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 v>EPA
              United Stales
              Environmental Protection
              Agency
              Office of Water
              Regulations and Standards
              Washington, D.C. 20460
                                         September 1969
              Office of Water
Report to Congress

Water Quality Improvement
Study

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                                        REPORT TO  CONGRESS
                                WATER QUALITY  IMPROVEMENT STUDY
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                                 Prepared by:
                     U.S. Environmental Protection Agency
                                Office  of Water
                   Office of Water  Regulations and Standards
                 Assessment and Watershed Protection Division
                              401 H Street, S.W.
                            Washington, D.C.  20460
LO
                                September 1989
                            US EPA Headquarters Library
                            401 M St., SW    (3404)
                            Washington, DC 20460

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                              TABLE OF CONTENTS
EXECUTIVE SUMHARY	      1


CHAPTER ONE:  INTRODUCTION	      1
    Legislative History	       2
    Genera] Approach and Assumptions in the Water Quality
      Improvement Study	       5
    Report Organization	      12


CHAPTER TOO:  METHODOLOGY	     13
    Overview	     13
    Information Sources	     16
    Description of Methods to Assess Improvements	     23


CHAPTER THREE:  RESULTS	     29
    Improvements in Water Quality - Water Quality Model	     29
    Improvements in Water Quality - Ambient Monitoring  Data	     35
    Improvements in Water Quality - Case Studies	     39


CHAPTER FOUR:  CONCLUSIONS	     49


CHAPTER FIVE:  REFERENCES....	     54

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NUNBER
2-1
3-1
3-2
3-3
3-4











                        LIST OF FIGURES
                                TITLE
Summary of Facilities Screening Process 	
Summary of Water Quality Modeling:   Overall  Results,
Summary of Ambient Monitoring Data Analysis:   Overall  Trends
  for BAT Reaches 	
Trends in Metal Concentrations in Oysters  -  Long  Island  Sound.
Trends in Metal Concentrations for the South  Fork Coeur  d'Alene
  River	
PAGE

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 34

 38
 41

 43

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NUMBER
                             LIST OF TABLES
TITLE
PAGE
1
1-1
1-2

2-1

2-2


2-3

3-1

3-2

3-3

3-4
3-5

Major Assumptions and Limitations 	
Promulgation History of BAT Regulations 	 .> 	
Comparison of RAW and BAT Pollutant Loadings for BAT
Industries 	
Frequency of Occurrence of Selected Priority Pollutants in
BAT Industrial Category Wastewater Discharges 	
Summary of Screening Process Used to Select BAT Facilities
and Reaches for Inclusion in the Water Quality Improvement
Study 	
EPA Ambient Water Quality Criteria Used in the Water Quality
Improvement Study 	 	
Summary of Water Quality Modeling Results: Compliance with
Criteria (At Low Stream Flow) 	
Summary of Water Quality Modeling Results: Compliance with
Criteria (At Average Stream Flow) 	
Summary of Ambient Monitoring Data Analysis: Pollutant
Trends 	
Water Quality Model Results for the Delaware Estuary.... 	
Ambient Water Quality Monitoring Data Summary for Delaware
Estuary 	 	 	
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7

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46

48

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APPENDICES
Volume II contains the technical appendices, providing the backup material
outputs from the water quality model and ambient data evaluation, and is
available under a

Appendix A -


Appendix B -
Appendix C -
Appendix D -

Appendix E -

Appendix F -

Appendix G -










separate cover.




and


Descriptions of EPA Data Bases and Files Used in the Water
Quality Improvement Study



RAW and BAT Pollutant Concentrations by Industrial Category
EPA Ambient Water Quality Criteria for States
(For Heavy Metals with Hardness-Based Criteria)
Reach-by-Reach Listing of BAT Industrial Facilities
by State
Results of Water Quality Modeling of BAT Industrial
Dischargers by State (At Low Stream Flow)
Results of Water Quality Modeling of BAT Industrial
Dischargers by State (At Average Stream Flow)
Results of Ambient Water Quality Monitoring Data Analysi
BAT Reaches by State
















s for











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                                                              Executive Summary
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            Report to Congress on the Mater Quality Improvement  Study

                              EXECUTIVE SUMMARY

     The  objective  of  this report  is to identify improvements in water quality
 attributable  to  the application of best available technology economically
 achievable  (BAT).  This study is  required by Section 308(g) of the Water
 Quality  Act of 1987.  Section 308(g) also requires an evaluation of the water
 quality  program  (including Section 302(a) site-specific water quality
 determinations)  and recommendations of methods for improving such program.
 This study  does  not include an evaluation of non-BAT aspects of the water
 quality  program  since this aspect is now the subject of a major concurrent
 effort mandated  under Section 308(a) of the 1987 Water Quality Act [Section
 304(1) of the Clean Water Act].

     This Report  to Congress presents the results and general conclusions of
 this study  on the  effectiveness of BAT effluent limitations for controlling
 pollutant'discharges  from industrial sources and the resulting improvements in
 chemical and  biological quality of streams and rivers receiving discharges
'from these  industrial sources.  This study does not address the benefits of
 controls other than the national  categorical effluent guidelines, such as
 "best professional judgment" or water quality-based controls implemented at
 the  individual permit level, pretreatment requirements, nonpoint source
 controls, and treatment requirements for publicly owned treatment works.  Nor
 does this study  address the non-water quality impacts that have resulted from
 improved wastewater treatment (e.g., generation of solid wastes or increased
 air  pollutant emissions due to volatization or stripping).

                    LEGISLATIVE HISTORY  AND BACKGROUND

     The  Clean Water Act establishes as a national  goal the restoration and
 maintenance of "the chemical, physical,  and biological integrity of the
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                                                               Executive Summary
 Nation's waters."  As a primary means of achieving this goal, Congress
 prohibited "the discharge of any pollutant by any person11 into the waters of
 the United States unless that discharge complies with the specific
 requirements of the Act Section 301  (a), 33 U.S.C. 1311(a).  Compliance may be
 achieved by obtaining a permit issued pursuant to Section 402 of the Act.
 Permits must incorporate applicable  technology-based effluent limitations
 guidelines promulgated by EPA on a nationwide, industry-by-industry basis
 under Sections 301(b) and 304, and if EPA has not promulgated guidelines,
 limitations are applied in individual permits on a case by case basis (Section
 302).  Effluent limitations are implemented in two stages.  By July 1, 1977,
Ldischargers to surface waters were required to achieve effluent limitations
 applicable to best practicable control technology currently available (BPT).
-For toxic pollutants and nonconventional pollutants, they are required, by
 1984, to achieve effluent limitations applicable to best available technology
 economically achievable (BAT).  Separate requirements were established for
 industrial facilities that discharged wastewaters to publicly owned treatment
 works (POTWs) and for new sources.

     The development of categorical standards, including BPT and BAT
 regulations, has spanned a period of 16 years.  Roughly half of the original
 BPT regulations promulgated in the mid-1970s have remained unchanged, despite
 additional regulatory activity for industrial categories.  For some of these
 categories, the BPT effluent limitations have equaled BAT.  Therefore, the
 technology basis for limitations for some industrial categories has been
 unchanged since the mid-1970s; for others, however, the statutory deadlines
 for compliance with BAT limitations  have not yet passed.

     "Technology-based" limitations are used by permitting authorities to set
 minimum pollution control requirements for all dischargers other than publicly
 owned treatment works.  In some instances, however, additional controls may be
 necessary to meet water quality standards.  Section 304(1) of the Clean Water

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 •              The  limitations  required  under  EPA's  effluent guideline  regulations have
I            resulted in  a significant  reduction in  the  amounts  of  toxic, conventional,  and
            nonconventional  pollutants that  are discharged  to the  nation's waters.  While
            these  reductions in  themselves have improved water  quality,  the extent of such
j|          improvements has not been  examined  closely.  This study  attempts to determine
            the  extent of these  improvements, on a  nationwide scale, through the
 I          examination  and  use  of currently existing EPA data  sources.  However, this
            study  does not attempt to  quantify  benefits which result from improved water
I            quality.  These  include increased sport and commercial fishing, and improved
            recreational opportunities.
                                                                          Executive Summary


            Act (added by the 1987 Amendments)  requires States to identify waterbodies
           /that are. impaired by toxic discharges from point sources  and develop
           v  - •
            strategies to control these discharges.   States were to identify waterbodies
            and develop individual control  strategies (ICSs) by February 4, 1989 and must
            achieve applicable water quality standards on or before June 4, 1992.   EPA
            approved or disapproved the ICSs on June 4, 1989,  and where EPA disapproved an
            ICS, the revised ICS must achieve applicable water quality standards on or
            before June 4, 1993.

                                             METHODOLOGY
                Three  methods,  or components, were  used  to  identify  and/or project the
            extent  of  improvements in  water  quality that can  be  attributed to the
            implementation  of BAT effluent regulations.   These are:   (1) water quality
           (modeling of pollutant discharges by  industries  regulated by the  BAT
            limitations;  (2)  analysis  of ambient water quality monitoring data for stream
            segments receiving  discharges from BAT  facilities; and (3) summarization of
            water quality improvement  case studies  relevant to the BAT regulations.  For
            the  purpose of  this study,  a water quality improvement,  as it pertains to the
            first two  components, was  defined by the Agency as:

                •   Complying  with EPA  national ambient water  quality criteria after the
                   implementation of BAT, having exceeded (not complied with) water
                   quality  criteria prior to BAT.
                                                  in

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                                                              Executive Summary
    •  A decrease In in-stream pollutant concentration after implementation
       of BAT.
    For the first component of the study, modeling was performed to project
 in-stream pollutant concentrations of ten selected pollutants^(six heavy
 metals, cyanide, and three organic chemicals) for comparison with EPA ambient
 water quality criteria.  These pollutants were selected because they are the
 most common toxic chemicals present in the wastewater discharges of BAT
 facilities.  Although national water quality criteria are guidance and may be
 more or less stringent than applicable State water quality standards, national
 water quality criteria were selected as the basis for comparison for two
 reasons.  First, national water quality criteria provide a nationally
 consistent measure for comparison and second, they account for the fact that
 many States have not yet adopted all necessary numerical water quality
 standards for toxic pollutants.

    Only direct discharging industrial facilities in those categories having
 BAT regulations that specifically regulate toxic pollutants (i.e., those
 toxic, or priority, pollutants identified in the Clean Water Act of 1977) were
 included.  Indirect dischargers (i.e., those that discharge to POTWs) were not
 evaluated in the model.  The model focused on determining the impacts of these
 discharges on the unique stream segments (or reaches) that receive the
wastewater discharges.  No effort was made to determine downstream or
 cumulative effects.  The model also evaluated only streams and rivers; lakes,
 estuaries, and shorelines were not included because of the difficulty involved
 in determining the dilution characteristics.

    Two treatment levels were used to project the benefits of the categorical
 limitations:  (1) raw, or untreated, discharge levels; and (2) levels
 representing compliance with BAT limitations.  Industry-wide pollutant
concentrations representing long-term average discharge levels were used.

    In the second component of the study, ambient water quality monitoring data
were analyzed for those reaches receiving discharges from the modeled BAT
 facilities.   Since the methods available for analyzing these monitoring data

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                                                              Executive Summary
are best suited for determining relative differences in concentrations over
specific time frames, this evaluation focused on showing trends in the
in-stream levels for the ten selected pollutants between two time periods
selected to represent pre- and post-BAT conditions.  The major assumptions and
limitations that pertain to the first two components of this study are
summarized in Table 1.

    The last component of this study involved the presentation of actual case
studies showing that the implementation of BAT resulted in improvements in the
chemical and biological quality of the receiving waters.  Most water quality
improvement studies have focused on conventional pollutants discharged from
municipal facilities, so few studies that target toxic pollutants from
industrial discharges exist.  Several studies, however, are pertinent to the
BAT regulations and resultant improvements in water quality, and these are
summarized below.

    A special case study was developed by the Agency to evaluate the
improvements resulting from BAT on a typical estuary.  This study used a water
quality model to project theoretical improvements, which were verified through
the review of ambient monitoring data.

