&EPA

               United States
               Environmental Protection
               Agency
                   Office of Water
                   Office of Policy, Planning
                   and Evaluation
                   Washington, DC
September 1987
Surface Water Monitoring:
A Framework for Change

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SURFACE WATER MONITORING
 A FRAMEWORK FOR CHANGE
           USEPA Office of Water




    USEPA Office of Policy, Planning, and Evaluation
             September 1987

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                      ACKNOWLEDGMENTS
       This study was conducted by EPA's Office of Water and by the Environmental Results
Branch of the Office of Management Systems and Evaluation in the Office of Policy, Planning,
and Evaluation.  Assistance was provided by American Management Systems, Inc. under EPA
contract number 68-01-7281.

       The principal contributors to this report were Mary E. Blakeslee, Office of Water; Paul
J. Campanella, Office of Policy, Planning, and Evaluation; and Donald A. Smalley, American
Management Systems,  Inc.  The study could not have been accomplished without the
continuous interest and support of the Director and Deputy Director of the Office of Water's
Office of Water Regulations and Standards and the staff of that Office's Monitoring and Data
Support Division.

       Additional important contributions, too numerous to mention individually, were
received from many persons in the Office of Water, other EPA Headquarters Offices, EPA
Regional Offices, EPA R&D laboratories, and State environmental agencies in Florida, New
Jersey, Oregon, and North Carolina.

       A draft of the report was reviewed by the Environmental Effects, Transport, and Fate
Committee of EPA's Science Advisory Board.  This final edition reflects many of their
comments and suggestions.

       Cover photographs were taken by James Plafkin, USEPA.

       Copies of this report are available from:

          Office of Water Regulations and Standards
          Monitoring and Data Support Division, WH-553
          USEPA Headquarters
          401 M Street, S.W.
          Washington, D.C.  20460

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                      TABLE OF CONTENTS
Executive Summary


Introduction	1


The Present Surface Water Monitoring Program	 2
The Need for Change: Emerging Challenges
Are Creating New Information Needs	 9
Obstacles To Meeting the New Information Needs	15


A National Framework for Change	21


Appendices

      A —  Assistant Administrator for Water's Memorandum
           Initiating the EPA Surface Water Monitoring Study

      B —  Project Chronology and List of Products

      C —  Members of the Policy Committee of the EPA Surface
           Water Monitoring Study

      D —  List of Interviewees for the EPA Surface Water
           Monitoring Study

      E —  Members of the U.S. Environmental Protection Agency
           Science Advisory Board, Surface Water Monitoring
           Subcommittee

      F —  Glossary of Selected Terms Used in the Report

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                        EXECUTIVE SUMMARY
   In December 1985, EPA's Assistant Administrator for Water initiated a major study of the
Agency's surface water monitoring activities. The project's principal objectives were to:

       Determine where EPA's surface water monitoring program should be heading
       in the late 1980s to ensure that it can meet the information needs of water
       quality managers in the 1990s; and

       Identify where specific adjustments to the current program are needed, and
       how they should be made.

   The study used a broad definition  of "water monitoring," encompassing all of the
numerous ways of collecting data on the physical, chemical, or biological characteristics of the
watercolumn, wastewater effluents, or sediments in inland, estuarine, and ocean waters.  The
project's scope also included the management of water monitoring data — the analysis, storage,
retrieval, and use of water-related information in making water quality management decisions.


• Water-Related Environmental Data Can Play an Important Role
   in Decision-Making.


   Monitoring  of surface water quality (including monitoring of sediments and living
resources) is an important source of information that can be useful to State and Federal
decision-makers in performing four key functions of water quality management programs:

   •   Characterizing Water Resources and Identifying Water Quality Problems and
       Trends, in inland, near-coastal, and marine waters;

   •   Developing Water Quality Management Priorities and Plans which direct
       pollution control resources toward the most significant water quality problems
       ~ point and nonpoint -- for which practical solutions can be found;

   •   Developing and Implementing Water Quality Management Programs, such as
       establishing permit limits for point sources and management plans for
       nonpoint sources; and

   •   Evaluating the Effectiveness of Management Actions to reveal instances where
       enforcement action, tighter  controls, or different approaches may be
       warranted.

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                                           11
• EPA and the States Use a Variety of Monitoring Approaches to Obtain Water
   Quality Information.

   The principal monitoring approaches are:

Source Monitoring

   •  Self-monitoring of effluent by industrial and municipal dischargers to check
      for compliance with permit conditions;

      Compliance sampling inspections by States or EPA to provide a cross-check
      on discharger self-monitoring; and

   •  Effluent characterization studies by EPA to determine the constituents of the
      wastestream typically produced by a specific industrial class of discharger.

Ambient Monitoring

   •  Networks of "fixed stations,"  locations where water samples are repeatedly
      collected over time  to provide an overview of water quality conditions and
      trends at a specific site and across the entire area covered by the network;

   •  Intensive surveys, which  are more  detailed studies of  water quality
      conditions, sediments, and/or aquatic life at specific sites or in relatively well-
      defined geographic areas such as river basins, lakes, and estuaries; and

   •  Statistically-designed special studies, most often one-time surveys with a
      broad geographic coverage and a specific  focus (e.g., the National Dioxin
      Study; studies of acid precipitation and bioaccumulation of toxic chemicals).


• While States Vary Widely in Their Methods and Priorities, the Current
   Surface Water Monitoring Program Nationwide Has  Several Salient
   Characteristics.

   •  EPA places a strong emphasis on intensive survey monitoring by States to
      support development of point source controls.

   •  Many States rely heavily on periodic watercolumn sampling at geographically-
      dispersed fixed stations to provide information on problems and trends.

   •  EPA and the States have significantly increased status and trend monitoring in
      near-coastal waters.

   •  Industrial and municipal wastewater dischargers monitor their own effluents
      regularly and report the results to their permitting agency.

   •  EPA and States conduct or participate  in a  limited number of large,
      statistically-designed water quality surveys.

   •  EPA and the States summarize water quality trends and progress in biennial
      reports to Congress and the public.

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                                           Ill
•  Emerging Challenges are Creating New Information Needs for State and
    Federal Water Quality Managers.


    The scope and complexity of water quality management issues are expanding rapidly.  The
task of pollution control and abatement is moving well beyond the focus on chemical-specific,
technology-based controls of conventional and toxic compounds that was dominant in the
1970s and early 1980s.  Technological, programmatic, statutory, and policy changes within
EPA over the past four years have created a whole new context for decision-making that will
carry over well into the next century.  State and EPA managers are  now confronting  new
decision-making requirements posed by at least five emerging challenges.  Taken together,
these challenges form a compelling argument for change in the kind of information the Agency
and the States collect, the way it is collected, and how it is stored, managed, and used.
Challenge 1: Develop and Use Biological Testing Methods to Control Toxic Water Pollutants

    Traditionally, EPA has pursued a chemical-specific approach to regulating pollutants. Over
the last five years, however, it has become apparent that this approach, by itself, cannot
adequately protect all surface waters. Because of limitations in the chemical-specific approach,
EPA has made a decisive move to develop biological testing as a tool to help manage pollution
in the Nation's waters. A number of quick, reliable, and relatively inexpensive biological tests
have been developed, validated, and published — each useful in measuring the toxicity of
complex mixtures to plants and animals. The challenge to EPA is to build on these successes
and extend the application of these procedures to all  State water quality  management
operations, and to municipal and industrial dischargers as well.
Challenge 2:   Increase Use of Biological Monitoring to Characterize Aquatic Systems and
              Identify Problems and Trends

    An important purpose of surface water monitoring should be to provide a baseline
characterization of the Nation's  aquatic resources.  The information gathered in  these
assessments can serve as the basis for a strategy for managing water quality and water-
dependent resources.  EPA now faces the challenge of developing efficacious techniques to
assess rapidly the very large number of streams, rivers, lakes, and coastal waters to identify
actual or potential problems and to determine the causes of those problems.  Biological
monitoring methods must play an important role in these assessments.


Challenge 3: Demonstrate That Pollutant Control Investments Are Achieving Desired Results

    EPA  senior management has recently stressed the need to strengthen the Agency's ability to
manage for environmental results — to base management decisions on an analysis of the
expected improvement in environmental quality with  the concomitant reduction in risk.
Increasing results-based decision-making will require EPA to evaluate past control actions to
see whether they have had the intended effect.  Better data on the effectiveness of pollution
control activities would enhance the Agency's ability to change or fine-tune programs, policies,
and regulations. Water quality managers are faced  with rapidly-increasing demands on a
slowly-expanding or static resource base.  Under such conditions, evaluation to determine
what is working can play an important role in decisions about how the available resources can
best be applied.

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                                           IV
Cliallenge4:   Identify and Characterize Toxic, Conventional, and Anthropogenic Pollutants
             From Nonpoint Sources

   Based on our current knowledge of the Nation's waters, point source pollution is no
longer, and in some cases never was, the paramount threat to surface water quality in many
parts of the country.  Many States have longstanding problems  with urban and agricultural
nonpoint sources, and some are dealing with more recently-identified threats  from toxic
chemicals such as pesticide runoff and seepage from hazardous  waste sites.  In some rivers,
nonpoint sources of conventional pollutants (e.g., nutrients and suspended solids) are the main
problems. To confront these kinds of problems, EPA and the States must have data on the
effects of nonpoint sources on conditions in many waterbodies.


Challenge 5:   Expand Efforts to Identify and Control Pollution Problems in Near-Coastal and
             Ocean Waters

   Much of the inland pollution — from nonpoint sources, unpermitted point sources, and
permitted but non-complying facilities  — is eventually washed  into the bays and estuaries,
where it combines with  pollution from shoreline sources.  The open ocean also receives
pollutants, mainly from direct dumping of sewage sludge and other materials, from discharges
by drilling rigs and ships, and from the air.  Monitoring needs will continue to increase in the
marine  and  estuarine programs as EPA and the States expand  current efforts to assess
environmental quality, identify pollution  sources, and develop water quality management plans
and programs.


• The Present Approach to Surface Water Monitoring  Cannot Fully Provide
   the Information that Managers Must Have to Meet These Challenges.


   Each of the  five emerging challenges is accompanied by new information needs.  The
State/EPA surface water monitoring program is now oriented toward the problems of the past
and present, not those of the future. To meet the challenges, water quality managers will need
environmental information that is not being collected now, and they will need to make better
use of the data that are being collected. In preparing to meet the information needs of the
future, EPA  and the States must work together to overcome three significant obstacles of the
present approach:
Obstacle 1:    Inadequate Methods  and  Resources  for Characterization,  Problem
             Identification,  and Trend Assessment in Inland, Near-Coastal, and Marine
             Waters

   EPA and the  States need better methods for ambient problem screening  and trend
monitoring, especially for toxics.  Most States have reduced their number of regularly-sampled
fixed stations over the past few  years, in response to the rising cost of data collection and
analysis and the growing need for intensive survey monitoring in support of point source
control decisions.  Even large  fixed station monitoring programs are not well-suited to support
the mounting battle against toxic chemicals in surface waters.

   Most States can benefit from added expertise in designing scientifically sound, cost-
effective assessment programs that incorporate biological and sediment analysis techniques to
complement the traditional water  chemistry methods. In addition, EPA must continue to strive

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for greater consistency among the States in their monitoring approaches, terminology, and
reporting formats so that the Agency and other organizations can use State data to create sound
national overviews of water quality conditions and progress.
Obstacle 2:    Inability to Assess the Effectiveness of Point Source Control and Nonpoint
             Source Management Actions in Terms of Environmental Results

    The Agency does very little ambient monitoring to determine if programs are working as
they were designed.  Typically, a program office will do good front-end work to promote a
program based on the environmental results it is expected to achieve.  Unfortunately, there is
little, if any, follow-up monitoring to determine if the assumptions and projections were valid.
If there are no effectiveness data, then there is little impetus to make mid-course corrections to
programs or policies that may not be working as originally planned. This is a major obstacle to
more effective environmental problem solving.


Obstacle 3:    Insufficient Use of Existing Water-Related Data to Guide, Complement, or
             Avoid New Monitoring

    Water quality managers often do not use available monitoring data from any source in
developing plans, setting priorities, or making operational decisions. EPA and the States have
invested heavily in data collection and in computer systems to store and manipulate the results,
and yet much of the data are never used again once they have  served their original purpose. As
the cost of data collection rises and the complexity of the water monitoring task increases, these
obstacles must be overcome so that greater value can be extracted from existing water quality
data. Major efficiencies in program operations can be gained  through analysis of existing  data
— for example, in narrowing the focus for additional monitoring, in targeting corrective
actions, and in revealing long-term pollution trends.
    The Office of Water Does Not Have a Strategy for Reorienting Surface
    Water Monitoring to Meet the Information Needs of the 1990s.
   EPA's water monitoring policy-makers have been addressing the emerging pollution
control challenges in a fragmented, reactive way. The Office of Water lacks a clear conception
of where the monitoring program should be going, why, and how it will get there.  In the
absence of a national framework, each individual State is proceeding independently to face the
problems posed by growing concern with toxics, nonpoint sources, near-coastal waters, and
the environmental results. Some States are making impressive progress at this task. Others are
falling behind and will require technical assistance to enable them to catch up to the leaders.

   EPA must now exert national leadership to close this growing "capability gap" among
States. A national framework is needed which clarifies EPA's objectives, defines a direction,
and provides a firm foundation for individual State monitoring programs.

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                                          VI
H The Actions Recommended Here Should Be Included in a National
   Framework for Change in Surface Water Monitoring.


   The recommendations, presented in detail in the full report, are aimed at three key objec-
tives for joint EPA/State action over the next three years:

   •  Enhance State and EPA Capabilities to Carry Out Characterization, Problem
      Identification, and Trend Assessment in Inland, Estuarine, and Marine Waters

   •  Increase Ambient  Follow-Up  Monitoring for  Use in Evaluating  the
      Effectiveness of Water Quality Management Actions

   •  Promote the Use of Available Water-Related Data in EPA and State Decision-
      Making.
Recommendation Area 1:  Issue Guidance on Efficacious Approaches to Characterization,
                       Problem Identification, and Trend Assessment


   •   Issue guidance to States  on re-evaluating their surface water monitoring
       programs.

   •   Develop one or more technical reference manuals on basic design principles
       for water quality monitoring.

   •   Issue guidance on establishing and maintaining "citizens' watch" programs.
Recommendation Area 2:  Accelerate the Development and Application of Promising Biological
                       Monitoring Techniques


   •   Survey and evaluate thoroughly the current situation with development and
       application of biological techniques in the United States and Canada.

   •   Evaluate the role that biological monitoring techniques should play in a
       systematic, cost-effective problem screening and trend monitoring program.

   •   Create a detailed action plan specifying the steps OW will take in FY 1988-90
       to accelerate the development and application of  biological monitoring
       methods.

   •   Fully support the implementation, refinement, and use of the BIOS subsystem
       of STORET, EPA's main water quality data system.

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                                           Vll
Recommendation Area 3: Analyze the Feasibility of Requiring NPDES Permittees to Conduct
                       Ambient Follow-Up Monitoring Studies


    •   Specify the type and quantity of ambient effects information needed by State
       and/or EPA decision-makers.

    •   Clearly describe the characteristics of a technically-sound approach, or range
       of approaches, to ambient effects monitoring.

    •   Identify alternative methods  by which the  costs of ambient follow-up
       monitoring could be borne by NPDES permittees.

