toward cleaner water
THE NEW
PERMIT PROGRAI
TO CONTROL
WATER POLLUTION
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"P
JCVesfonng the quality of our Nation's streams and
lakes, and our coastal waters as well, is a monumental challenge.
But it is absolutely vital to the health and well-being of the
American people. The 1972 Federal Water Pollution Control
Act is truly a major step forward. It gives the Federal Government
the standard-setting and enforcement authority it must have.
It preserves the critically important 'front-line' role of the
States, and it provides for the active and constructive involvement
of citizens, municipalities and industry."
RUSSELL E. TRAIN
EPA ADMINISTRATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
contents
What the Permit Program Is ... 1
How the System Works 4
Getting EPA Approval 6
Getting a Permit 8
The EPA Permit Process 8
The State Permit Process 11
the Permit 12
Permits and the Public 15
Postscript 17
Appendices 19
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NPDES. These initials are the key to cleaner water—to
protecting public health and welfare, and the environ-
ment, from the dangers of water pollution. NPDES stands
for the National Pollutant Discharge Elimination System—
a new national permit program to control discharge of
pollutants into the Nation's waters.
Created by the Federal Water Pollution Control Act
Amendments of 1972 (Public Law 92-500), the new per-
mit program replaces and improves upon the old permit
system under the 1899 Refuse Act. It is part of the com-
prehensive effort set in motion by the 1972 law to pre-
vent, reduce, and eliminate water pollution.
While the States retain primary responsibility to com-
bat water pollution, they must now1 do so within the
framework of a Federal law that contains real teeth. And
if the States do not or cannot fulfill their responsibilities
under this law, the Federal Government, through the U.S.
Environmental Protection Agency (EPA), is empowered
and directed to take action.
Building upon earlier water pollution control legislation,
-the 1972 law established a tight regulatory system with
precise and detailed abatement requirements, streamlined
enforcement procedures, and heavy penalties for viola-
tions. At the heart of this system to control water pollu-
tion are these requirements:
• EPA is required to establish national effluent limi-
tations and national performance standards for sources of
water pollution including factories, power plants, sewage
treatment plants, and animal feedlots. An effluent limita-
tion is the maximum amount of a pollutant that anyone
may discharge into a water body. Effluent limits may
allow some or no discharge at all, depending on the spe-
cific pollutant to be controlled.
• The law requires industries to use the "best practic-
able" technology to control water pollution by July 1,
1977, and the "best available" technology by July 1,
1983.
• The law requires publicly-owned waste treatment
plants to provide a minimum of "secondary treatment" by
July 1, 1977 and to apply the "best practicable" technol-
ogy by July 1, 1983.
• For various kinds of new industrial plants, EPA
will issue separate national performance standards that
will set effluent limits based on the best available demon-
strated control technology, including, where practicable,
no discharges of pollutants whatsoever.
• If effluent limits based on "secondary treatment" or
"best practicable" or "best available" technology will not
cut pollution enough to meet water quality standards es-
tablished by a State or EPA, still more stringent controls
THE NEW
PERMIT PROGRAM
TO CONTROL
WATER POLLUTION
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* Types of "point"
sources requiring a
permit for discharges
into water bodies include
municipal waste water
treatment facilities,
manufacturing plants,
agriculture, forestry,
mining and fishing
operations, and other
service, wholesale, retail
and commercial
establishments.
must be imposed on pollution sources so that those stand-
ards can be met.
The NPDES permit is the mechanism for insuring that
effluent limits are met, that necessary technology is ap-
plied, and that all requirements of the 1972 law for con-
trolling discharges and complying with water quality
standards are met on schedule. Under the 1972 law, it is
illegal to discharge any pollutant into the Nation's waters
without an NPDES permit.*
A permit is not a license to pollute. On the contrary, a
permit regulates what may be discharged, and how much.
It sets specific limits on the effluent from each source. It
commits the discharger to comply with all applicable pro-
visions of the 1972 law. If the discharger cannot comply
immediately, the permit sets firm targets. The permit
commits him to reduce or eliminate his discharges in an
orderly fashion, in specified steps at specified times. The
commitments are legally enforceable. If a permit contains
a compliance schedule, each step can be enforced without
waiting for final compliance, and clear limits are put on
discharges while the polluter is moving toward compli-
ance.
The permit system also requires dischargers to monitor
their wastes and to report the amount and nature of all
waste components.
An NPDES permit, in essence, is a contract between a
discharger and the government. If a discharger violates
the conditions of a permit—or makes illegal discharges
without a permit—he may be fined up to $10,000 a day.
Willful or negligent violations could bring a fine of up to
$25,000 a day and one year in prison for the first offense,
and up to $50,000 a day and two years in prison for sub-
sequent violations. EPA can require compliance with per-
mit conditions by issuing administrative orders, that are
enforceable in Federal court, or by seeking court action.
The combination of national effluent standards and
limitations, applied to specific sources of water pollution
by individual permits, with substantial penalties for failure
to comply, constitutes the first effective nationwide system
of water pollution control.
The ultimate guarantee that a permit is not a license to
pollute is that the entire permit process must be carried
out in the glare of public scrutiny. Under the 1972 law,
permit applications and proposed permits are available to
the public. There's an opportunity for a public hearing
before a permit is issued or denied. The permit itself,
with all conditions and requirements, is also a public doc-
ument. And the monitoring information that permit hold-
ers must report is also available to the public.
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Significant Terms
The best practicable technology and best available
technology, which industries are required to use
by 1977 and 1983 respectively, take into account
such factors as age of equipment, facilities in-
volved, process employed and process changes,
engineering aspects of control techniques, and en-
vironmental impact apart from water quality, in-
cluding energy requirements.
In assessing best practicable technology for a par-
ticular category of industry, a balance is struck
between total cost and effluent reduction benefits.
Best available technology is the highest degree of
technology proved to be designable for plant-
scale operation so that costs for this treatment may
be much higher than for treatment by best prac-
ticable technology.
Best available demonstrated technology, which
will be the basis for establishing effluent limits
for new industries, is described as those plant
processes and control technologies that have
demonstrated at a pilot plant level that technolog-
ically and economically they justify making in-
vestments in new production facilites.
Secondary treatment is a method of purifying
waste water using biological processes. Up to 90
percent of the organic matter in sewage is re-
moved by making use of the bacteria in it. The
principal methods are by filter, in which the
waste passes through a thick bed of stones, and by
the activated sludge process wherein organic mat-
ter, pumped into an aeration tank, is broken
down by the addition of air and bacteria-laden
sludge. The solids are removed to a sedimentation
tank and the effluent is chlorinated.
Thus the NPDES permit system enables any concerned
citizen to find out what a polluter is discharging into the
water, what he must do, and when, to control the dis-
charge, and finally, whether the polluter is indeed meeting
the legal requirements imposed by the permit.
The 1972 law proclaimed these goals for the Nation:
By July, 1983, wherever possible, water that's clean
enough for swimming and other recreational use, and
clean enough to protect fish, shellfish, and wildlife. By
1985, no more discharges of pollutants into the Nation's
waters. NPDES permits are the instruments of progress
toward those goals.
3
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how
the system
works
The national permit system created by the 1972 law
did not begin in a vacuum. Many states already had
permit programs. Moreover, the Federal Government,
through the U.S. Army Corps of Engineers, had issued
some permits for discharges under the 1899 Refuse Act
and had on hand approximately 20,000 applications for
permits under that law.
With enactment of the 1972 statute, no more Federal
permits were issued under the 1899 law. Permits issued
earlier remained in force subject to change to meet the re-
quirements of the new law. The pending applications be-
came applications for permits under the new law. And
State permit programs became subject to the 1972 Federal
law.
The new law required anyone who did not have a per-
mit but who was discharging pollutants into a stream to
apply for an NPDES permit by April 16, 1973. This re-
quirement covered dischargers who did not need a permit
under the old Refuse Act program, such as municipal
waste treatment plants and commercial operators.
The 1972 law required anyone who planned to begin
discharging after June 16, 1973 to apply for a permit at
least 180 days before starting operations. Anyone who
wanted to begin a new discharge before June 16, 1973
was required to give at least 60 days' notice or seek a
special waiver from EPA.
Since October 18, 1972, the day the Federal law was
enacted, permits for discharging pollutants into the Na-
tion's waters have been issued only by EPA, or by a State
if its permit program has been approved by EPA. Perma-
nent permit authority may be delegated to a State only if
the State meets the requirements set forth in the law and
in regulations published by EPA in the Federal Register
on December 22, 1972.
In fact, the law requires EPA to turn over permit-issu-
ing authority to a State if the State so requests and if its
program meets the Federal requirements. That's in keep-
ing with the general philosophy expressed by Congress in
the law that the States have "primary responsibilities and
rights" to prevent, reduce, and eliminate water pollution.
The assertion of States' "primary responsibilities and
rights" is not new; the 1972 law simply reiterates what
previous Federal water pollution control legislation stated.
What is new, however, is that for the first time the States
must carry out their responsibilities within a framework
of a meaningful and enforceable nationwide water pollu-
tion control program, and that for the first time the Fed-
eral Government can take effective enforcement action if
the States fail to act.
The permit program requirements were designed to
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make sure that discharges of pollutants into the Nation's
waters are subject to uniform minimum controls and that
the restrictions, terms, and conditions of a permit are sub-
stantially the same whether issued by EPA or a State. In
brief, water pollution is a national problem, and the per-
mit system is part of a national program to combat that
problem.
