of septage from the settling tanks).  Proper siting involves careful
analysis of the permeability of the soil, vertical distance between the absorp-
tion field and the water table, hydrogeology, soil type, and slope conditions.

The  Clean Uater Act of 1977 recognized that onlot and alternative wastewater
systems which were properly designed, installed, and managed could be the most
cost-effective and environmentally acceptable wastewater treatment approach
for  small communities and rural areas.  The authority for EPA to identify and
rectify nonpoint  source and ground water contamination problems associated
with onlot disposal systems can be found in Sections 201, 208(b)(2)(k), and
304(f) of the Act.

State and local  authorities have traditionally enforced regulations to protect
the health of the septic system user and immediate neighbors.   Such regulations
usually take the form of a State code or set of minimum standards.   Some
States have retained all  regulatory authority over onlot systems, while others
have delegated all or part of the responsibility to local  governments.
Administration of these regulations involves preliminary site and system eval-
uation (which includes permitting), system compliance and oerformance monitoring,
assessment of problems, public education, professional  training, and technical
assistance.

In the past, Section 201  provided funding to States for the planning of cost-
effective treatment systems.   The program has traditionally favored the plan-
ning and construction of centralized treatment olants.   However, several
amendments to the Act were passed in 1977 designed specifically to  encourage
the construction or rehabilitation of small  alternative wastewater systems.
In 201  facility planning, all  applicable wastewater treatment options must be
considered.   Overlap clearly exists between  activities  eligible for funding
under 208 and 201.  The current MQM policy is for 201  funds to be used  to
control  small  flow system disposal  problems  of a site-specific nature.
Section  208 funds the development of operational  regulatory programs, iden-
tification of management agencies and development of management agreements.
EPA recently drafted a small  flow systems strategy (available from  the   Water
Planning Division, EPA).

In the  past,  the HQM program has supported State and areawide problem assessments,
analysis and  improvement of management systems,  and identification  of technical
solutions.   The  following activities have been undertaken  through the 208
program:

     1.    Problem assessment (inventory and  identification  of failing  systems
          and their environmental  impacts,  including ground water contamination).

     2.    Analysis of existing  regulations  and institutional  arrangements.

     3.    Evaluation  of alternative technologies  (literature surveys, monitoring
          of  field performance  of  various  systems).
                                        117

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     4.   Development of management plans (prioritized BMPs, recommended
          legislative and organizational changes, financial planning, model
          codes, model program, design manuals).

     5.   Provision of training, public educational  materials, and other
          technical assistance activities.

     6.   Assistance in administering implementation programs (interagency
          agreements, grantsmanship).
WQM Agency Projections

For the management of small flow wastewater disposal systems, 43 States have
forecast the need for resources under CWA Sections 106 and 208.  The needs
increase from FY79 to FY81 and then stabilize.  Tablev-12below gives the WQM
projections for total dollar and staff year needs.
Table V-12:  Total
Projected Onlot Disposal  Needs,  FY 79-80 ($000,000)

Total
Total

Funding Needs
Staff Years
FY79
7.5
302
FY80
10.5
350
FY81
11.5
362
FY82
11.5
381
FY83
11.0
389
FY84
11.0
379
Total dollars and staff years increase only 6% and 8% respectively from FY 80
to 84.  Of the 19 Statewide programs which show increases between FY80 and
FY84, 6 increase by 100% or more. 18 programs decrease and 6 stay the same.
The projected needs for each of the activity categories (i.e., problem assess-
ment, program development, and administration of implementation) are graphed
in Figurev-23.  Problem assessment and program development grow rapidly from
FY 79 to FY 80, then gradually decrease over the five-year period.  Funding
needs for administration also rise sharply from FY 79 to FY 80 and continue to
rise slightly every year thereafter.  Over five years (FY 80-84), the WQM
collectively estimated needs of $12.4 million (20%) for problem assessment,
$10.1 million (16%) for development of management programs and $39.8 million
(64%) for implementation.  The number of States projecting administration
needs increases.  In FY79, 22 States requested funding for implementation
programs; 35 in FY81; and 38 by FY84.

Planning and administration of WQM  control programs  are eligible  needs under
Sections 106 and 208.  However,  the  degree of support projected varied greatly.
Some  States  projected  needs for  their  entire  program and  others for only  a
oortion.  The most  frequently  cited  needs  (in order  of  frequency) are:

          Evaluation  and  revision of control  program.

          Administration  of permit  program,  compliance  evaluation or  enforcement.

          Development  of  management capability.
                                         118

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          Identification of problem areas.

          Technical  assistance training and public education.

          Identification of alternative and innovative small  wastewater systems
          and  other  funding sources.
                                       Figure V-23
                                 Total Onlot Control Needs
                                   by Activity Category
    FY 79
                   FY80
                                   FY81
                                                   FY 82
                                                                  FY83
FY84
Analysis

As can be seen  in  the WQM  estimates,  total  funding  for small  flow activities
is expected to  peak  around FY  82  and  decrease  slightly after  that.   This
slight decrease  reflects a reduction  in  problem assessment and program develop-
ment activities  over time.   It is  anticipated  that  funding needs beyond FY 84
will not decrease  significantly,  since administration  activities are expected
to increase based  on an  increasing  population  and number of homes using small
flow systems.   Regulating,  managing,  and monitoring  small  flow systems will  be
necessary as new homes are built,  and population densities and associated
problems increase.

The funding picture  for small  flow  system management is  a  mosaic of  Federal,
State,  and local pieces.    In each State  the picture  is  slightly  different,
resulting in varied  projections of  States' needs.  EPA  estimated needs  for
individual  State small  flow control programs.   These estimates  covered  the
annual  support required for an adequate  State  program.   They  represent  the
maximum amount statewide which could  be  needed, if the  State  requested  106/208

                                         119

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support for their entire program.  These projections were derived through a
series of mathematical analyses, but simply stated, are based primarily on the
following:

          The number of existing and new small flow systems in each State

          Present and future problem severity

          State institutional arrangements for the management of small flow
           systems, and

          Funding data received from sample States.