       Assess the advantages and disadvantages of each alternative method, and
       recommend how the Office of Water should proceed.
Recommentation Area 4:   Continue and Expand Efforts to Improve Information on National
                        Progress in Water Pollution Control


    •   Provide detailed and  unambiguous guidance  to States on objectives,
       definitions, presentation formats, and recommended assessment methods.

    «   Proceed rapidly with development of a Water Quality Information Tracking
       System.

    •   Examine carefully the types of water quality monitoring performed by other
       Federal agencies, and develop  an approach for systematically drawing on
       these sources, when appropriate, in the national assessment process.
Recommendation Area 5: Improve EPA and State Knowledge About Sources and Uses of
                       Existing Water-Related Data


       Develop a standard for labelling the data quality of monitoring data sets.

    •   Issue guidance on sources and uses of existing water-related data.

    •   Improve STORETs usefulness as a decision support tool.
Recommendation Area 6: Establish Central Coordination of EPA Activities to Integrate Water-
                       RelatedData

   The Assistant Administrator for Water should establish a Water Data Management Council
for coordination, problem-solving, and planning on data integration issues.  Effective data
integration can benefit all OW program offices, as well as Regional Offices and States, and this
complex task should therefore be facilitated and monitored from the top.

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                                           V1U
   By the end of FY 1988, the Council should determine how the Office of Water will achieve
four cross-cutting objectives of particular importance in improving the use of existing data in
EPA and State decision-making:

   •  Develop tools to make better use of DMR data, including linking of PCS,
      STORET, and other Office of Water data files.

   •  Assess the feasibility of developing an automated data base of drinking water
      surveillance results, for use in identifying contaminated surface waters that
      present a high risk to human health.

   •  Ensure appropriate  development and use of "geographic information
      systems."

   •  Promote awareness and use of data integration tools.

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                               INTRODUCTION
    In December 1985, EPA's Assistant Administrator for Water initiated a major study of the
Agency's surface water monitoring activities.  (See Appendix A.)  The project's principal
objectives were to:

    •   Determine where EPA's surface water monitoring program should be heading
       in the late 1980s to ensure that it can meet the information needs of water
       quality managers in the 1990s; and

    •   Identify where specific adjustments to the current program are needed, and
       how they should be made.

    The study used a  broad  definition of "water monitoring," encompassing all of the
numerous ways of collecting data on the physical, chemical, or biological characteristics of the
watercolumn, wastewater effluents, or sediments in inland, estuarine, and ocean waters.  The
project's scope also included the management of water monitoring data — the analysis, storage,
retrieval, and use of water-related information in making water quality management decisions.

    This report presents the study's findings and recommendations.  The results are based on
more than 150 structured interviews with key State and Federal managers, and numerous less
formal discussions with EPA and State scientific and technical staff.  Several interim working
papers were discussed with the study's Policy Committee and other advisors inside and outside
of EPA.  A draft of this report was reviewed by the Surface Water Monitoring Subcommittee
of the  EPA Science Advisory Board (SAB).  Lists of the project milestones, the Policy
Committee members, the interviewees, and the SAB subcommittee members are presented in
Appendices B, C, D, and E respectively.

    The report presents, in  succeeding sections, the study's findings and conclusions on:
where surface water monitoring is today; why the present State/EPA program is not adequate to
meet emerging needs; and where and how changes should be made. Appendix F is a glossary
of terms used in the report.

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                              THE PRESENT
        SURFACE WATER MONITORING PROGRAM
• Water-Related Environmental Data
   Can Play an Important Role in Decision-Making.


   Monitoring of surface water quality (including monitoring of sediments and living
resources) is an important source of information that can be useful to State and Federal
decision-makers in performing four key functions of water quality management programs:

   •   Characterizing Water Resources and Identifying Water Quality Problems and
       Trends, in inland, near-coastal, and marine waters;

   •   Developing Water Quality Management Priorities and Plans which direct
       pollution control resources toward the most significant water quality problems
       — point and nonpoint — for which practical solutions can be found;

   •   Developing and Implementing Water Quality Management Programs, such as
       establishing permit limits for point  sources and management plans for
       nonpoint sources; and

   •   Evaluating the Effectiveness of Management Actions to reveal instances where
       enforcement  action,  tighter controls,  or different approaches  may  be
       warranted.

   The first function is essential to sound water quality management. This activity serves to
define the naturally-occurring variability in the physical, chemical, and biological systems
being managed.  It also establishes the extent, magnitude, and significance of environmental
anomalies.  The next three components occur sequentially, constituting a continual cycle of
developing priorities and plans to address important environmental problems identified in
Step 1, implementing programs to manage the problems,  and evaluating the effectiveness of
the actions. The final step in this cycle is to revise the priorities and plans based on new
information and to fine-tune the programs based on their  effectiveness in achieving program
goals.

   Figure 1 depicts the interrelationship of these four key functions and lists within each
function the major programmatic or regulatory tasks that can  be aided by water-related
environmental data. These individual activities are the reasons for using monitoring data in
surface water programs, whether the data are obtained through new monitoring or from
sources of existing data.

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                             Figure 1

 EPA and State Activities Supported
             by Water Quality Data
                          L Characterizing Water
                         Resources and Identifying
                    Water Quality Problems and Trends

                      • Identifying water quality problems and trends
                         on the National, Regional, State or local scale
                      • Characterizing the nature, extent, and likely
                         causes of a problem or set of problems
                      • Identifying individual water resources not
                         meeting water quality standards
                           IL Developing Water
                           Quality Management
                            Priorities and Plans
                         Developing priorities and plans for
                         —  Management Actions (e.g., BMPs)
                         --  Control actions (e.g., permits)
                         --  Corrective actions (e.g., enforcement)
                         —  Regulations (e.g., Effluent Guidelines)
                         —  Additional monitoring
    HI. Developing and
Implementing Water Quality
   Management Programs

•  Establishing or revising water quality
   criteria and standards
•  Developing permit conditions for industrial
   or municipal dischargers
•  Developing and implementing BMPs for
    nonpoint sources
       IV. Evaluating
      the Effectiveness
   of Management Actions
Determining compliance with permit conditions

Determining reduction in fish advisories
 caused by contamination

Determining changes in ambient water quality
 downstream from sewage treatment plants

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• EPA and the States Use a Variety of Monitoring
   Approaches to Obtain Water Quality Information.


   EPA's water quality monitoring approaches may be classified as either source or ambient
monitoring. Source monitoring involves assessing the composition of industrial or municipal
effluent discharged into waterways, and of the "mixing zone" where this wastewater merges
with the receiving water.  Ambient monitoring refers to all forms of monitoring conducted
beyond the immediate influence of a discharge pipe, including sampling of sediments and
living resources.  Staff performing monitoring use a variety of techniques, such as chemical
analyses of water, sediment, or animal tissue; taxonomical analyses; and the application of
"best professional judgment"  to visually note changes in a waterbody or its biota that may
indicate a change in water quality.

   The main monitoring approaches used by States and EPA are:

Source Monitoring

   •   Self-monitoring of effluent by industrial and municipal dischargers to check
       for compliance with permit conditions;

   •   Compliance sampling inspections by  States or EPA to provide a cross-check
       on discharger self-monitoring; and

   •   Effluent characterization studies by EPA to determine the constituents of the
       wastestream typically produced by a specific industrial class of discharger.

Ambient Monitoring

   •   Networks of "fixed stations," locations where water samples are repeatedly
       collected over time to  provide an overview of water quality conditions and
       trends at a specific site and across the entire area covered by the network;

   •   Intensive surveys, which are more detailed studies of water quality
       conditions, sediments, and/or aquatic life at specific sites or in relatively well-
       defined geographic areas such as river basins, lakes, and estuaries; and

   •   Statistically-designed  special studies, most often one-time surveys with a
       broad geographic coverage and a specific focus (e.g., the National Dioxin
       Study; studies of acid precipitation and bioaccumulation of toxic chemicals).

   Most ambient monitoring is performed by States because of the  high degree of State
autonomy provided for in the Clean Water Act and EPA's delegation of many responsibilities
to State authorities.  EPA provides guidance and technical support to State monitoring
activities, through the Environmental Services Divisions in the Regional Offices and through
guidance developed by the Headquarters staff.

   Figure 2 summarizes the current surface water monitoring activities, matching the purposes
of monitoring from Figure 1 with the approaches that States and EPA now use to obtain water
quality data.

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                            Figure 2



Current State and EPA Surface Water Quality Monitoring Activities
M-UGR ACTIVITIES
SUJPPORTEPBY WATER
QUALITY DATA
Identifying water quality
problems and trends on the
National or Regional scale
Identifying water quality
problems and trends on the
State or areawide scale
Characterizing the nature,
extent, and likely causes of a
problem or set of problems
Identifying individual segments
not meeting water quality
standards
Establishing or revising water
quality criteria and standards
Developing permit conditions
for industrial dischargers
Developing permit conditions
For municipal dischargers
Determining compliance with
permit conditions
Evaluating the effectiveness of
pollution control actions
Developing priorities and plans
for control, corrective action,
regulation development, and
additional monitoring
OtfeiCEOFWATOt
RECTJLATJQNS ANJ>STAN0ARBS
Statistically -designed national or Regional special
studies; aggregation and analysis of data collected by
States, EPA, and others; biennial National 305(b)
report summarizes State 305(b) reports
Primary reliance on State fixed-station sampling,
with increasing use of areawide (e.g., basin)
intensive survey to complement routine fixed-
station monitoring
Examination of previously-collected data on the
waterbody of interest; some use of intensive surveys
designed to provide more detail than trend monitoring
Use of existing data to determine whether the
waterbody is supporting designated use; professional
judgment (e,g., streamwalking) often used
Existing water quality data from a variety of source
helps in setting priorities for development or
revision of EPA Criteria and State standards and
their implementation
&mAxS$my*wmm?$fr •—&
S3^A<^p^ywnilO*g? 	 jr :

Very little follow-up monitoring is performed; some
use of existing data; a few States have conducted
"before and after studies"; EPA has funded watershed
monitoring projects to assess effect of nonpoint controls
Limited but growing use of water quality and
source self -monitoring (DMR) data in identifying
high-priority pollutants for regulation development
and local controls
OSRFICEOFWATER
ENFORCEMENT AND PERMITS
DMR data showing long-term patterns of significant
noncompliance by permittees may identify Region/State
jurisdictions! enforcement problems directly affecting
water quality.
Quarterly Noncompliance Reports (QNCRs) based on
DMR data may provide correlation with water
quality problems within a given State or basin.
DMR information on exceedances of permit limits
may help to characterize the nature and extent of
water quality problems involving the parameters in
question.
The location of permittees in violation may help
States to identify problem stream segments.
The impact of point source discharges is a
factor in developing or revising water quality
Primarily analysis of existing data on discharges and
ambient water quality, including modeling, to establish
TMDLs and WLAs; use of whole-effluent toxicity
testing for setting toxics limits is increasing
Evaluation of available data on physical, chemical,
and biological conditions in the receiving waters, and
the character of contributing industrial wastes
NPDES permittees submit Discharge Monitoring
Reports (DMRs) reporting self-monitoring results;
States or EPA conduct periodic compliance inspections
and annual DMR quality assurance programs.
States and Regions assess the level of non-
compliance and the level of water quality problems
related to regulated discharges.
Growing use of water quality and source self-
monitoring (DMR) data in targeting inspection and
enforcement

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                  APPENDIX A
ASSISTANT ADMINISTRATOR FOR WATER'S MEMORANDUM
INITIATING THE EPA SURFACE WATER MONITORING STUDY

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   5.  EPA and States conduct or participate in a limited number of large, statistically-
       designed water quality surveys.

   These widescale studies are screening mechanisms by which EPA and States can identify
both pervasive and localized threats to human health and the environment.  For example, the
Office of Water conducted the National Dioxin Study in 1984 and 1985 to detect the presence
and magnitude of dioxin pollution in the nation's waterways.  The Bioaccumulation Study,
which began sample collection in FY 1987, is looking for the presence of a wide variety of
toxic chemicals in tissue samples from fish collected nationwide. One disadvantage of studies
of this type is that they generally cannot be disaggregated and used by individual States in
assessing local conditions.


   6.  EPA and the States summarize water quality trends and progress in biennial reports to
       Congress and the public.

   In its periodic national assessments of surface water quality, EPA looks for general trends
of improvement or degradation that are useful in gauging the effectiveness of State pollution
control efforts and in identifying emerging national problems that may require Federal action.
To satisfy the requirements of Section 305(b) of the Clean Water Act, EPA requires each State
to report biennially on the water quality conditions in  the State, based on all the information
available at the time this reporting is required. With assistance from the Regional Offices, the
Office of Water integrates and summarizes these individual reports into a national report for
submission to Congress  and distribution  to the public  every two years.   Other sources of
information sometimes augment  the 305(b) process, such as the STEP Report, a 10-year
summary of State water quality changes prepared in  1983 by the Association of State and
Interstate Water Pollution Control Administrators (ASIWPCA).

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                       THE NEED FOR CHANGE:

                   EMERGING CHALLENGES ARE
           CREATING NEW INFORMATION NEEDS
   The scope and complexity of water quality management issues are expanding rapidly.  As
Figure 3 illustrates, the task of pollution control and abatement is moving well beyond  the
focus on chemical-specific, technology-based controls of conventional and toxic compounds
that was dominant in the 1970s and early 1980s. Water quality planners and managers now
need  more information on the occurrence and significance of a swiftly-growing list of
chemicals. The analyses needed to detect these chemicals efficiently in more complex matrices
are more costly and time-consuming.

   This trend is accompanied by a growing demand for ambient monitoring to provide early
warning of potential environmental problems, to develop environmentally-based regulations (as
opposed to technology-based regulations), and to assess the effectiveness of the numerous
environmental management problems. The EPA and State role in ambient monitoring has been
expanded  by the Water Quality Act of 1987, which articulates the need to assess waters
systematically and identify impairments of water quality due to point source toxic discharges
and pollution from nonpoint sources. Information from these assessments will be used to
establish priorities for State and EPA activities and to develop State Clean Water Strategies.

   The many programmatic requirements for information cannot be met by relying strictly on
traditional monitoring and analytical methods.  For example, many of the Nation's surface
waters are impaired because of physical habitat, sediment toxicity, modifications to  the
hydrological regimes, or other factors which cannot be identified or assessed by monitoring
chemicals  in the watercolumn.  Assessment of nonpoint sources of pollution, which is done
most effectively during and immediately following storm events, will require modification of
monitoring programs that have been keyed to measuring water quality at low flow conditions.
Also, ambient monitoring to detect ecosystem effects can require more attention to the design of
the monitoring program and often requires a commitment to monitor more parameters over a
larger area and for a longer time.

   Technological, programmatic, statutory, and policy changes within EPA over the past four
years have created a whole new context for decision-making that will carry over well into the
next century.   State and EPA managers are now confronting new decision-making
requirements posed by at least five emerging challenges. These challenges  may be grouped
into two major areas: the first three deal with the need to use ambient data to develop more
effective environmental management programs, and the last two are created by shifts in EPA
priorities. Taken together, these challenges form a compelling argument for change in  the kind
of information the Agency  and the States collect, the way it is collected, and how it is stored,
managed, and used.

