United States Office of Water June 1982
Environmental Protection Washington, DC 20460
Agency
v>EPA Office of Water Operating
Guidance and Accountability
System
Fiscal Year 1983
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TABLE OF CONTENTS
Page
I. INTRODUCTION 1
A. Purpose 1
B. Summary 1
II. NATIONAL PROGRAM DIRECTIONS IMPLEMENTATION 5
A. Clean Water Act 5
1. Overview 5
2. National Program Directions 8
a. Water Quality Management Planning .... 8
b. Monitoring 9
c. Water Quality Standards 11
d. Priority Waterbodies 12
e. Total Maximum Daily Loads/
Wasteload Allocations (303(d)) 13
f. Advanced Treatment Reviews 14
g. State Delegation 16
h. Construction Grants Management 17
i. Financial Management Capability 19
j. Permitting 21
k. Compliance 24
B. Safe Drinking Water Act 26
1. Overview 26
2. National Program Directions 27
a. Public Water Systems Supervision
Program 27
b. Underground Injection Control
(UIC) Program 28
C. Ocean Dumping and Discharge Regulation 29
1. Overview 29
2. National Program Directions 30
a. Marine Protection Strategy 30
b. Section 301(h) Waivers 32
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TABLE OF CONTENTS (continued)
Page
D. Ground Water Protection Policy 33
1. Overview 33
2. National Program Direction 34
a. Ground Water Protection Policy and
Coordination 34
III. ACCOUNTABILITY SYSTEM 37
A. Purpose 37
B. Relationship to Administrator's Management
Accountability System 37
C. Structure 37
D. FY 1983 Implementation Process 38
IV. OFFICE OF WATER FY 1983 FUNDING POLICY 41
A. Clean Water Act 41
B. Safe Drinking Water Act 42
APPENDIX A -- ACTIVITIES AND REPORTING MEASURES A-l
APPENDIX B DEFINITION OF TERMS B-l
APPENDIX C -- LIST OF ABBREVIATIONS C-l
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I INTRODUCTION
A. Purpose
The Office of Water Operating Guidance and Accountability
System for FY 1983 serves the following three major functions:
(1) provides national program directions for implementation; (2)
establishes a basis for the negotiation of grant funds between
Regions and States; and (3) outlines the measures that will be
used by Headquarters for accountability purposes.
This guidance does not cover all activities necessary for pro-
gram implementation; it concentrates only on national priorities.
This guidance does cover a wide range of activities, and States
are not expected to address every national priority. Rather,
Regions and States should use this guidance as they negotiate FY
1983 work programs and should address those priorities applicable
to their own situation.
EPA recognizes the ability of Regional and State program
managers to operate their continuing base level water quality
programs, but expects that a portion of Federal grant funds will
be directed toward the national program directions covered in
this guidance. The national program directions are the only
activities Headquarters will track for accountability purposes.
These national program directions are also the areas the Regions
and States may choose to address if they are preparing FY 1983
State/EPA Agreements.
B. Summary
Clean Water Act
In FY 1983, several major activities will take place as the
Office of Water, along with the Regions and States, implements the
Clean Water Act. There will be a continued emphasis on State
assumption and maintenance of programs. Greater attention will be
placed on adequate planning in advance of water quality decision-
making. Since technology-based controls will largely be estab-
lished, States are expected to examine their programs for making
water quality based decisions through standards attainability
analyses, ranking priority waterbodies, and conducting total
maximum daily load calculations under section 303(d). Implementing
the water monitoring strategy will help ensure the effectiveness
of water quality standards and the water quality based approach.
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In coordination with up-front planning, EPA is stressing the
importance of ensuring the financial capability of grantees to
achieve implementation and to produce environmental results. The
construction grants program will stress improved management,
restoration of uses, and reorientation of the project priority
list toward priority waterbodies. The Agency will continue to
review advanced treatment projects to determine whether they will
result in significant water quality improvements.
With the issuance of effluent guidelines and the development
of water quality based information, there will be an emphasis on
reducing the number of expired industrial permits. The overriding
principles for issuance of National Pollutant Discharge Elimina-
tion System (NPDES) permits are that they be based on good science,
they be of lasting value and not subject to frequent change, and
that ample opportunity for input is provided. These principles
are included in the second round permitting policy which further
clarifies how the principles apply to industrial dischargers whose
permits are in need of renewal or possible modification. In FY
1983, EPA will also seek to improve the compliance rate,
particularly for municipal dischargers.
Safe Drinking Water Act
The continuing priorities in FY 1983 under the Safe Drinking
Water Act are the Public Water Systems Supervision program and the
Underground Injection Control (DIG) program.
In the Public Water Systems Supervision program, EPA has three
major priorities for the Regions and States: (1) to extend the
coverage of the trihalomethane (THM) regulation to systems serving
10,000 to 75,000 people and to ensure that the microbiological
quality of the water is fully protected in the process; (2) to
respond effectively to incidents of the detection of significant
ground water contamination with unregulated contaminants; and (3)
to continue to improve compliance by small systems with the exist-
ing standards, giving highest priority to the most serious threats
to public health.
In the Underground Injection Control program, the major FY
1983 priorities are: (1) to encourage additional States to assume
primacy (primary enforcement responsibility); (2) to begin direct
implementation by EPA in non-primacy States and on Indian lands;
and (3) to provide oversight and assistance to primacy States as
needed.
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Ocean Dumping and Discharge Regulation
In FY 1983, EPA Regions will assume the responsibility of
reviewing applications for and issuing 301(h) waiver permits.
This activity will be based on technical studies performed at the
Headquarters level for the 70 communities which prepared final
applications. In addition, the 1981 amendments to the Clean Water
Act removed several prohibitions in EPA's 301(h) regulations and
reopened the application process to additional coastal communi-
ties. This will greatly increase EPA's workload, and will require
a re-evaluation of Agency resources for this activity.
In FY 1983, under the Marine Protection Research and Sanctu-
aries Act (MPRSA) EPA Regions will implement revised ocean dumping
regulations. The Agency can expect some increase in applications
for ocean dumping of materials which pass the scientific criteria.