Moreover, to insure the effectiveness of the national
permit program the 1972 law requires a State with permit-
issuing authority to send EPA a copy of every permit ap-
plication it receives. EPA has authority to veto a
proposed State permit if the permit does not comply with
the law or EPA regulations, or if the waters of another
State will be adversely affected by the proposed discharge.
If a discharger operating under an NPDES permit is-
sued by a State fails to comply with the terms of the per-
mit, EPA can step in and take enforcement action if the
State does not do so. EPA can also revoke a State's per-
mit authority if the program is not administered in com-
pliance with Federal requirements. EPA must first hold a
public hearing and give the State 90 days to take reme-
dial action.
What's a Pollutant?
It's illegal under the 1972 Federal Water Pol-
lution Control Act to discharge pollutants into
the Nation's waters except under an NPDES per-
mit.
Pollutants covered by this permit requirement
are: Solid waste, incinerator residue, sewage, gar-
bage, sewage sludge, munitions, chemical wastes,
biological materials, radioactive materials, heat,
wrecked or discarded equipment, rock, sand, cel-
lar dirt, and industrial, municipal, and agricul-
tural wastes discharged into water.
Excluded from the NPDES permit program
are: Discharges of sewage from vessels; pollu-
tants from vessels or other floating craft in
coastal or ocean waters; discharges from properly
functioning marine engines; water, gas, or other
material injected into oil or gas wells, or disposed
of in wells during oil or gas production if the
State determines that ground or surface water re-
sources will not be degraded; aquaculture proj-
ects; separate storm sewer discharges; and
dredged or fill material.
Discharges excluded from the NPDES permit
system are covered by other pollution control re-
quirements.
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If a State wants to operate its own permit program, here's
the procedure:
The State submits a complete description of its pro-
posed program to EPA, along with evidence that State
law gives it adequate authority to carry out the program.
fmf^M^mm^fm All procedures for establishing and administering the pro-
|JGlIlll|l posed permit program must be spelled out in State laws
run or reg^31'0118- ^ ^ nas l£Sa* authority to do so, a State
FPA has until January 1, 1974 to issue any regulations needed
to implement the program.
E^A then reviews tne proposed program to see if it
meets all requirements. Some of the major elements that
it must contain are:
• The State program must be at least equal in scope
and effectiveness to the EPA program.
• The program must be adequately funded and
staffed with qualified personnel. (The State must submit
proposed costs and describe available funds.)
• State law must make it illegal to discharge pollut-
ants except under an NPDES permit.
• The program must be legally enforceable in State
courts. The State must have the power to compel compli-
ance with national and State effluent standards and limi-
tations, and water quality standards. Civil and criminal
penalties must be at least equal to those in the 1972 Fed-
eral law, or high enough to be a substantial economic de-
terrent to violations.
• The State must have the power to enter, inspect
and monitor sources of pollution, and the authority to re-
quire polluters to install monitoring equipment, keep rec-
ords, and file reports.
• The State must have the power to immediately stop
discharges that pose an imminent or substantial danger to
public health or welfare. Lacking this authority, the State
must have a procedure for immediately notifying EPA by
telephone of actual or threatened emergencies.
• The State must have the power to regulate the dis-
posal of pollutants into wells.
• To avoid potential conflicts of interest, anyone who
receives, or has received in the two years previous, a sig-
nificant portion of his income, directly or indirectly, from
permit holders or applicants for a permit may not serve
on the State board or agency that approves permit appli-
cations. ("Significant portion" means 10 percent or more
of gross personal income. For someone over 60 years old,
it means 50 percent if the income comes from a retire-
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ment or pension plan. ''Income" includes retirement bene-
fits, consultant fees, and stock dividends. Income from
mutual funds or other diversified investments is exempt if
the recipient does not know the identity of the primary
sources.)
• The State must have an EPA-approved continuing
planning process designed to produce water quality man-
agement plans for all navigable waters within the State.
The plans can include an analysis of effluent reductions
needed to meet water quality standards, effluent limits,
and schedules of compliance, as well as priorities for
building new waste treatment facilities and schedules for
issuing permits.
• The State's proposed permit program must provide
for public access to all information, except trade se-
crets, generated in the permit process—permit application,
tentative findings, fact sheets, discharge data, the permits
themselves, monitoring data, compliance reports, etc.
• And the State's proposed program must" provide an
opportunity for a public hearing before a permit is issued
or denied.
(See Page 15—Permits and the Public—for details of
the public participation process.)
Protecting Our Wetlands
Wetlands—freshwater and tidal marshes and
swamps—are unique components of the ecosys-
tem. They provide habitat for many species of
fish, for waterfowl, and for fur-bearing animals.
They aid in the natural purification of water.
They recharge ground-water supplies. They mod-
erate extremes in water flow. They serve as nurs-
ery areas for fish and wildlife. They produce
great quantities of plant life that, in turn, are the
source of much of the organic matter consumed
by shellfish in estuaries.
Recognizing the biological, esthetic and recrea-
tional importance of those water areas, EPA's
policy is to safeguard those irreplaceable re-
sources to the greatest degree possible. EPA thus
attempts to see that permits are not issued for
discharges of pollutants that may adversely affect
the Nation's wetlands.
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How does the owner or operator of a factory, a city
sewage system, an animal feedlot, or any other
source of discharges covered by the NPDES permit
program go about getting a permit?
The first step is to obtain an application form.
If the State in which the discharge occurs does not have
an EPA-approved permit program, an owner or operator
gets the form from the appropriate EPA regional office.
(See Appendix F for a list of EPA regional offices and the
States covered by each region.) If the State has been au-
thorized by EPA to issue permits, forms also are available
from the State water pollution control agency. (See Ap-
pendix G for a list of State agencies.)
The discharger then returns the completed form to
EPA or the State agency, as appropriate, with the neces-
sary fee.
The permit application for a typical industrial operation
provides information on the amount and nature of the
proposed waste water discharge—how many gallons per
day, whether it's bathroom waste water, cooling water,
process water, or water containing food wastes. The appli-
cation shows if the discharges contain anything toxic—to
humans or other living things such as lead, mercury, zinc,
polychlorinated biphenyls (PCBs) — or disease-causing
materials. It shows where the discharges will be made—
into a water body, a well, etc. It shows whether any of
the discharges have been pretreated.
What happens next is essentially the same whether
EPA or a State control agency is processing the permit
application, with some differences, however.
the EPA permit process
After receiving the permit application, the EPA re-
gional office evaluates it. EPA may ask the applicant for
additional information and may inspect the site of the
proposed discharge. If any additional information is
sought by EPA but not delivered, EPA may deny the
permit and impose sanctions on the discharger.
EPA sends a copy of the permit application to other
Federal agencies for comments. The district office of the
U.S. Army Corps of Engineers, for example, evaluates the
impact of the proposed discharge on navigation. If the
Corps notifies EPA that the'proposed discharge will sub-
stantially impair anchorage and navigation, EPA may not
issue the permit. If the Corps finds that certain conditions
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are necessary to safeguard navigation, those conditions
must be made part of the permit.
The application must also receive certification from the
State in which the discharge takes place so that the dis-
charge will not violate national effluent limits and per-
Other Permits
Federal permit programs also regulate the dis-
posal of sludge from publicly-owned sewage treat-
ment plants, ocean dumping, and the disposal of
dredged or fill material.
The Federal Water Pollution Control Act pro-
hibits the disposal of sewage treatment plant
sludge except under a permit issued by EPA. The
permit system for sludge disposal operates just as
the permit system described in this pamphlet. A
State may administer its own sludge disposal per-
mit system if its program meets EPA require-
ments.
Discharging and dumping pollutants into coastal
and ocean waters is regulated by EPA under two
laws—the Federal Water Pollution Control Act
of 1972 and the Marine Protection, Research and
Sanctuaries Act of 1972. Under the water pollu-
tion law, an NPDES permit may be issued for
ocean discharges only if the discharges meet EPA
regulations for protecting human health and wel-
fare, marine life, wildlife, shorelines, beaches, and
esthetic, recreation and economic values.
Under the Marine Protection law, only EPA is
authorized to issue permits—after public notice
and an opportunity for a public hearing—for the
transportation and ocean dumping of materials
that do not "unreasonably degrade or endanger
human health, welfare, or amenities, or the ma-
rine environment, ecological systems, or economic
potentialities." No dumping permit may be issued
for materials that will violate water quality stand-
ards.
The water pollution law reaffirms the U.S.
Army Corps of Engineers' authority to issue per-
mits—after public notice and an opportunity for
a public hearing—for putting dredged or fill ma-
terial in specified water disposal sites. EPA has
authority to veto the designation of disposal sites
to prevent adverse effects on municipal water
supplies, shellfish beds, fishery areas, wildlife, or
recreation areas.
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formance standards, or that none is applicable. The State
certification may include any additional effluent limits,
performance standards, and monitoring requirements nec-
essary to insure compliance with Federal and State laws.
The State must give public notice of the certification appli-
cation and may hold a public hearing.
If EPA thinks the discharge may affect water quality in
another State, EPA must notify the other State, which, in
turn, may object to the proposed discharge and request a
public hearing.
Some Prohibitions
The 1972 law specifically prohibits certain discharges.