                            RESULTS  OF THE STUDY

    The results of the three methods indicate that water quality improvements
have occurred as a result of the application of BAT.  The model evaluated
2,490 individual BAT facilities, discharging to 1,546 unique reaches (totaling
24,289 river miles).  On a pollutant-by-pollutant basis, pre-BAT compliance
with water quality criteria ranged from 43 percent (copper) to 97 percent
(toluene) in the river miles assessed under low flow conditions.  Compliance
with criteria after BAT increased by an average of 20 percent for each
pollutant.  Improvements under average flow conditions are less pronounced;
compliance rates ranged from 75 (cyanide) to 100 (phenol, toluene, and
benzene) percent prior to BAT and from 90 (mercury) to 100 (nickel, phenol,
toluene, and benzene) percent after BAT.

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                                                       Executive Summary
                             TABLE 1
              MAJOR ASSUMPTIONS AND LIMITATIONS

Study is limited to only the reaches where BAT industries are located
because of the uncertainty in modeling the fate and transport of
pollutants without extensive site-specific information.  Consequently,
some reaches may have been excluded that benefited from BAT.

Analysis focused only on direct dischargers.  Indirect dischargers
were not included.  By not including indirect dischargers, BAT industry
plant population was reduced and potential water quality improvements
underestimated.

Projection of BAT benefits is limited to the ten most frequently
regulated and monitored pollutants instead of all priority pollutants
to facilitate data collection and analysis.  This approach was
considered adequate to determine trends in water quality improvements
while maintaining a manageable data base.   However, it also excludes
potential BAT benefits for overlooked pollutants.

Water quality model used untreated treatment levels to represent
industry's pre-BAT discharge levels due to the lack of representative
data on treatment in place prior to the BAT.  This approach appears
reasonable because only limited toxics controls existed in 1970s.  But
some BAT benefits may have been overestimated by not considering
existing treatment in-place.  The BAT treatment levels were used to
represent post-BAT conditions.

Water quality model used industry-wide average pollutant
concentrations for BAT industrial categories to represent individual
facility discharge levels.  This assumes every facility in a particular
industry discharges the same pollutants at the same concentrations.

The time period from 1970 to 1980 was selected to represent pre-BAT
conditions; from 1985 to 1988 to represent post-BAT conditions
(intervening years assumed as transition)  based on the BAT promulgation
dates (with an assumed 2-year implementation period) in our ambient
water quality analysis.   Consequently, the STORET monitoring data
available for analysis were considerably reduced in scope.  Also, full
benefit of BAT promulgated in the mid-1980s is not yet fully reflected
in monitoring data.

Ambient monitoring data was collected for  only those reaches
receiving discharges from BAT facilities.   The location of the
individual  monitoring stations in relation to the discharge(s) was not
readily available.

National water quality criteria were used  rather than individual
State standards because many States do not yet have numerical  standards
for many toxic pollutants, and EPA criteria provide a consistent basis
for nationwide in-stream pollutant concentration comparison.  Existing
State criteria may be more or less stringent than EPA criteria.

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                                                              Executive Summary



    Prior to the implementation of BAT, only 29 percent of the assessed river

miles were projected to comply with all the criteria for the ten selected

pollutants under low stream flow conditions (58 percent of the river miles

were projected to comply under average flow conditions).  After industries

meet the discharge requirements of BAT, an additional 29 percent of the

assessed river miles are projected to comply with criteria (at both average

and low flow conditions).  Individually, the pollutants most associated with

noncompliance are mercury, copper, and lead.  After the implementation of BAT,

this study projects that 42 percent of the river miles assessed may not comply

with criteria for one or more of the modeled pollutants under low flow (12

percent at average receiving stream flow).  This projection, however, is not a

precise measure of BAT derived improvements, since it is dependent on the

number of pollutants evaluated.  These river miles not complying with criteria

may require further water quality-based toxic controls depending on State

water quality requirements, including site-specific water quality criteria.


    Ambient monitoring data were available for both time periods evaluated for

at least one of the selected inorganic pollutants for 429 (8,434 river miles)

of the 1,546 reaches evaluated by the model.  Limited ambient data were

available for the three selected organic pollutants (toluene, benzene, and

phenol) but unfortunately, none of the reaches had monitoring data for both

time periods for any of the organics.  As a consequence, this monitoring data

analysis was reduced in scope, as compared to the discharge model.

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    On an individual pollutant basis, the ambient monitoring data analysis

found reductions in in-stream concentrations for each of the seven monitored

pollutants.  These reductions ranged in scope from 69 percent of the monitored

river miles for zinc to 87 percent of the monitored river miles for mercury.

In terms of overall pollutant reduction trends (considering all monitored
pollutants), improvements were shown for 76 percent (6,397 miles) of the 8,434

river miles assessed.
                                       vii

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                                                              Executive Summary
    However, ambient monitoring data also indicated that for 14 percent (1,147
miles) of the assessed river miles, overall  pollutant concentrations increased
between the two time periods.  Eleven percent of the river miles (890)  were
found not to have a significant difference between the pre- and post-BAT
average concentrations.  Possible explanations for this deterioration or lack
of progress include:  variability in stream conditions; discharges from new
sources; changes in upstream pollutant inputs; pre-BAT treatment may have been
equivalent to BAT (thus not changing the overall performance);  or sources that
either met required limitation prior to ambient sampling or have not yet
attained these limitations.

    The six case studies included in this study present various types of water
quality improvements that can be attributed to BAT.  Three show reduced heavy
metals concentrations, resulting from BAT-type limitations, in  the receiving
stream and the return of less pollutant-tolerant aquatic biota.  Another case
study presents data on oysters which shows a decrease in metal  concentrations
between samples collected in the 1970s and those collected in the 1980s (BAT
controls on metal industries were implemented on upstream sources in the
mid-1970s).  Two studies show that reduced pollutant discharges from pulp and
paper mills improved oxygen conditions, causing a return of indigenous  fish
species.

    In addition, the special case study verified that toxic pollutant levels
in the Delaware estuary have been reduced, at least partially as a result of
BAT.

                          CONCLUSIONS OF  THE STUDY
    The three components of this study (e.g.,  water quality modeling,
monitoring data evaluation and case study reviews) indicate that water quality
has improved significantly as a result of the implementation of the BAT
effluent limitation regulations.

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                                                              Executive Summary


    The water quality model projects that during average stream flow
conditions, compliance with WQC for each of the evaluated pollutants under BAT
is 90 percent or higher.  For four of the evaluated pollutants, compliance is
100 percent.  In addition, 88 percent of all stream miles are projected to
meet WQC for all 10 evaluated pollutants, compared to 59 percent prior to BAT.

    During low stream flow conditions, compliance with individual pollutants
ranges from 73 to 100 percent.  The percentage of waters meeting WQC for all
10 pollutants is projected to be 58 percent with BAT, compared to 29 percent
prior to BAT.

    Under BAT, 12 percent of all river miles are projected to exceed WQC for
one or more pollutants during normal stream flow; 42 percent of all river
miles may exceed one or more WQC during low stream flow.  Depending on
individual States WQC, additional water quality controls for some pollutants
may be necessary to bring those reaches completely into compliance.

    Ambient monitoring data analysis also shows significant improvements, in
terms of pollutant reductions trends.  Seventy-six percent of river miles in
the data base showed an overall decrease (improvement) in pollutant
concentrations after BAT.  At the same time, 14 percent of monitored river
miles were shown to increase in concentrations from pre-BAT to post-BAT
period.  The overall reductions in pollutant levels, however, reflect not only
the benefits of BAT controls but also the benefits from water quality-based
limitations, municipal treatment improvements, controls on non-BAT industries
and nonpoint sources, and, to an unknown extent, lower detection limits
between the two time periods.

    The full benefit of the implementation of the BAT regulations is not yet
reflected in the ambient monitoring analysis.  National categorical standards
have recently been promulgated for one major industry, organic chemicals
manufacturing, which will reduce the industry's toxic pollutant direct
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                                                              Executive Summary
discharge loadings by an estimated 1.1 million pounds per year.  Standards
have yet to be promulgated for another industrial category (pesticides
manufacturing).  While the ambient data do reflect some of the benefits
attributable to BAT, the full effect will not be evident until the early 1990s.

    Actual cases where the implementation of BAT has resulted in water quality
improvements present the best illustration of the effectiveness of the
categorical standards; however, few such cases are available.  Those studies
that do exist have shown that the BAT regulations have had a positive impact
on water quality of the receiving stream, both in terms of lower chemical
concentrations and increased biological activity.  In most instances, the
streams/rivers assessed in these case studies were highly polluted prior to
BAT, and even after the discharge levels had been reduced to BAT levels,
additional water quality-based controls were and will continue to be
necessary.  In all cases, the implementation of BAT has resulted in
considerable improvements in the chemical and/or biological quality (as
measured by an increase in less pollution-tolerant aquatic life) of the
receiving waters.

    The site-specific modeling of the Delaware River estuary predicts BAT will
achieve compliance with water quality criteria for the 10 modeled pollutants.
Ambient monitoring data also show a decreasing pollutant concentrations
trend.  However, full benefits of BAT are not yet reflected in monitoring data
because of the number of organic chemical facilities on this estuary.  Organic
chemical BAT guidelines were recently (11/87) promulgated, consequently many
of these facilities may not yet be operating at BAT levels.

    Considering the results of each component of this analysis, together with
their respective assumptions and limitations, the BAT regulations have been an
effective step toward improving the quality of our nation's surface waters.
The extent of their effectiveness is difficult to assess, however, given the
limits of existing EPA data sources and the fact that BAT controls have yet to

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                                                              Executive Summary



be universally applied.  Also, by not considering improvements resulting from

the categorical pretreatment requirements, the extent of the improvements

resulting from the overall national water quality program are underestimated.

There may be a need for additional water qualHy-based controls beyond BAT in

some cases to meet State water quality standards.  In addition, as required by

Section 304(m) of the Water Quality Act of 1987, the Agency will establish a

schedule for:  (1) the annual review and revision of promulgated effluent

guidelines, and (2) the promulgation of regulations for industrial categories

identified as sources of toxic and nonconventional pollutants for which

guidelines have not previously been established.
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                                                                   Introduction
                                  Chapter One


                                 INTRODUCTION


    This report presents the findings of the Water Quality Improvement Study,

conducted by the U.S. Environmental  Protection Agency (EPA) as required by the

amendments to the Federal Water Pollution Control  Act (Clean Water Act).

These amendments, known as the Water Quality Act of 1987 (PL 100-4), included

several requirements for studies of the Nation's water quality and the

regulations controlling pollutant discharges.  Congressional intent was to

determine the state of the Nation's water quality and to review the

effectiveness of regulatory programs protecting or improving that water

quality.  Section 308 of the Water Quality Act requires the Administrator of

the EPA to report to Congress on the effectiveness of the water quality

improvement program, especially the application of best available technology

(BAT) effluent limitations to control pollutant discharges from industrial

sources.  This report addresses the requirement for a Water Quality

Improvement Study.


    The specific areas to be addressed by the Water Quality Improvement Study,

as specified in Section 308(g), are:


 '   "The Administrator shall study the water quality improvements which have
    been achieved by the application of best available technology economically
    achievable pursuant to Section 301(b)(2) of the Federal Water Pollution
    Control Act.  Such study shall include,  but not be limited to, an analysis
    of the effectiveness of the application  of best available technology
    economically achievable (BAT) pursuant to such section in attaining
    applicable water quality standards (including the standard specified in
    Section 302(a) of such Act) and an analysis of the effectiveness of the
    water quality program under such Act and methods of improving such
    program, including site specific levels  of treatment which will achieve
    the water quality goals of such Act.
                                         -1-

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                                                                   Introduction
    Not later than 2 years after the date of the enactment of this Act, the
    Administrator shall submit a report on the results of the study ...
    together with recommendations for improving the water quality program and
    its effectiveness to the Committee on Public Works and Transportation of
    the House of Representatives and the Committee on Environment and Public
    Works of the Senate."

    EPA's Office of Water was directed by the Administrator to prepare this

Report to Congress.
                             LEGISLATIVE HISTORY


    The Clean Water Act established a comprehensive program to "restore and

maintain the chemical, physical, and biological integrity of the Nation's

water."   Under this program, industrial dischargers were required to achieve

"effluent limitations requiring the application of the best practicable

control technology currently available" (BPT) by July 1, 1977, and "effluent

limitations requiring the application of the best available technology

economically achievable (BAT) ... which will result in reasonable further

progress toward the national goal of eliminating the discharge of all

pollutants," by July 1, 1984 {under Sections 301(b)(l)(A) and 301(b)(2)(A),

respectively).  New industrial direct dischargers were required to comply with

Section 306 new source performance standards (NSPS) based on best available

demonstrated technology; existing and new dischargers to publicly owned

treatment works (POTW) were subject to pretreatment standards under

Sections 307(b) and (c), respectively, of the Act.