Also, as a result of the recent Sew lork City v. EPA court deci-
sion, the Agency will no longer automatically prohibit dumping of
materials which fail the criteria but will need to consider the
environmental consequences and need for ocean disposal versus the
environmental consequences and costs of land-based disposal alter-
natives. This decision has added impetus to the scientific review
of the current testing and monitoring procedures, including a con-
sideration of modifications to the regulation's bioassay test
procedures.
In FY 1983, EPA Regions will assume the responsibility for
reviewing applications for and issuing 301(h) waiver permits.
Ground Water Protection Policy
In FY 1983, EPA will implement a new ground water protection
policy. This policy will call for major efforts to enhance the
coordination of EPA and State activities to protect ground water
quality through the implementation of the Clean Water Act, Safe
Drinking Water Act, Resource Conservation and Recovery Act, the
Underground Injection Control program, Superfund, and related
programs.
Accountability
The activities that will be tracked in the Office of Water
Accountability System are based on the national program directions
highlighted above and covered in detail in Section II. The Office
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of Water will provide direct input to the Administrator's Manage-
ment Accountability System. All of the major water program direc-
tions of the Administrator's System are reflected in the Office of
Water System; for example, State delegation and management of the
construction grants program.
Funding
Using the available funding sources, States and local govern-
ments should develop and maintain a base level water quality pro-
gram. Each State should define its base program depending upon
its individual situation. While EPA recognizes the need to main-
tain a base level program, States should direct a portion of their
available resources toward priority waterbodies to undertake the
water quality planning activities necessary to make implementation
decisions.
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II NATIONAL PROGRAM DIRECTIONS - IMPLEMENTATION
The following section discusses national program directions
within the Office of Water. This section is organized by statu-
tory act or major policy area. Each program direction includes
a brief background discussion and then lays out FY 1983 Regional/
State activities and Headquarters activities. Each Headquarters
activity is referenced to a specific quarter in FY 1983 in which
it will be complete or available.
A. Clean Water Act
1. Overview
The Clean Water Act recognizes that it is the primary respon-
sibility of the States to prevent, reduce, and eliminate water
pollution. The States determine the desired uses for their
waters; set standards; identify current uses; and, where uses
are being impaired or threatened, develop plans for the protection
or restoration of the designated use. States implement the plans
through control programs such as permitting, enforcement, construc-
tion of municipal wastewater treatment works, -and nonpoint source
control practices. The Act also calls for the reliance on tech-
nology-based effluent limitations for control of industrial and
municipal point sources of water pollution. If designated uses
will not be attained through the technology limits established, the
States must either seek a greater level of control or re-examine
the attainability of designated uses.
EPA is dedicated to and recognizes the importance of complet-
ing guidelines for uniform technology-based controls. Under this
technology-based approach, the Agency establishes standards for
major industries discharging directly into navigable waters or
indirectly into publicly-owned treatment works (POTWs) by issuing
standards based on best practicable technology (BPT), best avail-
able technology economically achievable (BAT), best conventional
technology (BCT), as well as new source performance standards
(NSPS), and pretreatment standards for new and existing sources.
EPA has completed most of the technical and economic studies which
provide the basis for these effluent guidelines, and EPA plans to
promulgate guidelines for all major industries by 1984.
Along with completion of its effort to establish the uniform
technology-based BAT guidelines, EPA will emphasize the implemen-
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tation of a water quality based approach to pollution control. A
water quality based approach will allow States to focus on their
priority waterbodies and to provide adequate water quality protec-
tion beyond what will be achieved through technology-based
controls. Where designated uses are being attained, EPA maintains
its anti-degradation policy. .In re-emphasizing a water quality
based approach, certain basic questions must be considered:
1. What is the use to be protected?
2. To what extent does pollution contribute to the
impairment of the use?
3. What is the level of point source pollution con-
trol necessary to restore or enhance the use?
4. What is the level of nonpoint source pollution
control necessary to restore or enhance the use?
Answering these questions is critical to defining what is
actually meant by the terms "use" and "water quality problem" and
to developing plans to resolve problems. States and locals should
understand and utilize the answers to these questions as they
undertake their water quality based approach. In undertaking this
approach, States must first identify water quality limited water-
bodies under section 303(d) and prioritize these waterbodies,
taking into account the severity of pollution and the uses of the
water. This priority ranking provides a framework within which
States can consider their most pressing water quality needs and
identify subsequent water quality management (WQM) activities
necessary to meet their water quality goals.
Following this priority ranking, States should define their
water quality goals by setting attainable standards for their
waters under section 303(c). In FY 1983, EPA is encouraging
States to select priority waterbodies or segments for review,
rather than review all State water quality standards every three
years. In FY 1983, the Agency also encourages development of
site-specific criteria, by which a State may modify the EPA
laboratory-derived section 304(a)(l) criteria to reflect local
environmental conditions. States may also conduct a use attain-
ability analysis to fully consider the environmental and economic
factors impacting the attainment of their water quality standards.
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Once standards are set, States should prepare wasteload alloca-
tions (WLAs) and total maximum daily loads (TMDLs), emphasizing
priority segments first.
Using the information generated in setting water quality
standards, the States will certify or issue National Pollutant
Discharge Elimination System (NPDES) permits. In developing and
issuing permits, permit writers should use the following three
principles: (1) permits are of lasting value; (2) permits are
based on good science; and (3) ample opportunities for input are
provided. Permit limits are based on effluent guidelines., on
total maximum daily loads and wasteload allocations, and on best
professional judgment where national standards are not estab-
lished. The two largest implementation problems for the NPDES
permit program are: (1) the volume of permits that need to be
reissued; and (2) the uncertainty involved in developing BAT
limits in the absence of promulgated guidelines. EPA has devel-
oped a second round industrial permitting strategy to address
these implementation problems. The second round permitting
strategy focuses on issuing permits where BAT guidelines have
been issued or will never be issued and in areas with known or
suspected impairment of use attributable to water pollution.
Permits should also be issued where serious violations are
obviously occurring.