It is illegal, for example, to discharge any radiological,
chemical, or biological warfare material, or high-level
radioactive wastes. No permit may be issued to discharge
any of those dangerous materials. In addition, a permit
may not be issued:
—If the State where the discharge will take place de-
nies certification.
—If compliance with the water quality requirements of
all affected States cannot be insured.
—If the Corps of Engineers finds that the discharge
would substantially impair anchorage and navigation.
—If the source of the discharge is in conflict with an
approved areawide waste treatment management plan pre-
pared for an area with substantial water pollution prob-
lems. (This permit requirement will come into play after
EPA approves the areawide plan. Those plans will be
submitted by the States within two years after the plan-
ning process gets under way.)
—If the discharge will be into coastal or ocean waters
and if the discharge does not meet EPA's guidelines for
those waters. (The permit may not be issued if there's not
enough information available to determine whether the
discharge will comply with those guidelines.)
Tentative Decision
After analyzing all information and comments on the
proposed discharge, the EPA regional office makes a pre-
liminary decision to issue or deny the permit. The deci-
sion is spelled out in "tentative determinations," which in-
clude proposed effluent limits on pollutants that will be
discharged, a proposed compliance schedule for meeting
the effluent limits if full compliance is not immediately
possible, and proposed conditions to be included in the
permit.
EPA then issues a public notice of the permit applica-
tion and its intention to issue or deny the permit. The
10 tentative determinations and the permit application are
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made public, along with any available fact sheet.
EPA also provides an opportunity for a public hearing
before issuing or denying the permit.
When this process is completed, and after giving the
public 30 days to comment on its preliminary decision or
to request a public hearing, the EPA regional administra-
tor issues or denies the permit.
the state permit process
If a State water pollution control agency is handling
the permit program, the application is processed much as
EPA does it. The State may ask for more information
and may inspect the site. It sends a copy of the permit
application to involved Federal agencies and to any other
States that may be affected by the discharge. The State
must abide by the same prohibitions against issuing per-
mits that govern EPA's decision. (The certification proce-
dure described under the EPA permit-issuing process
does not apply to a State permit system. And while a
State must give other States whose waters may be affected
by discharges an opportunity to comment on the proposed
permit, the first State is not required to comply with sug-
gestions made by affected States. However, if a State does
not accept the recommendations of other affected States,
it must explain why, in writing, to the other States—and
to EPA, which can veto the permit.)
In addition, the State must send the EPA regional ad-
ministrator a copy of the permit application. If EPA re-
quests it, the State must require the applicant to submit
additional information. The State must also send EPA a
copy of any permit it proposes to issue. If EPA objects,
the State may not issue the permit. (EPA may waive its
right to review certain permit applications submitted to a
State by individual dischargers or by categories of dis-
chargers. Sources of discharges thus exempt from EPA
review in the permit process are spelled out in regulations
issued by EPA when it approves a State permit pro-
gram.)
After analyzing the application, the State then makes
its preliminary decision to issue or deny the permit. If
more than 500,000 gallons are to be discharged on any
day of the year, the State prepares a fact sheet on the
proposed permit.
The State announces its tentative decision publicly,
makes the information available to the public, and pro-
vides an opportunity for a public hearing, as does EPA.
After allowing at least 30 days for comments and re-
quests for a public hearing, the State issues or denies the
permit. The State must also send EPA a copy of every
permit it issues. 11
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A
ny permit issued by EPA or a State must contain
several elements.
The permit must specify which pollutants may
be discharged and must set average and maximum daily
._ limits on those discharges as needed to meet effluent
fllP nPPITIlt stan
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permit, will constitute a violation of the permit.
—That the permit may be modified, suspended, or re-
voked if its terms are violated, if it was obtained by
misrepresentation or failure to disclose all relevant facts,
or if conditions require the authorized discharge to be re-
duced or stopped, temporarily or permanently.
—That the permit holder will allow EPA or State
water pollution control agency officials to enter and in-
spect the plant, inspect and copy records required to be
kept under terms of the permit, inspect monitoring equip-
ment required by the permit, and sample pollution dis-
charges.
—That the permit holder will keep his pollution con-
trol systems in good working order and operating as
efficiently as possible to comply with the permit.
—That discharges will be consistent with toxic effluent
Federal Discharges
The Federal Water Pollution Control Act re-
quires all U.S. Government agencies to comply
with Federal, State, interstate and local water
pollution control laws and regulations, just as any
non-governmental source of pollution must. As
part of that compliance, Federal installations dis-
charging pollutants into water bodies are covered
by the NPDES permit system. Permits for dis-
charges from Federal installations are issued only
by EPA, however. Thus, even if a U.S. military
base, power plant, hospital, munitions plant, etc.
is located in a State that has an EPA-approved
permit program, EPA, not the State, is the permit
authority for that Federal installation.
The law empowers the President to exempt
any Federal effluent source from compliance if
it's "in the paramount interest" of the Nation to
do so. (However, no exemption may be granted
from the new source performance standards and
effluent standards for toxic pollutants that EPA
will issue in 1974, nor from compliance with pre-
treatment requirements for wastes going directly
into a publicly-owned treatment plant.)
The President may not grant an exemption be-
cause of the lack of funds to bring a Federal fa-
cility into compliance unless he has specifically
asked Congress for the funds, and Congress has
failed to appropriate the money.
The law also requires the President to report
annually to Congress all exemptions granted, with
the reason for each exemption.
13
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standards or prohibitions established under the 1972 law.
When a publicly-owned waste treatment plant receives
a permit, several other conditions must be met. For in-
stance: If the treatment plant handles discharges from in-
dustries, the permit holder must report any new pollutants
coming from those sources. Any substantial change in the
volume or nature of industrial discharges must also be re-
ported. And the permit holder must require industries
using the public plant to pretreat their wastes to get rid of
pollutants that cannot be treated by, or would interfere
with the operation of the public plant. (Note: Industries
discharging directly into a publicly-owned waste treatment
system do not need a permit for such discharges, but
must meet the pretreatment standards set by the public
system.)
14
For Further Information
EPA has published several pamphlets on water
pollution control and citizen participation in envi-
ronmental improvement programs. Items indi-
cated as free are available from EPA, Office of
Public Affairs, Washington, D.C. 20460. Cost
items are for sale by the Superintendent of Docu-
ments, U.S. Government Printing Office, Wash-
ington, D.C. 20402.
HIGHLIGHTS OF THE FEDERAL WATER POLLU-
TION CONTROL ACT AMENDMENTS of 1972—
Free.
HIGHLIGHTS OF THE MARINE PROTECTION, RE-
SEARCH AND SANCTUARIES ACT OF 1972—Free.
ACTION FOR ENVIRONMENTAL QUALITY: Stand-
ards and Enforcement for Air and Water
Pollution Control—65 cents.
THE METRO STORY: How Citizens Cleaned Up
Lake Washington—10 cents.
OREGOMANS RESTORE THE WILLAMETTE—15
cents.
DON'T LEAVE IT ALL To THE EXPERTS: The
Citizen's Role in Environmental Decision Making
—55 cents.
CITIZEN ACTION CAN GET RESULTS—20 cents.
GROUPS THAT CAN HELP—Free.
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Recognizing the importance of public understanding
and involvement in efforts to protect the environ-
ment, Congress wrote into the 1972 law a require-
ment that EPA and the States must provide for, encour-
age, and assist public participation in carrying out
provisions of the Act. Moreover, the 1972 law also re-
quires EPA and the States to make information on the
permit system available to the public and to provide an
opportunity for a public hearing before issuing or denying
a permit.
Those requirements, along with regulations issued by
EPA, give the public an unprecedented opportunity to
take part in a government regulatory program. The public
involvement opportunities give the public full access to all
information (except trade secrets) on proposed dis-
charges. They give citizens who care enough to take part
a chance to evaluate the information and to make their
views known early in the decisionmaking process.
After a permit is issued, it is a public document; con-
cerned citizens can learn exactly what a discharger may
put into a water body and what the discharger must do to
reduce or eliminate the flow of pollutants. The public also
has access to the monitoring and compliance reports that
dischargers must file with EPA or the State agency. Citi-
zens can use those reports to measure progress—or lack
of it—toward cleaner water. The public also has the right
under the 1972 law to challenge in court EPA's decision
to issue or deny a permit, to file suit against anyone vio-
lating a permit condition, an EPA order, and to file suit
against EPA itself if it fails to carry out any action re-
quired by the 1972 law. (There are some conditions on
this right to sue. See Appendix, A.)
Here's the public participation machinery built into the
permit system:
Public Notice
The public will be given notice before a permit is is-
sued or denied. The permit application and tentative de-
terminations must be made available to the public. At
least 30 days must be allowed for public comments on
the tentative decision to issue or deny the permit, and for
requesting a public hearing.
If EPA's or the State's preliminary decision is to issue
the permit, the tentative determinations must include the
proposed effluent limitations on pollutants to be dis-
charged, the proposed schedule of compliance, and any
other terms and conditions to be imposed on the dis-
charger. This, in effect, is a draft permit.
permits
and the
public
IS
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EPA and the State must set up mailing lists and auto-
matically send any individual or organization who asks to
be on the list a copy of all public notices on permit appli-
cations. Public notice of the permit application must be
posted in the post office and other public places nearest
the site of the proposed discharge, at the entrance to the
applicant's plant and in nearby places, or the public no-
tice must be published in local newspapers, including at
least one general-circulation newspaper. (See sample pub-
lic notice of a permit application, Appendix C.)