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                                   Figure  3
         Surface Water Quality Management
                 is  an Increasingly Complex
             and Information-Intensive Task
            Earlv 1970's
                       1976-84
                        1985-90
Be\ondl990
WHAT
 Chemical Data
Indicative of Water
   Quality:

 BOD and DO
 Suspended and
  Dissolved Solids
 Bacteria
 Nutrients
 Temperature
 pH
Priority Pollutants

Effluent Guideline
   Chemicals

  Pretreatment
   Chemicals
                                                         Toxics
                                                     Control Strategy:

                                                     • Water Quality-
                                                       Based Permits
                                                     • Non-Point Source
                                                       Assessments
                                                        Additional
                                                       Pretreatment
                                                       Chemicals:
                                                     • Domestic Sewage
                                                     • RCRA1TSCAI
                                                       F1FRA
  Multimedia
Risk Management:

• Air
• Ground-Water
• Drinking Water
• Sod
WHERE
             Surface, Marine,
              and Estuarine
             Water Columns
             Municipal and
            Industrial Sources
                       Sediments
Benthic Organisms

   Fish Tissue
                        Sampling
                     Matrices Remain
                        the Same
                                           Ecosystem
                                          Analysis Begins
                                                                Ecosystem
                                                                 Analysis
                                                                 Matures
HOW
               Chemical
               Analysis:
            • Ambient Fixed
               Stations
            • Effluents
                       Improved
                    Chemical Analysis

                       Biological
                       Monitoring

                     Intensive Surveys

                     Special Studies:
                    • Toxicology
                    • Bioaccumulation
                    • Acid Deposition
                    • Fisheries Survey
                         Further
                     Improvements in
                    Chemical Analysis:

                    • New Analytical
                      Tests
                    • Lower Detection
                      Levels
                    • Ecosystem Surveys
                                                     Rapid Assessment
                                                        Methods:
                                                     • Toxicity Testing
  Integration of
 Environmental
   Data from
 Multiple Sources


 Use of Existing
 Monitoring Data
   in Pro gram
  Planning and
 Priority Setting

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                                           11
                                   CHALLENGE 1

                         Develop and Use Biological Testing
                     Methods to Control Toxic Water Pollutants
   In the last few years, EPA and other environmental organizations have recognized that toxic
contamination from point and nonpoint sources is a widespread and serious threat. In addition
to the "priority pollutants" listed in the 1977 amendments, EPA has identified more than 600
hazardous or toxic chemicals that may require regulation, not only in surface waters but also in
groundwaters and finished drinking water, because of their potential threat to  aquatic
ecosystems and human  health. This list will continue to grow as  EPA expands its early
warning and other ambient monitoring programs.

   Traditionally, EPA has pursued a chemical-specific approach to regulating pollutants. Over
the last five years, however, it has become apparent that a chemical-specific  approach, by
itself, cannot  adequately protect all surface waters, because many toxic compounds cannot be
measured by available detection methods.  Analysis for toxics also can require a greater number
of samples, and the procedures used to conduct the analyses are often more complex (and
therefore generally more time-consuming), resulting in higher total costs for an adequate
monitoring program.  Moreover, lexicological data are not available for thousands of toxic
compounds routinely found in  surface and groundwater, and data  on the effects of individual
compounds do not account for the interactions (synergistic or antagonistic) among pollutants
that occur together in complex mixtures of toxicants.

   Because of limitations in the chemical-specific approach, EPA has made a decisive move to
develop biological testing as a tool to help manage pollution in the Nation's waters. A number
of quick, reliable, and relatively inexpensive biological tests have been  developed, validated,
and published — each useful  in measuring the toxicity of complex mixtures  to plants and
animals.  In  the past several years, some State and  EPA water quality  managers have
successfully used bioassays of water toxicity to identify environmental problems, establish
regulatory priorities, set permit limits on effluent discharges, identify appropriate corrective
actions, and monitor for compliance with permit conditions. In a few instances, this technique
— called "toxicity testing"  — has been used to evaluate the effectiveness  of management
programs. However, progress to date has been slow.

   The challenge to EPA is to build on these  successes and extend  the application of these
procedures to all State water quality management operations, as well as to municipal and
industrial dischargers. To be successful, EPA must continue to develop and validate toxicity
testing procedures and monitoring techniques which integrate the effects of chemicals and
assess the combined effects of all stressors.  The Agency must be involved in developing,
validating, and using new physiological, biochemical, and genetic techniques which can
indicate sublethal stress  caused by chemicals.  Managers will also need guidance on  how to
apply these procedures and interpret and test the results.  Finally, EPA will need to assist State
and local managers through training and technology transfer aimed at creating programs based
on these techniques.

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                                          12
                                  CHALLENGE 2

               Increase Use of Biological Monitoring to Characterize
                Aquatic Systems and Identify Problems and Trends
   An important purpose of surface water monitoring should be to provide a baseline
characterization  of the Nation's aquatic resources.  The information gathered in  these
assessments can  serve as the basis for a strategy for managing water quality and water-
dependent resources.  A comprehensive assessment of the Nation's aquatic resources,
conducted systematically over a number of years, would provide a foundation from which
managers can identify, from the universe of all waters, the subset that would benefit most from
management actions (i.e., largest reduction in hazard or risk, or largest gain in benefits
restored).  Once these assessments are made, State and local managers can more effectively
develop priorities and plans for specific waterbodies that are not attaining designated uses or
that are likely to be degraded in the future.

   EPA now faces the challenge of developing efficacious techniques for rapid assessment of
the very large number of streams, rivers, lakes, and coastal waters to identify actual or potential
problems and to determine the causes of those problems.  Biological monitoring methods will
play an  important role in these assessments.  The biota of a waterbody reflect the physical,
chemical, and biological integrity of the system.  Information on the conditions of individual
fish  (e.g., size, weight, occurrence of abnormalities or disease) combined with  data on
population and community-related parameters (e.g., age classes, diversity, abundance,
equitability, and function) can therefore be used to identify problem areas in the waterbody.

   Techniques for rapid analysis of ecosystems currently are being field-tested in several
States by EPA's Corvallis Laboratory. A principal objective of these methods is to quickly and
effectively monitor the health or biological integrity of an aquatic community as an indicator of
water quality. This rapid bioassessment might be only the initial stage of a tiered approach to
water resources characterization; later stages would employ more detailed intensive surveys of
physical/chemical parameters  and of other components of the ecosystem,  such as
macroinvertebrates and periphyton, to characterize further the nature, extent, and significance
of the environmental problem.
                                  CHALLENGES

                        Demonstrate That Pollutant Control
                     Investments Are Achieving Desired Results
   A basic goal of EPA's environmental programs is to reduce risks to human health, welfare
and the environment. In the early 1980s, the Agency developed an accountability system to
measure progress toward this goal by tracking certain programmatic indicators. This system,
the Strategic Planning and Management System, SPMS, has been used successfully to evaluate
progress in meeting high-priority program commitments such as enforcement actions or permit
reissuances. In most cases, however, such measures  are surrogates for true environmental

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                                           13
measures such as the actual change in concentrations of chemicals in the watercolumn, in
sediment, or in fish tissue.  They do not provide much information on how environmental
quality has  changed specifically as a result of EPA or State environmental management
activities.

    EPA senior management has recently stressed the need to strengthen the Agency's ability to
manage for environmental  results — to base management decisions  on  an analysis of the
expected improvement in environmental quality with the concomitant reduction in risk. This
approach to decision-making requires that EPA collect and use information on how its control
actions affect specific environmental conditions.  Such information has not been routinely
collected, however, hampering the Agency's ability to analyze the risk-reducing results of its
programs. A case in point is a recently-published EPA report on comparative risk, Unfinished
Business: A Comparative Assessment of Environmental Problems.  The authors of this report
evaluated the relative risks  associated with the various environmental problems that EPA is
addressing.  They found that a lack of environmental data limited their ability to perform
quantitative evaluations of environmental risk.

    Increasing results-based decision-making will require EPA to evaluate past control actions
to see whether they have had the intended effect. Better data on the effectiveness of pollution
control activities would enhance the Agency's ability to change or fine-tune programs, policies,
and regulations. Unfortunately, evaluation is the one aspect of environmental management that
receives the  least attention and is often left out completely. In State water quality management
programs, the importance of follow-up information is growing with the  increased emphasis on
water-quality based permitting and the expanding focus on the identification and control of
toxic pollutants and nonpoint sources.  Water quality  managers are faced with rapidly-
increasing demands on a slowly-expanding or static resource base. Under such conditions,
evaluation to determine what is working can play an important role in the decisions about how
the available resources can best be applied.

    EPA's challenge is to institutionalize the complete planning and management cycle
illustrated in Figure 1. To be  successful, senior managers must constantly ask the questions,
"What have we accomplished?", and "How do we know this program has been successful?"
They also must be prepared  to support their answers with  verifiable data illustrating the
environmental effects of their actions.
                                   CHALLENGE 4

                   Identify and Characterize Toxic, Conventional,
                and Anthropogenic Pollutants from Nonpoint Sources
   Most surface water quality problems are a result of pollutants from multiple sources,
including land, air, groundwater, and point source dischargers.  Although this relationship has
long been recognized by water quality managers, EPA has chosen, based on legislative
authority, to concentrate their regulatory activities on the point sources.  The Agency has kept
significant amounts of pollutants out of the Nation's surface waters through the use of
technology-based and water quality-based standards. Recent changes to the  Clean Water Act
specifically require EPA and State water quality managers to identify where uses of surface
waters are being impaired due to nonpoint sources of pollution and to develop management
plans to address these problems.

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                                           14
   Based on our current knowledge of the Nation's waters,  point source pollution is no
longer, and in some areas never was, the paramount threat to surface water quality in many
parts of the country. Six of EPA's ten Regional offices reported in their 1986 Environmental
Management Reports that nonpoint sources are the principal cause of their remaining water
quality problems.  Many States have longstanding problems with urban and agricultural
nonpoint sources, and some are dealing with more recently-identified threats from toxic
chemicals such as pesticide runoff and seepage from hazardous waste sites. In some rivers,
nonpoint sources of conventional pollutants (e.g., nutrients and suspended solids) are the main
problems.  For example, heavy siltation of stream beds in the Pacific Northwest, resulting
from forestry practices,  destroys fish breeding habitats and impairs the beneficial use of
streams.  Nonpoint sources of all kinds also contribute heavily to the degradation of coastal
waters and the loss or impairment of living marine resources such as shellfish.

   To confront these kinds of problems, EPA and the States must have data on the effects of
nonpoint sources on conditions in many waterbodies.  Nonpoint source monitoring introduces
a specific set of questions and concerns that differ from point source monitoring. Generally,
monitoring of nonpoint sources requires fixed stations, monitoring for long durations, and
collecting related data such as hydrologic, meteorologic, land use, and demographic data. The
expense of fixed station monitoring, in particular, will challenge water quality mangers to
formulate questions precisely  and to  evaluate periodically the effectiveness of chosen
management activities.
                                  CHALLENGES

                       Expand Efforts to Identify and Control
               Pollution Problems in Near-Coastal and Ocean Waters
   Much of the inland pollution — from nonpoint sources, unpermitted point sources, and
permitted but non-complying facilities — is eventually washed into the bays and estuaries,
where it combines with  pollution  from shoreline sources.  The open ocean also receives
pollutants, mainly from direct dumping of sewage sludge and other materials from ocean
outfalls  of land-based sources, from discharges by drilling rigs and ships, and from the air.
Monitoring needs will continue to increase in the marine and estuarine programs as EPA and
the States expand current efforts to assess environmental quality, identify pollution sources,
and develop water quality management plans and programs.

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                                         15
               OBSTACLES TO MEETING THE NEW
                        INFORMATION NEEDS
• The Present Approach to Surface
   Water Monitoring Cannot Fully Provide the
   Information That Managers Increasingly Need.


   Each of the five emerging challenges is accompanied by new information needs. Over the
next few years, State and Federal managers and scientists will need to answer questions and
make decisions that many of them have not faced before. Figure 4 lists examples of the
questions that are becoming increasingly important to decision-makers. To answer these and
other emerging questions, water quality managers will need environmental information that is
not being collected now, and they will need to make better use of the data that are being
collected.

   The State/EPA surface water monitoring program is now oriented toward the problems of
the past and present, not those of the future. In preparing to meet the information needs of the
future, EPA and the States must work together to overcome three significant obstacles of the
present approach:

   Obstacle 1:   Inadequate methods and resources for characterization, problem
                identification, and trend assessment in inland, near-coastal, and
                marine waters.

   Obstacle 2:   Inability to assess the effectiveness of point source control and
                nonpoint source management actions in terms of environmental
                results.

   ObstacleS:   Insufficient  use of existing  water-related  data  to guide,
                complement, or avoid new monitoring.

   Each of these obstacles corresponds to a major function depicted in Figure 1.  While the
present program does an adequate job of supporting one major function of water quality
management — Developing and Implementing Water Quality Management Programs - it does
not provide sufficient support to the other functions — Characterizing Water Resources and
Identifying Water  Quality Problems and Trends; Developing Water Quality Management
Priorities and Plans; and Evaluating the Effectiveness of Management Actions. The remainder
of this section describes each of the significant obstacles in more detail.

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                            Figure 4

          Examples of Key Questions
     Water Quality  Managers Will Face
                in the Next Decade
+  What are the characteristics, including ranges of natural variation,
   of the waters in the State? What are the general trends in water quality
   and water quality-related resources?
+ Where within the State are aquatic resources impaired or threatened?


+ What are the causes or sources of the impairment or threat?
   Which water pollution problems in the State pose the greatest threat to
   human health and the environment?
   What sorts of control or management actions address these problems?
   Do we need new or improved approaches to protect water and
   water-related ecological resources such as wetlands?
   What should the priorities be for developing management tools and
   approaches (e.g., water quality criteria, sediment criteria, risk
   assessment procedures for fishl shellfish, best management practices
   for nonpoint sources)?
   Within a geographic area (basin,water shed,or estuarine drainage area),
   what should be our management strategy? That is, what relative
   emphasis should we place on permit development, enforcement,
   POTW construction, nonpoint source control, combined sewer
   overflow controls, etc.?

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                                           17
                                    OBSTACLE 1

                         Inadequate Methods and Resources
                    for Characterization, Problem Identification,
         and Trend Assessment in Inland, Near-Coastal, and Marine Waters

   Ambient monitoring for characterization, problem screening, and trend assessment is
essential for effective water quality management, because the information can help to focus
scarce State and Federal resources where they will produce the greatest benefit in stopping or
preventing pollution. As noted earlier, most States have reduced their number of regularly-
sampled fixed stations over the past few years, in response to the rising cost of data collection
and analysis and the growing need for intensive survey monitoring in support of point source
control decisions.

   This overall reduction in assessment capacity has occurred at an inopportune time. The
impetus for status and trend monitoring has never been greater, due to the burgeoning concern
about nutrients and sedimentation from nonpoint sources and about organic and inorganic
toxics from all sources, including pesticides from agricultural runoff. The concern increasingly
extends to marine and estuarine environments, a top EPA priority for the late 1980s and early
1990s, where monitoring must help identify pollution patterns and track pollutant fates and
effects across large geographic areas.

   Even large fixed station monitoring programs are not well-suited to support the mounting
battle against toxic chemicals in surface waters. States are only beginning to explore methods
of expanding their monitoring activities to encompass a limited number of toxics, mainly metals
from the priority pollutant list (e.g.,  copper, cadmium, lead).  The process has been slowed by
the dependence on more complex and relatively expensive chemical analysis of water samples,
which makes it impractical for most States to use their traditional monitoring approaches in
screening for toxic pollution in ambient waters. Even if more resources were to be devoted to
watercolumn monitoring for toxics, adequate analytical techniques  are not yet available for
many impacts resulting from contaminated sediments or from modifications to the habitat or
hydrological regime. Finally, the fixed station designs that States typically use are not well-
suited to assess nonpoint source pollution problems.