Estimates of the number of existing and new systems statewide were based upon
Census data and projections provided by the National Association of Home
Builders.  Problem severity ratings for individual States were arrived at
through analysis of numerous sets of map and textual data related to the
performance of  small flow systems and potential problems.  Institutional
arrangements refer to the level of government at which most small flow system
programs are administered.  Finally, funding  data was solicited from  several
States judged to have model, or at least adequate,  small flow system  programs.
This data was essential to  realistically project nationwide costs for individ-
ual State programs.  Upon analysis of all of  the above data, two different
equations were  developed to project costs for the categories of States represented.

Most of  the projected needs submitted by WQM  Agencies statewide came  very
close to EPA's  estimates.   Where disparity existed, all but 9 States  adequately
explained their needs.  Correlation between the EPA and State projections was
best where States requested WQM funding for most, if not all, of their program
needs.   In comparing the total five-year projections, the collective  WQM
projections were about 71%  of that of EPA estimates.

The needs in 10 of the States that fell considerably below or above EPA's
projections could be adequately explained by  the narrative supplied with their
projections.  Those States  that fell below EPA projections typically  requested
funding  for only problem assessment and program development.  Those States
with higher projections than EPA's generally  included estimates for 208 areawide
agencies or anticipated involvement in special projects or activities normally
not found within the range  of typical State onlot activities.   In all, the
needs submitted by 42 States (including Washington, D.C.) could be adequately
justified on the basis of EPA's projection methodology or State-supplied
narratives.

The remaining 9 States projected needs either well  above or well below EPA
estimates.  3 of these States projected needs below EPA estimates and did not
provide  explanations for these projections.   Though many reasons could exist,
such as  alternative funding sources, priority of  problem in State or  adequacy
of existing program, until  EPA receives explanations, it believes these States
have underestimated their needs.  The other 6 States projected  needs  well
beyond those projected by EPA, which cannot be explained on the basis of any
data currently  available to EPA.  On the basis of what EPA knows about program
activities in each of these States, it is believed  that they have overestimated
their needs.
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                                     Part 3

                                    RESIDUALS
Conclusions
     •    WQM predicts small but stable needs in residual waste management.

     •    With WQM funding, HQM plans to manage sludge and septage disposal
          and assure protection of water quality in State residual management
          programs.

     •    The need for planning decreases from FY80 to FY84 and administration
          needs increase to compose 45% of the program by FY80; showing a
          definite shift for WQM from planning to administration of imple-
          mentation programs.

     •    EPA forecasts a diminished WQM role in residuals management, while
          WQM Agencies project need for continued support at about the same
          level of existing funding.


Background

For the purposes of this Assessment, residuals are defined as solid, liquid or
sludge wastes generated from human activities and collected for solid waste
disposal.  This is a broader definition than previously associated with resid-
uals; that is, simply those wastes generated in treatment of wastewater at
treatment plants.   The new definition increases the scope of residual waste
problems to include the following major categories:  wastewater sludge,
septage, water treatment residuals, municipal refuse, wastes from combustion
and air pollution controls, industrial  wastes, feedlot wastes, mine wastes,
and dredge spoil.

A number of EPA programs have management responsibility for different aspects
of residual waste management.  Section 201  of the Clean Water Act assigns
responsibility to the publically owned treatment works (POTWs) for the man-
agement of the sludge generated.  The Resource Conservation and Recovery Act
(RCRA) calls for the development and implementation of State solid waste
management plans,  an open dump inventory and the management of hazardous waste
disposal and handling.  The Safe Drinking Water Act (SDWA) becomes involved in
waste management where'residuals affect a sole source aquifer, are deposited
underground (Underground Injection Control  program) or are contained in a
surface impoundment.

The WQM role in residuals management has evolved with respect to the roles of
other EPA programs and its own mandate in Section 208(b)(2)(J) of the CWA,
which states that areawide planning is  to include a process to control residual
disposal where it may affect water quality.   The HQM policy is that States and
areawide Agencies  may use 208 funds for nonpoint source aspects of residuals
disposal to solve known water quality problems where other grant funds are not
available.   For the Assessment, EPA excluded mining and agricultural  wastes
from the residuals section and included them in the mining and agriculture
nonpoint source sections.  EPA also excluded from this Assessment costs for
the management of hazardous waste disposal.
                                        121

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The major activities which have been funded by 208 in residual  waste management
include sludge and septage disposal  management on an areawide basis and landfill
siting assessment.  These activities require coordination with  solid waste
offices, 201 agencies, local land-use planners, and the public.


WQM Agency Projections

WQM agencies in 39 States projected needs in residual waste management over
the next five years.  32 States received funding in residuals during FY 79-80.
Table V-13 gives the total dollar and staff year needs for residuals.


Table V-13:  Total VJQM Projected Residuals Needs, FY 79-80 ($000,000)	

                                 FY79    FY80    FY81    FY82    FY83    FY84
Total Funding Needs
Total Staff Years
3.5
87
4.0
76
3.0
89
3.5
87
4.5
87
4.0
96
The needs reflect a small but stable program.  The total needs increase from
FY80 to FY84 by only 5%.  Between FY80 and FY84, the total needs dip, rise
steadily and then begin to decrease slightly.  21  States'  needs increase from
FY80 to 84; 13 of those States'  needs increase by 100% or more.  18 States
have decreasing needs and one program remains the same.

The needs for the activity categories (i.e., problem assessment, program
development and administration of implementation programs) change only slightly
over the years (Figure V-24).  Though administration doubles from FY 80 to 81,
it levels off in the subsequent years.  Problem assessment needs fall dramat-
ically from FY79 to 80 and then hold fairly even.  Program development increases
sharply from FY79 to FY80 and then decreases steadily over the years.  The
trend towards more administration and less program development is similar to
other nonpoint source trends, but less dramatic.  The needs for residuals are
more evenly distributed among the activity categories.