Fact Sheet
To make additional information available to the public,
EPA and the State must also prepare a fact sheet on
every permit application that proposes discharges of more
than 500,000 gallons on any day of the year. (EPA or a
State may prepare a fact sheet on smaller proposed dis-
charges if it wishes.)
The fact sheet must be sent to anyone who requests it
after public notice of the permit application. EPA or a
State must also set up a mailing list and automatically
send any individual or organization who asks to be on
that list a copy of every fact sheet.
Among other things, the fact sheet must include the
following information:
• A sketch or detailed description of the location of
the proposed discharge.
• Average summer and winter temperatures of the
discharge.
• Average discharge in pounds per day of any pollu-
tants present in significant quantities or subject to limits
under the 1972 law.
• The tentative determinations described earlier.
• The uses for which the water body receiving the
discharge has been classified, and the water quality stand-
ards and effluent standards and limitations applied to the
discharge.
• A more detailed description of how a final decision
will be made on the permit application, including proce-
dures for requesting a public hearing, and any other ways
in which the public may take part in the final determina-
tion. (See sample fact sheet, Appendix D.)
Public Hearings
A State agency must hold a public hearing before
acting on a permit if there is "significant public
interest" in a hearing. This includes any requests or peti-
tions for a public hearing filed within 30 days of the pub-
lic notice of the permit application. EPA regulations spec-
ify that "instances of doubt should be resolved in favor of
holding the hearing."
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State public hearing procedures vary, but procedures
must be consistent with EPA regulations on the public
participation provisions of the 1972 law. These regula-
tions stress that individual citizens and organizations must
have a formal opportunity to present their views before a
control agency makes its final decision, and that the final
decision must reflect consideration of the views presented
at the public hearing.
EPA may hold a public hearing if there is a significant
degree of public interest in a proposed permit.
If a public hearing is held, the public must be given 30
days' notice of the hearing, and the hearing must be held
in the area of the proposed discharge or in another ap-
propriate location.
In addition, EPA regulations provide an opportunity
for a formal "adjudicatory hearing" on a permit that EPA
proposes to issue, in conformity with the Administrative
Procedures Act. An adjudicatory hearing may be re-
quested by a State in which a discharge takes place, by a
State that may be affected by a discharge, by the appli-
cant for a permit, or by any foreign country, Federal
agency or person whose interests may be affected by a
discharge.
That, in sum, is how the permit system—a key "ac-
tion" part of the 1972 law—works. As the law de-
clares, its objective is "to restore and maintain the
chemical, physical, and biological integrity of the Nation's
waters." The law provides the Nation with formidable
new tools to achieve that objective. But in applying those
tools and implementing the permit program—and in
carrying out all of its responsibilities to protect public
health and the environment—EPA needs and looks for-
ward to the support and cooperation of State and local
governments, of industry, and of the public.
The 1972 law gives the public formidable new oppor-
tunities to participate in the battle against water pollution.
EPA encourages citizens to use those tools, for unless
they are used, unless citizens get involved, the national
program to restore and maintain the integrity of our riv-
ers, streams, lakes and oceans will be impeded.
Through elected and appointed officials, the public will
ultimately determine how clean our waters will be. Public
participation in the permit system will help assure vigor-
ous implementation of the Federal Water Pollution Con-
trol Act and cleaner, safer water for all to enjoy. 17
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What Can Citizens Do To Help?
Concerned citizens, especially those organized
in voluntary citizen organizations to work for a
cleaner environment, can contribute greatly to the
campaign against water pollution. Among other
things, they can work to insure that water pollu-
tion control agencies—at the community, State
and Federal levels—have adequate funds and
staff to implement water pollution control laws
and regulations. They can support, encourage,
and stimulate control agencies and polluters to
move steadily and speedily toward compliance
with water pollution control laws and regulations.
They can keep the public informed, on a con-
tinuing basis, on the success or failure of water
pollution control programs, including the permit
system.
Citizen groups can play a direct role in the
national permit program. They can monitor per-
mit applications and proposed permits. They can
obtain and analyze draft permits and fact sheets.
They can request and take part in public hearings
and the formal adjudicatory hearings when
deemed necessary. They can learn the terms and
conditions of permits, obtain monitoring and
compliance reports, and check to see if compli-
ance schedules are being met on time. They can
report supposed violations of permits to control
agencies. If all else fails, they can use their right
to take court action to compel compliance.
In brief, concerned citizen organizations can
serve as public ombudsmen, public watchdogs of
the national program "to restore and maintain the
chemical, physical, and biological integrity of the
Nation's waters" under the Federal Water Pollu-
tion Control Act.
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APPENDIX A — Guidelines for Citizen Suits
Citizens are given the right to bring
a civil suit under the new Act against
any person who is alleged to be in vio-
lation of an effluent standard or limita-
tion (which includes violation of a
permit condition) or of an order issued ,
by the Administrator or a State in re-
gard to such limitation or standard, or
against the Administrator where he al-
legedly fails to perform any nondiscre-
tionary act or duty. Under the Act,
"citizen" is defined as "a person or per-
sons having an interest which is or may
be adversely affected," and "person" is
defined to mean "an individual, corpora-
tion, partnership, association, State,
municipality, commission, or political
subdivision of a State, or any interstate
body." According to relevant legal inter-
pretation, a citizen plaintiff must be a
person with an interest that is or may be
adversely affected in fact; a generalized
but not directly affected interest in the
environment would not be sufficient to
give a citizen standing to sue under the
Act.
Persons who can be named as de-
fendants in a citizen suit include the
United States and any other govern-
mental agency to the extent permitted
by the Eleventh Amendment to the
Constitution. The suit shall be brought
in the district court without regard to
the amount in controversy or the citizen-
ship of the parties. In addition to grant-
ing injunctive relief, the courts are
authorized to apply any appropriate
civil penalties of the Act.
A citizen may sue the Administrator
for failure to perform nondiscretionary
acts such as meeting a deadline in estab-
lishing regulations or standards or in
preparing studies or reports. If the
Administrator fails to take enforcement
action after he finds that a violation
of the Act has occurred, he is also sub-
ject to a citizen's action.
If a citizen is going to bring an action
in any of these circumstances, the citizen
must give at least 60 days' notice (except
for violation of standards for toxic pol-
lutants or performance standard re-
quirements) prior to commencement of
the action (1) to the Administrator, (2)
to the State in which the alleged viola-
tion occurs, and (3) to the alleged
violator. A separate suit may not be
brought by a citizen if the Administrator
or the State has commenced and is dili-
gently prosecuting a civil or criminal
action to require compliance with the
violated standard, permit condition, or
order.
APPENDIX B — Sample Permit Application
Application No.: AB 123 CDE 4567890
Name of Permittee: American Widget Co.
Effective Date:
Expiration Date:
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
DISCHARGE PERMIT
In reference to the above application for a permit to discharge in com-
pliance with the provisions of the Federal Water Pollution Control Act, as
amended by the Federal Water Pollution Control Act Amendments of 1972,
P.L. 92-500, October 18, 1972 (33 U.S.C. §1251 et. seq) (Hereinafter re-
ferred to as '"the Act"),
AMERICAN WIDGET CO.
BABYBUGGY DIVISION
BUMPER OPERATION
is authorized by Region V, U.S. Environmental Protection Agency
Regional Administrator
to discharge from its operation at Anytown, State
to the Local River
in accordance with the following general and special conditions:
19
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GENERAL CONDITIONS
1. All discharges authorized herein shall be consistent with the terms and con-
ditions of this permit; facility expansions, production increases, or process
modifications which result in new or increased discharges of pollutants must
be reported by submission of a new NPDES application, or if such new or
increased discharge does not violate the effluent limitations specified in this
permit, by submission to the permit-issuing authority of notice of such new
or increased discharges of pollutants in which case the permit may be modi-
fied to specify effluent limitations for any pollutants not identified and limited
herein); the discharge of any pollutant more frequently than or at a level
in excess of that identified and authorized by this permit shall constitute a
violation of the terms and conditions of this permit.
2. After notice and opportunity for a hearing, this permit may be modified,
suspended, or revoked in whole or in part during its term for cause including,
but not limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully
all relevant facts;
c. A change in any condition that requires either a temporary or perma-
nent reduction or elimination of the authorized discharge.
3. Notwithstanding (2) above, if a toxic effluent standard or prohibition
(including any schedule of compliance specified in such effluent standard or
prohibition) is established under section 307(a) of the Act for a toxic pol-
lutant which is present in the discharge authorized herein and such standard
or prohibition is more stringent than any limitation upon such pollutant in
this permit, the permit shall be revised or modified in accordance with the
toxic effluent standard or prohibition and the permittee shall be so notified.
4. The permittee shall allow the head of the State water pollution control
agency, the Regional Administrator, and/or their authorized representatives,
upon the presentation of credentials:
a. To enter upon the permittee's premises where an effluent source is
located or in which any records are required to be kept under the terms and
conditions of this permit;
b. To have access to and copy at reasonable times any records required
to be kept under the terms and conditions of this permit;
c. To inspect at reasonable times any monitoring equipment or monitor-
ing method required in this permit; or,
d. To sample at reasonable times any discharge of pollutants.
5. The permittee shall at all times maintain in good working order and oper-
ate as efficiently as possible all treatment or control facilities or systems in-
stalled or used by the permittee to achieve compliance with the terms and
conditions of this permit.