Monitoring is the basis for the above mentioned activities.
EPA is developing a monitoring strategy which will place greater
attention on: (1) generating a data base adequate to support
critical decisions; (2) encouraging local government and industry
involvement in data gathering; (3) increasing EPA's involvement in
technical guidance and support; (4) encouraging the use of selec-
tive biological surveys as opposed to widespread chemical sampling;
and (5) measuring the results of clean-up programs. The principal
objective of the monitoring strategy is to develop and use data to
set standards and treatment requirements where costs bear a reason-
able relationship to benefits on a site-specific basis. The
section 305(b) report will be the basic document identifying each
State's water quality status and needs. The 305(b) report will
also enable States and EPA to monitor progress toward achieving
water quality goals and environmental results.
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2. National Program Directions
a. Water Quality Management Planning
The revised Water Quality Management (WQM) regulations (Part
130) will stress the continued importance of the planning process
in water quality decision-making. The planning process outlined
in the Clean Water Act provides a framework for water quality
decison-making.
Each State should develop its planning agenda based upon its
individual planning needs for its priority waterbodies. States
should coordinate with designated areawide agencies while
designing their planning agenda. The two major emphases for FY
1983 in planning are: (1) the examination by States of their
continuing planning process (CPP) document; and (2) utilization of
WQM plans, through consistency reviews, to make proper
implementation decisions.
Regional/State Activities
In FY 1983, States and Regional Offices will ensure that the
planning process is properly described and operational.
o States should update their CPP as necessary,
giving special attention to the following
process descriptions:
-- determining priority waterbodies
-- identifying water quality limited segments
-- conducting TMDLs and WLAs
-- revising water quality standards
-- conducting water quality monitoring activities
and developing monitoring strategies
-- developing the construction grants priority
list
reviewing NPDES permits and construction grant
awards for consistency with WQM plans
-- completing the FY 1984 305(b) report.
o Regions and States should agree upon the process by
which WQM plans will be used to review NPDES permit
and construction grant decisions. Areawide agencies with
certified and approved plans must be afforded a consistency
review as part of their planning commitment. If the
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areawide plan is silent on this review, the State
should carry-out the consistency review.
Regions and States should continue to develop and
implement nonpoint source controls programs in priority
waterbodies.
Headquarters Activities
In FY 1983, Headquarters will:
Provide guidance to assist States in updating their
CPPs. (First Quarter)
Coordinate WQM-related guidance to assure consistency
with the revised WQM regulations and this document and
clarify interrelationships of such guidance. (First
Quarter)
b. Monitoring
EPA and the States must ensure that environmental decisions
are based on sound scientific data and information. EPA believes
that the amount of good quality, local site-specific information
will be strongly influenced by the degree to which local partici-
pants, including areawide agencies, municipalities, and the
regulated community, are involved in the design and implementation
of monitoring programs. Therefore, EPA Headquarters, with assis-
tance from Regional and State staff, is developing a water
monitoring strategy which will greatly improve the quality of
information available for water quality decisions and will make
more effective use of local. State, and Federal resources for
collecting, analyzing, and interpreting monitoring data. This
strategy will stress the following changes to existing State
monitoring programs: (1) an emphasis on biosurveys and bio-
assays to facilitate the analysis of impaired aquatic life uses;
(2) increased emphasis on local participation in the design and
implementation of monitoring programs; (3) increased use of
intensive surveys to help analyze causes and effects of water
quality problems; and (4) decreased emphasis on routine ambient
chemical-by-chemical monitoring.
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Regional/State Activities
In FY 1983, the States, with assistance from EPA Regional
Offices, should:
Develop and implement monitoring strategies to
make the best use of limited monitoring resources
and to collect the information needed for developing
realistic site-specific controls. The strategies
should address: (1) identifying priority waterbodies;
(2) collecting data to make water quality standards
and TMDLs/WLAs decisions; and (3) establishing coopera-
tive sampling and analysis programs with local, State,
and Federal participants.
t Participate with EPA Headquarters in revising the
Basic Water Monitoring Program.
Agree with the Regional Office on the format and
content of the State section 305(b) reports due
April 1, 1984.
Implement quality assurance procedures.
Headquarters Activities
In FY 1983, EPA Headquarters will:
Complete its revision of user-oriented guidance, the
Basic Water Monitoring Program, to assist States in
managing their water monitoring programs. (Third
Quarter)
Provide technical guidance and assistance for local
cooperative sampling programs. (Third Quarter)
Provide guidance on the use of the Aquatic Life Survey
and other approaches to assist in preparing section 305(b)
reports and other requirements. (Second Quarter)
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c. Water Quality Standards
The implementation of a revised water quality standards
regulation will provide a general mechanism for the States to use
in integrating programs authorized by the Clean Water Act. The
"Municipal Wastewater Treatment Construction Grant Amendments of
1981" link construction grant decisions to water quality standards
by requiring that after December 1984, a State must complete its
revision of the water quality standard for any segment affected by
a construction grant before the grant is awarded. The changes in
the water quality standards program will provide a general process
for determining the attainable uses of a waterbody, will be
scientifically based, and will also give States increased
flexibility to consider both economic and environmental factors
relating to the attainment of designated water uses. Once a State
determines that a use is being attained, that use cannot be
lowered. The result of these efforts will be to more effectively
direct public and private funds for environmental clean up.
Regional/State Activities
In FY 1983, States and Regional Offices will implement the
revised water quality standards regulations.
Regions and States will analyze the attainability of uses
based on environmental, technical, and economic factors.
Regions and States will review and possibly modify the
existing water quality standards for priority waterbodies.
States must develop and adopt a Statewide anti-degradation
policy to maintain those water uses which are currently
being attained.
Headquarters Activities
In FY 1983, EPA Headquarters will continue to implement the
revised water quality standards regulation by assisting the States
and Regional Offices in determining attainable water quality
standards for specific sites through guidance documents and water
quality standards reviews. Headquarters will:
Provide guidance and technical assistance for designating
appropriate attainable uses (including environmental
benefits assessments) and for developing criteria, pro-
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tective of these uses, which reflect local environmental
conditions. (Second Quarter)
Develop guidance for conducting waterbody surveys and
assessments for analyzing the attainability of uses.