    The requirements for direct dischargers are incorporated into the National

Pollutant Discharge Elimination System (NPDES) permits issued under

Section 402 of the Act.  Permits must incorporate applicable technology-based

effluent limitations guidelines promulgated by EPA on a nationwide,

industry-by-industry basis under Sections 301(b) and 304, and if EPA has not

promulgated guidelines, limitations are applied in individual permits on a
                                        -2-

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case by case basis (Section 302).  Effluent limitations are implemented in two
stages.  By July 1, 1977, dischargers to surface waters were required to
achieve effluent limitations applicable to best practicable control technology
currently available (BPT).  For toxic pollutants and nonconventional
pollutants, they were required, by 1984, to achieve effluent limitations
applicable to best available technology economically achievable (BAT).
Separate requirements were established for industrial facilities that
discharged wastewaters to publicly owned treatment works (POTUs) and for new
sources.  Pretreatment standards were made enforceable directly against
dischargers to a POTW (indirect dischargers).

    As a result of the Clean Water Act, BAT effluent limitation guidelines
have been promulgated for 24 industrial categories (for one category,
pesticides manufacturing, the BAT guidelines are currently being developed).
The promulgation of the effluent limitation guidelines for these industries
has occurred in two "phases."  The first "phase" was prior to the passage of
the Federal Water Pollution Control Act (PL 95-217), commonly referred to as
the Clean Water Act of 1977, with the limitations focusing mostly on
conventional pollutants.  Many of the BAT limitations promulgated at this time
were withdrawn or rescinded, while some of the BPT limitations remained in
effect.  The second "phase" regulations were promulgated after the 1977
amendments and reflect additional controls on toxic pollutants.  Most of the
second "phase" regulations were promulgated in the early 1980s (Table 1-1).
However, these regulations for one major industry (organic chemicals
manufacturing) were not promulgated until 1987, and one regulations for the
pesticide manufacturing category are presently being prepared.

    The effluent limitations specified under Section 301(b)(l)(A), (B) and (2)
of the Act are "technology-based" limitations.  These limitations are used by
permitting authorities (EPA or the States) to set minimum pollution control
requirements for all  industrial dischargers without regard to the quality of
                                         -3-

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Promulgation


Industry Name

Aluminum Forming
Battery Manufacturing
Coal Mining
Coil Coating
Copper Forming
-

Table 1-1

History of BAT Regulations

Promulqation Dates for
Phase I

. *
_ *
04/77
. *
_ *
Electrical & Electronic Components - *
Foundries
Inorganic Chemicals
Iron & Steel
Leather Tanning
Metal Finishing
Nonferrous Metals
Nonferrous Metals Forming
Ore Mining
Organ ics/P&SF
Pesticides
Petroleum Refining
Pharmaceuticals
Plastics Molding & Forming
Porcelain Enameling
Pulp & Paper
Steam Electric
Textiles
Timber Products
KEY
* These categories represented a
Products category during Phase
@ Minor changes (amendments) have
_ *
03/74
06/74
04/74
03/74
04/74
-
11/75
04/74
Introduction





BAT Requlations
Phase II

09/83 @
02/84 
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                                                                   Introduction
receiving waters.  In some cases, however,  technology-based  standards  are  not
enough.  If water quality does not support  the designated  use  even  after every
discharger meets his technology-based standards,  additional  controls must  be
applied.  Section 301(b){l){C) of the Act requires "any more stringent
limitations," including those necessary to  meet water quality  standards,
whenever meeting the technology-based standards in Section 301 fail to attain
or maintain the water quality called for in the river or stream (water
quality-based limitations).  Section 302(a) also  authorizes  the Administrator
to establish effluent limitations more stringent  than those  necessary  to meet
quality standards in order to meet the water quality goals of  the Act.

    In the Water Quality Act of 1987, Congress added new Section 304(1), which
requires States to develop lists of impaired waters,  lists of  point sources
and amounts of pollutants causing toxic impacts and "individual  control
strategies" for such point sources.  These  new requirements  should  aid in  the
identification of waters that will need water quality-based  standards.  These
provisions direct immediate attention to establishing controls where there are
known impacts due entirely or substantially to point sources of Section 307(a)
toxic pollutants.  The identification of waterbodies and point sources and the
development of control strategies is the subject  of a separate Agency  effort.
The statutory deadline for identification of waterbodies and development of
individual  control strategies (ICSs) was February 4,  1989, and must achieve
applicable water quality standards on or before June 4,  1992.   EPA  approved or
disapproved the ICSs on June 4,  1989, and where EPA disapproved  an  ICS, the
revised ICS must achieve applicable water quality standards  on or before June
4, 1993.

                     GENERAL APPROACH AND  ASSUMPTIONS
                 IN  THE WATER  QUALITY IMPROVEMENT STUDY

    The objective of this report is to identify improvements in  water  quality
attributable to the application  of best available technology economically
                                        -5-

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                                                                   Introduction
achievable (BAT).  This study is required by Section 308(g) of the Water
Quality Act of 1987.  Section 308(g) also requires an evaluation of the water
quality program (including Section 302(a) site-specific water quality
determinations) and recommendations of methods for improving such program.
This study does not include an evaluation of the water quality program since
it is now the subject, of a major concurrent effort mandated under
Section 308(a) of the 1987 Water Quality Act [Section 304(1) of the Clean
Water Act].

    Because of the implementation of BAT by industrial dischargers and the
subsequent reduction in pollutant loadings, it can be inferred that the water
quality in the nation has improved.  As illustrated in Table 1-2, the Agency
estimates that, the result of treatment including BAT, organic priority
pollutant discharges have been reduced by 99 percent from untreated levels and
that inorganic priority pollutant discharges have been reduced by almost
98 percent.  These estimates of pollutant reductions do not account for
treatment in-place prior to the implementation of BAT, and therefore, may
overestimate BAT benefits.  However, the extent of these pollutant reductions
and their contribution to attaining the goals of the national water pollution
control program have not been determined.  This study attempts to determine
the extent of these improvements on a national  scale, through the examination
and use of currently existing data sources.  However, this study does not
attempt to quantify benefits which result from improved water quality.  These
include increased sport and commercial  fishing, and improved recreational
opportunities.

    For purposes of this study,  "water quality improvement11 was defined as one
of the following:

    •  Compliance with EPA national water quality criteria (WQC) after BAT,
       having not complied with  WQC prior to BAT.
    *  A decrease in in-stream pollutant concentration after implementation
       of BAT.
                                         -6-

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                                                           -7-

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                                                                   Introduction
    To determine water quality improvements, the approach used had three major
components:  (1) projecting in-stream concentrations of selected pollutants by
modeling pre- and post-BAT effluent discharges of industries regulated by BAT
to determine theoretical improvements based on compliance with water quality
criteria;  (2) reviewing available ambient water quality monitoring data to
determine trends in chemical water quality; and (3) providing actual case
studies on the implementation of the national effluent regulations for
industrial dischargers and a discussion of any improvements in either the
chemical or biological quality of specific waters as a result of such
implementation.

    The modeling and ambient data review effort primarily focused on:
(1) facilities discharging directly to surface waters that are required, under
the BAT regulations, to control toxic pollutants; and (2) nationwide
improvements.  Indirect facilities (i.e., those that discharge their
wastewater to POTUs), which are controlled by pretreatment standards, were
excluded for two reasons:  (1) there was insufficient information on indirect
facilities within the EPA national data bases, and (2) these facilities are
not controlled by State or EPA-issued permits (NPDES), but rather by local
limits developed by the POTW receiving the discharge.  This study also
excludes industries which are not regulated by the national categorical
(technology-based) effluent limitation guidelines, but rather by "best
professional judgment" permits.  By not considering indirect facilities and
improvements in water quality resulting from pretreatment requirements or
controls on industries without additional categorical effluent limitation
regulations, this study underestimates the extent of the improvements
resulting from the national water quality program.  The effectiveness of the
BAT regulations in improving water quality can be addressed on a national
level because site-specific and/or regional factors are not taken into account
in establishing these technology-based effluent limitations.  The
site-specific nature of water quality-based limits prevents a theoretical
estimate of their effectiveness.  Specific instances where water quality
improvements are attributable to indirect facilities will be discussed, when
applicable, in the case studies.
                                         -8-

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                                                                   Introduction



    The first two components (or analyses) of this study made use of existing

EPA computerized information to expedite the nationwide study.  Ideally, such

information sources would have historical information available for each of

the industrial facilities affected by the BAT regulations.  Ideally, this

information would include pollutant loading information prior to, and after,

implementation of BAT treatment technologies; the date when BAT treatment was

implemented; and in-stream ambient monitoring data specific to each facility.

Unfortunately, existing data bases were developed primarily for the purpose of

and tracking ambient water quality for localized pollution control purposes
and not specifically for performing a nationwide water quality improvement

study.  Thus, the ideal data base described above is not available.


    Other factors also need to be considered, including the long time frame

over which BAT regulations have been implemented.  In addition, for a number

of years some States have been writing water quality-based permits for

industrial dischargers that are generally more stringent than the treatment

requirements of BAT.  Differentiating between the time periods that represent

pre- and post-BAT and which facilities have effluent limitations based on

technology or water quality is not feasible using these sources of data.


    Several assumptions were necessary in order to complete the first two

components of this study using the available EPA information:


    1.  All industrial facilities covered by the BAT regulations will be
        evaluated assuming that technology-based limitations are the basis for
        their respective discharge levels.

    2.  Pre-BAT effluent discharges will  be represented by untreated, or raw,
        levels as determined by EPA sampling programs.

    3.  The pre-BAT period for evaluating ambient monitoring data is from 1970
        to 1980.

    4.  The post-BAT period is from 1985 to the present.
                                         -9-

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                                                                   Introduction
    5.  Ten pollutants were selected to represent toxic pollutant discharges
        from BAT-regulated facilities.  These selected pollutants are the most
        frequently discharged and regulated priority pollutants.
    6.  Only stream segments receiving direct discharges for BAT facilities
        were evaluated.

    One limitation of this study is that it is not currently feasible to
determine which BAT industrial facilities actually have and meet permit
limitations based on the national effluent guideline (technology-based)
regulations.  However, by not considering more stringent controls imposed by
water quality-based permits and assuming that all BAT industries meet the
requirement of the technology-based limitations only, the overall need for the
more stringent controls can be more accurately assessed on a national level.
This is one of the requirements of the water quality improvement study.

    In evaluating the improvements resulting from the BAT regulations, the
ideal scenario would consider discharge levels prior to the implementation of
treatment requirements mandated by the Federal water quality program (i.e.,
pre-BAT), which began in 1972.  Unfortunately, no accurate method exists to
determine or estimate these discharge levels, especially in the area of toxic
pollutant discharges.  In some instances, facilities had treatment of their
wastewater discharges.  In others, untreated wastewaters were discharged
directly to receiving waters.  In addition, EPA's initial sampling of
industrial facilities in the mid-1970s to define effluent characteristics
focused on conventional pollutants and a few toxic metals.  Only later, in
response to the NRDC Settlement Agreement and subsequent amendments to the
Clean Water Act, did the Agency focus its regulatory efforts on the toxic, or
priority, pollutants referenced in the Act.  For this reason, and because it
is Agency policy when determining benefits of BAT guidelines, untreated
wastewater was used as the basis for determining the improvements.  This
assumption will overestimate the actual benefits of the technology-based
program, but the extent of this overestimate is uncertain.
                                        -10-

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                                                                   Introduction
    It was difficult to select appropriate time periods for comparing pre- and
post-BAT ambient water quality monitoring data because BAT treatment levels
for some industries (such as metal finishing/electroplating, pulp and paper,
and textiles) have remained essentially the same since the mid-1970s, while
for others, BAT limitations have yet to be fully implemented or promulgated
(organic chemicals and pesticide manufacturing, respectively).  Taking into
consideration, however, the fact that monitoring for toxic pollutants was not
as common prior to the mid-1970s as it is today and that detection limits for
individual chemical parameters have changed as technology has improved, the
years from 1970 to 1980 were selected to serve as the pre-BAT period.  During
this period some reductions in ambient pollutant concentrations would be
reflected in the monitoring data, but the overall average for that period
should tend to be representative of levels prior to the implementation of
technology-based regulations.  To reflect post-BAT levels, 1985 was selected
as the start date.  A majority of the "Phase II" BAT regulations for the
industrial categories were promulgated in the early 1980s (Table 1-1), so the
period from 1981 to 1984 was considered a transition period and was not
evaluated.