12 States indicated they will have regulatory programs in residuals and 6 will
have nonregulatory programs.  In describing their programs, they mentioned the
following activities (from most to least cited):

          Coordination with  other programs to assure water quality protection

          Sludge disposal management

          Septage disposal management

          Site assessments

          Education, training or public participation.
                                        122

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                                       Figure V-24
                                Total Residual Control Needs
                                    by Activity Category
                                                                   Program Administration
                                                                     Problem Assessment
                                                           Program Development
   0
   FY79             FY80            FY 81            FY 82            FY 83             FY 84


Analysis

The magnitude of  the waste  disposal  problem in the  country may require more
resources than EPA thought  to  be  necessary.   Though residuals has received a
low WQM priority;  in WQM  Agencies,  it remains a substantial UQM need.   The
number of WQM Agencies  requesting funds  and the level of resources they have
requested are higher than EPA  estimates.   EPA forecasts  a diminished role for
WQM in residuals  waste  management based  on (1) the  existence of other funds
(i.e., 201, RCRA,  SDWA) from programs with lead responsibilities in residuals
and (2) competing  needs for WQM funds.   However,  States  have projected the
need for a continuing role  for 106/208 at  approximately  the same level as is
now funded.  Further study  should be  undertaken on  meeting those needs with
other sources.

EPA statistically  analyzed  the WQM  Agencies'  projections in order to evaluate
their validity.   EPA compared  the population  of each  State to its residual
waste needs for the year  FY84.  The  States data was found to be consistent
with each other.   Of the  39 States  with  projected needs, 30 States'  needs fell
within a range of  magnitude, (i.e.,  spent  from .1 to  .01 cents per person) and
one State spent more.   2  of those States outside  the  order of magnitude supplied
adequate explanations for their projections:

          One State with  lower costs  plans to use WQM funds for coordination
          activities only,  which  makes its needs  lower than other States
          projecting more activities.

          One State with  higher costs  included in its assessment a special
          study project on  waste  oil  disposal.

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                                        Part  4

                              GROUND  WATER  MANAGEMENT
Conclusions
     •    There is inadequate funding to manage ground water resources.   Most
          States are just beginning to address the problem.   WQM agencies
          support continued development of ground water management capability
          and indicate modest increases in FY 81-83, but declines in FY  84
          levels.   Between FY 80-84 emphasis shifts from planning to program
          administration.  Resources peak in FY 81 ($10.5M)  as that shift
          occurs.

     §    WQM is continuing the priority established in the  WQM Strategy.
          Ground water management is a stable priority between FY 80-84.

     •    EPA believes additional emphasis beyond that projected by many  WQM
          agencies will be necessary to make adequate progress toward ground
          water management in FY 81-84.


Background

For the purposes of the Assessment, ground water management  is defined to
include the development and oversight of ground water management plans,
general monitoring for quality not feasible for funding under other sources,
saltwater intrusion problems, and ground water mining and diversion.  Because
of the tremendous variation of pollution sources and existing control pro-
grams, ground water management programs must be flexible and tailored to  State
and local needs.  While there are relatively sophisticated ground water  pro-
tection programs in a few States (e.g., New York, New Mexico), generally, there
has been inadequate attention given to management.  Most States have not  or
are just beginning to focus on the problem.  Thus, the activities to be  addressed
during the next five years will most often involve building  inhouse technical
capability, assessing problems, developing programs and making incremental
progress toward administrating such programs.  These activities may be funded
under SDWA, RCRA, CWA, and other sources.  The VJQM "fair share" of the program
responsibility, covered here, is just a portion of the total program.

WQM Agencies Projections


WQM Agencies indicate nationally moderate increases in ground water management
needs over the next few years.   In FY 80, $8M is allocated to ground water in
management.  Needs peak is FY 81 at $10.5M.  By 1984, $8.5M  is projected.
Growth is moderate, in part because ground water currently is a National  WQM
priority and already receives a  relatively high level of funding through  the
WQM program.
                                        124

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                                                                        1
Table V-14:Tota1 State Projected Ground Water Management Needs, FY 79-84

Total
Total

Funding Needs ($000,000)
Staff Years
FY79
5.5
140
FY80
8.0
186
FY81
10.0
304
FY82
10.0
397
FY83
10.0
249
FY84
8.5
219
States are continuing the priority established in the WQM Strategy.   The
emphasis on ground water management is relatively stable.  Growth in needs  is
highest in geographic areas with substantial  problems (e.g., Northeast,
Southwest).  7 States indicated large programs exceeding $500 thousand or 12
staff years by FY 84.  All of them are among  those having the most serious
ground water problems (Arizona, California, Texas, South Carolina, Florida,
New York, and New Jersey).  16 States projected fiscal  resources EPA believes
adequate to build toward a conservative program over the period of the Assess-
ment.  14 States projected very marginal  capability ($60 thousand or less by
1984).  This is of particular concern in  4 of those 14  States which  are  major
industrial or populated States where ground water is a  major concern.

44 States indicated current activities in ground water  management.  Virtually
all States indicated needs in FY81-84.  10 States indicated comprehensive
programs; 15 indicated the need to develop such a program.   The 14 States
indicating marginal capability focused on limited aspects of ground  water
management.  Both voluntary and regulatory programs were popular.  The fol-
lowing activities were discussed (in order of most to least frequently cited):

          assess ground water problems

          map or classify aquifers

          develop control programs

          develop ground water quality standards

          evaluate and modify legal authorities

          permit sources

          provide technical  assistance

States (and areawide agencies) felt the following problems  needed to be
addressed in conjunction with those activities (in order of most to  least
frequently cited):   aquifer recharge;  energy  development; ground water intru-
sion; impoundments; waste disposal; pits, ponds, and lagoons; wells; hydro-
logic modification; agriculture; and surface-ground water relationships.
1
Includes National  Prototype projects  for FY  80.
                                        125