(First Quarter)
Issue sediment criteria identifying harmful levels of
pollutants in sediment which would be released into the
aquatic environment and impair water quality uses.
(Fourth Quarter)
d. Priority Waterbodies
The States and EPA need to focus their attention and resources
on those waterbodies which: (1) have the greatest water quality
problems in terms of impaired water uses; (2) have a high existing
or potential economic or social value; and (3) provide the greatest
margin of environmental protection for the resources expended.
Priorities may include segments where advanced treatment and
combined sewer overflow funding decisions are pending, permit
revisions are scheduled or toxics have been identified or are
suspected of precluding a use and are posing an unreasonable risk
to human health. This prioritization will enable the States and
EPA to assure that water quality based control decisions in these
areas, including standards setting, planning, and permitting, are
made on the basis of sound scientific data. States, through their
negotiations with EPA Regions concerning their CPP and their
sections 106 and 205(j) work programs, should update and submit a
list of priority waterbodies within the State which will receive
attention for water quality based controls. This list will be
included in the States' CPP submissions and section 305(b) report.
The list will be used to set priorities for: (1) collection of
field data needed to make decisions; (2) revision of water
quality standards; (3) establishment of TMDLs/WLAs; (4) issuance
of water quality based permits; and (5) construction grants.
Regional/State Activities
In FY 1983, the States, with assistance from EPA Regional
Offices, will:
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Identify and prioritize waterbodies using the 305(b)
report where possible. These lists should be submitted
to EPA to aid in the prioritization of the FY 1984
State and EPA activities.
Headquarters Activities
In FY 1983, EPA Headquarters will provide guidance and
technical assistance to Regions and States, including:
Completion of technical guidance on techniques which
may be useful for screening and identifying water
quality limited waterbodies. (Third Quarter)
Provide limited assistance in the use of the River Reach
File and the Aquatic Life Survey to help organize
information on waterbodies in a format useful for screen-
ing and priority ranking. (On-going)
t Assist Regions and States in addressing significant water
quality and public health concerns, particularly showing
progress to date in priority waterbodies and measuring
future improvements. (On-going)
e. Total Maximum Daily Loads (TMDLs)/Wasteload
Allocations (WLAs) (303(d))
The development of TMDLs is a key step in the process of
planning for appropriate levels of controls to achieve designated
uses. EPA is reasserting this basic requirement of section 303(d)
because it strongly believes that the data collection and analysis
to produce TMDLs and WLAs provide the primary information needed
to answer three of the basic questions posed in the overview: To
what extent does pollution contribute to the impairment of the use?
To what extent will control of pollution from point sources restore
or enhance the use? From nonpoint sources? Section 303(d)
provides the overall planning context which enables the States to
develop reasonable permit limits derived from water quality
criteria necessary to meet designated uses. Alternative forms of
setting limitations, such as the use of biological monitoring as a
surrogate, can be developed.
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Regional/State Activity
In FY 1983, the States, with assistance from the Regions,
should undertake the following activities:
Conduct TMDLs/WLAs in priority waterbodies.
States, working with the Regional Offices, are encouraged
to update their CPP to cover:
a description of the States' process for conducting
TMDLs/WLAs, including public involvement
an agreement on the Regional Office review role
-- a schedule of implementation, based upon priority
waterbody determination
integration of the State implementation of TMDLs/
WLAs, where the Region is the permitting authority
-- a description of other accepted methods for setting
discharge limits, including bio-monitoring.
Identify the extent uses are being impaired by point
and nonpoint sources.
Headquarters Activities
In FY 1983, EPA Headquarters will continue to:
Issue detailed technical guidance on conducting TMDLs/WLAs,
including guidance for toxic pollutants. (First Quarter)
Issue guidance for use of biological monitoring in setting
permit conditions. (Third Quarter)
f. Advanced Treatment Reviews
In response to Congressional direction, the Agency conducts
reviews of Advanced Treatment (AT) projects to determine whether
proposed AT projects will result in significant water quality
improvements. During FY 1983, the Agency will conduct the AT
reviews in accordance with the revised AT Review Policy, which
reflects the Agency experience over the past three years in
conducting AT reviews. Before grants are awarded for AT projects,
justification criteria contained in the new policy must be met,
including an assessment of the significance of the water quality
improvements that takes into account the designated use being
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impaired, the effect point source pollutants have on the impair-
ment of the use, and the contributions toward restoration of the
use that the project will make. AT reviews will ensure that
significant improved uses of receiving waters will result from
funded AT projects, while avoiding unnecessary municipal and
Federal expenditures when reasonable benefits cannot be
demonstrated.
Regional/State Activities
In FY 1983, the Regions and States will:
t Identify municipal dischargers that will require the
construction of AT facilities, based on identified water
quality limited stream segments.
Determine a need for revised WLAs and establish a
priority ranking for those stream segments. Notify
potential grantees of pending WLA revisions and pro-
vide an opportunity for the grantee to develop
scientific site-specific data to support the proposed
effluent limitations.
Conduct AT project reviews for projects with incremental
AT costs of less than $3 million in accordance with the
revised AT Review Policy.
Submit AT projects with incremental AT costs of greater
than $3 million to Headquarters in a timely fashion.
Conduct analyses of water quality improvements from AT
facilities, under a program of "before and after"
studies.
Headquarters Activities
In FY 1983, Headquarters will:
t Review all AT projects with incremental AT costs of
greater than $3 million. (On-going)
Evaluate Regional and State AT project reviews under
the revised AT Review Policy for consistency. (Third
Quarter)
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Issue methodology for reviewing and revising existing
AT permits. (First Quarter)
Issue guidance and coordinate analyses of water quality
improvement from AT facilities, under a program of
"before and after" studies. (Second Quarter)
Issue updated technical guidance for use by Regions
and States in analyzing and justifying AT projects.