   EPA and the States  need better methods  for ambient problem screening and trend
monitoring, especially for toxics.  Some States have already begun to move away from routine
watercolumn monitoring of a static network and are experimenting with flexible  siting
approaches (e.g., basin networks)  that employ biological monitoring, sediment and biota
chemical analysis, and analysis of existing water quality data to identify problems that require
more intensive monitoring. Some EPA offices also have made a good start in developing and
applying sophisticated approaches to network design and sampling frequency. Good examples
of this progress are OMEP's programs for monitoring marine discharges by oil and gas drilling
operations and by sewage treatment plants.

   There is great disparity among the States, however, in the speed with which more effective
methods and strategies are being explored and adopted. Most States can benefit from added
expertise in designing scientifically sound, cost-effective assessment programs that incorporate
biological and sediment analysis techniques to complement the traditional  water chemistry
methods. In addition, EPA must continue to strive for greater consistency among the States in
their monitoring approaches, terminology, and reporting formats so that the Agency and other
organizations can use State data to create sound national overviews of water quality conditions
and progress.

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                                           18
                                    OBSTACLE2

          Inability to Assess the Effectiveness of Point Source Control and
     Nonpoint Source Management Actions in Terms of Environmental Results

   In the functional area of Evaluating the Effectiveness of Management Actions, the task of
monitoring is to provide follow-up information after an action has been taken to assess the
environmental results of those actions.   EPA has placed overwhelming emphasis on the
compliance monitoring approach, relying on dischargers to regularly provide evidence of their
compliance with effluent limitations.  In the era of technology-based controls, "effectiveness"
generally has been defined as continued compliance with the permit limitations.  This approach
relies on the assumptions that the permit includes all of the important pollutants, that the
Discharge Monitoring Reports are accurate and are used to develop an enforcement strategy,
and finally, that permits are the appropriate management tool to address the problem.

   The Agency does very little ambient monitoring to determine if programs are  working as
they were designed. Typically, a program office will do good front-end work to promote a
program based on the environmental results it is expected to achieve.  Unfortunately, there is
little, if any, follow-up monitoring to determine if the assumptions and projections  were valid.
If there are no effectiveness data, then there is little impetus to make mid-course corrections to
programs or policies that may not be working as originally planned. This is a major obstacle to
more effective environmental problem solving.

   Without such information  on the effectiveness of permit conditions and treatment plant
construction decisions, permitting agencies cannot "close the loop" on point source controls.
They cannot systematically determine, for example, which dischargers should  have  more
stringent effluent limits because of unanticipated effects on water quality. Nor can they identify
pollution contributed by  nonpoint sources, which may in fact be the real reason for the
continuing water quality problems.

   Without follow-up data, the regulatory agencies  cannot determine whether  the cost of
control is producing the benefits sought.  EPA has found it very difficult, for example, to
assemble evidence showing the efficacy of the nation's  multi-billion dollar investment in grants
to municipalities for construction of wastewater treatment plants. (See The Nation's Water:
Key  Unanswered Questions About the Quality of Rivers and Streams, General Accounting
Office, 1986.) Although some treatment plant operators  periodically assess  ambient water
quality downstream from their outfalls, these monitoring studies usually are not conducted at
EPA or State request, and the data are not formally reported to the permitting authority.

   Ambient effects monitoring is vital to EPA's State water  quality-based  toxics control
program, which places great emphasis on  developing water quality-based permit limits. To
ensure the success of the water quality-based permitting strategy, EPA and the States also need
information on the effectiveness of the post-technology control measures — the wasteload
allocations and the individual water quality-based permit limits.  Periodic repetitions of the
ambient studies are needed to determine whether the permit conditions have produced the
required improvement in water quality (or lack of degradation) necessary to meet water quality
standards, and, more generally, to demonstrate the environmental benefits of the costly water
quality-based requirements. Dischargers must be relied upon systemically to provide ambient
as well as discharge information.

   Finally, as  States increase their efforts  to control nonpoint sources of pollution,  they will
increasingly need to evaluate the effectiveness of the Best Management Practices and other
nonpoint source actions in achieving and maintaining water quality standards.

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                                           19
                                   OBSTACLES

                     Insufficient Use of Existing Water-Related
              Data to Guide, Complement, or Avoid New Monitoring

   In any given State, many organizations collect water quality data for a wide variety of
purposes —  State agencies, local authorities, universities,  and several Federal agencies,
including EPA, the U.S. Geological Survey (USGS), and the National Oceanographic and
Atmospheric Administration (NO A A). Much of these data are stored in multi-user computer
data bases or is referenced in a computerized catalog, making it more accessible to a wide range
of potential  users.  However, water quality managers often do not use available monitoring
data from any source in developing plans, setting priorities, or making operational decisions.
EPA and the States have invested heavily in data collection and in computer systems to store
and manipulate the results, and yet much of the data are never used again once they have served
their original purpose.  Three reasons are offered repeatedly by water quality specialists in
States and EPA Regional Offices:

   •   The pervasive mistrust of data collected by someone else for another purpose;

       The difficulty of making effective use of EPA's water-related data bases; and

   •   The generally low level of awareness among EPA and State water quality
       managers and staff about where potentially-useful data may reside — at EPA,
       in the States, at other Federal agencies, or elsewhere.

   As the cost of data collection rises and the complexity of the water monitoring task
increases, these obstacles must be overcome so that greater value can be extracted from existing
water quality data. Major efficiencies in program operations can be gained through analysis of
existing data — for example, in narrowing the focus for additional monitoring, in targeting
corrective actions, and in revealing long-term pollution trends.

   The Office of Water, the Office of Research and Development, Regional Environmental
Services Divisions, and numerous States are slowly gaining experience in using existing data
to narrow the focus of field monitoring.  For example, examination of historical data from a
variety of sources has been  a  key element  in the monitoring  strategy  of EPA's National
Estuaries Program. Much additional work is needed, however, to expand and institutionalize
EPA and State knowledge about potential sources and uses of existing data.

   In the past few years, managers in the Office of Water and  in other EPA organizations have
recognized the benefits of combining water-related data from  two or more systems to perform
integrated analyses. For example, joint analysis of NPDES  discharge data from the Permit
Compliance  System (PCS) and ambient monitoring data from the  STORET Water Quality File
may provide important clues as to the upstream source of toxic pollutants in a river segment.
In this and numerous other ways, "data integration" can help EPA and  State water quality
managers identify  problems and trends and target their field  activities more effectively.
Sophisticated use of existing data in this way can be a major source of productivity  gains as
EPA and the States attack the complexitites of water quality management in the 1990s.

   The Office of Water has now made a commitment to steady progress in linking the various
data bases, and some notable advances have been made in the last year. For example, systems
technicians  from the  Office of Water Regulations  and Standards and EPA's Office of
Information Resources Management have created a computer  program that can draw together,

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                                            20
manipulate, and display data from STORET and several other water-related data files.  While
this and other activities are steps in the right direction, there has been no central coordination of
the data integration efforts of the respective OW offices, or the integration projects of EPA
Regional Offices. A number of problems have arisen from this failure to aggressively manage
the process:

    •   The individual offices involved have approached  the integration task with
       somewhat different goals in mind, and there is very little interaction among
       them that might help to avoid duplication of effort or ensure a "big picture"
       approach;

    •   The integration projects are being conducted in a piecemeal fashion, without a
       blueprint that ties these activities to other important data management projects
       and needs within the water programs;

    •   Discrepancies in data element definitions and numering conventions have not
       been adequately resolved; and

    •   Too little attention has been paid to how the new capabilities can best be
       "marketed" to the States and Regional Offices — the real beneficiaries of data
       integration.

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                                          21
          A NATIONAL FRAMEWORK FOR CHANGE
•  The Office of Water Does Not Have
   A Strategy for Reorienting Surface Water
   Monitoring to Meet the Information Needs of the 1990s.


   EPA's water monitoring policy-makers  have been addressing the emerging pollution
control challenges in a fragmented, reactive way.  The Office of Water lacks a clear conception
of where the monitoring program should be going, why, and how it will get there. In the
absence of a national framework, each individual State is proceeding independently to face the
problems posed by growing concern with toxics, nonpoint sources, near-coastal waters, and
the environmental results. Some States are making impressive progress at this task. Others are
falling behind and will require technical assistance to enable them to catch up to the leaders.

   EPA must now exert national leadership to close this growing "capability gap" among
States.  The Office of Water has only a narrow window of opportunity for creating a
nationally-consistent monitoring program to meet State and EPA needs for water quality
information in the  next decade. If the growing discrepancy among State objectives, methods,
and resources continues, EPA will find it extremely difficult to focus these disparate programs
on national objectives, once they are defined. Moreover, the lack of comparability in  State
methods  and results  will continue to be a major obstacle to satisfactory national-level
summaries of water quality problems and trends.

   A national framework is needed which clarifies EPA's objectives, defines a direction, and
provides a firm foundation for individual State monitoring programs.


•  The Actions Recommended in This
   Report Should Be Included in a National
   Framework for Change in Surface Water Monitoring.


   The remainder of this report  describes actions that should be  included in the Office of
Water's agenda for reorienting surface water monitoring. These recommendations are aimed at
the three major obstacles identified by this study,  restated as key objectives for joint EPA/State
action over the next three years:

   Objective 1:   Enhance State and EPA Capabilities to Carry Out Characterization,
                Problem Identification,  and Trend  Assessment  in Inland,
                Estuarine, and Marine Waters

   Objective 2:   Increase Ambient Follow-Up Monitoring for Use in Evaluating the
                Effectiveness of Water Quality Management Actions

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                                           22
   Objective 3:    Promote the Use of Available Water-Related Data in EPA and
                 State Decision-Making

   Figure 5 relates these strategic objectives to the study's six general Recommendation Areas,
and Figure 6 lists the individual actions recommended in each area.  Figure 7 presents a
preliminary implementation schedule for these activities, showing the estimated duration of
each task, the lead program office, and a proposed sequencing of the respective actions.
                          RECOMMENDATION AREA 1

                    Issue Guidance on Efficacious Approaches to
          Characterization, Problem Identification, and Trend Assessment
   The Office of Water can play an important role in disseminating knowledge about
monitoring techniques from the pioneering few to all State and EPA monitoring programs.  The
steps outlined in Recommendation Area 2, on the development and application of biological
monitoring techniques, will contribute significantly to this "technology transfer." In addition,
the Office of Water should begin issuing detailed guidance on several related topics during
FY 1988.  These subjects could all be treated in a single guidance document, but OW probably
will find it desirable to produce two or more separate documents.


   A.  Issue guidance to States on re-evaluating their surface water monitoring programs.

   Before making changes in the current approach to characterization, problem identification,
and trend assessment, individual States must take stock of where they are now with respect to
all types of water monitoring, identify the weaknesses of the present program, and determine
what they want to achieve in  surface water monitoring over the next five years.  This re-
evaluation process should culminate in an explicit plan for improving the State's monitoring
program.  Several States (e.g., North Carolina, Florida) have systematically re-evaluated and
redirected their monitoring programs in the past few years, and EPA should determine whether
their approach can serve as a model that other States could use.

   EPA's guidance on re-evaluating monitoring programs should recommend a detailed, step-
by-step method for:

   •   Determining the present and future needs for water quality data in supporting
       management and technical decisions;

   •   Defining "Data  Quality  Objectives" for data collection in support of key
       regulatory and programmatic decisions;

   •   Identifying current monitoring activities that are not adequately meeting
       existing or future information needs;

       Identifying current monitoring activities for which there is no existing or
       anticipated future need;

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                                  Figure 5

Major Objectives and Areas of Recommended Action
         for Improving Surface Water Monitoring
  OBJECTIVE i
Enhance State and EPA
  Capabilities to Carry
 Out Characterization,
Problem Identification,
 and Trend Assessments
  in Inland, Estuarine,
  and Marine Waters
  RECOMMENDATION
        AREA1
  Issue guidance on efficacious
  approaches to characterization
    problem identification,
    and trend assessment
  RECOMMENDATION
        AREA2
  Accelerate the development
  and application of promising
    biological monitoring
       techniques
  OBJECTIVE 2

  Increase Ambient
Follow-Up Monitoring
 for Use in Evaluating
   the Effectiveness
   of Water Quality
 Management Actions
   RECOMMENDATION
        AREA 3
   Analyze the feasibility of
  requiring NPDES permittees
    to conduct ambient
  follow-up monitoring studies
   RECOMMENDATION
        AREA 4
    Continue and expand
 efforts to improve information
   on national progress in
   water pollution control
 OBJECTIVE 3

  Promote the Use
    of Available
 Water-Related Data
  in EPA and State
  Decision-Making
 RECOMMENDATION
      AREA 5
  Improve EPA and State
  knowledge about sources
   and uses of existing
    water-related data
 RECOMJMQHVDATION
       AREA 6
Establish central coordination
   of EPA activities to
 integrate water-related data

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                                                                       Figure 6

                          Summary  of  Specific Actions  Recommended
          RECOMMENDATION AREA 1

     Issue Guidance on Efficacious Approaches to
      Characterization, Problem Identification,
               and Trend Assessment
      •  Issue guidance to States on re-evaluating their
        surface water monitoring programs.

      •  Develop one or more technical reference manuals
        on basic design principles for water quality
        trend monitoring.

      «  Issue guidance on establishing and maintaining
        "citizens' watch" programs.
         RECOMMENDATION AREA 4


Continue and Expand Efforts to Improve Information
  on National Progress in Water Pollution Control

  •  Provide detailed and unambiguous guidance to States
     on objectives, definitions, presentation formats, and
     recommended assessment methods.

  •  Proceed rapidly with development of a Water Quality
     Information Tracking System.

  •  Carefully examine the types of water quality monitoring
     performed by other Federal agencies, and develop an
     approach for systematically drawing on these sources,
     when appropriate, in the national assessment process.
        RECOMMENDATION AREA 2

 Accelerate the Development and Application of
  Promising Biological Monitoring Techniques

 •  Thoroughly survey and evaluate the current situation
    with development and application of biological
    techniques in the United States and Canada.

 •  Evaluate the role that biological monitoring
    techniques should play in a systematic, cost-effective
    problem screening and trend monitoring program.

 •  Create a detailed action plan specifying the steps OW
    will take in FY 1988-90 to accelerate the development
    and application of biological methods.

 •  Fully support the implementation, refinement, and use
    of the BIOS subsystem of STORET, EPA's main
    water quality  data system.
        RECOMMENDATION AREA S

Improve EPA and State Knowledge About Sources
     and Uses of Existing Water-Related Data
      Develop a standard for labelling of monitoring
      data sets.
      Issue guidance on sources and uses of existing
      water-related flata

      Improve STORET's usefulness as a decision
      support tool.
                                                                                                        .
          RECOMMENDATION AREA 3

Analyze the Feasibility of Requiring NPDES Permittees
  to Conduct Ambient Follow-Up Monitoring Studies

  •  Specify the type and quantity of ambient effects
     information needed by Stale and/or EPA decision-makers.

  •  Clearly describe the characteristics of a technically-sound
     approach, or range of approaches, to ambient effects
     monitoring.

  •  Identify alternative methods by which the costs of
     ambient follow-up monitoring could be borne by the
     regulated community.