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Projections, while consistent with  direction  taken  in  the  WQM  Strategy,  do not
incorporate EPA emphasis on  prototype  projects.   Projections emphasized
general program development  rather  than  a  project orientation.   States focused
on building technical and  institutional  capability  to  manage ground water and
administer implementation  programs.  Between  FY81-84,  the  program  shifts from
planning towards program administration  (FigureV-25).  Administration grows,
reflecting the institutionalization of the program  and increasing  implementa-
tion of planning outputs.  Planning needs  peak  in FY 83,  indicating satisfac-
tion of the immediate need to fill  major gaps in  planning  and  a decreased but
continuing planning need.  Movement from problem  assessment  toward less  costly
program administration accounts for the  decrease  in  total  WQM  needs.
                                        Figure V-25
                            Total Ground Water Management Needs
                                    by Activity Category
w
c
o
I  3
                                                            Problem Assessment
            Program Administration
                                                            Program Development
   0
   FY79
                   FY80
FY81
                                                  FY82
FY83
                                                                                  FY84
Analysis

Although there was wide variability  in State  projections,  they  are  statistically
valid when standardized to population.  There is also  a  strong  correlation  of
costs to population dependent upon ground water for  drinking  and  to the  extent
of known contamination.  When standardized, costs generally  ranged  from  $.01
to $.15 per capita.  States falling  substantially below  this  level  (e.g.,
$.0007) indicated very low levels of  program  activity  (e.g.,  $8K).   In only
one case, costs above the norm could  not be explained  considering the extent
of contamination, population dependency, expected future growth,  or the  minimum
requirements (for small States) to operate an adequate program.   When analyzed
for cost per population actually dependent upon ground water for  drinking,
States fall in two categories ($.01-.l and $.1-1 per capita).   States  in the
                                         126

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upper range indicated comprehensive programs or minimum levels (in small
States) to operate an adequate program.  States in the low range indicated
minimal or very specialized programs, low level of program development, or
restricted needs by assuming decreasing Federal support for nonpoint source
programs.  Approximately 20 States projected costs of $.1-1 per capita which
actually are dependent upon ground water in contaminated basins.

EPA anticipates needs are higher than some State projections indicate.  This
reflects the need to maintain a minimally adequate V!QM capability to monitor
for problems, protect public health, and manage the resource so as to prevent
future contamination.  This ground water management capability is important
because no other program has the "umbrella" or cross cutting responsbility
essential for ground water protection.  EPA is particularly concerned because
of the low level of some projections (e.g., $8K).   EPA estimates are, of
course, to be supplemented by other nonpoint programs (onlot and residual
wastes), SDWA, RCRA, Surface Mining Act, USGS, and other programs.

In industrial, populated, or otherwise vulnerable States, EPA estimated a
minimum of 4 staff-years is desirable to develop ground water management
plans, oversee plan implementation, give technical assistance, oversee and
maintain minimal Statewide monitoring capability,  and begin to address existing
salt water intrusion, ground water mining, or diversion problems.  Less populous
or critical States should maintain a staff complement of 2.  These estimates
are preliminary; further study should be undertaken to evaluate their adequacy.
EPA accepts State staff estimates exceeding these minimum levels reflecting
more comprehensive programs or advanced stages development.  Staff needs,
particularly in more rural States, may be higher than EPA estimates because of
limited local capability.

In addition to program administration, all States  need a ground water monitoring
capability.  Conservatively estimating such needs  to average $100 thousand per
State, over $5 million would be needed annually.  Assuming $35,000 per staff-
year is required for salary and overhead for the highly technical staff
necessary and the program is phased in over the fiscal years to FY 84, EPA
estimates are compared to State identified needs in (FigureV-26).  Some States
exceed the EPA estimates because of intensive monitoring, other special
projects, or non-staff related resources ($2 million by FY 84).  These needs,
although legitimate, have not been included.

Building States up to these levels by FY84 will not, as many States indicated,
be sufficient to administer a comprehensive program.  It will, however, repre-
sent progress in that direction and provide a minimum capability to respond to
ground water management problems.   Plan outputs can be gradually implemented.
This trend should be continued into the 1990's.  As previously discussed,
additional resources would be required for special projects.  The National
prototype projects for FY 81-84 are not included.
                                        127

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SUM
$12M
$10M
 S8M
 $6M
 $4M
 $2M
                                            Figure V-26
                                 State and EPA Projections of Total
                                Groundwater Management Needs**
   1979*
                     1980*
1981
1982
1983
                                                                                                 1984
    *Actual or planned
   *'State projections based on 49 State submissions
                                                 128

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        Chapter VI

           OTHER


Section A - Overview

Section B - Ambient Monitoring

Section C - Water Quality Standards

Section D - Total Maximum Daily Loads and
            Waste Load Allocations

Section E - Emergency Response

Section F - Other State Programs
           129

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                               Section A

                               OVERVIEW
This chapter includes aspects of WQM not directly related to municipal
planning and management, industrial and municipal regulation, or nonpoint
source planning and administration.  It covers ambient monitoring; Water
Quality Standards; total maximum daily loads, wasteload allocations, and
general basin planning; emergency response; and State programs not covered
elsewhere in this report.  The first three of these programs areas relate
to general and point source planning.

The activities covered here constitute 16% of the WQM program needs in FY 80
and 84 (Table II-3).  This stable priority is not reflected among the pro-
gram elements.  Ambient monitoring, and total maximum daily loads/waste
load allocations (and basin planning) retain relatively the same priority
in FY 80 and 84.  Emergency response increases in priority while Water
Quality Standards and other State programs receive decreased emphasis.
Ambient monitoring and emergency response account for most of the growth
in this area between FY 80 and 84 (37% and 32% respectively).  As Table VI-I
indicates Emergency Response is primarily responsible for the maintenance of
this program area's priority.