(Third Quarter)
g. State Delegation
A central feature of EPA's management approach is to transfer
authority and program responsibilities to the States. Encouraging
State implementation is a central element in EPA's philosophy of
dealing with water quality problems closer to the level where they
exist, thereby enhancing not only the knowledge of the problem but
also the concern for improvements. EPA is revising the NPDES
program approval regulations to simplify equivalency requirements
and to provide more flexibility.
Regional/State Activities
In FY 1983, Regions must continue to work with the States to
identify and remove remaining barriers to State assumption and
maintenance of programs.
Working with the States, the Regions should develop a
strategy to assist States in assuming and maintaining
program delegation for all programs by expediting pro-
gram development, review, and approval processes.
This should include an analysis of the impacts of the
new regulations.
In the NPDES program, the Regions should work to approve
State program submissions requesting full NPDES program
administration and work to approve program modifica-
tion requests for implementing the pretreatment and
Federal facilities programs.
t Regions are expected to complete delegation of all
construction grant activities which may be delegated
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to the States or assign them to the Corps of Engineers
(COE)in 25 States.
Headquarters Activities
Headquarters will undertake a number of activities to assist
Regions and States in the transfer of program authority. Head-
quarters will:
Revise and implement the permit regulations to provide
more flexibility for States to receive program authoriza-
tion. (Fourth Quarter)
t Implement a fast track program approval procedure for
NPDES. (Fourth Quarter)
Develop, with Region and State participation, a policy
statement on roles and responsibilities under delega-
tion, including Office of Water oversight guidelines.
(Second Quarter)
In coordination with this document and the Accountability
System, perform national oversight of construction grant
State delegation consistent with the revised 205(g)
regulations. (On-going)
Provide guidance to the Regions on the extent and
structure of State delegation and oversight. (Second
Quarter)
h. Construction Grants Management
During FY 1983, EPA will continue the FY 1982 environmental
and management emphasis for the construction grants program to
implement the Clean Water Act amendments and new Agency management
initiatives. The regulations and guidance for the 1981 amendments
will be completed in FY 1982, with full implementation in FY 1983.
Major emphasis will be placed on water quality/public health
improvements and restoration of uses in project priority and fund-
ing decisions. There will be a shift of major management responsi-
bility to the States, as well as a reorientation of Federal, State,
and local management activities to reflect the 1981 amendments and
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management initiatives, particularly in the areas of the elimina-
tion of Step 1 and 2 grants, fulfilling National Environmental
Policy Act (NEPA) requirements and meeting the 45-day EPA review of
grants. The Agency will be emphasizing results-oriented management
and efficient use of EPA, State, and Corps of Engineers resources.
Regional/State Activities
In concert with the water quality standards, water quality
management, and permit programs, a coordinated program of improving
water quality/public health in critical waterbody areas involving
municipal wastewater treatment funding will be implemented.
Specific priority activities are as follows:
Develop Regional/State agreements to identify phased/
segmented projects and State funding strategies.
Develop a method for implementing Regional and State
programs to:
-- utilize Corps of Engineers resources fully and
effectively
-- eliminate the backlog of projects in need of
completion and closeout
manage obligations and outlays
-- address Federal grant award responsibilities,
including NEPA, innovative/alternative technology
program, and advanced treatment projects
-- complete 45-day approval of grants
-- bring all completed facilities into compliance
with design/permit requirements within one year
of construction completion.
§ Ensure selection of affordable and operable technologies
for small communities taking into consideration the revised
treatment definition for secondary.
Implement procedures to maintain program integrity (i.e.,
prevent waste, fraud, and mismanagement in the program).
Review and revise State construction grant priority
systems to ensure incorporation of State's priority
waterbodies.
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Office of Water Operating Guidance and Accountability System
t Identify priority waterbodies where existing impaired
uses may be improved significantly by municipal
construction.
Headquarters Activities
The Headquarters activities primarily involve national
management, oversight, and assistance to Regions and States.
Specific activities are as follows:
Provide national management of obligations and
outlays. (Monthly)
t Provide national management of procedures to eliminate
backlog in the program (i.e., completions/closeouts,
audits, change orders, claim resolution). (Quarterly)
t Oversee programs to ensure technologically appropriate
projects, including effective use of I/A and small
community setasides. (On-going)
0 Issue guidance for reviewing, revising, and developing
priority systems and lists. (First Quarter)
Provide oversight/assistance on phased/segmented
projects and other Step 2+3/3 assistance to Regions/
States. (On-going)
i. Financial Management Capability
The construction and operation of a wastewater treatment
facility to meet the enforceable requirements of the Clean Water
Act is often the largest capital improvement and public enterprise
undertaken by a community. Financial issues related to costs,
revenues, structure of the financing, debt recovery, expansion, and
impact on users are critical to the successful operation of the
treatment works and the achievement of intended environmental
results.
The Clean Water Act requires applicants for construction grant
awards to have the "... managerial and financial capability to
ensure adequate construction, operation, and maintenance of treat-
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Office of Water Operating Guidance and Accountability System
ment works throughout the applicant's jurisdiction, as determined
by the Administrator." The requirement for applicants to demon-
strate financial management capability is in the construction
grants regulations. To implement this requirement the Agency has
drafted a policy statement on financial management capability that
affects proposed projects, projects under construction, and opera-
tional facilities. One major purpose of the policy is to ensure
that grantees are aware of a project's costs and its financial
impacts on the community and its residents before applying for a
grant for building municipal treatment works. Also, if an opera-
tional treatment plant is in significant non-compliance with its
NPDES permit, the State may review the adequacy of the operator's
revenue system. Applicable laws and regulations must also be
followed when acquiring real property for projects receiving
Federal funds.
Regional/State Activities
The States will have the primary responsibility for assuring
the demonstration of financial management capability. Draft work-
sheets and guidance have been prepared concurrently with the policy
statement.
States should modify the worksheets to more fully meet
their needs to tailor national guidance in accordance with
States statutes.
Regions and States should conduct reviews of all Step 3
grantees and make a determination that the applicant has
demonstrated financial and management capability to
construct, operate, and maintain the proposed facilities.