    By using only a select group of toxic pollutants, the overall trends in
water quality can be identified without the need for voluminous amounts of
data.  However, by not considering improvements resulting from reductions of
other toxic pollutants, the full benefits of BAT are underestimated.

    Only those stream segments receiving discharges from BAT-regulated
facilities were included in the first two components of this study.  Because
of difficulty in modeling the fate and transport of these pollutants, no
impacts to downstream stream segments were considered,  thus reducing the scope
of potential improvements.

    The first two components of this study project and estimate improvements
in water quality resulting from the application of BAT.  While these analyses
                                                    -11-

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                                                                   Introduction
provide a good picture of overall national trends, case studies best present
water quality improvements since such improvements are "real  life,"  not
projected or estimated.  Case studies reviewed for this study had to show a
direct benefit in water quality (either chemical or biological) as a result of
facilities implementing limitations set forth by BAT.   The focus of such
improvements or benefits was the reduction of toxic pollutants.  However,
other aspects of technology-based limitations, such as reductions in
conventional pollutant discharges for industrial sources were also considered,
as well as the beneficial results of the implementation of pretreatment
program for indirect dischargers to publicly-owned treatment  works.   However,
this study does not attempt to quantify benefits which result from improved
water quality.  These include increased sport and commercial  fishing,  and
improved recreational opportunities.

                             REPORT ORGANIZATION

    The remainder of this report consists of four chapters that address the
objective of Section 308(g) of the Water Quality Act of 1987  relevant to the
BAT regulations.  Chapter 2 presents a general discussion of  the data sources
and methodology used to identify water quality improvements.   Chapter 3
summarizes the results of the analyses.  Chapter 4 addresses  the study
findings and the evaluation of the effectiveness of the BAT regulations.
Chapter 5 lists the various references used in this study. Volume II  of this
report contains the technical appendices, providing the backup material and
outputs from the water quality model and ambient data evaluation.  Volume II
is available under a separate cover.
                                        -12-

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Methodology

Chapter Two
METHODOLOGY
OVERVIEW
Three different components were used to Identify water quality improvements
resulting from the application of best available technology economically
achievable (BAT): (1) projection of theoretical improvements in water quality
for stream reaches with BAT industries {those industries covered by the BAT
regulations} using water quality modeling; (2) review of ambient water quality
data for pre- and post-BAT time periods; and (3) summary of specific instances
(case studies) where water quality has improved because of BAT. Specifically,
this methodology included the following:
Water quality modeling of industrial facilities with BAT effluent
limitations to control toxics. The model predicted in-stream concentrations
of ten selected pollutants at pre-BAT and post-BAT treatment levels at low and
average receiving stream flow conditions. Concentrations were then compared
to EPA water quality criteria to determine the potential/theoretical water
quality improvements.
Analysis of STORET ambient water duality monitoring data, for the same
ten selected pollutants, for stream segments receiving BAT industrial
discharges for time periods assumed to reflect pre-BAT (1970 to 1980) and
post-BAT (1985 to 1988) conditions. The average values for these two time
periods were used to determine trends in ambient pollutant levels.
Summary of case studies that associate the implementation of national
technology- based effluent limitations with improvements in the chemical and/or

-13-


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                                                                    Methodology
biological quality of the receiving waters.  All improvements that can be
attributable to BAT regulations are considered, primarily reductions in toxic
pollutant discharges but also including controls on conventional pollutants and
indirect dischargers.  A special case study was developed by the Agency to
evaluate the benefits of BAT regulations in estuaries.

    The ten pollutants selected to be evaluated were representative of toxic
pollutants regulated by BAT and could be considered "indicator" pollutants.
These pollutants are the most frequently discharged and regulated priority
pollutants found in the wastewater of the BAT facilities and include six heavy
metals (cadmium, mercury, copper, lead, nickel, and zinc), cyanide, and three
organic chemicals (phenol, toluene, and benzene).  Table 2-1 lists these
pollutants and their frequency of occurrence in the BAT industries effluent.
Also shown are the industries in which these pollutants are regulated.  In
addition, limiting the number of pollutants also reduced the modeling effort
to a manageable size.

    The modeling and ambient data analyses are limited to only those reaches
receiving BAT industrial discharges.  (Reaches are unique segments of streams
and rivers that have been delineated by EPA for the purpose of integrating
water quality and facility information.)  It was beyond the scope of this study
to address the effects of the discharges on reaches downstream of the
industries, even though the downstream reaches are likely to be directly
affected.

    The methodology used to identify water quality improvements is presented in
the following sections:  (1) Information Sources, which presents a brief
description of all the EPA information sources used for the first two
components of the study; and (2) Description of Methods to Assess Improvements,
which presents general discussions of the components of this study - the water
quality modeling analysis, the ambient water quality data evaluation, and
site-specific case studies.  The latter section also provides, for each
                                        -14-

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                                                       Table  2-1
                                Frequency of Occurrence of  Selected Priority Pollutants
                                    in BAT  Industrial Category Vastewater Discharges
Occurrence of
Industrial Category
Aluminum Forming
Battery Manufacturing
Coil Coating
Copper Forming
Electrical & Electronic Components
Metal Molding & Casting (Foundries)
Inorganic Chemicals
Iron i Steel
Leather Tanning & Finishing
Metal Finishing
Monferrous Metals
Nonferrous Metals Forming
Ore Mining i Dressing
Organic Chemicals, Plastics, ft
Synthetic Fibers
Petroleum Refining
Pharmaceuticals Manufacturing
Porcelain Enameling
Pulp & Paper
Textiles
Total Occurrences
Total Regulated
Cadniun
1
R
1
1
1
1
R
1
1
ft
1
R
R


1

1

1
16
5
Mercury

R
1

1
1
R
1
1

1

1


1
1

1
1
13
2
Copper
1
R
R
R
1
R
R
1
1
R
R
R
R

R
1
1
1
1
1
19
10
Lead
1
1
1
R
1
R
R
R
1
R
R
R
R

R
1
1
R
1
1
19
10
Pollutant in
Nickel
1

1
R
1
1
R
R
1
R
R
R
R


1
1
R
1
1
17
8
Zinc
ft
R
R
R
1
R
R
R
1
R
R
R
R

R
1
1
R
R
1
19
14
Industrial Catenorv
Cyanide
R
ft
R
1
1

R
R
1
R
R
R
1

R
1
R

1
1
17
10
Phenol
1

1

(R)
1

1
1
(R)
1



R
1
1

1
1
13
1(2)
Toluene


(R)
1
(R)
I

1
1
(R)

1


R
1
1

1
1
13
1(3)
Benzene



1

1

R
1
(R)




R
1
1

1
1
10
2(1)
KEY


R - Regulated pollutant  in  industrial category.

1 - Detected, but not regulated,  in wastevater of industrial  category.


Values in parentheses denote when pollutant is regulated as part of "Total Toxic Organics.'


SOURCE:  U.S. EPA. 1986.
                                                    -15-

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                                                                    Methodology
component, a summary of the approach and purpose of the analysis,  assumptions

used and limitations in performing the analysis, and the actual  analysis

conducted.  Outputs from the water quality model and the ambient water quality

monitoring data analyses are included in the technical  appendices (Volume II).


                             INFORMATION SOURCES


    To perform the first two components of this study,  readily available and

accessible information contained in the following EPA data bases were used:

Permit Compliance System (PCS), Industrial Facilities Discharge  (IFD) file,

GAGE file, REACH file, and STORE! Water Quality file.  A brief description of

each data base and how it was used is presented below:


    •  Permits Compliance System (PCS) - PCS is a computerized
       management information system for tracking permit status  data for the
       National Pollutant Discharge Elimination System (NPDES).   This system
       was used to identify BAT facilities by SIC code  and to determine their
       discharge status (active or inactive).

    •  Industrial Facilities Discharge (IFO) file - The IFD file
       provides a comprehensive data base of industrial and municipal point
       source dischargers, including discharge flow and location information,
       standard industrial classification (SIC) codes,  and categorization of
       discharge types.  This file was used to locate the BAT facilities,
       identified by PCS, on specific reaches and to provide wastewater
       discharge flows for the water quality model.

    •  GAGE file - The GAGE file stores data from stream gaging
       stations, including:  station location, types and frequency of data
       collected, and stream flow data (mean, annual, and low flow).  The GAGE
       file was used to provide stream flows (both average and low) for the
       water quality model.

    •  REACH file - The REACH file is a digital data base of streams,
       rivers, reservoirs, lakes, and estuaries in the  contiguous  U.S. divided
       into unique segments called "reaches."  The reaches allow EPA (and
       other system users) to integrate data from different files  and data
       bases by assigning unique reach numbers to individual water body
       segments.  This file identified the type of reach (stream or nonstream).
                                        -16-

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                                                                    Methodology
    *  STORE! Mater Quality file - STORET is a data base composed of
       several individual, but related, files, and includes data on:  stream
       flow; physical and chemical characteristics of streams, fish tissue,
       and sediment; municipal waste sources and disposal systems; and
       pollution-caused fish kills.  STORET was used to obtain ambient water
       quality information for the ten selected pollutants.


    All information contained in these data bases was retrieved during

December 1987, with the exception of the STORET data, which was retrieved in

July 1988.


Screening and Evaluation

    Data were retrieved from the EPA data bases and subsequently compiled and

analyzed using a computerized software system.  The files were then screened

to select only those facilities that would be covered by the BAT regulations

and could be evaluated by the water quality model.  All currently active

facilities were also assumed to be active prior to BAT implementation,

therefore neglecting the impacts on water quality for new sources and plant

closings.  The reaches identified as receiving BAT discharges in water quality

model will serve as the basis of retrieving ambient monitoring data.  The

following is a brief description of the screening process:


    1. The EPA data bases contain information on 120,992 industrial dischargers
       and roughly 68,000 reaches.  Of these dischargers, 46,467 are inactive
       (e.g., closed) or their discharge status is unknown, and 53,621 reaches
       do not have any assigned dischargers on them.   All inactive/unknown
       facilities and reaches without dischargers were excluded from this
       study.

    2. Of the 74,525 active dischargers, 59,338 facilities are not covered by
       the BAT regulations and were not included in this study.  This also
       removed 8,556 reaches from consideration.

    3. Five BAT industrial categories (coal  mining, steam electric, plastics
       molding and forming, timber products, and pesticide manufacturing) were
       not evaluated in this study because their effluent regulations either:
       (1) do not specify toxic pollutants;  (2) control only a small volume of
       the total  discharge; or (3) have been rescinded. Therefore, an
       additional 8,353 dischargers and 1,593 reaches were excluded from the
       model/ambient analyses.
                                                   -17-

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                                                                    Methodology
    4. Because  It  is necessary to correlate dischargers with stream locations
       (i.e., reach numbers), those facilities  in the EPA data bases without
       assigned reach numbers were excluded, resulting in the removal of 1,837
       facilities  from the study.  This step also removed all facilities in
       Hawaii, Alaska, and the U.S. Territories, since streams in these areas
       are not currently hydrologically linked.

    5. The water quality model can evaluate only facilities located on
       hydraulic transport ("stream") type reaches; therefore, all reaches
       that are nonhydraulic or boundaries (e.g., coastlines, estuaries,
       lakes, and  shorelines) were excluded.  This screening step eliminated
       683 facilities and 322 reaches from consideration in the study.

    6. The remainder of the facilities and reaches were then screened to
       determine if flow data were available.   One hundred and forty-four
       reaches were excluded because they did not have both average and low
       flows  (which also eliminated 484 facilities) and 1,232 industrial
       facilities  did not have process flows (which removed 497 reaches from
       consideration).  The final step eliminated facilities that may have
       erroneous process flows stored in the data base.  If the process flow
       exceeded the 95th percent!le flow for a  particular industrial category,
       the facility and its corresponding reach were excluded.  This step
       removed 108 facilities and 53 reaches because of possible erroneous
       process flows.