Table VI-I: Other Programs WQM Agency Projected Needs	

                         % of           % of           % of
                         FY 80 needs    FY 84 needs    Growth FY 80-84
Water Quality Standards
Ambient Monitoring
TMDL/WLA
Emergency response
Other State programs
Total
10%
36%
21%
16%
17%
100%
8%
37%
22%
20%
13%
100%
5%
37%
25%
32%
1%
100%
                                  130

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Table VI-2: Total WQM Agency Needs for Other UQM Programs ($000,000)*

Ambient Monitoring
Water Quality Standards
TMDL/WLA
Emergency Response
Other
TOTAL
FY79
11.0
3.5
5.5
3.5
3.0
26.5
FY80
12.5
3.5
7.0
5.5
6.0
34.5
FY81
15.0
3,5
9.5
8.0
6.0
42.0
FY82
16.0
3.5
9.5
8.0
5.5
42.5
FY83
16.5
4.0
10.0
8.5
5.5
44.5
FY84
16.5
4.0
10.0
9.0
6.0
45.5
   *Some administration costs are not included ($000,000).  See Table II-3.
                                     131

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                                 Section B

                             AMBIENT MONITORING
Conclusion
State projected needs maintained the existing effort in ambient monitoring.
However, its relative importance among monitoring activities has been
lowered in favor of other aspects of the program.  This trend is consistent
with EPA policy relying on intensive surveys for more focused determination
of general water quality and cause and effect relationships.  Ambient
monitoring needs increase from $12.3 million in FY 80 to $16.7 million
in FY 83 and FY 84.  These costs, in aggregate, are nearly identical  to
those forecast by EPA.  However, when taken State by State, the variation
among these State projections is very great.  Further study may be
necessary to explain this difference.

Background

Ambient water quality monitoring covers a network of fixed or continuously
operated stations.  A core set of approximately 1,000 fixed stations
provides data for national assessments.  A supplementary program operated
to provide information to State decision  makers is larger and contains
several thousand additional stations sampled at various intervals.
Information gathered from this network is used in setting water quality
standards, classifying water segments, giving perspective to the restrictions
that will be placed on waste dischargers through permit requirements, and
generally describing progress in pollution control and long-term water
quality trends.  The data collected is particularly important in preparing
the water quality monitoring reports required under Section 305 (b) and
the permit programs under Section 402 and 404. EPA provides and maintains
the STORET system to store and display the data for all levels of government
in their programs.


Projected Needs

The following figures reflect the total needs for operating ambient
monitoring programs:

Table VI-3: Total UQM Projected Ambient Monitoring Needs, FY 79-84.

               FY 79     FY 80     FY 81      FY 82     FY 83     FY 84

Total  Needs
($000,000)     11.0      12.5      15.0      16.0      16.5      16.5


Every State projected ambient monitoring needs with 39 showing increases for
the FY 80-84 period.  Two States projected decreasing needs, while seven provided
costs that remained static.
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Ambient monitoring is projected to change in nature during the period covered
by the Assessment.  Some of these changes will  tend to increase the funding
needed to support the effort; others will tend to decrease the cost by changing
practices or diverting effort to other areas.  For example, States recognize
that the parameters covered by State monitoring programs must be increased to
include toxic materials.  However, reliance on simplified techniques such as
biological  monitoring can reduce these needs by using living indicators of
water quality.   In the future, the States expect that much of the information
once furnished by ambient monitoring will be provided by the more focused,
intensive surveys, an area which is anticipated to assume a greater role in
monitoring over the period of the Assessment (see Chapter IV, Section A and
D).


Analysis

The projected needs for ambient monitoring correspond well with the needs
estimated by EPA (see Figure IV-5), particularly in the latter part of the
period when States' programs will have reached a new plateau of sophistication.
The method used by EPA to estimate these costs was based on experience with
the program nationally and does not account for State circumstances.  State
projections on an individual basis sometimes ranged widely from those derived
by EPA.  The factors believed to have been responsible for this variation
include:

     •    State size

     t    Hydro!ogic characteristics (the mix of lakes and streams, etc.)

     •    Population and its density

     •    Industrial patterns, and the number and nature of dischargers in the
          State

     •    The amount of monitoring data deemed to be required to initiate
          administrative action within the State

     •    The amount of monitoring done by local agencies
                                    133

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                                 Section C

                         WATER QUALITY STANDARDS
Conclusions
     States project review and revision of water quality standards as a
     relatively stable need.   They indicate the need for more sophisticated
     standards covering toxics and other additional  parameters which are
     more sensitive to the actual  water quality.  This shift has a minimal
     effect on projected resource  requirements.

     Projections probably underestimate the level  of activity or resources
     required to accomplish the objectives.  Further study is underway
     in EPA to estimate needs.
   Background

   All States have, as required by the CWA, water quality standards.  These
   standards provide a baseline of instream water quality goals for assessing
   the quality of the nation's water and the adequacy of existing programs
   (e.g., minimum technology based requirements) for achieving these goals.
   Standards prescribe instream water quality and consist of designated water
   uses (e.g., drinking water supply, agriculture, wildlife protection, aquatic
   propagation, and recreation), narrative and numeric criteria for pollutants
   to protect uses, and antidegradation policy.  At least once every three years,
   States are required to review and, if necessary, revise these standards
   after public hearings.  Generally, revisions are incorporated on a more
   frequent basis.

   State Projections

   States indicate relatively stable resource needs for standards.  This is
   contrary to the general growth trend in the Assessment.  In any particular
   State, costs fluctuate from FY 80-84 depending on their timetable for review
   and revision.  Examination of the need to increase toxic coverage was the
   most frequently cited activity, with one-half the States indicating such
   plans.  They were split as to whether such activity affects costs.  States
   appear to be relying on the Federal government to bear the cost and respon-
   sibility for developing technical justification.  States also indicated
   the need to adopt groundwater, bioassay, and nonpoint source standards,
   reclassify uses of water segments (e.g., considerating attainability and
   economic impact); and review and revise antidegradation policy.  AWT/AST
   impacts were a major consideration.  Within the resources projected, public
   participation was a major need.

   Table VI -4: Total State Projected Needs to Review and Revise Water Quality
   	Standards, FY 79-80.	~	

             FY 79     FY 80     FY 81     FY 82     FY 83     FY 84

   Needs
   ($000,000)  3.5       3.5       3.5       3.5      4.0        4.0
                                     134

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Other programs support review and revision of standards,specifically
monitoring surveys (See Chapter IV, Section D) and total maximum daily
loads and waste load allocations (See Section D) which translate standards
into point and nonpoint source control requirements.  These projections
should be reviewed in conjunction with this Section.

