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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
CHAPTER I
INTRODUCTION
SECTION A - BACKGROUND
SECTION B - METHODOLOGY
-------
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.
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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
-------
CHAPTER II
SUMMARY
SECTION A - SUMMARY OF WQM AGENCY PROJECTIONS
SECTION B - OBSERVATIONS AND IMPLICATIONS
-------
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
-------
"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
-------
"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
-------
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
-------
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
-------
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.
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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.
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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.
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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.
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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."
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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.
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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.
56
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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
65
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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.
66
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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.
67
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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.
68
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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).
69
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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
70
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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
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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
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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
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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
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14
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I I I I I
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Rural
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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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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%
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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.
132
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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
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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
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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.
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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.
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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).
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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.
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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 $2,574,000) in California
for water quality research and wastewater reclamation. As resources become
increasingly scarce and CWA responsibilities increase, the priority allocated
to this aspect of the program progressively wanes.
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Chapter VII
Clean Lakes
[Reserved]
143
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State Clean Lakes Program Needs — FY-80 to FY-84
FY 80 FY 31 FY 32 FY 33 FY 34
# of # of # of # of # of # of # of # of # of * of
Phase Phase Phase Phase Phase Dhase Phase Phase Phase Phase
Is II's I's II's I's ri's I's II's I's II's
Alabama 0 00
Alaska 3 03
Arizona 0 01
Arkansas 1 0 2
California (1) (1) (3)
0 000000
1 030201
0 (1) (1) (1) (1) (1) (1)
0 213232
3) (3) (3) (3) (3) /3) (3)
North Carol ina
not returned — — — — — — — — — —
South Carol i na 0 00
Colorado 2 0 '7)
0 2 C 2 2 2 2
7) (8) (8) (4) (4) 0 1
Connecticut (3) (3) (3) (3) (3) (3) (3f (3) (3) [3)
Nortn Dakota 1 0 1
South Dakota 0 22
Delaware (1) (1) (1)
Washington O.C. 0 00
Florida (4) f4) fd)
Seorgia 3 05
Guam G 0 0
Hawaii 0 00
Idaho 0 01
11 1 1 nois 1 04
Indiana ''1 fll (21
Iowa i 4; (41 (4j
Kansas 0 0 1
5) (4) f4) 'a1. ;3)
J ' i : ( 1 5 • 1 ) ' 1 ) ' - ' ( i 1
2 '21 ( 2 ) •' 2 ) ' 2 ' : . ) 2 ;
•3) 3) |l\ .^11 '5) -5)
1 / 1 -- y v 1 ^ - . \ - ' \ 1 /
0 3 0 0 J 0 0
0 : 3 0 1 3 1
i •' i ' ( i ) ' i ) ' i • i ) : i ;
5; '5) '.5) (5) ;5, ;5) !-;)
3 524532
i 122102
1 310301
J 3 () ^ ; ^ 1
0 '2) (2) (21 (2) '2* (2)
1 100113
0 00000 0
0 i 0 1 0 0 C
0 202020
5} '4) (^ (4) '^) '7', '.7|
o h) (i) /i^ 'D !i; (i)
0 003000
(30) (7) (7) (5) (5) (5) (5)
0 000000
(5) '4) f4) (5) (5) (6) (6)
(6) (9) (9) (10) (10) (10) (10)
0 010110
TOTALS 31 71 133
120 130 124 125 131 121 132
TOTAL DOLLARS If 4,566 ff 11,336-$ 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
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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.
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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.
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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
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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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