    This screening process, summarized in Table 2-2 and Figure 2-1, identified

2,490 facilities and 1,546 reaches (representing 24,289 river miles) to be

evaluated in the water quality modeling component of the Water Quality

Improvement Study  (WQIS).  The 1,546 reaches were also used as the basis for

retrieving ambient monitoring data for the second component of this study.

Additional Sources

    Additional EPA sources of information (for  the model and ambient analysis)

include (1) industry-wide effluent characteristics by industrial category and

(2) EPA ambient water quality criteria.


    The industry-wide effluent characteristics were used in the water quality

modeling effort to determine the pollutant concentrations discharged by each

of the facilities  evaluated.  The source of these concentrations was the

Monitoring and Data Support Division (MDSD) report, Summary of Effluent
                                        -18-

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                                                                    Methodology
                                    Table 2-2

                          Summary of Screening Process
                    Used to Select BAT Facilities and Reaches
              for  Inclusion in the Mater Quality  Improvement Study
Description of Screening Step
Total facilities/reaches in EPA data bases
No. of reaches without assigned facilities
No. of inactive facilities excluded
No. of non-BAT facilities/ reaches excluded
No. of BAT facilities/ reaches not evaluated*
No. of BAT facilities not assigned reaches
No. of BAT facilities/reaches excluded
because of non- steam reach type**
No. of BAT facilities/reaches excluded
because of unavailable reach flow
No. of BAT facilities/reaches excluded
because of unavailable process flow***
No. of BAT facilities/reaches excluded
because of "erroneous" process flow
No. of BAT facilities/reaches evaluated
No. of
Facilities
120,992
0
46,467
59,338
8,353
1,837
683
484
1,232
108
2,490
No. Of
Reaches
-68,000
-53,621
1,668
8,556
1,593
0
322
144
497
53
1,546
  *Coal/steam/plastics molding and forming/timber products/pesticides
   manufacturing categories.
 **Lakes/coast-shoreline/estuary/artificial/etc.            ^
***Includes "zero discharge" facilities (those facilities that do not
   discharge process wastewater).
                                        -19-

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                                                                  Methodology
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                                                                    Methodology
Characteristics and Guidelines for Selected Industrial Point Source
Categories:  Industry Status Sheets (U.S. EPA, 1986).  For direct dischargers,
pollutant concentrations are provided for four treatment levels:  RAW
(untreated wastewater), CURRENT (the average level of discharge determined by
sampling during the second phase of the BAT rulemaking process), BPT, and BAT
(the expected BPT and BAT discharge levels based on the required treatment
technology specified in the effluent limitations).  These industry-wide
effluent concentrations, developed by EPA's Industrial Technology Division,
were used to provide a consistent source of data for the selected treatment
levels and represent long-term averages.  RAW and BAT levels were used in the
water quality model analysis.

    The calculated in-stream pollutant concentrations from the water quality
model analysis were compared to EPA ambient water quality criteria (either
chronic freshwater aquatic life or human health ingestion of organisms only
criteria) for the ten selected pollutants.  The more stringent human health
ingestion of water and organisms criteria were not used because exposures due
to drinking untreated surface waters (most surface water sources are treated)
are not as likely.

    The human health criterion for benzene (a human carcinogen) represents a
risk level of 10   (1 excess cancer death per 1,000,000 people exposed over
a 70 year period).  For each pollutant, the lower of the two criteria was
used.  Table 2-3 shows the criteria used in this study.  Four of the metals
have hardness-specific criteria.  For these metals, the median hardness value
(as determined through a separate STORET analysis) for each State was used to
calculate State-specific criteria.

    The study used EPA criteria rather than individual State water quality
standards because:  (1) most States do not yet have numerical standards for
toxic pollutants;  and (2) EPA criteria provided a consistent basis for
comparison with in-stream pollutant concentrations, even though some existing
State standards may be more or less stringent than EPA criteria.
                                        -21-

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                                                                    Nethodology
                                    Table 2-3

                       EPA Ambient Mater Quality Criteria
                   Used 1n the Mater Quality Improvement  Study
Pol1utant
  Criteria (ug/1)
              Type
Cadmium
Mercury
Copper
Lead
Nickel
Zinc
Cyanide
Phenol
Toluene
Benzene
Hardness-specific*
    0.012
Hardness-speci f1c*
Hardness-specific*
  100
Hardness-speci fi c*
    5.2
  750
  650
   40
Freshwater aquatic life-chronic
Freshwater aquatic life-chronic
Freshwater aquatic life-chronic
Freshwater aquatic life-chronic
Human health-ingesting organisms only
Freshwater aquatic life-chronic
Freshwater aquatic life-chronic
Freshwater aquatic life-chronic**
Freshwater aquatic life-chronic**
Human health-ingesting organisms only
 *  Hardness-specific criteria are calculated as follows:

       Cadmium  e(°-7852nn(hardness)]-3.49)

       Copper   e(°-8545[1n(hardness)]-1.465)

       Lead     e(1.273[ln(hardness)]-4.705)

       Zinc     e(0.8473[ln(hardness)J+0.7614)

**  Lowest Reported Toxic Concentration:

SOURCE:  EPA Ambient Water Quality Criteria Documents (various dates).
                                        -22-

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                                                                    Methodology
             DESCRIPTION OF METHODS  TO ASSESS  IMPROVEMENTS


    The following section contains brief descriptions of the three methods used

to assess water quality improvements that have resulted from the implementation

of BAT treatment technologies.


Hater Quality Nodeling Analysis

    Water quality modeling was performed to identify theoretical water quality

improvements by pollutant, as well as by reach.  The analysis consisted of

modeling industrial facilities with BAT effluent limitations that directly

control toxic (priority) pollutants.  The model calculated theoretical

in-stream concentrations of the ten selected pollutants at pre-  and post-BAT

treatment levels under low and average receiving stream flow conditions.   The

in-stream concentrations were then compared to applicable water  quality

criteria to identify improvements in meeting these criteria.  Of the 6,834 BAT

facilities with toxic limitations (not including the 8,353 facilities in  the

coal mining, steam electric,  timber products,  pesticides manufacturing, and

plastics molding and forming categories) identified in the EPA data bases,

2,490 were evaluated in the modeling procedure.


    Assumptions and Limitations

    In conducting the water quality modeling,  a number of assumptions were

made.  These assumptions, together with their limitations,  are as follows:


    1. Industry-wide pollutant concentrations  for the BAT industrial
       categories were used to represent individual facility discharge
       levels.  This approach assumes that every facility in a particular
       industrial category discharges the same pollutants at the same
       concentrations; the only difference between facilities in the same
       category is the volume of wastewater discharged.  This assumption  does
       not reflect "real life" conditions, since each facility is different
       and effluent levels vary across categories.  Since this is a national
       study, however, the differences in levels (some higher, some lower)
       will tend to cancel each other out.
                                        -23-

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                                                                    Methodology
    2. Two treatment levels from U.S. EPA  (1986) were used in the water
       quality model:   RAW and BAT.  The RAW treatment level was used to
       represent a particular industry's discharge level prior to the
       promulgation of  BAT. The use of RAW as the pre-BAT discharge level
       overestimates the actual pre-BAT (1972) discharge levels because it
       does not credit  industry with treatment in place at that time.  Since
       it is not known  how much treatment was occurring prior to BAT, RAW
       levels were used.  The BAT treatment level was used to represent the
       levels at which  an industry should be discharging after the
       implementation of the BAT regulations (post-BAT).

    3. Process wastewater flows contained in the IFD data base were used to
       represent pre-BAT (RAW) flows.  Where flow reduction was required by
       the BAT limitations, this was taken into account by reducing the
       pollutant concentration by a proportional amount.  Flow reduction was
       required for the following industrial categories:  aluminum forming,
       battery manufacturing, coil coating, copper forming, foundries,
       inorganic chemicals, iron and steel, nonferrous metals, nonferrous
       metals forming,  and porcelain enameling.

    4. BAT treatment levels were assumed to be the only effluent limitation
       imposed on the industries.  Water quality-based limitations were not
       considered since the site-specific nature of such limitations prevents
       a theoretical estimate of their effectiveness.

    5. The model assumed the pollutant was completely mixed in the receiving
       stream and that no fate-related removal (e.g., sedimentation,
       biodegradation, volatilization) occurred.  While fate-related removal
       could be significant (especially for the organics), this assumption is
       partially offset by not considering background concentrations.

    6. The model assumed that all currently active BAT facilities (as
       designated in PCS) were also active prior to BAT (i.e., plant closings
       and new sources were not accounted for).


    Analysis

    The objective of the water quality modeling was to project pre- and

post-BAT in-stream pollutant concentrations for each reach in the contiguous
U.S. that received wastewater discharges from BAT industries.  There are
currently 24 major industrial categories for which BAT effluent limitation

guidelines have been promulgated (as presented in Table 1-1).  The effluent
discharge water quality modeling was performed for 19 of the 24 industries
using industry-wide concentrations for the ten selected pollutants.  Five of
                                        -24-

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                                                                    Methodology
the 24  industries were excluded because their effluent regulations either did

not specifically regulate toxic pollutants  (coal mining, timber products, and

plastic molding and forming); controlled toxics discharge only for a small

volume  of the total discharge (steam electric); or have been rescinded

(pesticide manufacturing).


    For each of the facilities identified as BAT facilities from the EPA data

bases,  individual plant loadings were calculated (the product of industry-wide

effluent concentrations and process wastewater flows) for each of the ten

pollutants.  To calculate in-stream concentrations, the individual plant

loadings were summed for each pollutant for all facilities on a particular

reach.  These total loadings were then divided by the stream flow (either low

or average, depending on the analysis) and sum of the plant flows.  The

following equation illustrates this procedure:


                             2 (Ce x Qe)

                      '   '   Qs + s ^e)

                        where: C^ = In-stream pollutant concentration (ug/1)
                               Ce = Effluent pollutant concentration (ug/1)
                               Qe - Process wastewater flow (MGD)
                               Qs = Receiving stream flow (MGD).

    This procedure was followed for each pollutant on each reach for the pre-

(RAW) and post-BAT (BAT) effluent levels and summarized on a reach-by-reach

basis (included in Volume II).  The resulting in-stream pollutant

concentrations were also compared to water quality criteria (WQC) to determine

compliance.


Ambient Mater Quality Monitoring Data Analysis

    An analysis of ambient water quality monitoring data for those reaches

identified as having BAT discharges was also conducted to determine water

quality improvements.   Ambient water quality monitoring data (from STORET) for

the ten selected pollutants for time periods reflecting pre-BAT (1970 to 1980)
                                        -25-

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                                                                    Methodology



and post-BAT  (1985 to 1988) were used to determine trends in ambient pollutant

concentrations.  Corresponding monitoring data (i.e., data from both time

periods) was  available for at least one pollutant for 429 of 1,546 reaches

receiving BAT discharges.


    Assumptions and Limitations

    The following is a brief discussion of the specific assumptions, and their

limitations,  made in performing the ambient water quality monitoring analysis:


    1. The monitoring period from 1970 to 1980 represents pre-BAT conditions
       and the period from 1985 to 1988 represents post-BAT conditions.  The
       intervening years were considered a time of transition and were not
       addressed.  All monitoring data for the individual time periods were
       averaged together.  Improvement trends within each time period are not
       considered as well as trends during the transition period.

    2. Monitoring data reported below detectable levels were included only
       where  detected levels were also available.  In those instances, the
       monitored values were set equal to one-half the detection limit.  It
       can not be determined whether or not this practice overestimates or
       underestimates the actual pollutant concentration.

    3. The STORET water quality monitoring data should be used with some
       caution, in that:

       •  The origins of the pollutants monitored include all upstream
          sources, including facilities and sources not evaluated in this
          study (e.g., POTWs, non-BAT industries, natural and nonpoint
          sources);

       •  Information on the location of the monitoring station(s) in
          relation to the BAT industrial facilities (i.e., upstream or
          downstream) was not readily available; and

       •  The flow conditions during sampling were unknown.