Analysis

EPA evaluated State projections for statistical validity.  State FY 84
projections were compared with the number of point source dischargers.
Projections were found to be statistically valid.  42 States costs
ranged from $.01 to $.10 per point source.  4 other States below and
above this range indicated a different priority for the program which
cannot be interpreted without further explanation.

State standards activities projected generally reflect a national EPA
trend in standards toward:

     *    incorporating toxic criteria

     •    designating attainable uses and criteria to protect them

     •    use of standards in municipal facility planning and management

     *    assessing impacts and adequacy of minimum technology based
          (BAT/BCT) requirements (although the latter is not a State
          emphasis)

     •    point and nonpoint source trade-offs

Standards policy envisioned by the national program reflects a more
water quality based WQM program than has historically been the case.
This will impact resources.  Although there apparently is substantive
consensus among States and EPA on program direction in standards, EPA
believes States underestimated the resources required to review and
revise standards toward that end.  This may be due to a difference of
opinion on costs, a lower level or intensity of activity than anticipated
nationally, or States apparent reliance, particularly for toxics, on
increased assistance from EPA in refining standards.

EPA is developing proposed revisions to the water quality standards
regulations which will further discuss this trend.  Consideration is being
given to resource implications at the State level and how those needs
will be met.  There are also implications for other aspects of the
program (specifically NPDES, monitoring and general and point source
planning).  Any changes in direction toward a more water quality based
point and nonpoint source control program are in addition to needs
projected by WQM Agencies in this Assessment.
                                 135

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                               Section D

         TOTAL MAXIMUM DAILY LOADS AND WASTE LOAD ALLOCATIONS
Conclusions
     *    States indicate a stable priority for total  maximum daily
          loads, waste load allocations and general  basin planning.

     *    States project an increased emphasis on obtaining a general
          understanding of water quality problems.

     *    States are confused about the UQM priority and direction for
          this aspect of general and point source planning.

Background

This section covers general and point source related water planning.   It
includes the translation of monitoring and other information generally
conducted under intensive surveys into determinations of problems and
cause-effect relationships, basin plans, allowable pollutant loading  for
sources, and point source discharge limitations beyond minimum technology
based requirements.  The latter, called waste load allocations, may be
required to meet water quality standards.  All of these activities
commonly include modelling and economic analysis.  Public hearings under
due process requirements for NPDES permits may occur at this stage for
waste load allocations or during permit development.

Costs can vary widely in the program area depending upon the complexity
of the problem, the approach, and other factors.  Detailed modelling  may
be necessary or a simple approach may be adequate.  EPA encourages the
simplest approach possible to minimize costs and expedite planning and
control.  Availability of WQM funding for such activities has been
limited in the past because of other priorities (e.g., NPDES minimum
technology based requirements) and alternative funding sources have been
explored.  EPA policy has been issued on the availability and use of
section 201 and 205 (g)  funds for examining the need to go beyond
secondary treatment for publicly owned treatment works. This policy is
particularly important because of the need for cost-effective investment
of construction) grants dollars.
WQM Agency Projections

WQM Agencies project a relatively stable priority for the program (See
Table VI-5).  A modest increase in emphasis is given to general or basin
planning.  States appear to be concerned about the need to get a better
understanding of water quality problems which reflects a trend toward
intensive monitoring (See Chapter IV, Section D).  Most of the needs in
this area continue to be related to development of loadings and point
source control requirements.
                                 136

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and General

TMDL/WLA
Other
TOTAL
FY
4
1
5
Basin
79
.0
.5
.5
Planning ($000
FY
5
1
7
80
.5
.5
.0
FY
7
2
9
,000)
81
.0
.5
.5

FY
7
2
9

82
.5
.0
.5

FY
7
2
10

83
.5
.5
.0

FY 84
7.5
2.5
10.0
Most States indicate the need to examine toxic problems.  Advanced waste
treatment and advanced secondary treatment (AWT/AST) planning were also
frequently cited.  States were concerned about providing adequate
justification for the need to go to AWT/AST.   Projections indicate the
unavailability or undesirability of using 201 funds for that purpose.
No explanation was provided.  The need to assess nonpoint source problems,
water quality standards, stream hydrology, instream flow, seasonal
treatment requirements, euthrophication, and  water conservation/reuse
were also discussed.
Analysis

Total projections are generally consistent with the direction taken
elsewhere in the Assessment.  This program constitutes 3% of the total
program in FY 30 and 84.  WQM Agencies desire to incrementally improve
their understanding of water quality problems and selectively develop
waste load allocations for point sources while giving highest priority
to the minimum statutory requirements.

EPA evaluated State projections for statistical validity.  Results
indicated some variability among States on the priority or cost of the
program.  80% of the States were within order of magnitude spending from
$.01 to $.10 per major point source discharger.  8 other States, falling
below and above this range, indicated costs which cannot be adequately
explained without additional information.   The variability does not
appear to correspond to known water quality problems.

Some States explicitly stated that this area was a very minor part of
their program while others indicated it was important.  Differences not
only reflect the different priorities for this program area, but also
variations in emphasis given total maximum daily loads/waste load allocation
as compared to general problem identification and basis planning.  The
lack of consistency among States may reflect confusion over national
policy or EPA expectations in this program area. States may also be taking
approaches which vary widely in costs.  EPA policy to keep modelling
simple may not be reflected in State projections.  The failure in some
States to rely on 201 funding for AWT/AST planning may be in part respon-
sible for the variability.  AWT/AST projections indicated confusion
over the 201 funding policy or problems with implementation.
                                 137

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This diversity indicates several alternative actions.  EPA's policy on total
maximum daily loads, waste load allocations, and general  basin planning may
need clarification.  EPA's expectations and the relationship to national
program priorities should be more clearly understood among States and EPA.
Agency policy on 201 funding for AWT/AST should be evaluated to identify any
implementation problems and assure adequate procedures are in place to use 201
funding at the State and local level  for that purpose.  A more explicit
understanding among States and EPA on the modelling methodology required and
the resources to be invested.  Increased emphasis in water quality based
control will unquestionably increase needs in this area (see Chapter III,
Section D).
                                     138

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                               Section E

                          EMERGENCY RESPONSE
Conclusions
     •    State's projections indicate continued growth in the Emergency
          Response program through FY 84.