6. The issuance of this permit does not convey any property rights in either
real or personal property, or any exclusive privileges, nor does it authorize
any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
7. This permit does not authorize or approve the construction of any onshore
or offshore physical structures or facilities or the undertaking of any work
in any navigable waters.
8. The specific effluent limitations and other pollution controls applicable to
the discharge permitted herein are set forth below in the special conditions.
Also set forth below are self-monitoring and reporting requirements. Unless
otherwise specified, the permittee shall submit duplicate original copies of all
reports to the head of the Stale water pollution control agency and the
Regional Administrator. Except for data determined to be confidential under
section 308 of the Act, all such reports shall be available for public inspec-
tion at the offices of the head of the State water pollution control agency
and the Regional Administrator. Knowingly making any false statement on
any such report may result in the imposition of criminal penalties as pro-
vided for in section 309 of the Act.
20
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SPECIAL CONDITIONS
1. Initial Effluent Limitations
During the period beginning on the effective date of this permit and
lasting until September 1, 1974, discharges from outfalls #001 shall be
limited and monitored by the permittee as specified below:
a. The following shall be limited and monitored by the permittee as
specified:
Effluent
Characteristic
Flow
Total Susp. Solids
Chromium, Total
Copper, Total
Iron, Total
Nickel, Total
Oil & Grease
kj|/day (Ibs./day)
Daily Daily
Average Maximum
29.0 (63)
.4 (0.9)
.4 (0.8)
1.8 (4.0)
.7 (1.6)
21.0 (47)
43.0 (95)
.6 (1.4)
.6 (1.2)
2.7 (6.0)
1.1 (2.4)
32.0 (71)
Other Limitations
(Specify Units)
Average Maximum
Monitoring Requirements
Frequency Sample
Measurement Type
Monthly 24-hr. Composite
Monthly 24-hr. Composite
Monthly 24-hr. Composite
Monthly 24-hr. Composite
Monthly 24-hr. Composite
Monthly 2 Grabs/24 hrs.
(I) Net additions to intake
In addition to above, Discharges 002, 003, shall be limited and monitored as
specified below:
Flow
Total Solids
Chromium, Total
Copper, Total
Nickel, Total
Oil & Grease
Monthly Estimate
Quarterly 24-hr. Composite
Quarterly 24-hr. Composite
Quarterly 24-hr. Composite
Quarterly 24-hr. Composite
Quarterly 2 Grabs/24 hrs.
For the purposes of this subsection, the daily average discharge is the
total discharge by weight during a calendar month divided by the number of
days in the month that the production or commercial facility was operating.
For the purposes of this subsection, the daily maximum discharge means
the total discharge by weight during any calendar day.
b. The pH shall not be less than 6.0 or greater than 8.5.
2. Final Effluent Limitations
During the period beginning September 1, 1974 and lasting until the
date of expiration of this permit, discharges from outfalls #001 shall be
limited and monitored by the permittee as specified below:
a. The following shall be limited and monitored by the permittee as
specified:
Characteristic
Flow
Total Susp. Solids
Chromium, Total
Copper, Total
Iron, Total
Nickel, Total
Oil & Grease
Chloride
Sulfate
Sulfide
Discharge Limitation'11
.. kg/day (Ibs/day)
Daily Daliy
Average Maximum
4.4 (9.5)
.06 (.14)
.06 (.12)
.27 (.6)
.11 (.24)
3.2 (7.1)
6.5 (14.3)
.09 (.21)
.09 (.18)
.41 (.9)
.17 (.36)
4.8 (10.7)
Other Limitations
(Specify Units)
Average Maximum
Monitoring Requirements
Frequency Sample
Measurement Type
DAILY ESTIMATE
Weekly 24-hr. Composite
Weekly 24-hr. Composite
Weekly 24-hr. Composite
Monthly 24-hr. Composite
Weekly 24-hr. Composite
Weekly 6 Grabs/24 hrs.
Monthly 24-hr. Composite
Monthly 24-hr. Composite
Monthly 24-hr. Composite
(1) Net additions to intake
21
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Additionally, Outfalls 002, 003, shall be monitored as follows:
Flow, Temperature and Total Solids—Once per month, Grab samples
Maximum Discharge Temperatures above upstream receiving waters shall be
in accordance with the following: April through November -15°F;
December through April -20°F. The temperature shall be monitored once
per month on each outfall.
For the purposes of this subsection, the daily average discharge is the
total discharge by weight during a calendar month divided by the number of
days in the month that the production or commercial facility was operating.
For the purposes of this subsection, the daily maximum discharge means
the total discharge by weight during any calendar day.
b. The pH shall not be less than 6.0 or greater than 8.5 for Outfalls
001, 002, 003, The pH shall be as follows: All outfalls—Monthly
Grab Samples.
3. Schedule of Compliance for Effluent Limitations
a. Permittee shall achieve compliance with the effluent limitations speci-
fied above for discharges from outfalls in accordance with the following
schedule:
(1) Report of Progress N/A
(2) Report of Progress N/A
(3) Completion of final plans by 3 months from date of permit
issuance
(4) Award of contract or other com-
mitment of financing by N/A
(5) Commencement of construction by 5 months from date of permit
issuance
(6) Report of construction progress N/A
(7) Report of construction progress N/A
(8) Report of construction progress N/A
(9) Completion of construction by June 1, 1974
(10) Attainment of operational level by September 1, 1974
b. The permittee shall submit to the permit-issuing authority the re-
quired report of progress or, where a specific action is required in (a) above
to be taKen by a certain date, a written notice of compliance or noncompliance
with each of the above schedule dates, postmarked no later than 14 days
following each elapsed date. Each notice of noncompliance shall include
the following information:
(1) A short description of the noncompliance;
(2) A description of any actions taken or proposed by the permittee to
comply with the elapsed schedule requirement without further delay;
(3) A description of any factors which tend to explain or mitigate
the noncompliance; and
(4) An estimate of the date permittee will comply with the elapsed
schedule requirement and an assessment of the probability that permittee will
meet the next scheduled requirement on time.
4. Compilation of Monitoring Data
a. Samples and measurements taken to meet the monitoring requirements
specified above shall be representative of the volume and nature of the
monitored discharge.
b. Following promulgation of guidelines establishing test procedures for
the analysis of pollutants, published pursuant to section 304(g) of the Fed-
eral Water Pollution Control Act, as amended, all sampling and analytical
methods used to meet the monitoring requirements specified above shall con-
form to such guidelines. If the section 304(g) guidelines do not specify test
procedures for any pollutants required to be monitored by this permit and
until such guidelines are promulgated, sampling and analytical methods used
to meet the monitoring requirements specified in this permit shall, unless
otherwise specified by the Regional Administrator, conform to the latest edi-
tion of the following references:
(1) Standard Methods for the Examination of Water and Waste-waters,
22
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13th Edition, 1971, American Public Health Association, New York,
New York 10019.
(2) A.S.T.M. Standards, Part 23, Water; Atmospheric Analysis, 1972,
American Society for Testing and Materials, Philadelphia, Pennsyl-
vania 19103.
(3) Methods for Chemical Analysis of Water and Wastes, April 1971,
Environmental Protection Agency Water Quality Office, Analytical
Quality Control Laboratory, NERC, Cincinnati, Ohio 45268.
c. Permittee shall take samples and measurements to meet the monitor-
ing requirements specified above at the locations indicated below:
Outfalls 002, 003.
Outfalls 001 at sedimentation basin before mixing with other waters.
River intake.
5. Recording of Monitoring Activities and Results
a. The permittee shall make and maintain records of all information
resulting from the monitoring activities required by this permit.
b. The permittee shall record for each measurement or sample taken
pursuant to the requirements of this permit the following information: (1)
the date, exact place, and time of sampling; (2) the dates analyses were
performed; (3) who performed the analyses; (4) the analytical techniques
or methods used; and, (5) the results of all required analyses.
c. If the permittee monitors any pollutant more frequently than is re-
quired by this permit, he shall include the results of such monitoring in the
calculation and reporting of the values required in the Discharge Monitoring
Report Form (EPA Form 3320-1 [10-72]). Such increased frequency shall
be indicated on the Discharge Monitoring Report Form.
d. The permittee shall retain for a minimum of 3 years all records of
monitoring activities and results including all records of calibration and
maintenance of instrumentation and original strip chart recordings from
continuous monitoring instrumentation. This period of retention shall be ex-
tended during the course of any unresolved litigation regarding the discharge
of pollutants by the permittee or when requested by the Regional Administra-
tor or the State water pollution control agency.
6. Reporting of Monitoring Results
a. Monitoring information required by this permit shall be summarized
and reported by submitting a Discharge Monitoring Report Form (EPA
Form 3320-1 [10-72]), properly filled in and signed, to the Regional Admin-
istrator and the State agency at the following addresses:
U. S. Environmental Protection Agency State Environmental Protection Agency
Region V, Permit Branch P. O. Box 1049
1 North Wacker Drive Capital City, State
Chicago, Illinois 60606
b. Each submitted Discharge Monitoring Report shall be signed as fol-
lows: .