    Analysis

    To aid in the determination of the water quality improvements attributable

to the BAT guidelines, ambient in-stream water quality monitoring data for the
ten selected pollutants were analyzed for two monitoring periods - pre-BAT and

post-BAT.  The ambient pollutant data were obtained from EPA's STORET Water
                                        -26-

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                                                                    Methodology
Quality file.  Monitoring data that were "unremarked" (i.e., pollutant
concentration was quantifiable) and data "remarked" (pollutant concentration
less than the detection limit) were used in this analysis.  The individual
monitoring values were retrieved from STORE! and aggregated on a reach basis.
The average concentration for a particular pollutant for each of the two time
periods was calculated by using both the unremarked and the remarked data
(which was set to one-half the detection limit).  This averaging procedure was
used only when there was at least one unremarked value.

    In order to compare the two time periods, it was necessary to exclude
average values where data were available for only one of the two time
periods.  Of the 1,546 BAT reaches, 429 had ambient water quality monitoring
data available for at least one pollutant for both time periods.  The average
concentration for the two time periods were used to determine trends in
chemical water quality.  Three different classifications were used to define
pollutant concentration trends:  improved, deteriorated, and no change.  An
"improved" trend signifies that the pollutant concentration decreased by more
than 10 percent between the two time periods.  Likewise, a "deteriorated"
trend denotes an increase in the post-BAT concentration of more than 10
percent.  A "no change" designation signifies that the pollutant concentration
did not change by more than 10 percent between the two periods.

Mater Quality Improvement Case Studies
    The third approach to determining ambient water quality improvements was
to identify actual improvements (case studies) that can be attributed to the
implementation of BAT requirements.  The focus of this effort was different
from that used for the water quality and ambient monitoring data analyses
since all types of improvements would be applicable, not just improvements
from direct dischargers of toxic pollutants.   Such improvements could include
reductions in conventional (suspended solids or biochemical oxygen demand) or
nonconventional (ammonia and chlorine) pollutants and reductions in toxic
pollutants discharged from POTWs as a result of the implementation of
                                        -27-

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                                                                    Methodology



pretreatment programs.  Improvements could be shown through reduced in-stream

pollutant concentrations, attainment of designated water use, or improved

biological integrity of the receiving stream.


    In order to identify possible case studies, the 1988 State Water Quality

Assessment [305(b)3 Reports were reviewed.  From these reports, potential case

studies were selected for further investigation.  Of the thirty-six 305(b)

reports reviewed, nine States were identified as having potential case

studies.  Based on contacts with these nine States, five case studies were

selected to illustrate water quality improvements attributed to the

application of BAT regulations.  An additional case study was provided by EPA

Region X.  The summary of these case studies are presented in Chapter 3.


    A special case study was developed by the Agency to represent improvements

resulting from BAT on a typical estuary.  This case study used a water quality

model to project theoretical improvements (similar to the nationwide model)

and analyzed ambient monitoring data to verify these projected improvements.

This special study is also discussed in Chapter 3.
                                        -28-

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                                                                        Results
                                 Chapter Three


                                    RESULTS


    The overall results of the three methods used to identify water quality

improvements that are attributable to BAT are presented in this  chapter.   For

the water quality model and ambient monitoring data, water quality

improvements are presented in terms of river miles that (1) complied with

water quality criteria or (2) showed a decrease in ambient pollutant

concentrations, respectively.  Only nationwide summaries are presented  here,

along with summaries of specific cases studies in which the implementation of

the BAT regulations have resulted in water quality improvements.  The results

of the model/ambient analyses, on a reach-by-reach/State basis,  are provided

in Volume II, Technical Appendices.



          IMPROVEMENTS IN  WATER QUALITY - WATER  QUALITY MODEL


    As defined in Chapter 1,  a water quality improvement can mean either

(1) compliance with water quality criteria after  implementation  of  BAT

treatment technology when criteria had been exceeded prior to BAT,  or (2)  a

reduction in in-stream pollutant concentrations after BAT.   The  water quality

model addresses improvements  only in water quality criteria compliance, since

theoretically all reaches receiving discharges from BAT facilities  have

improved in terms of pollutant concentration reductions (e.g., all  industrial

categories evaluated in this  study reduced their  discharge levels from pre-BAT

to post-BAT).


    The model assessed 2,490  BAT facilities on 1,546 reaches (totaling 24,289

river miles).  The model calculated theoretical in-stream concentrations for

the ten selected pollutants using industry-wide effluent concentrations,

process wastewater discharge  flows, and low (7-Q-10) and average receiving
                                        -29-

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                                                                        Results
stream flows.  The results of the water quality model are presented on both an

individual pollutant basis and a reach basis (to determine if all modeled

pollutants comply with their respective criteria).


Pol1utant-by-Pol1utant

    Nationwide summaries of the river miles complying (instream concentration

below criteria) and not complying (instream concentration at or above

criteria) with water quality criteria (WQC) for the individual pollutants,

based on pre- and post-BAT discharge levels, using low and average receiving

stream flow are shown in Tables 3-1 and 3-2, respectively.  Under low flow

conditions, pre-BAT discharges are projected to result in less than half of

the river miles complying with the WQC for copper (43 percent), lead (47

percent), and cyanide (47 percent).  No pollutant had 100 percent compliance

under low flow conditions prior to BAT.  After BAT, compliance ranged from

73 (mercury) to 100 percent (phenol, toluene, benzene).   The average increase

in compliance was 20 percent.  On a pollutant-by-pollutant basis, the

additional percentage of river miles complying with WQC after BAT is shown

below:
              Pollutant
               Cadmi urn
               Mercury
               Copper
               Lead
               Nickel
               Zinc
               Cyanide
               Phenol
               Toluene
               Benzene
    Additional Percentage
of River Miles Complying with
   WQC After BAT (Low Flow)
              25
               7
              33
              28
              22
              30
              34
               8
               3 *
               9
              * 97 percent compliance prior to BAT.
                                                    -30-

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Table 3-1
Sunaary of Water Quality Modeling Results:
Dalliance with Criteria (at Low Stream Flow)
Pre-BAT


Cadmium River Miles
Percent
Mercury River Hiles
Percent
Copper River Miles
Percent
Lead River Miles
Percent
Nickel River Miles
Percent
Zinc River Miles
Percent

Cyanide River Miles
Percent
Phenol River Miles
Percent
Toluene River Miles
Percent
Benzene River Miles
Percent





Not
Cooplying
w/WOC
9.030.2
an
8,176.4
34X
13.791.9
57X
12,864.3
53X
6,265.7
26X
9.748.1
40X

12,916.3
53X
1,836.1
8X
730.3
3X
2,283.8
9X






Conplying
•/HOC
15.258. 5
63X
16,112.3
6GX
10,496.8
43X
11,424.4
47X
18.023.0
74X
14.540. 6
60X

11,372.4
47X
22,452.6
92X
23,558.4
97X
22,004.9
91X



-31-

Post-BAT
Not
Conplying
w/WQC
3,038.2
12X
6,523.8
27X
5.752.0
24X
6,174.2
25X
1,043.2
4X
2.469.0
10X

4,562.1
19X
0.0
OX
0.0
OX
37.5
OX






Total
Coop lying River Miles
M/UQC Assessed
21,250.5
88X
17.764.9
73X
18.536.7
76X
18,114.5
75X
23.245.5
96X
21.819.7
SOX

19,726.6
81X
24.286.7
100X
24,288.7
100X
24.251.2
100X





24,288.7
24.288.7
24.288.7
24,288.7

24.288.7

24.288.7


24.288.7

24.286.7

24,288.7

24.268.7





Results

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Table 3-2
Suonary of Water Quality Modeling Results:
Co^liance With Criteria (at Average Stream Flow)
Pre-BAT


Cadniun River Niles
Percent
Mercury River Niles
Percent
Copper River Miles
Percent
Lead River Miles
Percent
Nickel River Niles
Percent
Zinc River Miles
Percent

Cyanide River Miles
Percent
Phenol River Niles
Percent
Toluene River Niles
Percent
Benzene River Miles
Percent






Not
Complying
w/WQC
2,807.4
12X
4,704.3
19X
5.421.6
22X
5,764.3
24X
1,328.7
5X
2.915.2
12X

6,059.2
25X
115.0
OX
50.3
OX
44.5
OX







Ccoplying
v/UQC
21,481.3
8BX
19.584.4
SIX
18,867.1
78X
18,524.4
76X
22.960.0
9SX
21,373.5
88X

18,229.5
75X
24,173.7
100X
24.238.4
100X
24.244.2
100X



-32-


Post-BAT
Not
Complying
w/WQC
332.9
IX
2.488.8
10X
923.1
4X
1,007.6
4X
2.6
OX
338.7
IX

436.2
2X
0.0
OX
0.0
OX
0.0
OX







Total
Complying River Niles
w/WQC Assessed
23.955.8
99X
21.799.9
90X
23.365.6
96X
23,281.1
96X
24,286.1
100X
23.950.0
99X

23.852.5
9BX
24,288.7
100X
24.288.7
100X
24.288.7
100X





•••^M
24.288.7
24.288.7
24.288.7
24,288.7

24.288.7

24.288.7


24.288.7

24.288.7

24.288.7

24,288.7






•^•^•va
Results

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                                                                        Results
     Improvements  in meeting WQC are less pronounced under average receiving

stream flow conditions.  Prior to BAT, between 75  (cyanide) and 100  (phenol,

toluene, and benzene) percent of the river miles assessed complied with WQC.

After the implementation of BAT, compliance ranged from 90  (mercury) to

100  (nickel, phenol, toluene, and benzene) percent.  The average increase in

compliance as a result of the implementation of BAT, at average flow, was 10

percent.  Individually, the additional percentage of river miles complying

with WQC as a result of BAT for each of the pollutants, is shown below:
              Pollutant
    Additional Percentage
of River Miles Complying witfr
 WQC After BAT (Average Flow)
Cadmium
Mercury
Copper
Lead
Nickel
Zinc
Cyanide
Phenol
Toluene
Benzene
11
9
18
20
5
. 11
23
0 *
0 *
0 *
              * 100 percent compliance prior to BAT.


Overall Reach

    The second method of evaluating the water quality improvements attributable

to BAT, based on the water quality model, examines the reach as a whole.  If

the reach is to meet WQC, then all modeled pollutants on that reach must comply

with their respective criteria.  These "overall" reach evaluations, therefore,

assess the effects of BAT on individual reaches for all the selected

pollutants.  The results of assessing water quality improvements using this

methodology, under low and average flow conditions, are shown in Figure 3-1.
                                        -33-

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                                                                                 Results
3
D
r

CE
                  e ~
                  No\°
                  *- CM
r
o
                   tx.
                   o
                   tc.
                   a.
              U
z o
o z
  
   a
    U)
 >v J=
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                                                                                       to
                                   QJ



                                   D)

                                  U_

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                                                                       Results
    Under low flow conditions, only 29 percent of the river  miles were

projected to meet all WQC prior to the implementation of BAT controls.  After

attaining discharge levels required under the BAT regulations,  the model

predicts that 58 percent of the river miles would meet criteria, that is,  an

additional 29 percent of the river miles would be in compliance.  Even  after

BAT, 42 percent of the river miles assessed are projected to exceed  criteria

for one or more of the ten pollutants.  Under this scenario,  mercury and lead

are the main causes of noncompliance.


    At average stream flow, only 59 percent of the river miles  were  projected

to comply with WQC for all the modeled pollutants prior to the  implementation

of BAT.  After the implementation of BAT, an additional 29 percent of river

miles would comply with WQC; 12 percent will still not comply with criteria.

The major cause of noncompliance after BAT is mercury.



       IMPROVEMENTS  IN WATER QUALITY - AMBIENT  MONITORING  DATA


    Improvements in water quality, as determined through analysis of ambient

monitoring data, focus on trends in pollutant concentrations (both on an

individual and on a reach basis) as opposed to comparison with  water quality

criteria.  The primary reasons for this approach center on the  general  lack of

monitoring data for reaches evaluated using the water quality model  and the

method of determining average pollutant concentrations for the  pre-  and

post-BAT time periods.