  4  Assess the advantages and disadvantages of each
     alternative method, and recommend how the Office
     of Water should proceed.
          RECOMMENDATION AREA 6

        Establish Central Coordination of EPA
      Activities to Integrate Water-Related Data


       Develop tools to make better use of DMR data,
       including linking of PCS, STORET, and other
       OW data files.

       Assess the feasibility of developing an automated
       data base of drinking water surveillance results.

       Ensure appropriate development and use of
       "geographic information systems."

       Promote awareness and use of data integration tools.

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                                                                 Figure 7
                                          Implementation Schedule  for
                  Surface  Water Monitoring  Study  Recommendations
         RECOMMENDATION
                                                                                FY19M
FY19S9
                                             LEA»
                                              EPA
  |«j
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                                           26
   •   Identifying and evaluating new approaches to characterization, problem
       screening, and trend monitoring (e.g., rapid bioassessment techniques such
       as the Index of Biotic Integrity used in conjunction with EPA's ecoregion
       concept; citizens' watch programs; and basin-oriented sampling networks);
       and

   •   Developing a written Action Plan for improving the cost-effectiveness of
       status and trend monitoring.

   In developing the guidance, the Office of Water should keep some important issues in
mind.  For example, EPA should encourage  States to design their monitoring programs to
address all types of surface water monitoring, including marine and estuarine monitoring and
nonpoint source studies.  These  programs  should attempt to  use cost-effective  source
assessments in conjunction with biological monitoring to help identify specific pollutants likely
to contribute to water quality problems. Why sample water, sediment, or biota to screen for
pollutants, for instance, if a thorough assessment of potential land-based sources can provide
the same screening-level information? Finally, a revised approach to characterization, problem
screening, and trend assessment cannot be developed in isolation from a State's needs for
permit-related intensive surveys, compliance monitoring, and use attainability studies.


   B.  Develop one or more technical reference manuals on basic design principles for water
       quality monitoring.

   The "cookbook-style" manual(s) should provide guidance on the statistical and scientific
considerations, such as network design and sampling frequency, which should be observed in
conducting problem screening and trend assessments. The guidance should show clearly how
these considerations differ for various monitoring objectives, pollutants, parameters, and
waterbody types. The document(s) should not contain a tutorial in statistical theory but instead
should provide basic, practical information to help State and EPA monitoring specialists meet
specific design needs. Creation of this guidance should aid significantly in the development of
guidance on re-evaluating monitoring programs (see Recommendation 1A)  by providing
information on the costs of scientifically valid monitoring to meet various program objectives.

   To provide a framework for the guidance, EPA should begin by identifying the  specific
purposes for which States  conduct water  quality monitoring  (e.g., detecting ambient
concentrations  of a single pollutant introduced into a freshwater stream by  industrial
dischargers; determining relative nutrient contributions in a watershed from POTWs and from
nonpoint sources; assessing the baseline condition of living resources  in a near-coastal
waterbody). The guidance should describe basic design principles for monitoring intended to
meet each purpose in this typology.

   The guidance should cover design issues unique to marine and estuarine environments as
well as freshwater habitats, and it should encompass assessment of nonpoint problems as well
as point source pollution.  (The Office of Water should consider issuing one entire technical
reference manual dealing only with nonpoint source monitoring.)  The guidance also should
incorporate the results of State/EPA efforts to  determine the role of biological monitoring
techniques in problem and trend assessments (see Recommendation 2B).

   The Office of Water should develop the specifications  for the manual(s), with extensive
participation from OWRS, OMEP, ORD, ESDs, selected States, and other organizations, as
appropriate.  Broad State participation is especially important,  since EPA must begin  by
determining what types of information States say they would find most useful.  OMEP has

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                                           27
already begun development of monitoring methods guidance specific to the marine and
estuarine programs, and OW should take full account of this experience in deciding how best to
proceed on this task. Sources of useful information and ideas on fresh water and salt water
monitoring include:

   •   Region X's Puget Sound Monitoring Program;

   •   The 30 l(h) program's monitoring guidance;

   •   The Chesapeake Bay Mainstem Monitoring Program;

   •   The Incineration-at-Sea Monitoring Plan;

   •   The Rural Clean Water Project's nonpoint source studies;

   •   The Great Lakes International Surveillance Plan (GLISP);

   •   ORD/Corvallis Laboratory's guidance on lake and reservoir restoration, on
       the Index of Biotic Integrity, and on the ecoregion approach to biological
       assessments (see Recommendation Area 2); and

   •   The seminar on statistical design of water monitoring studies offered through
       Colorado State University.
    C. Issue guidance on establishing and maintaining "citizens' watch" programs.

    Technical assistance from skilled and even unskilled members of the public can aid State
monitoring programs. Many States have organized formal "stream watch," "lake watch," and
"beach walk" programs to take advantage of community concern with water quality.  The
participants typically are organizations such as civic groups, environmental group chapters,
property owners' associations, and high school clubs.   In some programs,  each group
"adopts" a waterbody, or even an entire watershed, estuary, or bay, to be the focus of its
activities.  The  State provides general information  on  aquatic ecology in the area and
recommends procedures for observing and reporting a variety of water quality indicators such
as fish kills,  suspicious discharges, the condition of benthic fauna, and the physical and
chemical characteristics of the water.

    EPA can provide a service to States by serving as a clearinghouse for information on these
State  efforts, as well as developing guidance to aid their formation.  OWRS, with OMEP,
Regional, and State assistance, should take the following steps in producing this guidance:

    •  Review the experience  of States and other organizations  (e.g. the Izaak
      Walton  League, EPA's Great Lakes Program,  the Chesapeake Bay
      Foundation). What are the strengths and weaknesses of these citizens' watch
      programs ~ what has worked well and what has not, and why? How are the
      most effective programs organized?  How are  they funded?  How are they
      managed? How does the sponsoring agency record and use the information it
      receives?  What problems have been encountered, and how were they
      overcome?

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                                          28
      Assess in general terms the likely costs and potential benefits of a well-run
      citizens' watch program.  How can a program of this kind  contribute to
      improved cost-effectiveness in problem identification and trend assessment?
      Is it feasible to incorporate these groups in the State's formal waterbody
      assessment process?  What are the key factors that determine whether a
      program provides the intended benefits?

      Prepare guidance  to States describing a procedure for organizing and
      managing a public involvement program.
                          RECOMMENDATION AREA 2

                    Accelerate the Development and Application
                  of Promising Biological Monitoring Techniques
   Biological monitoring techniques assess the effects of pollution on the aquatic ecosystem,
on a particular species, or on individual test organisms. Effective use of these methods is vital
to the surface water monitoring program, because they can help water quality managers screen
large areas for pollution problems - particularly toxic contamination  — and focus additional
sampling and chemical analysis where problems are known to exist.  Biological monitoring
thus can play an important role in improving EPA's and States' ability to use chemical analysis
more effectively.

   EPA has conducted research and development on biological monitoring for several years,
and some States also have begun to develop and apply these tools. Examples of techniques
currently in use or under development include:

   •   Toxicity testing. These techniques assess the short-term effects of a sample
       of effluent  or ambient water on  an indicator  organism (e.g.,  a  sensitive
       species of fish). Whole-effluent toxicity testing is seeing increasing use as a
       means to determine whether a wastewater contains "toxic chemicals in toxic
       amounts."  If the effluent as a whole is found to be toxic to the organism,
       further analysis and testing may  be undertaken to isolate the  constituent
       chemical or combination of chemicals responsible. Techniques for testing the
       toxicity of ambient water have also been developd and field-tested  by EPA's
       Office of Research and Development.

   •   Rapid bioassessment techniques.  In this biological monitoring approach,
       field  biologists survey the biota in a waterbody and compare the  observed
       populations  and  community structures with norms established for that
       ecological zone.  A statistically-significant divergence from the baseline
       conditions may indicate the presence of pollutants not detected through routine
       watercolumn monitoring.

       EPA's Corvallis Laboratory is developing a rapid bioassessment  approach
       based on use ofan "Index of Biotic Integrity" (IBI) for a given waterbody.
       The IBI provides a baseline for such properties of biological communities as
       species richness and composition, trophic structure, and abundance. The IBI

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                                            29
       score for a stream is compared to the most unpolluted reference stream in the
       same "ecoregion" to determine if the waterbody being assessed has achieved
       its full biotic potential.  This technique is now being field-tested in Ohio and
       Arkansas.  Other rapid bioassessment techniques  include the  Habitat
       Evaluation Procedure developed by the U.S. Fish and Wildlife Service, and
       the Tennessee Valley Authority's Automated Fish Response System.

   •   Tissue analysis. In conjunction with the nationwide Bioaccumulation Study,
       EPA researchers are developing improved techniques for analysis of specific
       chemicals in fish tissue samples.  These techniques will permit laboratory
       analysis of a broader range of toxic chemicals and lower detection levels for
       many substances covered by present techniques. Advanced methods of this
       type can be especially useful in assessing the risk to human health through
       bioconcentration of toxic compounds in food fish and shellfish.

   While EPA and States are conducting some biological sampling and analysis, the rapidly
growing emphasis on control of toxics  demands an all-out, well-coordinated effort to make
these methods — and others yet to be developed — an integral part of water quality monitoring
programs. A top surface water monitoring priority for FY 1988-90 should be to accelerate the
existing efforts to develop cost-effective biological monitoring techniques, and to create
institutional mechanisms to promote the introduction and adoption of these techniques in State
monitoring programs. EPA must strengthen its important role in facilitating technology
transfer from lab to field office and from States that are relatively advanced in biological
monitoring to States that have limited experience with these approaches.

   The Office of Water should take four steps within the next year to expedite progress with
biological monitoring.


   A.  Survey and evaluate thoroughly the current situation with development and application
       of biological techniques in the United States and Canada

   This  intensive review of scientific and programmatic  experience will provide an
indispensable knowledge base to support EPA decision-making in this area. The survey and
evaluation should examine:

   •   The full range of biological methods applicable  to characterization, problem
       identification,  and trend monitoring, including  whole  effluent and ambient
       bioassays; rapid field assessment techniques; tissue analysis methods; and
       other emerging techniques of interest.

   •   Laboratory and field experience acquired by EPA, individual States, USGS,
       NOAA, TVA, other Federal agencies, Canadian environmental agencies,
       universities, and private organizations;

   •   The status of biological monitoring for marine and estuarine environments and
       for fresh water habitats;

   •   The status of biological monitoring for nonpoint pollution (e.g., from urban,
       agricultural, silvicultural, mining, and construction sources) in inland and
       near-coastal waters; and

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                                           30
   «  Key management problems (e.g., economics,  training, data handling,
      integration with other monitoring methods) as well as scientific or technical
      problems  revealed  by  experience to date, and how the  pioneering
      organizations have addressed them.


   B. Evaluate the role that biological monitoring techniques should play in a systematic,
      cost-effective problem screening and trend monitoring program.

   Biological monitoring is best viewed as a complement to physical and chemical monitoring
of waters and sediments.  The Office of  Water sees  biological methods not as "the next
generation" of monitoring techniques but rather as an important addition to the range of tools
for evaluating water quality. The Office of Water has made some preliminary decisions, at
least in the area of developing NPDES permits, about how and when to use biological methods
within an overall monitoring program. In the current approach, biological monitoring is used
primarily as a technique to assess impacts to aquatic life and to develop discharger controls for
aquatic life protection, while chemical-specific monitoring remains an important method of
detecting human health effects.

   The proper mix of biological and other methods in a well-balanced monitoring program still
needs to be determined for other programs.  For example, should biological methods be used
as the first step in a well-structured "tiered approach" — i.e., followed by chemical screening
when needed, and then by intensive chemical sampling? It is especially important to resolve
this issue soon in  the case of EPA/State efforts to develop the State Clean Water  Strategies
required by the Water Quality Act of 1987.

   The  effort to  determine the proper role for biological monitoring methods must be
coordinated with Recommendation 1A, the development of guidance on re-evaluating
monitoring programs.  The integration of biological methods into State monitoring programs
will evolve over the next decade, and it would be premature to look for a single, ideal mix at
this time. However, EPA  must begin to develop a conceptual model of how biological
techniques can contribute to cost-effective point source and nonpoint source monitoring and the
direction that State and Federal programs should take in this area. Several States have already
begun to deal with this issue, and it is likely that some  State programs will provide excellent
models for a generalized approach.


   C. Create a detailed action plan specifying the steps OW will take in FY 1988-90 to
      accelerate the development and application of biological monitoring methods.

   OWRS, OMEP, and OWEP must define and  adhere to an integrated, well-reasoned
strategy for Office of Water action to evaluate and promote biological methods. The action plan
should address a wide variety of topics, including:

   •  Demonstration projects and pilot studies for specific techniques, for both
      point source and nonpoint source  applications in fresh water and  marine
      water,

   •  Comparative field evaluations of similar techniques (e.g., EPA Index of
      Biotic Integrity, FWS Habitat Evaluation Procedure, TVA Automated Fish
      Response System);

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                                           31
   •   Development or  improvement  of selected  techniques  (e.g.,  rapid
       bioassessment methods for living resources in marine and estuarine waters;
       ambient bioassays);

   •   Technical assistance (e.g., guidance, field training, workshops);

   •   Development or enhancement of EPA data bases, statistical models, and other
       tools to support storage and analysis of biological data;

   •   Establishment of standard protocols, where needed, to guide the design of
       monitoring studies employing biological methods; and

   •   On-going information exchange and collaboration between the Office of Water
       and the Office of Research and Development, between EPA and States, and
       between EPA  and other Federal agencies in support of all actions specified in
       the plan.

   In  implementing Recommendations  2A, 2B,  and 2C, the Office of Water should
energetically solicit and promote contributions from many quarters.  While Office of Water
managers must be responsible for creating the action plan, this important direction-setting effort
cannot succeed without extensive participation by all entities with significant experience in
biological monitoring.  The Office of Water's process  for creating the plan should include
provisions for well-structured interaction among representatives from at least the following
organizations:

       EPA Headquarters

          Office of Water Regulations and Standards
          Office of Marine and Estuarine Protection
          Office of Water Enforcement and Permits
          Office of Research and Development
          Office of Policy, Planning, and Evaluation
          Office of Information Resources Management

       EPA Regional Offices

          Environmental Services Divisions
          Water Management Divisions

       State Environmental Agencies IASIWPCA

          States with significant biological monitoring experience
          States with limited biological monitoring experience

       Other Federal Agencies

          Department of the Interior (e.g., U.S. Geological Survey, U.S. Fish and
             Wildlife Service, Bureau of Land Management)

          Department of Commerce (e.g., National Oceanographic and Atmospheric
             Administration)

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                                         32
         Department of Agriculture (e.g., U.S. Soil Conservation Service, U.S.
            Forest Service)

         Department of Defense (e.g., U.S. Army Corps of Engineers)

         Department of Transportation

         Tennessee Valley Authority

      Others

         Universities
         Environmental groups
         Industries and POTWs


   D. Fully support  the implementation, refinement, and use of the BIOS subsystem of
      STORET, EPA's main water quality data system.

   BIOS, a successor to the little-used BIOSTORET system, currently is undergoing pilot
testing. Far from being an outgrowth of BIOSTORET, the new system will provide important
new capabilities for categorizing, storing, and retrieving biological data and analytical results.
If supported properly by the Office of Water and OIRM, BIOS can become an instrumental tool
in the overall effort to encourage the effective use of biological monitoring techniques.