Regions and States should screen all PL 92-500 facilities
under construction or operational and all projects pro-
posed for Step 3 funding, 1 MGD and less to assess appro-
priateness of technology.
Regions and States should notify all grantees of the
financial management capability policy and subsequent
demonstration.
Regions and States should screen and review all projects
calling for land acquisition for adherence to Federal
laws.
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Office of Hater Operating Guidance and Accountability System
Headquarters Activities
EPA Headquarters will focus on providing assistance to Regions
on financial management issues and evaluating Regional performance.
Headquarters will:
Review Regional/State land acquisition activities.
(Third Quarter)
Prepare guidance further defining Regional roles/
responsibilities, and conduct additional workshops/seminars
on financial management capability, as resources permit.
(Third Quarter)
t Assist with identifying and trouble-shooting high-cost
projects. (On-going)
Disseminate information on appropriate technologies
for small communities. (On-going)
j. Permitting
In FY 1983, EPA and the States will be faced with a number of
competing needs, including: (1) issuance of permits to protect the
environment; (2) removing the legal vulnerability of dischargers
from expiring permits (especially where NPDES States do not have
provisions to extend expired permits); (3) reducing uncertainties
of permit requirements and timing for permit issuance; and (4)
developing permits that reflect good science and limitations that
will not be subject to frequent change. In addressing these needs,
the permit should represent the final step in a series of actions
and considerations including, for example, BAT guidelines promulga-
tion and a thorough analysis of waterbodies with suspected or
actual water use impairment.
EPA recently completed a detailed policy for second round per-
mitting. This policy requires the use of procedures reflecting the
best science available. Major emphasis is placed on development of
a priority listing of industrial facilities discharging to areas
where water impairment exists or is suspected. Permits in areas
where water use impairment is known should be issued expeditiously.
Regions and States should also address areas where water use
impairment is suspected. In these areas, additional chemical and
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Office of Water Operating Guidance and Accountability System
biological monitoring requirements may be required in permits, and
a more thorough analysis of water use impairment must be made.
Once sufficient information exists, permit limitations should be
developed and the permit modified accordingly. As BAT guidelines
are promulgated in FY 1983, permits should also be issued to
reflect these requirements. In addition to this major emphasis
placed on industrial permitting, it will also be necessary to focus
on modification, as appropriate, of municipal permits to reflect
the amendment to section 301(i) of the Clean Water Act, to reflect
the new definition of secondary treatment, and to implement the
pretreatment program. We are also encouraging the Regions and
States to use general or areawide permits, where appropriate, to
cover many facilities with similar operations and waste-stream
discharges.
Permits are a management tool to ensure that municipalities are
moving forward on a schedule to meet the enforceable provisions of
the Clean Water Act. Special attention will be given to
coordinating municipal permit compliance schedules with grant
agreements and conditions and in tracking the grantee's progress
according to these schedules.
Regional/State Activities
Industrial Permits
t Regions will work with States to develop and update, as
necessary, a strategy to reduce the number of expired
permits, which includes priority lists for industrial
permit reissuance by NPOES States.
Regions and States will issue permits in accordance with
the priority lists and promulgated effluent guidelines.
Regions will issue general permits, as appropriate, to
facilities with similar discharges and monitoring
needs.
States will develop and/or modify second round per-
mitting strategies by the end of FY 1983 to address
FY 1984 permit issuance.
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Office of Water Operating Guidance and Accountability System
Municipal Permits
In early FY 1983, Regions will develop priority lists
of those permits requiring modification or issuance by
EPA.
Regions will work with States to develop priority lists
of those permits requiring modification of issuance by
NPDES States.
To the extent possible, Regions will modify municipal
permits to reflect 301(i), revised secondary treatment
definition, and required pretreatment schedules.
Regions should ensure that technically sound water quality
based permits are issued for AT facilities.
Regions and States will coordinate schedules for construc-
tion with permit compliance schedules to ensure consistency
and track implementation progress.
Headquarters Activities
Industrial
Headquarters will expedite procedures for general permit
promulgation and will develop a national model for general
permits for appropriate industrial categories. (First
Quarter)
Headquarters will continue to develop and promulgate
effluent guidelines for major industries in FY 1983.
(On-going)
Headquarters will provide technical guidance and
assistance to Regional and State permit writers in
interpreting the guidelines. (On-going)
Municipal
Headquarters will revise the definition of secondary
treatment to incorporate changes mandated by the 1981
amendments. (Second Quarter)
Headquarters will provide guidance and assistance to
Regions and States concerning the implementation of
the general pretreatment program, especially in response
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Office of Water Operating Guidance and Accountability System
to the Regulatory Impact Assessment (RIA) recommendations,
(Second Quarter)
k. Compliance
A major emphasis is to improve the compliance rate for munici-
pal permittees. This effort will focus on implementing the Munici-
pal Compliance Improvement Strategy (MCIS). The major emphasis is
to assure that federally funded treatment facilities are operated
and maintained properly and, in the case of non-compliance, that
muncipalities take adequate steps to correct design or other defi-
ciencies. EPA has the responsibility to assure that all municipal-
ities involved in the construction grants program are adequately
prepared to manage the operation and maintenance of their newly
constructed facilities in compliance with applicable NPDES permit
requirements throughout the useful life of the facility. Where
significant non-compliance persists, administrative enforcement
and, if necessary, formal enforcement action should be initiated.
I
Also of importance will be to maintain, or improve, the
relatively high compliance rate of industrial dischargers and to
track compliance and take appropriate enforcement action to ensure
compliance with schedules in newly issued second round industrial
permitting.
Regional/State Activities
a Regions will work with States to develop State-by-State
compliance strategies, including plans for inspections
and follow-up instances of non-compliance.
Regions will increase use of administrative enforcement
tools to resolve instances of non-compliance where other
assistance/administrative actions are unsuccessful.
(In this regard, special attention will be given to the
Municipal Compliance Improvement Strategy.)
Regions will develop referrals for court action and
provide technical support on enforcement litigation
where negotiations and administrative enforcement do
not result in compliance.