(1) If submitted by a corporation, by a principal executive officer of
at least the level of vice president, or his duly authorized representative, if
such representative is responsible for the overall operation of the facility
from which the discharge described in the Discharge Monitoring Report
originates;
(2) If submitted by a partnership, by a general partner;
(3) If submitted by a sole proprietor, by the proprietor;
(4) If submitted by a municipality, State or Federal agency, or other
public entity, by a principal executive officer, ranking elected official,
commanding officer, or other duly authorized employee.
c. All information submitted on the Discharge Monitoring Form shall be
based upon measurements and sampling carried out during the three previous
calendar months. The first Discharge Monitoring Report shall be submitted
for a period ending 60 days from issuance. Thereafter, reporting periods
shall end on the last day of each month.* The permittee shall submit a
* December, March, June and September
23
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Discharge Monitoring Report postmarked no later than the 28th day of the
month following each completed reporting period.
7. Limitation of Discharges of Oil and Hazardous Substances in Harmful
Quantities
The permittee shall not discharge oil into or upon navigable waters or
adjoining shorelines in quantities defined as harmful in regulations published
at 40 CFR 110, including any amendments or revisions to such regulations
effected subsequent to the date of this permit. In addition, the permittee
shall not discharge hazardous substances into or upon navigable waters or
adjoining shorelines in quantities defined as harmful in regulations promulgated
by the Administrator pursuant to section 311(b)(4) of the Federal Water
Pollution Control Act, as amended. Nothing in this permit shall be deemed
to preclude the institution of any legal action nor relieve the permittee from
any responsibilities, liabilities, or penalties to which the permittee is or may
be subject under section 311 of the Federal Water Pollution Control Act, as
amended, or under any other Federal or State law or regulation.
8. Limitations of Visible Floating Solids and Foam
During the period beginning (date of issuance) and lasting until the
date of expiration of this permit, the permittee shall not discharge floating
solids or visible foam.
9. Disposal of Collected Solids
a. Intake Water Treatment
Solids, sludges, dirt, sand, silt, or other pollutants separated from or
resulting from treatment of intake or supply water prior to use by the per-
mittee shall be disposed of in such manner as to prevent any pollutant from
such materials from entering navigable waters. Any live fish, shellfish, or
other animals collected or trapped as a result of intake water screening
or treatment may be returned to their water body habitat.
b. Waste Water Treatment
Solids, sludges, filter backwash, or other pollutants removed from or re-
sulting from treatment or control of waste waters shall be disposed of in such
manner as to prevent any pollutant from such materials from entering naviga-
ble waters.
10. Noncompliance with Effluent Limitations
a. If for any reason the permittee does not comply with or will be un-
able to comply with any daily maximum effluent limitation specified in this
permit, the permittee shall immediately notify the permit issuing authority
or his designee by telephone at 216/333-7550 and provide the permit issuing
authority with the following information in writing within five days of such
notification:
(1) Cause of noncompliance;
(2) A description of the noncomplying discharge including its impact
upon the receiving waters;
(3) Anticipated time the condition of norcompliance is expected to con-
tinue, or if such condition has been corrected, the duration of the period of
noncompliance;
(4) Steps taken by the permittee to reduce and eliminate the noncomply-
ing discharge; and
(5) Steps to be taken by the permittee to prevent recurrence of the con-
dition of noncompliance.
b. Permittee shall take all reasonable steps to minimize any adverse im-
pact to navigable waters resulting from noncompliance with any effluent
limitation specified in this permit, including such accelerated or additional
monitoring as necessary to determine the nature and impact of the noncom-
plying discharge.
c. Nothing in this permit shall be construed to relieve the permittee from
civil or criminal penalties for noncompliance, whether or not such noncom-
pliance is due to factors beyond his control, such as equipment breakdown,
electric power failure, accident, or natural disaster.
11. Limitation of Batch Discharges
N/A
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12. Provision for Electric Power Failure
The permittee shall either
a. no later than June 1, 1974, certify in writing to the permit issuing
authority that the permittee has installed or provided for an alternative elec-
tric power source sufficient to operate all facilities utilized by permittee to
maintain compliance with the terms and conditions of the permit; or
b. no later than 30 days after the effective date of this permit, certify
in writing to the permit issuing authority that upon the reduction, loss, or
failure of one or more of the primary sources of electric power to any facili-
ties utilized by the permittee to maintain compliance with the terms and con-
ditions of this permit, the permittee shall halt, reduce, or otherwise control
production and/or all discharges in order to maintain compliance with the
terms and conditions of this permit.
13. Prohibition of Bypass of Treatment Facilities
The diversion or bypass of any discharge from facilities utilized by the
permittee to maintain compliance with the terms and conditions of this permit
is prohibited, except (i) where unavoidable to prevent loss of life or severe
property damage, or (ii) where excessive storm drainage or runoff would
damage any facilities necessary for compliance with the terms and conditions
of this permit. The permittee shall immediately notify the permit issuing au-
thority in writing of each such diversion or bypass in accordance with the
procedure specified above for reporting noncompliance.
14. Spill Prevention and Containment Plan
Within 90 days of the effective date of this permit, the permittee shall
prepare and submit to the permit issuing authority, a Spill Prevention, Con-
tainment, and Countermeasure Plan for the facility covered by this permit.
Such plan shall include the following information and procedures relating to
the prevention of spills and unauthorized discharges of oil and hazardous
substances:
a. a description of a reporting system to be used to notify immediately
persons responsible for management of the facility and appropriate State and
Federal authorities;
b. a description of equipment or facilities (including overall facility plot)
for the prevention, containment, or treatment of spills and unauthorized dis-
charges;
c. a list of all oil and hazardous materials used, processed, or stored at
the facility including the normal quantity maintained on the premises for
each listed material;
d. a brief description of any spills or unauthorized discharges which
occurred during the 36-month period preceding the effective date of this per-
mit and subsequent measures taken by permittee to prevent or to reduce the
possibility of further spills or unauthorized discharges; and
e. an implementation schedule for additional equipment or facilities
which might be required for (b) above, but which are not yet operational.
15. Interim Effluent Requirements
N/A
This permit shall become effective on the date of the issuing authority's
signature, provided, however, that if the issuing authority is the Regional Ad-
ministrator, the permit shall become effective on the thirtieth day following
the date of the Regional Administrator's signature unless a request for an
adjudicatory hearing is filed pursuant to the provisions of section 125.34 of
NPDES regulations published at 40 CFR 125.
This permit and the authorization to discharge shall expire on midnight
(date). Permittee shall not discharge after the above date of expiration. In
order to receive authorization to discharge beyond the above date of expira-
tion, the permittee shall submit such information, forms, and fees as are
required by the agency authorized to issue NPDES permits no later than 180
days prior to the above date of expiration.
By authority of.
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APPENDIX C — Sample Public Notice
JOINT PUBLIC NOTICE
Date: June 20, 1973
STATE ENVIRONMENTAL U. S. ENVIRONMENTAL
PROTECTION AGENCY PROTECTION AGENCY
p O BOX REGION V, PERMIT BRANCH
CAPITAL CITY, STATE 1 NORTH WACKER DRIVE
(312) 123-4567 CHICAGO, ILLINOIS 60606
(312) 353-1346
Joint Public Notice No.: 12A-0001 NPDES Application No.:
AB 123 CDE 4567890
NOTICE: Application for National Pollutant Discharge Elimination System
(Public Law 92-500) Permit by AMERICAN WIDGET CO, Any-
town, Anystate, to discharge cooling waters, treated process waste
waters and boiler feed water into the Local River and for State
Certification of said discharge.
AMERICAN WIDGET CO., Babybuggy Division, Bumper Operation,
Anytown, Anystate, has applied for a National Pollutant Discharge Elimina-
tion System (NPDES) Permit to discharge treated waste waters into the
waters of the State. The permit will be issued by either the U.S. Environ-
mental Protection Agency or the State Environmental Protection Agency.
AMERICAN WIDGET CO. has also applied for State certification to be
issued concurrently with the NPDES Permit in the event the permit is issued
by the U.S. Environmental Protection Agency.
The applicant manufactures babybuggy parts and rubber babybuggy
bumpers. There are three discharges described in the application:
Discharge 001—Consists of treated process waste waters and cooling
waters
Discharge 002—Consists of storm waters, chemical lab drain and over-
flow from storage tank
Discharge 003—Consists of storm waters and cooling waters
On the basis of preliminary staff review and application of applicable
standards and regulations, the Regional Administrator of the U.S. Environ-
mental Protection Agency or the State Environmental Protection Agency pro-
poses to issue a permit for the discharge subject to certain effluent limitations
and special conditions. The State Environmental Protection Agency after re-
view of all the comments and objections, also proposes to issue a certification
pursuant to Section 401 of the Federal Water Pollution Control Act, as
amended. State certification will not be necessary if the NPDES Permit issu-
ing authority Is granted to the State prior to issuance.
The proposed determination to issue an NPDES Permit is tentative. Per-
sons wishing to comment upon or object to the proposed determination are
invited to submit the same in writing to:
Region V, Permit Branch
U.S. Environmental Protection Agency
1 North Wacker Drive
Chicago, Illinois 60606
The permit application and joint public notice numbers should appear next
to the above address on the envelope and on the first page of any submitted
comments. All comments received by (date) will be considered in the
formulation of the final determination. Copies of all comments and objec-
tions received will be transmitted to the Director, State Environmental Pro-
tection Agency.