   OW must ensure that potential users in States, Regions, ORD laboratories, and elsewhere
are adequately informed about the capabilities of BIOS and can obtain the necessary
documentation and training to enable them to use the system to support decision-making. For
example, OWEP believes that BIOS data can be used effectively in developing NPDES permit
limits. Once users become experienced with the new system's features, the Office of Water
must also support needed enhancements to the system, the user documentation, and the training
program.  Most important, OW managers must provide the oversight necessary to ensure that
technical decisions about  BIOS capabilities are consistent with the overall  strategy for
promoting development and application of biological monitoring methods (Recommendation
2C).
                         RECOMMENDATION AREA 3

                   Analyze the Feasibility of Requiring NPDES
          Permittees to Conduct Ambient Follow-Up Monitoring Studies
   To determine how ambient follow-up monitoring can best be performed without placing
further strain on tight monitoring budgets, the Office of Water should examine the feasibility of
requiring permittees to bear the cost, either through direct responsibility for the monitoring or
through some other mechanism such as a permit fee to defray the permitting agency's
monitoring costs. This detailed study should:

   •  Specify the type and quantity of ambient effects information needed by State
      and/or EPA decision-makers. That is, who needs this information and why
      do they need it?

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                                          33
       Clearly describe the characteristics of a technically-sound approach, or range
       of approaches, to ambient effects monitoring.  What methodologies are
       appropriate? How often should studies be performed?  The answers to these
       and many other technical questions will provide a concept of what the typical
       ambient effects monitoring program would entail.  This baseline picture is
       needed so that permitting authorities and the regulated community can
       objectively assess the costs and benefits. The study team must obtain the
       advice and opinions of field monitoring experts in creating this vital outline of
       the basic requirements.

       Identify alternative methods by  which the costs  of ambient follow-up
       monitoring could be borne by NPDES permittees, including fees of various
       types and direct imposition of the cost through added self-monitoring and
       reporting requirements.

       Assess the advantages and disadvantages of each  alternative method,
       including economic, political, legal, and procedural considerations.

       Recommend how the Office of Water should proceed.  What issues and
       concerns require further analysis before the final feasibility determination can
       be made? How should they be addresssed? If at least one alternative appears
       feasible, what steps should OW take  to design and implement the program
       (e.g., what must be done in the areas of regulation-writing, guidance-writing,
       information systems development)?
                          RECOMMENDATION AREA 4

                      Continue and Expand Efforts to Improve
           Information on National Progress in Water Pollution Control
   Improvements are needed in EPA's process for conducting national assessments — the
overview of the Nation's water quality conditions and trends published in the biennial "305(b)
Report" to Congress.  EPA's requirements for State assessments, set forth in 305(b) guidance,
can have  a signficant influence on how and where individual States do much of their
monitoring. For this reason, addressing the shortcomings of the national assessment process
must be viewed as part of the wider task of improving monitoring methods.

   The national 305(b) Reports have contained much useful information about water quality
conditions and trends across the country.  However, the Office of Water's approach to national
assessment has been criticized inside and outside EPA for its failure to adequately characterize
the overall quality of the Nation's waters and its inability to document the results of pollution
control efforts. In preparing the 1984 and 1986 305(b) Reports, EPA did not explicitly define
its management objectives for national  assessments.  States  also were not required to use
standard formats for data compilation and reporting. The State reports varied widely in scope,
methods,  definition of terms, reporting format, and quality of analysis.   This lack of
consistency severely limited EPA's ability to integrate them into a national picture.

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                                           34
   Recognizing these shortcomings, the Office of Water Regulations and Standards, which is
responsible for the 305(b) reporting process, is now working to change the way States collect,
analyze, and present information on water quality.  The long-term goal is to increase the
number of waters assessed and to monitor the effectiveness of pollution control actions taken
toward waters that do not meet the  State water quality standards. OWRS should aggressively
pursue its planned activities and should take additional steps to ensure their success.


   A. Provide detailed and unambiguous guidance to States on objectives, definitions,
       presentation formats, and recommended assessment methods.

   OWRS made some important improvements in the guidance for 1988 State 305(b) reports,
issued in April 1987.  Many important issues were not addressed adequately in this document,
however, and OWRS must make plans to resolve them in time for inclusion in the guidance on
1990 reports. For the 1990 guidance, OWRS, with appropriate input, should:

   •   Carefully define EPA's management objectives for  national water quality
       assessments.   Senior Office  of Water managers should determine  the
       fundamental questions the Agency wishes to answer ~ for Congress, for the
       public, for EPA's Administrator — concerning progress in water pollution
       control. This basic and essential first step has never been taken. As a result,
       EPA has not been able to articulate clearly what information is desired, how it
       should be obtained, and how it  should be presented  in State 305(b) reports.
       The OWRS investment in efforts to improve the 305(b) process cannot be
       assured of a firm foundation until the management objectives are specified.

   •   Continue to refine standard definitions for the categories of designated use
       support. At present, definitions of "fully", "partially", and i:not" supporting
       designated use are ambiguous, and State reports in previous years therefore
       did not have the uniformity necessary for a national summary of use support.
       OWRS has recognized the need for improved definitions,  and a State/EPA
       work group drafted standard definitions for the 1988 guidance.

   •   Provide a standard unit of assessment for marine waters.  Summarizing use
       attainment in bays and estuaries  is hampered by the lack of a standard method
       of designating segments of these very large waterbodies.  EPA and coastal
       States should work with NOAA to partition near-coastal waters into ecological
       subunits rather than arbitrary geometric divisions.

   •   Provide a scheme for characterizing the level of assessment performed on
       each waterbody assessed.  OWRS included a classification  scheme in the
       1988 guidance.  In the past, it had been impossible  for EPA confidently to
       determine the number of waterbodies assessed nationwide and, in turn, the
       number of assessed waters that do not support their designated use.  One
       important reason is that States differ in their interpretation of what constitutes
       a "reportable" assessment. Also, there has been no standard way of reporting
       the  extent of a given assessment;  for example, if a State  reports that a
       waterbody adjacent to a hazardous waste dump fully supports its designated
       use, EPA may not be able to determine from the  State's information whether
       the assessment included chemical testing for toxics or a desktop evaluation of
       known sources.

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                                           35
   •   Recommend monitoring methods to be used in each level of assessment.
       Levels of assessment are closely tied to the nature of the monitoring method
       used.  While it is not desirable to prescribe specific methods for each level of
       assessment, EPA should provide general guidance on the range of appropriate
       techniques and protocols.


   B.  Proceed rapidly with development of a Water Quality Information Tracking System.


   OWRS has had a difficult and time-consuming task in integrating and synthesizing the State
305(b) reports into a biennial national assessment.  The job has been complicated by a
cumbersome, poorly-organized method of managing information about State assessment
results (not the chemical and biological data itself).  In addition to improving definitions,
OWRS plans to develop, with assistance from OIRM, an automated data base to store and
manipulate this information.  The office  anticipates that this new system will facilitate
preparation of the national 305(b) Report, aid in EPA oversight control programs, and serve as
a quick-reference tool in responding to questions about the quality of particular waterbodies.

   OWRS has created a State/EPA work group to develop specifications for the "Water
Quality Information Tracking System."  The group  established a  development  and
implementation schedule that was to produce a fully-functioning system by the end of FY
1987.  It is important that the system be available in time to be useful in the 1988 305(b)
process, which will begin in the first quarter of FY 1988. The OWRS Office Director should
take all steps necessary to ensure that this important new management tool is completed on
schedule.
   C.  Examine carefully the types of water quality monitoring performed by other Federal
       agencies, and develop an approach for systematically drawing on these sources, when
       appropriate, in the national assessment process.


   Numerous Federal agencies routinely collect data that EPA might use to augment — and in
some cases even replace — the information provided by States in the 305(b) process. Examples
of these organizations are:

   •   U.S.  Geological Survey, which conducts routine monitoring via its fixed
       station NASQAN network and also conducts  more specialized water
       monitoring studies;

   •   National Oceanographic and Atmospheric Administration, which produces the
       National Coastal Pollutant Discharge Inventory, the National Estuarine Atlas,
       the National Status and Trends report,  the National Shellfish Register, and
       other regular compilations of data from  monitoring in near-coastal and ocean
       waters;

       (The Office of Marine and Estuarine Protection, working with the Office of
       Policy, Planning and Evaluation, has initiated a major cooperative program
       with NOAA's Office of Oceanography and Marine Assessment The intent of
       this program is to integrate and use data effectively to characterize the status
       and Likely future condition of the Nation's marine and estuarine waters.)

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                                          36
   •   U.S. Fish and Wildlife Service, which performs water monitoring in support
       of studies on wetland habitats, and freshwater and near-coastal fisheries; and

   •   U.S.  Forest  Service  and U.S. Soil  Conservation  Service, which have
       extensive collections of case studies  and demonstration project reports on
       water-related issues.


   The Office of Water Regulations and Standards has not yet examined such non-EPA
sources thoroughly with an eye toward using some of their data in preparing the national
305(b) Report or other high-level assessments of water quality status and trends. The potential
benefits of using these data include independent validation of trends identified through the State
305(b) process, amplification of some trend analyses through more extensive data, and
identification of emerging problems not revealed through the State/EPA assessments.  There
also are sizable obstacles to effective use of data collected by other agencies, and in any case,
the benefits to EPA are likely to be specialized and incremental rather than sweeping. The
Office of Water Regulations and Standards should conduct a detailed analysis by the end of FY
1988  and incorporate the findings as appropriate in planning for the 1990 national 305(b)
Report.

   The possibility also exists for EPA to reduce its costly reliance on States to monitor for
pollutants of concern to EPA  (e.g., lead, arsenic) as part of their individual water assessment
programs.  Much of this contaminant-specific monitoring could be performed by other Federal
agencies that are already routinely monitoring nationwide for some pollutants. Building on the
recent experience of OMEP,  OWRS should examine the feasibility of developing working
agreements with USGS and NOAA wherein these organizations would address certain EPA
needs in their own trend monitoring programs.  In return, EPA would provide guidance and
technical support to ensure that the information received does indeed complement the 305 (b)
process.  An important prerequisite for these arrangements  is the delineation of EPA
management's objectives for national assessments, as recommended earlier in this section.
                          RECOMMENDATION AREA 5

                     Improve EPA and State Knowledge About
                  Sources and Uses of Existing Water-Related Data


   Over the next two years, the Office of Water should take the following important lead-off
steps:


   A.  Develop a standard for labelling the data quality of monitoring data sets.

   A serious impediment to wider use of existing monitoring data is the fact that it usually is
difficult or even impossible for a prospective user to determine whether a set of data is suitable
for his or her purposes.  Many water quality scientists and managers are very reluctant to use
data  unless they can find  out how and why  it originally was collected and what quality
assurance procedures were used. The common tendency is to automatically assume that the
data is "bad."

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                                           37
   To promote the future use of monitoring data, the Office of Water should develop and
implement a standard for labelling data sets with basic information that will help the prospective
user judge the suitability of the data for the purpose at hand. Such information might include,
for example, the purpose of data collection, the location and depth, the sampling and analytic
methods, the date and time, the flow conditions, and a contact name and telephone number.

   An important corollary to developing a standard for data quality labelling is to formally
establish "data  quality objectives" (DQOs) for major monitoring projects.  In developing
DQOs, key decision-makers who will use the resulting data must clearly specify the intended
use and the acceptable degree of precision before the data collection plan is created.  This
process helps to ensure that the monitoring will meet the need for information as economically
as possible. Going through the DQO process with the initial users will produce much of the
information that should be included in labelling a data set for the benefit of future users. The
Office of Water should capitalize on the excellent start it has already made toward adapting and
institutionalizing the DQO process developed by the Office of Research and Development.


   B. Issue guidance on sources and uses of existing water-related data.

   Labelling of water quality data sets will produce scant results unless this  effort is backed up
by a broader campaign to educate managers and analysts in how to find and use existing data to
focus or supplement new monitoring. The Office of Water must exert national leadership in
this arena.  Numerous States and EPA offices have experience in using existing data, and yet
the expertise is fragmented. OWRS and OMEP should collaborate to collect this experience,
distill it into basic precepts and procedures, and distribute it throughout the water quality
management community.

   By the middle of FY 1988, OWRS and OMEP should issue  one or more guidance
documents to accomplish this important objective. The guidance should provide at least the
following:

   •   A policy statement on the importance of increasing the use of available data.
       OWRS and  OMEP should announce their commitment to  advancing the
       capabilities of States and EPA to use existing data to focus or even replace
       new field monitoring activities, when appropriate.

   •   Examples  of successful  use of existing data in support of water quality
       analysis and management decision-making (e.g., the National Estuaries
       Program, the Region VII ESD's evaluation of ambient surface water quality in
       Iowa). These brief case studies, which could be prepared by the analysts
       who performed the studies, will help to stimulate thinking about the range of
       uses for existing data and the problems that may be encountered.

   •   Descriptions of automated tools for analysis  of existing data (e.g., data
       systems, models, data integration programs), how to gain access to them, and
       how to use them to support management and technical decisions. Information
       should be provided on tools maintained  by EPA  Headquarters,  Regional
       Water Management Divisions, Environmental Services Divisions, States, and
       other organizations.

   •   Descriptions of potentially-useful water data sources outside of EPA and the
       State agencies, and how to obtain access to  these sources.  The  Office of
       Water Data  Coordination in  the Department of the Interior can provide

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                                          38
      information  on the water-related data maintained by  other Federal
      organizations.

   •  Primers on statistical methods for analyzing trends, filling data gaps, and
      making valid projections from small or non-random samples.

   The guidance should be reviewed and updated periodically to reflect the Agency's evolving
experience in analysis of available water quality data.


   C. Improve STORET's usefulness as a decision support tool.

   The  STORET Water Quality File is a very large data base used by States, EPA, and
numerous other organizations throughout the country to store and retrieve the analytic results of
ambient water quality monitoring. The Office of Water, in cooperation with the Office of
Information Resources Management, should act immediately to protect the huge investment the
Agency has made in developing and maintaining the STORET. Three actions are needed:

   •  Add a data set labelling capability. Once a data set labelling standard has been
      established, STORET should be modified to permit labelling of all newly-
      entered data sets.  The needed capability is different from  the present
      provision for "Quality Assurance Codes" and will replace this seldom-used
      feature.

   •  Create  "targeted documentation."   STORET offers an intimidating array of
      processing and report-generation features. Most potential end-users of water
      quality data have little or no knowledge of the system's contents and
      capabilities, and they must therefore rely on  trained specialists to retrieve
      information.  In conjunction with the development of guidance on  use of
      existing data (Recommendation 5b above), the Office of Water should also
      take steps to increase managers' awareness of how STORET can help them.
      This effort should begin with a series of targeted overview documents aimed
      at showing different types of end-users what they can ask for from STORET
      — through a trained analyst — to help them make the key decisions their job
      requires.

   •  Establish a STORET Steering Committee to guide the continued development
      and management of the system. STORET has been managed as a computer
      storage and processing utility. The thrust must now shift to an emphasis on
      promoting effective use of the data by managers as well as technicians. The
      Steering Committee (a body distinct from the existing User Group)  should
      include representation from all OW offices, other media offices, OIRM, ORD,
      Regional  Offices, and selected States and other organizations that use
      STORET.   This group should provide broad oversight for investment
      decisions, ensuring that these decisions are not made on technical criteria
      alone but on a wider conception of STORET's role as a tool for supporting
      managers in all media programs.  The Steering Committee should be
      established by  the end of FY 1987.  One of its  first tasks should be to
      determine how to address the two needs cited above - the data set labelling
      capability and targeted documentation.