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Office of Hater Operating Guidance and Accountability System
Regions will maintain and improve the quality of data
in the Permit Compliance System (PCS) which will be used
as the official source of information on the status of
NPDES permits.
Regions will provide guidance to States on the operations
and maintenance (O&M) provisions of 1981 amendments
(principally performance certification) and assist States
to establish or improve O&M programs.
Regions will selectively audit State Management Systems
developed under the Enforcement Management System (EMS),
the Municipal Management Strategy (MMS), and any other
compliance-related activities.
Regions will track performance of newly completed
grant funded publicly owned treatment works (POTWs)
for the first year of operation.
Headquarters Activities
Headquarters is responsible for national management of
compliance-related activities providing guidance and oversight of
Regional and State programs. Headquarters will:
Provide guidance to assist the Regions in increasing the
effectiveness of compliance inspections to improve the
enforcement presence. (Second Quarter)
Provide guidance to Regional Offices and States regarding
performance aspects of the construction grants program,
including engineering performance certification issues to
improve compliance. (Third Quarter)
Participate in the Office of Research and Development
(ORD) program to provide feedback on POTW design problem
information to Architectural/Engineering firms. (On-
going)
Selectively audit Regional Enforcement Management System
(EMS) and other NPDES compliance and administrative
enforcement activities. (On-going)
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Office of Water Operating Guidance and Accountability System
Provide guidance on how to deal with compliance and
enforcement of existing permits in light of a revised
definition of secondary treatment. (Dependent upon
issuance of revised definition of secondary treatment)
B. Safe Drinking Water Act
1. Overview
The Safe Drinking Water Act provides the framework for a
national program to assure the safety of drinking water supplies.
The Act established programs to protect public health by ensuring
the quality of drinking water provided by the Nation's public water
systems and to regulate injection wells to avoid contamination of
ground water sources of drinking water. The legislation provides
for delegation of implementation responsibilities for both programs
to the States.
In the Public Water Systems Supervision program, EPA has three
major FY 1983 priorities for the States and Regions: (1) to extend
the coverage of trihalomethane (THM) regulation to systems serving
10,000 to 75,000 people and to ensure that the microbiological
quality of the water is fully protected in the process; (2) to
effectively respond to incidents of the detection of significant
contamination of ground water sources with unregulated contami-
nants; and (3) to continue to improve compliance by small systems
with the existing standards, giving highest priority to the most
serious threats to public health. The program has been underway
for a number of years and already includes a high level of State
delegation.
The Act also sets up a program to protect underground sources
of drinking water from endangerment through well injection. This
program is in a much earlier stage of implementation. Program
regulations were promulgated in 1980, a legal challenge was
settled, and the regulations amended early in 1981. The Under-
ground Injection Control (UIC) program establishes an analogus
Federal-State relationship for implementation. EPA expects addi-
tional States to assume primacy during FY 1982; however, it is
likely that some States will still be working toward it in FY 1983.
Thus, the major FY 1983 priorities are: (1) to continue to encour-
age additional States to assume primacy; (2) to begin direct imple-
mentation by EPA in non-primacy States and on Indian lands; and (3)
to provide oversight and assistance to primacy States as needed.
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Office of Water Operating Guidance and Accountability System
2. National Program Directions
a. Public Water Systems Supervision Program
The Safe Drinking Water Act gives EPA the responsibility of
establishing standards for ensuring the safety of the drinking
water while encouraging the States to accept primary enforcement
responsibility (primacy) for implementing these programs. If a
State does not elect to assume primacy, EPA must implement a
program in the State. In FY 1983, EPA will emphasize State primacy
of the drinking water program in the seven States which do not
already have the program. EPA must also provide oversight and
technical assistance to States with primacy.
Regional/State Activities
The Regions/States will:
Foster the monitoring for THMs in systems serving
between 10,000 and 75,000 people (required by
existing regulation). Provide technical assistance
on monitoring for THMs and make sure that the effective-
ness of disinfection is not endangered by attempts to
control THMs.
Respond to the detection of instances of serious ground
water contamination impacting public water supplies.
This will require the capacity to analyze and confirm
samples, to assess the seriousness of the health threat
(using EPA's Health Advisories where appropriate),
to investigate the possible sources of the contamina-
tion, to evaluate alternatives for affected public water
systems, and to ensure that serious health risks are dealt
with effectively.
Improve compliance with existing drinking water standards,
particularly among small systems, using the approach
outlined in EPA's Compliance Strategy. The strategy will
stress voluntary compliance and will emphasize prioriza-
tion of follow-up based on the seriousness of the related
public health risks.
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Office of Water Operating Guidance and Accountability System
Implement a program in non-primacy States and on Indian
lands.
Encourage the remaining seven, non-primacy States to
assume primacy.
Investigate persistent violators and initiate legal
action against recalcitrant violators of the Primary
Drinking Water regulations in non-primacy areas, as
appropriate.
Initiate emergency enforcement actions where necessary.
Headquarters Activities
Headquarters will continue to:
Support Regional ground water contamination activities
by developing additional health advisories and treat-
ment information on unregulated contaminants. (On-
going)
Foster public debate in the control of Volatile Organic
Chemicals (VOCs) which include the contaminants most
frequently detected at high levels in ground water
sources (follow-up on recent Advanced Notice of Pro-
posed Rulemaking (ANPRM) on VOCs). (On-going)
Develop guidance on compliance data, verification,
analysis, and use. (First Quarter).
b. Underground Injection Control (UIC) Program
In FY 1983, EPA will actively work with the States in their
efforts to assume primacy by providing technical assistance and
review of program plans. In those States which will not assume
primacy and on Indian lands, the Regions are developing the
necessary framework for direct Federal implementation of the UIC
program. By FY 1983, forty States are expected to have primacy for
the UIC program. It will be the first full year of Regional
implementation in non-primacy States and on Indian lands.
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Section II National Program Directions - Implementation Page 29
Office of Water Operating Guidance and Accountability System
Regional/State Activities
Activities in FY 1983 will focus on:
Continuing to encourage additional States to assume
primacy.