     *    The program shifts from program development to implementation.

     •    Superfund passage, not contemplated in State projections, will
          have substantial impacts on WQtl resource requirements unless
          administration or staff response capability is made eligible.

Background

With the increase in land transportation of oil  and hazardous wastes, it is
essential that States be prepared for accidental spills and other mishaps.
Section 106 of the CWA requires adequate authority for such emergencies as
a condition of 106 grant award.  EPA believes that each State should have
a contingency plan to:

          Quickly respond and investigate spills reported

          Determine and eliminate source of emergency

          Monitor cleanup activities

          Examine work sheets and verify cleanup activities

          Write reports and document activities

          Prepare cases for enforcement action

          Inspect hazardous waste sites for licensing and/or remedial action

          License marine terminals

          Review plan for oil/water separator installations

          Respond and investigate pollution complaints

          Followup inspection to insure compliance

It is important to note here that 70% of the States have established programs
to implement the above (Figure VI-I).

In 1978, a WQM Policy Memorandum (SAM 35) was issued which outlined increased
State responsibilities in responding to environmental  emergencies under the
CWA.  Subsequent to SAM 35, the proposal for Superfund legislation was intro-
duced.   Under the proposed legislation, Superfund will not cover administrative
                                 139

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    cost for the emergency response  program.  However, equipment  costs nay be
    covered.

    State Projections

    States project substantial  program growth with relatively no  change in priority
    for the program by FY 84.   The program constitutes 3% of the  total needs.  Pro-
    jections indicate a shift  from planning toward implementation.

    Table VI-6: Total State Projected Needs for Emergency Response,  FY 79-84	

                             FY 79     FY 80     FY 81     FY 82      FY 83     FY 84
    Total Needs ($000,000)    3.5
5.5
3.0
8.0
3.5
9.0
     In projecting needs, States  did  not take into consideration  Superfund passage.
                                   FIGURE VI-1
            STATUS OF EMEREGENCY REPONSE PROGRAMS PROJECTED
ALASKA
HAWAII
       NO PROGRAM

       NO DATA

       DECREASES THROUGH FY 84

       NO GROWTH

       WELL IMPLEMENTED PROGRAM
                                        140

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Analysis

EPA views the States' role in the emergency response program as one of continued
growth in response capabilities.  State projections reflect this as a growth
in planning and implementation of a contingency program response to pollution
emergencies (spills, etc.).  Administrative costs which constitute the majority
of needs projected, are not eligible under Superfund, as proposed by the
Administration.  Increased responsibility above State projections will inevitably
be placed on the WQM program with Superfund passage.  Needs would increase
substantially.   The funding outlook for meeting those needs at existing resource
levels is unfavorable.   Emergency response needs should be more comprehensively
addressed through a joint State/EPA effort.  A strategy for meeting these
needs under Section 106 and 311 of the CWA, SDWA, RCRA, Superfund, and other
means should be developed.
                                          141

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                                   Section F

                             OTHER STATE PROGRAMS
Conclusion

There is a continuing but limited need for WQM support to other State
program activities.  States perceive relatively no growth in this area.
Background

In addition to all of the activities previously discussed in this report,
other State activities are eligible for WQM funding under section 106
of the Clean Water Act.  States indicated these needs separately in the
Assessment.
State Projections

Generally these needs represented priority activities in a particular State
of projects of short duration which are not part of ongoing activities in
other program areas.  There tends to be some overlap or relationship to other
program areas specifically discussed elsewhere in the Report.   Some of the
activities covered here are water quality research, technical  assistance,
education programs, Statewide conferences, and experimental projects in
wastewater reclamation and sludge management.


Table VI-7: Total State Projections for Other State Programs,  FY 79-84	

               FY 79     FY 80     FY 81      FY 82     FY 83     FY 84

Total Needs
($000,000)      3.0        6.0       6.0       5.5       5.5       6.0

Total Staff
Needs          80.6      104.0     121.4     127.9     131.8     138.0
13 States projected needs in this category.  The large increase between FY 79
and FY 80 is explained by 1091% increase, ($216,000 to $2,574,000)  in California
for water quality research and wastewater reclamation.  As resources become
increasingly scarce and CWA responsibilities  increase, the priority allocated
to this aspect of the program progressively wanes.
                                     142

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Chapter VII



Clean Lakes
[Reserved]
      143

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State Clean Lakes Program Needs — FY-80 to FY-84
FY 80 FY 31 FY 32 FY 33 FY 34
# of # of # of # of # of # of # of # of # of * of
Phase Phase Phase Phase Phase Dhase Phase Phase Phase Phase
Is II's I's II's I's ri's I's II's I's II's
Alabama 0 00
Alaska 3 03
Arizona 0 01
Arkansas 1 0 2
California (1) (1) (3)
0 000000
1 030201
0 (1) (1) (1) (1) (1) (1)
0 213232
3) (3) (3) (3) (3) /3) (3)
North Carol ina
not returned — — — — — — — — — —
South Carol i na 0 00
Colorado 2 0 '7)
0 2 C 2 2 2 2
7) (8) (8) (4) (4) 0 1
Connecticut (3) (3) (3) (3) (3) (3) (3f (3) (3) [3)
Nortn Dakota 1 0 1
South Dakota 0 22
Delaware (1) (1) (1)
Washington O.C. 0 00
Florida (4) f4) fd)
Seorgia 3 05
Guam G 0 0
Hawaii 0 00
Idaho 0 01
11 1 1 nois 1 04
Indiana ''1 fll (21
Iowa i 4; (41 (4j
Kansas 0 0 1
5) (4) f4) 'a1. ;3)
J ' i : ( 1 5 • 1 ) ' 1 ) ' - ' ( i 1
2 '21 ( 2 ) •' 2 ) ' 2 ' : . ) 2 ;
•3) 3) |l\ .^11 '5) -5)
1 / 1 -- y v 1 ^ - . \ - ' \ 1 /
0 3 0 0 J 0 0
0 : 3 0 1 3 1
i •' i ' ( i ) ' i ) ' i • i ) : i ;
5; '5) '.5) (5) ;5, ;5) !-;)
3 524532
i 122102
1 310301
J 3 () ^ ; ^ 1
0 '2) (2) (21 (2) '2* (2)
1 100113
0 00000 0
0 i 0 1 0 0 C
0 202020
5} '4) (^ (4) '^) '7', '.7|
o h) (i) /i^ 'D !i; (i)
0 003000
(30) (7) (7) (5) (5) (5) (5)
0 000000
(5) '4) f4) (5) (5) (6) (6)
(6) (9) (9) (10) (10) (10) (10)
0 010110