    Of the 1,546 reaches (24,289 river miles) assessed by the water  quality

model, 429 (totaling 8,434 river miles) had monitoring data  for at least one

of the selected pollutants for both time periods.  None of the  evaluated

reaches, unfortunately, had monitoring data for both the pre-BAT and post-BAT

time periods for the selected organic chemicals (phenol, toluene, and benzene).
                                        -35-

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                                                                        Results
Pol 1utant-by-Pol1utant
    Table 3-3 presents a summary of the In-stream concentration trends for each
of the seven monitored pollutants.  Between the pre-BAT (1970 to 1980) and
post-BAT (1985-1988) time periods, each of the pollutants showed a marked
decrease in in-stream concentration.  On the average, each of the pollutant
concentrations decreased in 78 percent of the monitored river miles.  Cadmium
and mercury showed the greatest concentration decreases (or improvement) in
monitored levels (84 and 87 percent of the river miles improved).  Zinc levels
reflected the least improvement (69 percent improvement).  The extent of no
significant change in monitored pollutant concentrations between the two time
periods ranged from 1 percent of the river miles (for mercury) to 11 percent
of river miles (for copper).  A deterioration, or increase in concentration,
occurred along some reaches for each pollutant.  The extent of deteriorations
ranged from 11 percent of the river miles (for cadmium) to 25 percent of river
miles (zinc).

Overall Reach
    Using a method to show overall trends on a reach basis (similar to the
method used in presenting the results of the water quality model for overall
compliance with WQC), the ambient monitoring data were analyzed to determine
overall trends in pollutant concentrations for the monitored pollutants.
Using this method, about 76 percent of the river miles with monitoring data
available showed an overall improvement (or net decrease in pollutant
concentrations).  Roughly 14 percent of the river miles showed a net increase
(deterioration) in monitored concentrations and 11 percent showed no
significant change.  Figure 3-2 illustrates these overall trends based on the
ambient monitoring data analysis.
                                        -36-

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                                                             Results
                Table 3-3


Summary of Ambient  Monitoring Data Analysis:
             Pollutant Trends
Improved No Change
Cadmium
Mercury
Copper
Lead
Nickel
Zinc
Cyanide
River Miles
Percent
River Miles
Percent
River Miles
Percent
River Miles
Percent
River Miles
Percent
River Miles
Percent
(
River Miles
Percent
3,822.6
MX
2.807.4
87X
4,349.9
70X
4.659.7
8zx
3.590.4
72X
5,296.2
69X
^
1,228.2
SOX
193.0
4X
31.5
IX
667.3
11X
279.3
SX
229.8
5X
498.1
6X
110.7
7X
Deteriorated
519.5
11X
375.6
12X
1.238.2
20X
766.1
13X
1.172.9
23X
1.889.7
25X
205.3
13X
Total
Monitored
4.535.1
3,214.5
6.255.4
5,705.1
4.993.1
7.684.0
1.544.2
              -37-

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6, 397
f ~7fiy )



Results


890
n 1*1



/ ooS
/ x?s
&I
•
k/
fck 4< 14?
k ( A A Of \

\

1
\x //
->v^ ^
\ ^ — ,. . 	 ^^^
^^__^
/
^^— 	 ^-"^

TOTAL RIVER MILES ASSESSED: B434







^Jxq NO SIGNIFICANT CH
ffiffiffl DETERIORATED
[" | IMPROVED


ANGE




* River miles for reaches with BAT facilities and monitoring data
for one or more of the ten toxic pollutants.
Note: Percentages add up to more than 100 percent due to rounding.
•Figure 3—2. Summary of Ambient Monitoring Data
Analysis: Overall Trends for BAT
Reaches .
1
1
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1

-38-



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                                                                        Results
              IMPROVEMENTS  IN WATER QUALITY  - CASE STUDIES

    Potential case studies screened for this study could represent any
 improvement in water quality attributable to the implementation of BAT
 regulations, including controls on conventional pollutants and regulations
 applicable to indirect dischargers.  However, the focus was on toxic pollutant
 controls for direct discharging facilities.  After a review of a number of
 State 305(b) reports as well as conversations with State officials,  it appears
 that the focus of case studies have been on municipal discharges, where
 controls on oxygen-demanding pollutants and nutrients have resulted  in
 improved oxygen levels in streams.  The major concern with toxic chemicals, as
 evidenced by the 305(b) reports, is sediment contamination, primarily because
 of PCBs and pesticides.  Little information is available concerning
 improvements that have resulted from toxic pollutant discharges,
 especially instances involving technology-based (i.e., BAT) controls.
However, six studies have been reported that indicate improvements in water
 quality resulting from BAT or BAT-type controls.

    In addition to the above case studies, a detailed water quality  model  and
ambient monitoring data analysis was performed by the Agency on an estuary
 (Delaware River Estuary) to highlight the effects of BAT regulations on these
types of waterbodies.

Long Island Sound - Connecticut
    In 1985, the Connecticut Department of Environmental Protection  (CT DEP)
 initiated a study to collect current fish tissue contaminant data for
comparison with historical  data in order to show temporal trends. Of the  many
sites and organisms selected for testing, oyster data obtained from  Bridgeport
Harbor and the Housatonic River areas indicated that these contaminated areas
had improved over the past  decade.  Both Bridgeport Harbor and the Housatonic
River have a heavy concentration of metals-related industries (metal
                                        -39-

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                                                                        Results


finishing, copper forming, and foundries).  The comparison of 1972-1974 oyster
metal concentrations to the data collected in 1985-1986, shown in Figure 3-3,
indicates that the "levels of cadmium, chromium, copper, mercury and zinc were
currently lower than the lowest concentrations observed in an intensive study
from the early 1970s.  Although the 1985-1986 survey was not detailed enough
to permit rigorous statistical analysis, the disparity in metals levels
strongly suggests a reduction in metals contamination of oyster tissues in the
Bridgeport and Housatonic Rivers" (NY DEC, 1988).  Since Connecticut currently
does not write water quality-based permit limitations, but instead bases its
industrial discharge levels on BAT-type standards, the improvements in metals
concentrations can be at least partially attributed to reductions in discharge
levels from the metal industries located in these areas.

Naugatuck River - Connecticut
    Another example of water quality improvements in Connecticut is the
Naugatuck River.  According to CT DEP (1988), the Naugatuck was once
considered one of the most polluted rivers in the nation.  From 1973 to 1976,
CT DEP issued abatement orders to 77 industrial dischargers along the river.
Metal finishers, the most prevalent type of industry on the river, were
required to neutralize acids, destroy cyanide water, and precipitate heavy
metals (BAT-type treatment technologies).  "Monitoring data has shown a marked
reduction in heavy metals, such as copper and zinc, and improved pH levels.
While the river was virtually devoid of aquatic life in 1970, water quality
has now improved to the point where the upper 22 miles ... have been stocked
with trout on an experimental basis.  The river has been identified by CT DEP
Fisheries Unit as a potentially valuable resource for cold water and anadromous
fisheries" (CT DEP, 1988).  Water quality problems still exist on the lower
portions of the river, which will require more stringent (e.g., water
quality-based) permits in order to achieve water quality goals.
                                        -40-

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-
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- ^
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117® 's 118®' e 1170 'e 1180 's

COPPER


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NICKEL

-BV • -*-

1«»7®'B 118®'8 1170-8 1188'B
BRIDGEPORT HARBOR HOUSRTONIC RIVER
•Figure 3-3. Trends in Metal Concentrations
in Oysters - Long Island Sound.
• Source: NY DEC, 1388.
1

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                                                                        Results
South Fork Coeur d'Alene River - Idaho
    The South Fork Coeur d'Alene River has had serious pollution problems for
many decades, which were the result of ore mining and related activities.  At
the time of the enactment of the Federal Water Pollution Control Act of 1972,
heavy metals concentrations in the river reached 23,000 ug/1 for total zinc,
200 ug/1 for total cadmium, and more than 500 ug/1 for total lead during the
summer low flow periods.  These levels are roughly two orders of magnitude
higher than EPA's acute (short-term) water quality criteria for protection of
aquatic life.  As a result of the 1972 Act, effluent limits for industrial
dischargers were required.  EPA's Region X Office initiated a monitoring
program in 1972 to document the improvements in the South Fork Coeur d'Alene
River and identify any remaining sources of heavy metals.  Figure 3-4 shows
the trends in zinc, cadmium, and lead at the mouth of the South Fork Coeur
d'Alene River from 1972 to 1986 (USEPA, 1987).  Each metal shows a decrease of
roughly 90 percent during this period.  While metal concentrations still
exceed criteria levels, conditions of the South Fork are now suitable for many
of the less sensitive indigenous species of aquatic biota, and conditions of
the mainstream are enabling game fish to return downstream of the South Fork
confluence.  Data now indicate that nonpoint sources are responsible for 50 to
90 percent of the metals.

Lower Fox River - HisconsIn

    The Fox River Valley is heavily industrialized, especially with paper
mills, and 50 percent of all point source discharges occur in the lower
portion (from Depere to Green Bay).  High pollutant loadings from the paper
mills have contributed greatly to the historically low dissolved oxygen levels
in the Lower Fox River.  As a result of the Clean Water Act of 1972, improved
wastewater treatment systems, which began operation in the 1970s,  have
resulted in the attainment of the 5 mg/1 dissolved oxygen standard for much of
the time period after the treatment systems became operational.  Permitted
effluent levels for the paper mills have been set at the limits established by
                                        -42-

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                                                     Results
   25,OOO —i
   15,OOO—
   10,009 —
    5,000 —
                                 ZINC
         1«J7Z  1474
                      I
                     147b
                          117B   14BO   14a2
                                                      i«iaa
(A
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I—I


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                                                                        Results
the national categorical standards (BPT/BAT), however, many of the mills are
discharging at lower levels.  The Wisconsin Department of Natural Resources
(WDNR) is currently revising its effluent permits to reflect water
quality-based limits for toxic pollutants; nonetheless, the national effluent
standards have had a beneficial impact on the Lower Fox River.  According to
historical trends related to macroinvertebrates, there has been a recent
increase in pollution intolerant aquatic life (WDNR, 1985).

Other Case Studies
    There are several other case studies in which the water quality
improvements can be at least partially attributed to the implementation of
national categorical effluent standards.  The first involves the Scioto River
in Ohio.  Using a macroinvertebrate index as a measure of overall water
quality, the Ohio Environmental Protection Agency (OEPA) determined that prior
to 1976, the Scioto River had marginal attainment of a warm water habitat.  A
great change in the index was noted between 1977 and 1978, reflecting an index
indicative of exceptional macroinvertebrate fauna.  These exceptional
conditions continued to exist through 1985.  The changes in water quality "are
most attributable to improvements in wastewater treatment" at a major pulp and
paper facility on the river (OEPA, 1988).

    Using the same macroinvertebrate index, OEPA has shown an improving trend
in biological conditions on the Mohican River.  "These improvements may be
attributable to industrial waste pretreatment (electroplaters) requirements in
the cities of Mansfield and Ashland, as well as wastewater treatment
improvements by various industries and WWTPs" (OEPA, 1988).

Delaware River Estuary
    To determine the effects of the BAT regulations on estuaries a case study
of the Delaware Estuary was performed.  The general methodology for this case
study follows that used in the nationwide analyses of BAT facilities and
reaches.  A modified water quality model, developed for EPA [from information
                                        -44-

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                                                                        Results
obtained from the National Oceanic and Atmospheric Administration (NOAA)], for
use in determining 304(1) lists of waters impaired by toxics, was used to
project in-stream pollutant concentrations from pre- and post-BAT effluent
discharges from BAT industries.  This model used the same industry-wide
concentrations of the ten selected pollutants as the nationwide water quality
model analysis.  Ambient water quality monitoring data were also retrieved
from EPA's STORET Water Quality File to show trends in selected pollutant
levels between the pre-BAT (1970-1980) and post-BAT (1985-1988) time periods
and to verify projected compliance with WQC (no State standards available).

    This analysis was based on estuary zones rather than reaches.  There are
three zones in any estuary: a freshwater tidal zone, a saltwater tidal zone,
and a mixing zone located between the two.  For this analysis, the in-stream
(or in-estuary) pollutant concentration was calculated using "pollutant
concentration potentials," a procedure developed by NOAA, that takes into
consideration both the flow available for dilution and the zone characteristics
(salinity).  The concentration potentials do not consider pollutant fate.  A
more detailed explanation of this approach can be found in U.S. EPA (1988).