The application, proposed permit including proposed effluent limitations
and special conditions, comments received, and other information are on file
and may be inspected at the U.S. Environmental Protection Agency, 1 North
Wacker Drive, Chicago, Illinois, at any time between 9:30 a.m. and 3:30 p.m.,
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Monday through Friday. Copies of the Joint Public Notice and the corre-
sponding Fact Sheet summarizing application information and proposed permit
conditions are available at no charge at the State Environmental Protection
Agency and the U.S. Environmental Protection Agency. Copies of all other
information are available at a cost of $.20 per page at the U.S. Environmental
Protection Agency.
Please bring the foregoing to the attention of persons whom you know
would be interested in this matter.
APPENDIX D — Sample Fact Sheet
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT PROGRAM
(Section 402, Federal Water Pollution Control Act)
JOINT FACT SHEET
Date: June 20, 1973
STATE ENVIRONMENTAL U.S. ENVIRONMENTAL
PROTECTION AGENCY PROTECTION AGENCY
P.O. BOX REGION V, PERMIT BRANCH
CAPITAL CITY, STATE 1 NORTH WACKER DRIVE
(312) 123-4567 CHICAGO, ILLINOIS 60606
(312) 353-1346
Joint Public Notice No. 12A-0001 NPDES Application No.:
AB 123 CDE 4567890
FACT SHEET—PROPOSED NPDES PERMIT TO DISCHARGE TO
NAVIGABLE WATERS
AMERICAN WIDGET CO., Babybuggy Division, Bumper Operation,
Anytown, Anystate, has applied for a National Pollutant Discharge Elimina-
tion System (NPDES) Permit to be issued by the U.S. Environmental Protec-
tion Agency to discharge pollutants into State waters.
Applicant manufactures babybuggy parts and rubber babybuggy bumpers.
There are three discharges to the Local River described in the application:
Discharges 001, 002, and 003 consist of cooling waters, storm waters, treated
process waste waters and boiler feed water. A more complete description of
the discharges and a sketch of their location follow below.
The proposed staff determination to issue an NPDES permit is tentative.
Persons wishing to comment upon or object to the proposed determination
are invited to submit the same in writing to:
Region V, Permit Branch
U.S. Environmental Protection Agency
1 North Wacker Drive
Chicago, Illinois 60606
All comments or objections received prior to (date) will be considered in
the formulation of final determinations regarding the application. The com-
ments and objections should be in sufficient detail to assist the Regional
Administrator in his decision to issue or not issue the Permit or to hold
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a public hearing. The application and joint public notice numbers should ap-
pear next to the above address on the envelope and on the first page of any
submitted comments. A public hearing may be held if response to public
notice indicates significant public interest.
Information and Copying
Persons wishing further information may write to the above address or
call the Permit Branch at (312) 353-1346. Copies of the proposed permit, in-
cluding proposed effluent limitations and special conditions, comments re-
ceived, and other documents (other than those which the Regional Admin-
istrator maintains as confidential) are available at the Environmental Protec-
tion Agency, 1 North Wacker Drive, Chicago, Illinois 60606, at any time
between 9:30 a.m. and 3:30 p.m., Monday through Friday, for inspection and
may be copied at a cost of $.20 per page.
Register of Interested Persons
Any person interested in a particular application or group of applications
may leave his name, address, and phone number as part of the file for an
application. Persons so listed will be mailed a copy of any public notice pub-
lished with regard to the application.
Public Hearings
If submitted comments indicate a significant public interest in the appli-
cation, or if the Regional Administrator believes useful information may be
produced thereby, the Regional Administrator, at his discretion, may hold a
public hearing on the application. Any person may request the Regional Ad-
ministrator to hold a public hearing on the application. The written request
should contain specific reasons for the holding of a public hearing and the
issues to be considered at the public hearing.
Public notice of a hearing will be circulated at least 30 days in advance
of the hearing. An attempt will be made to hold any such meeting or
hearing in the vicinity of the discharge. The guidelines require that a timely
determination be made after the hearing. Further information regarding the
conduct and nature of the public hearings may be obtained by writing or
visiting the Permit Branch, Environmental Protection Agency, I North Wacker
Drive, Chicago, Illinois 60606.
DESCRIPTION OF EXISTING DISCHARGES
Discharge #001
Average Flow
Average
Temperature
Summer
Winter
Constituents:
Total Suspended
Solids
Total Chromium
Copper
Nickel
Oil & Grease
Chlorides
Sulfates
Sulfide
pH
Treated process waste waters and cooling waters
1,900,000 gallons per day
Intake
72°F
50°F
A verage
Milligrams
Per Liter
4.00
0.06
0.05
0.10
3.00
3.00
19.00
3.00
7.90
Discharge
79°F
Unknown
Pounds
Per Day
63.0
.9
.8
1.6
47.0
47.0
301.0
47.0
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Discharge #002 Storm waters, chemical lab drain and overflow
from storage tank
Average Flow
Average
Temperature
Summer
Winter
Constituents:
Total Suspended
Solids
Total Chromium
Nickel
Chlorides
Sulfates
Sulfide
pH
Discharge #003
Average Flow
Average
Temperature
Summer
Winter
Constituents :
Total Suspended
Solids
Sulfates
Sulfide
PH
1,800 gallons
Intake
70°F
Unknown
Milligrams
Per Liter
10.00
0.10
0.40
2.00
5.00
2.00
7.5
Storm waters
per day
Discharge
70°
Unknown
Average
Pounds
Per Day
.15
.001
.006
.03
.07
.03
and cooling waters
100,000 gallons per day
Intake
70°F
50°F
Milligrams
Per Liter
1.0
5.0
2.0
7.6
Discharge
85°F
Unknown
Average
Pounds
Per Day
.8
4.3
1.7
Proposed determinations
The U.S. Environmental Protection Agency has examined the above
application. On the basis of applicable effluent limitations and water quality
standards, the Agency proposes to issue the applicant a permit to discharge for
five years, subject to effluent limitations and certain other conditions. The
following is a brief description of the proposed effluent limitations and special
conditions.
1. Proposed Effluent Limitations
Discharges 001, 002, 003,
a. Interim Limitations
Until September 1, 1974 (the proposed implementation schedule for
attainment of operational conditions), the applicant may discharge to
the Local River an effluent the characteristics of which shall not ex-
ceed the concentrations specified in the description of the existing dis-
charges.
b. Final Limitations
Discharges 001
After September 1, 1974, the applicant is authorized to discharge to
the Local River a final effluent whose characteristics shall at no time
exceed the following limitations:
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DISCHARGE LIMITATION
kg/day (Ibs/day)
EFFLUENT DAILY DAILY
CHARACTERISTIC AVERAGE MAXIMUM
Total Susp. Solids 4.4 (9.5) 6.5 (14.3)
Chromium, Total .06 (.14) .09 (.21)
Copper, Total .06 (.12) .09 (.18)
Iron, Total .27 (.6) .41 (.9)
Nickel, Total .11 (.24) .17 (.36)
Oil & Grease 3.2 (7.1) 4.8 (10.7)
(ii Net additions to intake
pH (All Outfalls)—6.0-8.5 Standard Units
Maximum discharge temperatures above upstream receiving waters
shall be in accordance with the following:
All Outfalls—April through November—15°F
All Outfalls—December through April—20°F
2. Proposed Schedule for Compliance
The applicant shall achieve the effluent levels described in subsection (!)
in accordance with the following schedule:
Completion of preliminary plan N/A
Final plans 3 months from date of permit issuance
Contract awarded N/A
Commencement of construction 5 months from date of permit issuance
Completion of construction lune 1, 1974
Operational level attained September 1, 1974
3. Proposed Special Conditions/Monitoring Requirements
Initially, monthly samples for total suspended solids, metals, oil and
grease and pH for Outfall 001; quarterly samples for same parameters
for Outfalls 002, 003.
After September 1, 1974, weekly samples for suspended solids, metals
(except iron), oil and grease; pH, chloride, sulfate, temperature and sulfide
shall be monitored monthly.
Applicable Effluent Limitations and Water Quality Standards
The following are the effluent and water quality standards which were
applied to applicant's discharge in the formulation of the above proposed
determinations:
Total Suspended Solids Guidelines
Chromium, Total Guidelines
Copper, Total Guidelines
Iron, Total Guidelines
Nickel, Total Application
Oil & Grease Guidelines
pH State Water Quality Standards
Temperature Local River Water Quality Standards
The stream water uses for the waters of the East Branch of the Local
River and the Local River are as follows:
Primary contact recreation
Public water supply
Well-balanced warm water fishery
Industrial water use
Agricultural use and stock watering
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APPENDIX E — Contents of a Notice for a Public Hearing
A notice of a public hearing is similar
in many details to the public notice of
an application. The regulations govern-
ing the National Pollutant Discharge
Elimination System (Federal Register,
Volume 38, Number 98, May 22, 1973)
set forth these minimum contents of a
public hearing notice:
• Name, address, and phone number of
regional office holding the hearing.
• Name and address of each applicant
whose application will be considered
at the hearing.
• Name of waterway to which each dis-
charge is made and a short description
of the location of each discharge on
the waterway.
• A brief reference to the public notice
issued for each application, including
identification number and date of
issuance.
• Information regarding the time and
location for the hearing.
• Purpose of the hearing and a brief
description of the nature of the hear-
ing including rules and procedures to
be followed.
• A concise statement of the issues
raised by the persons requesting the
hearing.
• A statement, where applicable, that
confidential information has been re-
ceived that may be used in determin-
ing some of the conditions for the
permit.
• Address and phone number of prem-
ises at which interested persons may
obtain further information, request a
copy of each draft permit or fact sheet
prepared, and inspect and copy
forms and related documents.