TOTALS 31 71 133
120 130 124 125 131 121 132
TOTAL DOLLARS If 4,566 ff 11,336-$ 8,106 f 26,400 f 8,070 $ 32, 936f8, 983 93,954 J 6 ,468 f 37,985
                          144

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    CHAPTER VIII



INTERSTATE  AGENCIES
         145

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                              INTERSTATE AGENCIES

The traditional issue of whether water pollution programs are to be administered
primarily on the basis of watershed or political boundaries has been resolved
by the passage of P.L. 92-500 and by the subsequent issuance of EPA regulations
governing the national water pollution control  effort.   The net effect of this
Act and set of regulations is to establish a joint Federal-State program, which
relies on the State as the basic administrative unit.   Interstate Agencies play
an important role in water pollution control.  In interstate waters with partic-
ularly complex problems and interrelationships, their perspective is valuable
in assisting with or complementing State activities.   With regard to the specific
role of Interstate Agencies, the Act states that: "The Administrator shall
encourage compacts between States for the prevention  of pollution" (section 103).

The Interstate Commissions can  play a valuable role in coordinating the pro-
grams of several States as they relate to a specific  river basin or other body
of water.  This coordination is particularly valuable in the areas of standard
setting, monitoring and water quality management planning but may extend to
other program areas as the need arises.  Included in  the coordination function
is the facilitating of information exchange between States, for example, by
arranging meetings focused on functional areas of concern to all States in a
river basin.

In addition to the coordination role, there are several functions which are
particularly suited to interstate agencies.  One of these is determination
of wasteload allocations between States on a stream but not within those
portions of a stream inside one State's boundaries.  Another is the preparation
of mathematical models of a stream.  Additionally, an interstate agency is in
the position to review monitoring data on a river, to point out major problem
areas and to assist in holding an individual compact State accountable to the
other States regarding a particular problem.

Also, interstate agencies are able to fund and supervise contracts for special
studies or projects which affect and entire stream or an interstate portion
thereof which are of benefit to compact States.  Additional functions may be
assigned to the interstate Agencies by EPA and the States according to changing
needs and priorities consistent with EPA's national strategy.
                K
6 Interstate Agencies participated in the Assessment.  The Interstate Agency
projections and a summary is provided below  (see table).  The Assessment
indicates Interstate Agencies perceive the need to continue activities discussed
above with a moderate increase in resources.  These activities are similar
to those undertaken by States.  For further explanation of program areas, see
Chapters II-VI.  Interstate Agencies will continue to focus on monitoring which,
by FY 84, represents 46% of the total needs.  Interstate Agencies stress the
continuation of support activities to the NPDES program with permit review,
application processing, review and interpretation of water quality data for
compliance, and assistance in enforcement negotiations.
                                     146

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They will conduct and coordinate with 208 agencies.  Nonpoint source activities
will emphasize development and implementation of urban runoff control programs.
All Interstate Agencies project monitoring needs, including ambient and
intensive surveys.  Some project the need to assist municipal facilities with
operator training to improve plant operation.  Emergency response programs are
expanded in the areas of spill prevention and spill response preparedness.
One Agency projected pretreatment needs and continued work in developing
source control requirements.  The Agencies will  participate with States in the
development of 305(b) reports, provide technical assistance in various areas
of pollution control, conduct public education and information programs, and
coordinate State and Interstate programs.
                                   147

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                            INTERSTATE  AGENCIES
                     NEEDS  ASSESSMENT  SUMMARY SHEET


A)   Total Funding Needs  Identified In the /leeds Assessment.


     On the table below,  include  total funding needs from aach
problem/program section of  the  Guidance for each year from Ff 79 to
34.
                                       Total Funds
Problem/ Program Section
Construction
Srants fcnagoMnt

Point Sourct Penults
ComoUanct
Evaluation
£nf ore went
General and 9o1nt Sourct
WOM Planning
UPS Planning
and do 1 (mentation
tonitorlng
.^nldoal Facilities
Qoersftons and
Maintenance: Training
emergency Response
"rscrea went


*Cf1 Program
Manaqwieflt
Other Program
icf.vttiss
TOTAL
FT79


75.0
48.1
13.9
274.5
89.7
1416.0
123.0
89.9
5.0


263.8
343.0
2741.9
nrao


74.0
88.0
27. -0
439.0
47.0
1269..0
133.0
179.0
8.0


322.0
360.0
2946.0
Pf 31


140.0
98.0
45.0
525.0
164.0
1739.0
152.0
270.0
50.0


173.0
390.0
3846.0
FY 32


195.0
125.0
65.0
994.0
254.0
1984.0
177.0
270.0
50.0

_
1 	
214.0
457.0
4785.0
n 33


172.0
130.0
80.0
665 . 0
304.0
1996.0
184.0
270.0
45.0


180.0
509.0
4535.0
*Y 34

	 — j
165.0 '
130.0
80.0
467.0
248.0
1997.0
216.0
270.0
40.0 ;


218.0
512.0
4343.0
                                  148

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   .•L-.vironLsrrual Protection Aes
 -•-•n f,.  Library (5PL-16)
; 3  r-earbcrn Street,  Room 1670
Lcago,  IL   60604

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