    The Delaware estuary water quality model evaluated 64 BAT facilities
discharging at pre- and post-BAT levels., Twenty-two discharged to the
freshwater zone (Zone 1), 39 discharged to the mixing zone (Zone 2), and
3 discharged into the saltwater zone (Zone 3).  The model evaluated each zone
independently and did not account for inputs from upstream zones or other
sources.  Table 3-4 presents the results of the water quality model for the
Delaware estuary.  Prior to the implementation of BAT, Zone 1 was projected to
not comply with freshwater criteria for mercury, copper, lead, zinc, and
cyanide.  After the facilities met the discharge requirements of BAT, all
pollutants were projected to comply with of WQC.  Likewise, in Zone 2, four
pollutants (mercury, copper, lead, and cyanide) did not comply with WQC prior
to BAT and full compliance was projected after BAT.  The WQC used for this
zone was the more stringent of the two freshwater and saltwater criteria.  All
                                        -45-

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                                                                        Results


pollutants in Zone 3 were projected to comply with WQC (saltwater) both before
and after the implementation of BAT.

    The ambient monitoring data analysis used information obtained from
monitoring stations designated as "estuarine," as opposed to ambient "stream"
stations used in the nationwide evaluation.  Values that were reported as
"less than detection limit" were handled in the same manner as the nationwide
evaluation.  Data from two stations were used to represent average pollutant
concentrations in Zone 1 and seven stations were averaged for Zone 2 (see
Table 3-5).  No ambient estuarine data were available for Zone 3 and limited
data (in terms of the number of pollutants) were available for Zones 1 and 2.
The results of the monitoring data analysis compare favorably to the water
quality model.  In Zone 1, the average pre-BAT concentrations for copper and
lead did not comply with WQC.  After BAT, only lead still did not comply with
criteria, but only by a slight margin.  All monitored levels decreased by at
least 83 percent.  In Zone 2, all pollutants showed a marked decrease in
average pollutant concentration.  Cadmium decreased by 91 percent, mercury by
55 percent, copper and lead by over 90 percent each, and zinc by 81 percent.
The pre-BAT average concentrations for cadmium,  mercury, copper, and lead were
above WQC levels.  These pollutants were also above WQC after BAT, but by a
much smaller margin.  One possible reason to account for the non-compliance is
that 12 of the 39 BAT facilities were in the organic chemicals category and
may not have fully implemented the requirements of the BAT regulations (the
phase II regulations were promulgated in November 1987).
                                        -47-

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                                                Table 3-5


                    Ambient Water Quality Monitoring Data Sunnary for Delaware Estuary
                                               Average Pollutant Concentration  (ug/11
      Number of       Cadmium           Mercury
Zone  Facilities   70-BO    85-      70-80    85-
                                         Copper
                                                   Lead
                                     70-80
                                      85-
                                      70-80    85-
                                                  Zinc
                                              70-80  85-
          22

          39

           3
29.2
2.52
1.6
0.722
49.7 *

51.5 *
2.70

2.92 *
53.2 *

53.8*
5.1 *

5.1 *
61.0

64.0
10.4

11.9
Fresh WQC
Salt WQC
         1.1

         9.3
                  0.012

                  0.025
                             11.4

                              2.9
                                      3.0

                                      5.6
                                           102

                                           86
* Average concentration exceeds WQC.


NOTE:  Fresh WQC conpared to ill-stream concentrations  in Zone 1.
       Salt WQC compared to in-streaa concentrations in Zone 3.
       The more stringent of the two  WQC was  conpared  to in-stream concentrations in Zone 2.
       70-80 represents the pre-BAT time period  (1970-1980).
       85-   represents the post-BAT  time period (1985-present).
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                                                                    Conclusions
                                  Chapter Four


                                  CONCLUSIONS


    The three components of this  study indicate that water quality has improved

as a result of the  implementation of the BAT effluent limitation regulations:


Hater Quality Model.


    The results of  the water quality modeling effort, which evaluated 2,490

BAT facilities impacting 24,289 total river miles (1,546 unique reaches), show

that under low stream flow conditions 14,169 river miles (58 percent) comply

with all the water  quality criteria for the ten selected pollutants after the

implementation of BAT (an additional 29 percent improvement over pre-BAT

conditions).


    Under average receiving stream flow conditions, the model predicts that

59 percent of the river miles modeled will  comply with all  criteria prior to

the implementation  of BAT.  After BAT, 88 percent of the river miles assessed

(an additional 29 percent) were projected to meet all ten criteria.  The major

causes of noncompliance with criteria are discharges of mercury, lead, and

copper.  All other  pollutants comply with criteria in at least 81 percent of

the assessed river miles at low flow (98 percent at average flow).


    The use of the water quality model does have certain limitations.  The

model  does not consider upstream sources of pollutants,  nor does it consider

the discharge of other "nonselected" pollutants by the BAT  facilities.  These

sources could impact the extent of compliance with criteria.   This  limitation

is offset to a certain extent by the fact that pollutant fate is also not

considered.  The model also assumed all  facilities, within  a particular
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                                                                    Conclusions


 category, discharged the  same pollutants at the same concentrations.  While
 this  is  not  a  particularly valid assumption when dealing with an individual
 facility, on a nationwide basis, the tendency to overrepresent or
 underrepresent actual discharge levels  is, at least partially, eliminated.
 Finally, this  modeling effort does not  take into consideration the treatment
 technologies in place prior to the Clean Water Act, and thus the actual
 improvements should be somewhat less than projected.

    Based on the results  of the water quality model, the national categorical
 effluent standards program (BAT) has been found to be an effective tool for
 improving water quality up to a point.  However, there may be a need for
 additional water quality-based controls beyond BAT in some cases in order to
 meet State water quality  standards.  The model predicts that 42 percent of the
 assessed river miles may  exceed EPA national water quality criteria under low
 stream flow conditions after BAT is in  place (12 percent of the river miles do
 not comply at  average flow conditions).  This projection, however,  is not a
 precise measure, since it is dependent  on the number of pollutants evaluated.
 In many cases, water quality-based NPDES permit limits may have been already
 developed in order to meet locally applicable State water quality standards,
 and in other cases new water quality-based permit limits may be needed.

Ambient Water  Quality Monitoring Data

    Improvements in water quality,  based on the ambient water quality
monitoring data analysis,  are not as evident.   Appropriate ambient  monitoring
data were available for only 35 percent of the river miles assessed by the
model, and no  comparable data (same reach for both the periods)  were available
for the organic chemicals selected.  This lack of ambient monitoring data is
expected, especially for the organic chemicals,  since the Agency's  major focus
during the early and mid-1970's was on conventional  pollutants.   Only after
the Clean Water Act of 1977 were toxic pollutants emphasized.  It is also
 important to note that ambient monitoring data is collected for  many other
purposes that just to determine the effectiveness of controls placed on
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                                                                    Conclusions
industrial discharges.  Nevertheless, it is apparent that a more goal-oriented
and focused effort needs to be made to truly evaluate controls on industrial
discharges.

    The monitoring data analysis, however, did show a great improvement, in
terms of pollutant reductions, between the pre- and post-BAT time periods.
About 76 percent of the river miles (assessed in this evaluation) indicated an
overall decreasing trend in in-stream concentrations of toxic pollutants.
However, about 14 percent showed an increase.  Concentrations of individual
pollutants (cadmium, mercury, lead, and cyanide) improved in 80 percent or
more of the assessed river miles, while zinc, nickel, and copper showed
increases (deterioration) in 20 to 25 percent of the assessed miles.

    The full benefit of the implementation of BAT is not reflected in the
ambient monitoring analysis.  National categorical standards have recently
been promulgated for one major industry, organic chemicals manufacturing,
which will reduce the industry's toxic pollutant direct discharge loadings by
1.1 million pounds per year.  Standards for another category (pesticides
manufacturing) are currently being prepared.  While the ambient data do
reflect some of the benefits attributable to BAT, the full effect will  not be
evident until the early 1990s.  The second component of this study has several
other limitations.  The sources of pollutants represented in the monitoring
data are not known, although these sources should include the BAT facilities
evaluated in the model.  Other sources could include upstream BAT facilities,
municipal facilities, hazardous waste sites, nonpoint,  and natural
(background) sources.  Reductions in the monitored pollutants could possibly
be attributed to controls on these sources.  Another factor that could account
for some of the decreasing pollutant concentration trends is the increase in
accuracy of the analytical  techniques used to determine the pollutant
concentrations.  In the past decade, increased sophistication of the
laboratory equipment has enabled the detection limits for all  pollutants to be
1owered.
                                                                               V

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                                                                    Conclusions


    The statistical significance of comparing monitoring data >frotn time
periods of different spans was not evaluated.  Also, the naturally occurring
variability in monitored pollutant levels was not assessed; however, the
effect of such variability should be reduced by using average values over the
periods evaluated.

Case Studies

    Actual cases where the implementation of BAT has resulted in water quality
improvements present the best illustration of the effectiveness of the
categorical standards.  The few case studies that are available show that the
BAT regulations have had a positive impact on the receiving stream quality, in
terms of both chemical and biological improvements.  In most instances, the
streams/rivers assessed in these case studies were highly polluted prior to
BAT.  Even after the discharge levels were reduced to levels proscribed by
BAT, additional water quality-based controls may be needed in order to meet
State water quality standards.  In all  cases, the implementation of BAT has
resulted in considerable improvements in the biological quality (as measured
by an increase in less pollution-tolerant aquatic life) of the receiving
waters.

    The special case study predicted and verified that improvements have
occurred in the chemical water quality of the Delaware estuary.   All
pollutants, as projected by the water quality model, that exceeded criteria
prior to BAT complied with criteria after the implementation of these
regulations.  The ambient monitoring data analysis verified these
improvements.   However, in Zone 2, the area most influenced by organic
chemical  manufacturing discharges, the predicted improvements are not yet
fully realized (e.g., the BAT regulations for the organic chemicals category
are not yet fully implemented by industry).
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                                                                    Conclusions
Summary of Hater Quality Improvements


    Considering the results of each component of this analysis, together with

their respective assumptions and limitations, the BAT regulations have been an

effective step toward improving the quality of our nation's waters.  The

extent of this effectiveness is difficult to assess using the existing EPA

data sources and considering the fact that the full benefit of BAT has not yet

been realized.  Also, by not considering improvements resulting from the

categorical pretreatment requirements, the extent of the improvements

resulting from the overall national water quality program are underestimated.

There may be a need for additional water quality-based controls beyond BAT in

some cases to meet State water quality standards.  In addition, as required by

Section 304(m) of the Water Quality Act of 1987, the Agency will establish a

schedule for:  (1) the annual review and revision of promulgated effluent

guidelines, and (2) the promulgation of regulations for industrial categories

identified as sources of toxic and nonconventional pollutants for which

guidelines have not previously been established.
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                                  Chapter Five
                                  REFERENCES


Connecticut Department of Environmental Protection, 1988.  State of
    Connecticut 1988 Water Quality Report to Congress.  Water Compliance Unit.

New York Department of Environmental Conservation, 1988.  New York State Water
    Quality 1988.  Division of Water, Bureau of Monitoring and Assessment.

Ohio Environmental Protection Agency, 1988.  Ohio's Water Quality Inventory -
    1988 305(b) Report, Volume I.  Division of Water Quality Monitoring and
    Assessment.  Columbus, Ohio.

U.S. Environmental Protection Agency, 1988.  Summary of Effluent
    Characteristics and Guidelines for Selected Industrial Point Source
    Categories:  Industry Status Sheets.  Interim Final Report.  Office of
    Water Regulations and Standards, Monitoring and Data Support Division.
    Washington, D.C.

U.S. Environmental Protection Agency, 1987.  Coeur d'Alene Basin - EPA Water
    Quality Monitoring (1972-1986), Draft Final.  EPA Region X.

U.S. Environmental Protection Agency, 1988.  Estuarine Dilution Analyses to
    Estimate Toxic Substance Impairment for 304(1) Identification, Draft
    Report.  Office of Marine and Estuarine Protection and Office of Water
    Regulations and Standards.  Washington, D.C.

U.S. Environmental Protection Agency (various dates).  Ambient Water Quality
    Criteria Documents.  Office of Water Regulations and Standards, Criteria
    and Standards Division.  Washington, D.C.

U.S. Environmental Protection Agency.  National Primary Drinking Water
    Regulations.  40 CFR Parts 141 and 142.

Wisconsin Department of Natural Resources, 1985.  Lower Fox River - Depere to
    Green Bay:  Water Quality Standards Review.  Bureaus of Water Resources
    Management and Fish Management.
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