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                                          39
                          RECOMMENDATION AREA 6

                          Establish Central Coordination of
                   EPA Activities to Integrate Water-Related Data
   The Assistant Administrator for Water should establish a mechanism for coordination,
problem-solving, and planning on data integration issues. Effective data integration can benefit
all OW program offices, as well as Regional Offices and States, and this complex task should
therefore be facilitated and monitored from the top.  The AA/Water should direct each Office
Director to designate a representative to serve on a Water Data Management Council.  The
Office of Water's Senior Information Resources Management Officer should chair the group.
The OW participants should determine how best to structure the vital participation of other EPA
Headquarters offices (especially OIRM and OMSE), EPA Regional Offices, and States. An
organizing meeting should be held during FY 1988.

   While this study has focused on surface water issues, the need for water data integration
encompasses OW's drinking water and groundwater programs as well.  Toxic contamination
of drinking water, either through surface water intakes or groundwater exchange, is a growing
EPA concern because of the potential public health threat. The Office of Drinking Water and
the Office of Ground-Water Protection must therefore be full members of the Council.

   The first objective of the Water Data Management Council should be to ensure that each
OW office is well-informed about all of EPA's implemented, developmental, or planned
integration  activities. The scope of this survey should include any systems integration efforts
arising from the State/EPA data management pilot each Region will conduct during FY 1987.
Once this baseline of mutual awareness is established, the group should concentrate on creating
a Water Data Management Plan to aid the allocation of resources in FY 1989 and to influence
FY 1990 budget planning.

   By the end of FY 1988, the Council should determine how the Office of Water will achieve
four cross-cutting objectives of particular importance in improving the use of existing data in
EPA and State decision-making.


   A.  Develop tools to make better use of DMR data, including linking of PCS, STORET,
       and other Office of Water data files.

   EPA requires NPDES  permit holders to monitor the composition  of their wastewater
effluents and report the results regularly to the permitting agency (State or EPA Regional
Office) by  means of Discharge Monitoring Reports (DMRs).   The regulated community
submits some 800,000 DMRs per year, one of the largest reporting burdens that EPA imposes
on its regulatees. DMR data from major sources and significant minor sources are entered into
the Permit  Compliance System (PCS) for automated comparison with permit conditions to
determine violations of effluent limitations.

   One of OWEP's main reasons for developing PCS and for requiring States and Regions to
enter major-source DMR data into it is the benefit that can be derived from a national data base
of effluent measurements.  In addition to promoting national consistency  in compliance
determination, PCS also provides a convenient means of storing the DMR  data for future
analysis. States, Regions,  and Headquarters analysts may find this wealth of pollution data
useful  for a variety of purposes not directly related to compliance management, such as in

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                                           40
predicting toxic "hot spots" where the pollution from one or more upstream dischargers may
threaten aquatic life or human health.

   The Office of Water should now take a close look at just how EPA and State decision-
makers might benefit from analysis of DMR data, defining specific uses for compliance
managers, permit writers, and water quality specialists. OWEP, OWRS, and OIRM should
then build on the start they have already made in developing software to analyze DMR data, by
itself and in conjunction with data from other files.

   In particular, the Office of Water must ensure timely implementation and refinement of
software  for on-line integration of up-to-date PCS and STORET data. This project, already
under way, must be considered a vital component of OW's data integration strategy.  The
Water Data Management Council should assign high priority to overcoming the problems
which inevitably accompany such a complex interoffice task.


   B. Assess the feasibility of developing an automated data base of drinking water
       surveillance results, for use in identifying contaminated surface waters that present a
       high risk to human health.

   The Office of Drinking Water's Federal Data Reporting System (FRDS)  maintains
descriptive and compliance information about public water supply systems.  EPA does not,
however, have a data base containing the analytic results of water  supply self-monitoring to
check for compliance with Maximum Contamination Levels. Such data could be very useful to
OWRS and OWEP, when combined with data in PCS and other  systems, in tracing point
source contributors to the contamination and in targeting control actions based on an
assessment of human health risk.
    C. Ensure appropriate development and use of "geographic information systems."

    The results of integrating data may be easier to comprehend fully when displayed on a map
(e.g., plotting hazardous waste sites located upstream from public water supply intakes). EPA
program offices and Regions have recently begun to examine the capabilities of commercial
geographic information systems which  permit automated manipulation, overlaying, and
cartographic display of a wide variety of data types relevant to water quality management. The
Office of Water's decision on its approach to this spatial integration should be made only after a
thorough analysis of the questions that Headquarters, Regional, and State managers wish to
answer.  OW's moves in this area  should be made in conceit with OIRM, which has the
Agency lead in asessing technological alternatives for geographic information systems.


    D. Promote awareness and use of data integration tools.

    Technical excellence in creating these systems is not enough to guarantee  their usefulness.
The Office of Water must also commit resources to ensure that decision-makers are fully able to
take advantage of their benefits. Data integration tools must be made accessible to EPA and
State managers, not just to computer specialists.  Important goals for the Water Data
Management Council to pursue in this area are:

    •   Creating "user-friendly front-ends." This type of user interface allows users
       to  enter, manipulate, and retrieve data using plain-English  commands and

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                                     41


menu responses rather than the code-like conventions used by most query
languages.

Aggressively marketing and arranging access. EPA and the States cannot
derive full benefit from data management tools unless the program offices take
an active role in advertising their existence, demonstrating their usefulness,
and helping users to obtain the necessary hardware, computer accounts, and
access codes.

Providing adequate training and user support. Once the user community's
interest has been captured, Headquarters must cultivate and sustain user
expertise.  The Office of Water should reexamine the present approach to
training, documentation, and technical assistance for individual systems (e.g.,
STORET, PCS), and determine how best to ensure proper support for data
integration tools that bridge these systems.

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• While States Vary Widely in Their Methods and
   Priorities, the Current Surface Water Monitoring
   Program Nationwide Has Several Salient Characteristics.


   1.  EPA places a strong emphasis on intensive survey monitoring by States to support
       development of point source controls.

   In recommending priorities for State expenditures on ambient monitoring, EPA has focused
on fulfilling the mandates of the Clean Water Act with respect to construction of wastewater
treatment plants and permitting of major industrial and municipal dischargers.  Most States
have responded by increasing the number of intensive surveys they perform.

   An intensive survey is a relatively focused and in-depth field study, usually conducted to
support point source control activities. Monitoring of this type often requires more samples to
be taken over a longer period and a larger area than other approaches. The survey may include
analyses  of sediments and aquatic life in addition  to watercolumn sampling.  States and EPA
Regional Offices have conducted these studies mainly to determine priorities for municipal
treatment plant construction or modification.

   More surveys are now being conducted to aid in defining permit limits for toxic chemicals
in industrial discharges.  Some States are devoting a larger share of  their monitoring resources
to intensive surveys than they did five years ago, but this is not a widespread trend. For
example, a 1986 report by the Michigan United Conservation Clubs and the National Wildlife
Federation on Michigan's Water Quality Monitoring Program states that in 1985, for the 100
major dischargers scheduled for permit reissuance statewide, only one intensive survey was
performed to generate information to be used in drafting permit conditions.


   2.  Many States rely heavily on periodic watercolumn sampling at geographically-dispersed
       fixed station locations to provide information on problems and trends.

   A fixed station is a point with  geographic coordinates that is  visited repeatedly for the
purpose of collecting information on water quality.  Most of this fixed station monitoring is
aimed at measuring trends in water quality associated with point sources.  For the most part,
the pattern of locations and the frequency of sampling have not  been designed to support
rigorous  statistically-based conclusions about water quality over wide areas. Station siting,
sampling frequency, and the length of time a station is maintained depend on a variety of
economic, scientific, political,  and historical considerations — all  of which will differ from
State to State and from project to project.

   Chemical analysis of samples drawn from the watercolumn is the predominant method used
to measure the presence of individual pollutants in the ambient water.  Chemical analysis of
sediment samples is  slowly increasing throughout the country, as  are biological monitoring
techniques for assessing ecological integrity.

   In fixed station assessments (and in many intensive  surveys), most States are strongly
oriented toward measuring the point-source "conventional pollutants" that have been the focus
of water pollution control efforts for the last 15 years (e.g., dissolved oxygen,  biological
oxygen demand, total suspended solids).  States have also begun to monitor for a limited
number of the 126 "priority pollutants" listed in  the 1977 Clean Water Act amendments --
primarily metals and certain pesticides.

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   Comparatively little fixed station monitoring (or intensive survey monitoring either) is now
aimed specifically at detecting problems and trends caused by nonpoint sources of pollution.
Assessing impacts from nonpoint sources, such as urban and agricultural runoff, requires a
monitoring approach that addresses the gradual and long-term nature of most types of nonpoint
source pollution, as distinct from approaches to monitoring for shorter-term impacts from point
source discharges.  Some  States, particularly in the West, are beginning to use fixed station
monitoring and other approaches to support the development of Best Management Practices for
nonpoint sources. Most States have not developed expertise in this area, though, and EPA has
not yet  produced national guidance that could  accelerate the growth of nonpoint source
monitoring.

   In the past few years, most States have scaled back the number of samples they routinely
collect from a fixed  station network and have also reduced the number of water quality
assessments they perform. The total cost of the monitoring program has risen, principally due
to the complexity of the analysis conducted or because of the larger number of samples needed
to perform a complete water quality assessment.  The  higher resource demand makes  it
impossible for States to continue at earlier sampling levels while at the same time attempting to
shift resources into intensive surveys and other specialized monitoring projects.  As a result,
although water quality assessment  monitoring  still consumes about 60% of State-level
monitoring resources  nationwide, most States can accomplish much less than they could five
years ago.


   3. EPA and the States have significantly increased status and trend monitoring in near-
      coastal waters.

   The  shift toward intensive survey monitoring in inland waters has been accompanied by
increased attention to assessing the pollution problems of bays, estuaries, and ocean waters.
Since FY 1984, the Office of Water's monitoring  budget has grown by 40% to accommodate
this expanded effort,  and marine and estuarine monitoring now constitutes an important new
component of the overall surface water monitoring program.

   In EPA's estuaries program, assessment efforts have relied heavily on analysis of data
gathered in past monitoring studies conducted by universities and other research organizations.
Increasingly, EPA and the States are using these  historical data in targeting new monitoring
designed to  support  decisions on control  of pollution from point and nonpoint sources.
Monitoring activities are also expanding in the ocean dumping program, where EPA may issue
permits for marine disposal of sludge and other wastes.


   4. Industrial and municipal wastewater dischargers monitor their own effluents regularly
      and report the results to their permitting agency.

   Facilities that receive discharge permits under the National Pollutant Discharge Elimination
System  (NPDES) program are required to take samples at the end of their outfall pipes and
measure the level of pollutants specified in  the permit. Dischargers send these results to the
agency that issued their permit (either EPA or the State), where the level of each parameter is
checked to determine whether the permit limit was exceeded. If significant exceedances are
found, the NPDES authority may initiate  an enforcement action to  return the violator to
compliance.

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 \      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 I                     WASHINGTON. D.C.  20460
V
                          DEC 12 1985                  OFF.CEOF
                                                       WATER
  MEMORANDUM

  SUBJECT:  Water Monitoring Study

  FROM:      Lawrence J.  Jensen,  Assistant Administrator
              for Water

  TO:        Addressees
      Understanding  the  quality of  the Nation's  surface  waters
  is  a prerequisite  to developing and implementing meaningful
  water pollution  control programs.  We all recognize  that we
  will never have/ nor can we afford, a complete understanding
  of  water quality.  Nevertheless,  I am convinced that we need
  a better understanding than we currently have of water quality
  for some of the  things we are trying to accomplish today.  We
  also should be obtaining baseline and trend measurements that
  will be needed in  the future.

     While I am pleased with some of the progress we have
 made to improve water monitoring and  analysis programs, I
 believe the time has come  to review our information needs in
 the  larger  program  management  context.   In  particular,  I want
 to take a fresh look at what information we as managers need
 to have  about  water quality  and  how our  monitoring  programs
 can  help provide  that information.

     Accordingly,  I  am establishing a water monitoring study
 to develop  a sound  water monitoring strategy  attuned  to
 decision-making needs.  A policy committee and  project
 staff are being established  to conduct the  study.

     The overall objective of the study is to  identify program
 directions and priorities over the  next  five  years with  a
 series of intermediate objectives  to address  specific near-
 term issues.  The first objective  is to  evaluate by May  1,
 1986 water program information  requirements and their
 impact on EPA and State water monitoring programs.

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                             - 2 -
      Other issues that are most likely to influence the
 evolution of program directions and priorities over time--
 such as further delegation of  operating  responsibilities to
 the States,  resource constraints,  new legislation-- will be
 isolated  and their  implications discussed.   In addition the
 study will look at  the likely  state of  the  art in monitoring
 technology and  related developments  in information  management
 over the  next  three-to-five years  in  order  to  recommend the
 kinds  of modifications and enhancements  that will be appro-
 priate in  the  evolving context  of  OWs program requirements.

     Attached is a draft implementation plan  for the study.
 It will probably change as the  study  leaders determine selected
 areas for  emphasis  and focus.   I am asking  that  each of you
 receiving  this memorandum  fully support  this effort.   You will
 be asked  to  provide  information and staff assistance,  but
 most importantly I  would like your own thoughtful  ideas and
 recommendations.  This  study is an opportunity  for  each  of
 you who relies  on water monitoring  information  to register
 your needs and  your proposals.  I will contribute my own
 perspective  and objectives to the  study and  look forward to
 using  the  results in some very concrete ways in our programs
 for FY  1988  and beyond.

     Thank you for your support  of  this project.

 Attachment


 Addressees;

 Assistant  Administrators
 Regional Administrators
 Regional Environmental  Services Division Directors
 Regional Water  Management Division Directors
 Office  Directors, Office of Water
 Office  Directors, Office of Policy, Planning, and Evaluation
 Office  Directors, Office of Research and Development
 Laboratory Directors, Office of Research  and Development

cc:  Administrator
     Deputy Administrator
     Associate Administrators
     Staff  Office Directors
     Policy Committee Members
     Project  Staff Members

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                                  APPENDIX B
             PROJECT CHRONOLOGY AND LIST OF PRODUCTS
December 12, 1985


March 13, 1986

April 28,  1986

June 5, 1986

August 8, 1986


October 24, 1986

January 14, 1987


February  9, 1987


February  24, 1987


April 1987


August 1987


September 1987
AA for Water initiates the Surface Water Monitoring
Study

First meeting of the study's Policy Committee

Second Policy Committee meeting

Third Policy Committee meeting

Interim  report on  study  findings  distributed to
Headquarters, Regional, and State reviewers

Draft final report distributed to reviewers

Briefing of EPA Science Advisory Board subcommittee
in Washington, D.C.