APPENDIX F — EPA Regional Offices
The Public Affairs Director in each Regional Office can provide assistance
and materials to individuals and groups who are seeking to work on water
pollution control problems.
Regional Offices
EPA Region I
John F. Kennedy Building
Boston, Massachusetts 02203
(617)223-7223
EPA Region II
26 Federal Plaza
New York, New York 10007
(212)264-2515
EPA Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
(215)597-9904
EPA Region IV
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
(404)526-3004
EPA Region V
One North Wacker Drive
Chicago, Illinois 60606
(312)353-1478
EPA Region VI
1600 Patterson Street
Dallas, Texas 75201
(214)749-1151
EPA Region VII
1735 Baltimore Avenue
Kansas City, Missouri 64108
(816)374-5894
EPA Region VIII
1860 Lincoln Street
Denver, Colorado 80203
(303)837-4905
EPA Region IX
100 California Street
San Francisco, California 94111
(415)556-6266
EPA Region X
1200 Sixth Avenue
Seattle, Washington 98101
(206)442-1203
States covered
Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island,
Vermont
New Jersey, New York,
Puerto Rico, Virgin Islands
Delaware, Maryland, Pennsylvania,
Virginia, West Virginia, D.C.
Alabama, Florida, Georgia,
Kentucky, Mississippi, North
Carolina, South Carolina, Tennessee
Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas
Iowa, Kansas, Missouri, Nebraska
Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming
Arizona, California, Hawaii, Nevada,
American Samoa, Guam, Trust
Territories of the Pacific, Wake Island
Alaska, Idaho, Oregon, Washington
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APPENDIX G — State Water Pollution Control Agencies
Department of Environment
Conservation
Division of Air and Water Quality
Control
Juneau. Alaska 99801
Phone: 907-586-5371
State Water Improvement Commission
State Office Building
Montgomery, Alabama 36104
Phone: 205-269-7971
Environmental Quality Commission
Government of American Samoa
Office of the Governor
Pago Pago, American Samoa 96920
Environmental Health Service
Division of Water Pollution Control
Hayden Plaza West
4019 North 33rd Avenue
Phoenix, Arizona 85017
Phone: 602-271-4656
Department of Pollution Control and
Ecology
8001 National Drive
Little Rock, Arkansas 72209
Phone: 501-371-1701
Water Resources Control Board
1416 Ninth Street
Sacramenlo. California 95814
Phone 916-445-3085
Department of Public Health
Water Pollution Control Division
4210 East llth Avenue
Denver, Colorado 80220
Phone' 303-388-6111
Department of Environmental Protection
Water Compliance Unit
State Office Building
Hartford, Connecticut 06115
Phone: 203-566-3245
Department of Natural Resources
and Environmental Control
Division of Environmental Control
Dover, Delaware 19901
Phone: 302-678-4765
D.C. Department of Environmental
Services
Bureau of Air, Water, and Noise
25 K Street NE
Washington, D.C. 20002
Phone: 202-629-3748
State Department of Pollution Control
2562 Executive Center Circle East
Tallahassee. Florida 32301
Phone: 904-488-4807
Department of Natural Resources
Environmental Proiection Division
47 Trinity Avenue S-W.
Atlanta. Georgia 30334
Phone: 404-656-4713
Environmental Protection Agency
Government of Guam
P.O. Box 2999
Agana, Guam 96910
Phone 749-9903
State Department of Health
Environmental Health Division
P- O. Box 3378
Honolulu. Hawaii 96801
Phone: 808-548-4139
Department of Environmental Protection
and Health
Air and Water Programs
Boise, Idaho 83701
Phone: 208-384-2390
Environmental Protection Agenc)
Land and Water Pollution Division
2200 Churchill Road
Springfield. Illinois 62706
Phone 217-525-6760
Stream Pollution Control Board
1330 West Michigan Street
Indianapolis. Indiana 46206
Phone: 317-633-4420
Department of Environmental Quality
Water Quality Management
Lucas State Office Building
Des Moines, Iowa 50319
Phone: 515-281-3045
State Department of Health
Division of Environmental Health
Water Quality Section
535 Kansas Avenue
Topeka, Kansas 66603
Phone: 913-296-3821
Department for Natural Resources
and Environmental Protection
Division of Water
275 East Main Street
Frankfort. Kentucky 40601
Phone: 502-564-3410
Stream Control Commission
P. O. Drawer FC
University Station
Baton Rouge, Louisana 70803
Department of Environmental Protection
Bureau of Water Pollution Control
State House
Augusta, Maine 04330
Phone: 207-289-2591
Environmental Health Administration
Division of Water and Sewerage
610 North Howard Street
Baltimore, Maryland 21201
Phone: 301-383-2740
Department of Natural Resources
Division of Water Pollution Control
101 Cambridge Street
Boston, Massachusetts 02202
Phone: 617-727-3855
Water Resources Commission
Stevens T. Mason Building
Station A
Lansing, Michigan 48926
Phone: 517-373-3560
Pollution Control Agency
Division of Water Quality
717 Delaware Street, S.E.
Minneapolis, Minnesota 55440
Phone: 612-296-5518
State Air and Water Pollution Control
Commission
Division of Water Pollution Control
P. O. Box 827
Jackson, Mississippi 39205
Phone: 601-354-6783
Clean Water Commission
P.O. Box 154
Jefferson City, Missouri 65101
Phone: 314-751-3241
Department of Health and
Environmental Science
Water Quality Bureau
Helena. Montana 59601
Phone: 406-449-2407
Department of Environmental Control
Water Pollution Control
1420 P Street
Lincoln, Nebraska 68509
Phone 402-471-2186
Department of Health. Welfare
and Rehabiliialion
Bureau of Environmental Health
201 S. Fall Street
Carson City. Nevada 89701
Phone: 702-8*2-7458
Water Supply and Pollution Control
Commission
105 Loudon Street, Prescotl Park
Concord. New HampNhire 03301
Phone: 603-271-3502
Department of Environmental Protection
P. O- Box 1390
Trenton, New Jersey 08625
Phone: 609-292-2885
Environmental Improvement Agency
Water Quality Section
Sanla Fe. New Mexico 87501
Phone: 505-827-2373
Department of Environmental
Conservation
Albany. New York 12201
Phone 5IK-457-144A
State Department of Natural and
Economic Resources
Office of Water and Air Resources
Division of Water Quality
P. O. Box 27687
Raleigh, North Carolina 27611
Phone: 919-829-4740
State Department of Health
Division of Water Supply
and Pollution Control
Bismarck, North Dakota 58501
Phone: 70l-::4-2386
Environmental Protection Agency
361 East Broad Street—Room 339
Columbus, Ohio 43216
Phone: 614-469-7785
Deputy Commissioner
for Environmental Health
Department of Health
3400 North Eastern Avenue
Oklahoma City. Oklahoma 73105
Phone: 405-427-6561
Department of Environmental Quality
Administrator of Wjter Quality
1400 S.W. Fifth Avenue
Portland. Oregon 97201
Phone: 503-229-5696
Bureau of Water Quality Management
Department of Environmental Resources
Harrisburg, Pennsylvania 17120
Phone; 717-787-2666
Environmental Quality Board
c/o Solid Waste Branch
P. O. Box 11785
Santurce, Puerto Rico 00910
Division of Water Supply and
Pollution Control
Environmental Health Services
R. I. Health Building Room 209
Providence, Rhode Island 02908
Phone: 401-277-2234
Water Pollution Control Division
Slate Pollution Control Authority
2600 Bull Street
Columbia. South Carolin.i 29201
Phone: 803-758-2915
Department of Environmental Protcclion
Room 415. Office Building 2,
Pierre. South Dakota 57501
Phone: 605-224-3141
Department of Public Health
Water Quality Control Division
621 Cordell Hull Building
Sixih Avenue. North
Nashville, Tennessee 37219
Phone: 615-741-2275
Water Quality Board
P. O. Box 13246
Capitol Station
Austin. Texas 78711
Phone: 512-475-2651
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Department of Health Services
Division of Environmental Health
Trust Territory of the Pacific Islands
Saipan, Mariana Islands 96950
Bureau of Environmental Health
Water Quality Section
44 Medical Drive
Salt Lake City, Utah 84113
Phone: 801-328-6146
Agency of Environmental Conservation
Montpelier, Vermont 05602
Phone: 802-828-3357
State Water Control Board
P. O. Box 11143
Richmond, Virginia 23230
Phone: 804-770-2241
Commissioner of Health
Department of Health
P. O. Box 1442
Charlotte Amalie
St. Thomas, Virgin Islands 00801
Phone: 809-774-1321
Department of Ecology
Olympia. Washington 98501
Phone: 206-753-2800
Division of Water Resources
Department of Natural Resources
1201 Greenhrier Street
Charleston, West Virginia 25311
Phone: 304-345-2107
Department of NaturaJ Resources
Division of Environmental Protection
Madison, Wisconsin 53701
Phone: 608-266-2747
Department of Hcnllh and Social Services
Sanitary Engineering Service1. Department
State Office Building
Cheyenne, Wyoming 82001
Phone: 307-777-7513
The reader is free to quote or reproduce any part
of this publication without further permission.
•&U.S. GOVERNMENT PRINTING OFFICE: 1973 546-312/140
For sale by Superintendent of Docs. U.S. GPO.
Washington, D.C. 20402. Price 50 cents.
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