Revised draft  final report, incorporating reviewer
comments, distributed to key reviewers

Study team presents and discusses findings with EPA
Science Advisory Board subcommittee

EPA Science Advisory Board  presents  preliminary
findings on the draft report to members of the study team

EPA Science Advisory Board issues final findings on the
Surface Water Monitoring Study

Final report published

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                                 APPENDIX C

                MEMBERS OF THE POLICY COMMITTEE OF
             THE EPA SURFACE WATER MONITORING STUDY
Al Morns

Bill Muszynski

Russell Rhoades

Bill Rice
Steve Tedder


Robbi Savage
            REGIONAL OFFICES

Director, Water Management Division, Region m

Deputy Regional Administrator, Region n

Director, Environmental Services Division, Region VI

Deputy Regional Administrator, Region VII


                 STATES

Head, Technical Services  Branch,  Division of  Environmental
      Management, State of North Carolina

Executive Director, Association of State and Interstate Water Pollution
      Control Administrators (ASIWPCA)


            OFFICE OF WATER

Deputy Assistant Administrator (after May 1, 1986)

Deputy Assistant Administrator (until May 1, 1986)


      OTHER HEADQUARTERS OFFICES

National Environmental Services Officer, Office of Regional Operations

Director, Office of Information Resources Management

Director,  Management  Systems Division, Office of Management
      Systems and Evaluation

Director, Office of Acid Deposition, Environmental Monitoring, and
      Quality Assurance, Office of Research and Development
Rebecca Hanmer

Ed Johnson
Carol Finch

Ed Hanley

Cynthia KeUy


Courtney Riordan

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                                  APPENDIX D


                      LIST OF INTERVIEWEES FOR THE

                EPA SURFACE WATER MONITORING STUDY



   NOTE: Titles and organizational affiliations may have changed since this list was prepared.




                                OFFICE OF WATER


Assistant Administrator for Water

Rebecca Hanmer    Deputy Assistant Administrator

Office of Water Regulations and Standards

William Whittington  Director
James M. Conlon    Deputy Director
Jim Lund           Analysis and Evaluation Division
Ed Richards        Chief, Water Quality Management Branch
Tim Icke           Water Quality Management Branch
Edmund Notzon     Director, Criteria and Standards  Division
Dave Sabock        Chief, Standards Branch
Carl Myers         Chief, Nonpoint Sources Branch
Bob Shippen        Nonpoint Sources Branch
Bill Telliard         Chief, Engineering and Mining Branch, Industrial Technology Division
Fred Leutner        Acting Director,  Monitoring and Data Support Division
Alec McBride       Chief, Water Quality Analysis Branch
Phil Taylor         Water Quality Analysis Branch
Morrie Mabbitt      Water Quality Analysis Branch
Tim Stuart          Chief, Monitoring Branch

Office of Water Enforcement and Permits

Ed Kramer         Director, Program Management  Staff
Bill Jordan         Director, Enforcement Division
Larry Reed         Chief, Compliance Information and Evaluation Branch
Dave Lyon         Chief, Enforcement Support Branch
Gary Polvi         Enforcement Support Branch
Geoff Grubbs       Chief, Technical Support Branch, Permits Division

Office of Municipal Pollution Control

Jim Hanlon         Director, Municipal Construction Division
Robert Blanco       Director, Municipal Facilities Division
Karen Klima        Municipal Facilities Division
Connie Bosma      Municipal Facilities Division

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Office of Marine and Estuarine Protection

Tudor Davies        Director
Ginger Webster      Office of Marine and Estuarine Protection
Tom DeMoss        Director, Technical Support Division
Michelle Hiller       Technical Support Division
Ron DeCesare       Director, Marine Operations Division
Allison Duryee       Marine Operations Division


              OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE


Office of Emergency and Remedial Response

Henry Longest       Director


Office of Solid Waste

Jeff Denit           Deputy Director


                 OFFICE OF PESTICIDES AND TOXIC SUBSTANCES


Office of Pesticide Programs

Susan Wayland      Deputy Director
David Severn        Chief, Exposure Assessment Branch, Hazard Evaluation Division
Tom Dixon         Exposure Assessment Branch

Office of Toxic Substances

Susan Rudzinski     Chief, Chemical Regulation Branch, Exposure Evaluation Divison
Bill Wood          Exposure Assessment Branch
Phil Robinson       Design and Development Branch
Joe Breen           Chief, Field Studies Branch
Tom Murray        Field Studies Branch


                     OFFICE OF RESEARCH AND DEVELOPMENT


Office of Acid Deposition, Environmental Monitoring, and Quality Assurance

Courtney Riordan    Director
Dick Nalesnik       Special Assistant
Stan Blacker        Director, Quality Assurance Management Staff
Nancy Wentworth   Quality Assurance Management Staff

Office of Environmental Processes and Effects Research

Fredrick Kutz       Acting Director, Toxics and Pesticides Division

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           OFFICE OF ADMINISTRATION AND RESOURCES MANAGEMENT
Office of Information Resources Management

Edward Hanley      Director
Sam Conger        Director, Program Systems Division
Phil Lindenstruth    Chief, Client Services Branch
Chuck Tobin        Chief, Systems Integration Branch
                 OFFICE OF POLICY, PLANNING, AND EVALUATION


Office of Policy Analysis

Bob Raucher        Chief, Water Branch, Economic and Analysis Division
Bob Greene         Water Branch

Office of Standards and Regulations

David Schwarz      Chief, Information Management Branch, Regulation and Information
                          Management Division
Oscar Morales       Information Management Branch
Eric Strassler        Information Management Branch
                                     REGION H
Environmental Services Division
Barbara Metzger     Director
Richard Spear       Chief, Surveillance and Monitoring Branch
Jerry McKenna      Monitoring Management Branch
John Higgins        Monitoring Management Branch

Water Management Division

Patrick Harvey      Chief, Water Standards and Planning Branch
Leslie Peterson      Chief, Construction Grants Planning Section
Felix Locicero       Standards and Planning Section
Patrick Durack      Chief, Compliance Section, Water Permits and Compliance Branch
George Meyer       Chief, Permits Management Section, Water Permits and Compliance Branch
Dennis Suszkowski   Chief, Marine and Wetlands Protection Branch

Policy and Management Division

Abe Siegel          Information Systems Branch

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                                     REGION IV


Alec Little           Deputy Regional Administrator

Environmental Services Division

Jim Finger           Director
Billy Adams         Deputy Director
George Collins       Acting Chief, Ecological Support Branch
Dave Hill            Ecological Support Branch
Russ Todd           Ecological Support Branch

Water Management Division

Rebecca Slack       Special Assistant
E. S tailings Ho well   Director, Office of Groundwater Protection
John Marlar         Chief, Facilities Performance Branch
Gilbert Wallace       Chief, Compliance Section
John Hagan         Chief, South Area Grants Management Section, Facilities Construction
                          Branch
Bo Crum            Nonpoint Source Program
Jim Greenfield
Bill Patton

Policy and Management Division

Randall Davis        Chief, Information Management Section
Tom Nessmith       Information Management Section
Wayne Savage       Contractor
                                     REGION X
Environmental Services Division
Ben Eusebio         Chief, Ambient Monitoring and Analysis Branch
Ray Peterson        Ambient Monitoring and Analysis Branch
Bruce Cleland        Ambient Monitoring and Analysis Branch
Evan Hornig         Ambient Monitoring and Analysis Branch

Water Management Division

Robert Burd         Director
John Underwood     Chief, Office of Puget Sound
Martha Burke        Office of Puget Sound
John Armstrong      Office of Puget Sound
Tom Wilson         Chief, Office of Water Planning

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            FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION


Office of the Secretary

Retcher Herrald     Environmental Specialist, Office of Planning and Research
Frank Andrew       Administrator, Grants Section, Office of Planning and Research

Division of Adminsitrative Services

Bill Bradford        Senior Systems Analyst, Bureau of Information Systems

Division of Environmental Permitting

Peter Goren         Environmental Specialist

Division of Environmental Programs

Randy Armstrong    Chief, Bureau of Laboratory and Special Programs
Roxane Dow        Chief, Bureau of Water Quality Management
Carolyn Lewis       Administrator, Water Quality Monitoring and Quality Assurance
Joe Hand           Environmental Supervisor, Water  Quality  Monitoring and Quality
                         Assurance
          NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
Office of Science and Research

Bob Tucker         Deputy Director
Tom Burke         Assistant to Director
Marty Rosen        Special Assistant to the Director
Bob Meullers        Water and Biota Unit
Suzanne Rohardt    Manager, GIS Unit
Jack Schooley       GIS Unit
Diane Keck         GIS Unit

Division of Water Resources

Doug Clark         Assistant Director, Monitoring and Planning Element
Bill Eisele          Chief, Bureau of Shellfish Control
Bob Runyon        Chief, Bureau of Monitoring and Data Management
               OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
Andy Schaedel      Supervisor, Water Quality Monitoring
Tom Lucas          Water Quality Program
John Jackson        Water Quality Program

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                         TENNESSEE VALLEY AUTHORITY
Bob Johnson
Dick Fitz
AlDuda
David Garden
Jack Garrison
David G. Page
James S. Morris
Bill Waldrop
Roger Thomas
Tom McDonough
Frank R. Perchaliski
Bruce Rowland
J. Edward Lawrence
Jim Wright
Larry R. Clark
Neil E. Carriker
Billy G. Isom
Chief, Environmental Evaluation Branch
Environmental Analysis Section
Environmental Analysis Section
Field Operations
Field Operations
Field Operations
Office of Natural Resources and Economic Development
Engineering Lab
Power Environmental Coordination Staff
Data Services
Mapping Serivces Branch
Geographic Information Services
Office of Agriculture and Chemical Division
Fisheries and Aquatic Ecology Branch
Water Quality Branch, Chattanooga, TN
Water Quality Branch, Chattanooga, TN
ARL-BF

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                                 APPENDIX E


                              MEMBERS OF THE
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                        SCIENCE ADVISORY BOARD

         ENVIRONMENTAL EFFECTS TRANSPORT AND FATE COMMITTEE,
                 SURFACE WATER MONITORING SUBCOMMITTEE
Chairman
Dr. Kenneth Dickson, Chairman
   Institute of Applied Sciences, North Texas State University, Denton, Texas

Members

Dr. Robert Huggett
   Senior Marine Scientist, Virginia Institute of Marine Science,
   College of William and Mary, Gloucester Point, Virginia

Dr. Ronald Jarman
   Oklahoma Water Resources Board, Oklahoma City, Oklahoma

Dr. Kenneth Jenkins
   Professor of Biology, California State University at Long Beach, Long Beach, California

Dr. Richard Kimerle
   Monsanto Corporation, St. Louis, Missouri

Dr. David Maschwitz
   Minnesota Pollution Control Agency, St. Paul, Minnesota

Dr. John Neuhold
   College of Natural Resources, Utah State University, Logan, Utah

Dr. Mike Smolen
   North Carolina State University, Water Quality Group, Raleigh, North Carolina


Executive Secretary

Ms. Janis C. Kurtz
   U.S. Environmental Protection Agency, Washington, DC


Staff Secretary

Ms. Lutithia V. Barbee
   U.S. Environmental Protection Agency, Washington, DC

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                                APPENDIX F

                        GLOSSARY OF SELECTED
                      TERMS USED IN THE REPORT
Ambient Monitoring
All forms of monitoring conducted beyond the imme-
diate  influence  of  a  discharge  pipe,  including
sampling of sediments and living resources.
Benthic Fauna (Benthos)
Organisms attached to or resting on the bottom or
living in the bottom sediments of a waterbody.
Best Management Practices (BMP)
A practice, or combination of practices determined by
a State or designated area-wide planning agency to be
the most effective, practicable means of preventing or
reducing pollution attributable to nonpoint sources.
Bioaccumidation
Accumulation of a chemical substance in a living
organism.  This condition occurs when the rate of in-
take of a chemical is greater than the rate of excretion
or metabolism, resulting in an increase in tissue con-
centration relative to the exposure concentration.
Bioassay
A test used to evaluate the relative potency of a chem-
ical by comparing its effect on a living organism with
the effect of a standard preparation on the same type
of organism.
Designated Use
The predominant use to which a body of water is
put.
Effluent
Treated or untreated waste material discharged into
the environment.  Generally refers to water pollution.
Fixed Station Monitoring
The repeated long-term sampling or measurement of
parameters at representative points for the purpose of
determining environmental quality characteristics and
trends.

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Geographic Information System
A computerized system for combining, displaying,
and analyzing geographic data.  A GIS  produces
maps for environmental planning and management
by integrating physical and biological information
(soils, vegetation, hydrology, living resources, etc.)
and cultural information (population, political bound-
aries, roads, bank and shoreline development, etc.).
Intensive Survey
The sampling or measurement of parameters at repre-
sentative points for a relatively short period of time
within a  limited geographic area to determine
environmental quality conditions, causes, effects, or
cause-and-effect relationships of such conditions.
Mixing Zone
A limited area downstream from a discharge in which
the concentration of pollutants is greater than in the
ambient water measured at a more distant point
downstream.  Many State water quality standards
allow less stringent criteria to apply in a mixing zone
than to the rest of the waterbody.
NASQAN
The National Stream Quality Accounting Network,
operated by the U.S. Geological Survey, encom-
passing more than 300 monitoring stations around
the country at which many water-quality character-
istics are measured at regular intervals.
Nonpoint Source Pollution
A contributory factor to water pollution that cannot
be traced to a specific spot; e.g., pollution resulting
from water runoff from urban areas, construction
sites, agricultural and silvicultural operations.
NPDES
The National  Pollutant Discharge  Elimination
System, a permit program under Section 402 of the
Clean Water Act that imposes discharge limitations
on  point sources,  basing them  on a  control
technology's effluent limitation capabilities or on
local water quality standards.
Point Source Pollution
Pollution discharged through a pipe or some other
discrete source  from municipal  water treatment
plants,  factories,  confined  animal feedlots,  or
combined sewers.

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Priority Pollutant
One of the 126 toxic pollutants named specifically in
Section 307(a)(l) of the Clean Water Act.
River Reach
A river or stream segment of a specific length.  Most
reaches extend between the points of confluence with
other streams.
Source Monitoring
Monitoring to determine the level of pollutants in an
effluent discharge.
Technology-Based Permits
An NPDES permit in which the allowable effluent
limits are determined by the level of quality achieve-
able by the best available control technology.
Total Maximum Daily Load (TMDL)
The total allowable pollutant load to a receiving water
such that any additional loading will  produce a
violation of water quality standards.
Toxicity Test
A means of using living organisms to determine the
toxicity of a chemical or an effluent. A toxicity test
measures the degree of response of an exposed test
organism to a specific chemical or effluent.
WasteloadAllocation (WLA)
The portion of a receiving water's total maximum
daily pollutant load that is allocated to one of its
existing or future point sources of pollution.
Water Quality-Based Permits
An NPDES permit in which the allowable effluent
limits are determined by the level of quality needed in
order for the receiving water to meet water quality
standards.
Water Quality Criteria
Scientifically-derived values (based on bioassays)
that establish in-stream concentrations of chemicals
which will be protective of the ecosystems even if
excursions of the criteria occur.   EPA develops
criteria to protect aquatic life and human health.

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Water Quality-Limited Segment       A stretch or area of surface waters where technology-
                                  based effluent limitations in NPDES permits for
                                  direct discharges are not sufficient to prevent viola-
                                  tions of water quality standards. I   such cases, new
                                  permit limitations are based on amuient water quality
                                  considerations.
Water Quality Standard              A government regulation establishing water quality
                                  conditions which must be met in a waterbody to
                                  support the desired uses of that water. The standard
                                  includes both a designated use (e.g., protection of
                                  aquatic life)  and numerical criteria (e.g., copper of
                                  5.6  micrograms/liter) that, if not exceeded, will
                                  protect that use.


Watershed                         The land area that drains into a stream, river, lake,
                                  estuary, or coastal zone.

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