Directly implementing programs in non-primacy States
and on Indian lands, including issuing permits for
new and existing injection wells that are required to
have permits under the DIG regulations and enforcing the
regulations in non-primacy States. These activities
will occur in an environment of limited resources,
making hard choices and clear priorities necessary.
Developing a Regional strategy for oversight of primacy
States and providing assistance where requested.
Headquarters Activities
FY 1983 will be the' first full year of implementation of the
UIC program. While a number of guidance documents have been
developed to support Regional implementation activities, Head-
quarters will:
Continue to expedite review of State primacy applica-
tions. (On-going)
Assist Regions in establishing direct implementation
program and issuing permits in non-primacy States and
on Indian lands. (On-going)
Review data collected by the States and Regions to
determine whether regulatory changes are desirable or
necessary. (On-going)
Develop guidance on implementation issues including
data management, permit issuance, compliance tracking,
inspections, and enforcement. (On-going)
C. Ocean Dumping and Discharge Regulation
1. Overview
The Marine Protection Research and Sanctuaries Act (MPRSA)
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Office of Water Operating Guidance and Accountability System
authorizes the Agency to issue ocean dumping permits to potential
users able to meet environmental criteria and other statutory
factors, including the need for the proposed dumping. The Agency's
approach to implementing this statute is provided in the ocean
dumping regulations. The regulations will undergo re-examination
in FY 1982 and FY 1983. MPRSA reauthorization is expected in late
FY 1982 or FY 1983. The Agency may seek authority to recover the
Agency's program costs for ocean disposal.
Under section 301(h) of the Clean Water Act, EPA is autho-
rized to grant waivers from secondary treatment requirements to
municipalities which can demonstrate that their discharges will not
harm aquatic life or jeopardize other beneficial water uses. Under
the 1977 amendments, EPA has been evaluating 30 major 301(h) waiver
applications. Congress recently amended the law to remove some of
the prohibitions in EPA's 301(h) regulations, to prohibit discharge
of sludge, and to reopen the application period for a year.
2. National Program Directions
a. Marine Protection Strategy
In FY 1983, the Office of Water will develop a marine strategy
which will identify the relationships between the Office of Water's
marine programs including ocean dumping, 403(c), incineration-
at-sea, and 301(h). This will include criteria, standards, and
monitoring activities for estuarine waters. The objective of this
effort is to provide for a well-coordinated, integrated marine pro-
gram. In addition, the Agency is re-examining the ocean dumping
regulation. Environmental and economic tradeoffs will be con-
sidered on a case-by-case basis in assessing the need for and
acceptability of waste for ocean disposal and in determining unrea-
sonable degradation to marine waters. Emphasis will be placed on:
(1) improving the Agency's scientific capability to predict the
effects of ocean dumping of materials; (2) completing the environ-
mental impact statements for dredged material sites and improving
guidance for characterizing appropriate types of dredged materials
for appropriate sites and methods; and (3) improving the Regions
capability to conduct reviews. EPA will initiate development of an
integrated sludge strategy which will provide, among other things,
a better basis for evaluating sludge disposal options including
ocean dumping.
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Office of Water Operating Guidance and Accountability System
Regional/State Activities
The Regional Offices and States will implement the marine
protection strategy by:
Reviewing applications to COE for ocean dumping of dredged
materials for compliance with ocean dumping criteria.
Managing ocean dump sites assigned to the Region in
accordance with 40 CFR 228.
Processing applications and issuing permits for ocean
dumping of non-dredged material.
Issuing general/individual NPDES permits for offshore
discharges.
Determining unreasonable degradation and irreparable
harm of the marine waters using 403(c) criteria for
the issuance of NPDES permits to ocean waters.
Headquarters Activities
In FY 1983, EPA Headquarters will:
Complete revisions to the ocean dumping regulation and
provide technical assistance to interpret the revised
403(c) guidance. (Second Quarter)
Implement the strategy which will provide for a
coordinated marine program. (First Quarter)
Provide guidance and technical analysis to the States
in determining the impacts of dischargers on marine
waters in support of ocean discharge NPDES activities,
301(h) waivers, and the water quality criteria program.
(First Quarter)
t Review quantitative criteria and modify as necessary
for the selection of ocean disposal sites for dumping
dredged material and initiate development of criteria
for other types of waste material which pass the
environmental criteria (e.g., sewage sludge, industrial
wastes). (Second Quarter)
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Office of Water Operating Guidance and Accountability System
t Develop and implement a monitoring program for ocean
dumping related activities. (First Quarter)
t Develop guidance and assistance to the Regions in the
determination of unreasonable degradation and irreparable
harm of the marine waters for the issuance of NPDES
permits. (Third Quarter)
Determine environmental indices for assessing impacts of
dumping particular wastes. (Third Quarter)
Review and make determinations for research and emergency
permit applications for ocean dumping. (On-going)
Complete site designation process for historic ocean
dump sites. (On-going)
Develop vessel certification and incineration-at-sea
protocol. (First Quarter)
t Develop permits for incineration-at-sea. (On-going)
Develop a system for classifying and evaluating marine
"areas of biological concern." (Second Quarter)
Develop section 403(c) permit conditions, for deep sea-
bed mining. (First Quarter)
Develop 403(c) permit conditions for Ocean Thermal Energy
Conversion (OTEC) activities. (Third Quarter)
b. 301(h) Waivers
Legislative changes and proposed regulatory revisions will now
allow between 500 and 1,000 new and revised applications for 301(h)
waivers to be submitted. In FY 1983, we expect to process 30 major
applications (over 50,000 population or 5 MGD) and 200 minor
applications nationwide. The expressed policy in the proposed
regulations for the 301(h) program will delegate application
decision responsibility to EPA Regional Offices. Monitoring will
be implemented to ensure that permit conditions are adhered to and
that environmental changes will be detected promptly. Toxic
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Office of Water Operating Guidance and Accountability System
control programs will also be implemented, where necessary, to
prevent degradation from such discharges.
Regional/State Activities
States will review waiver application to ensure con-
formance to State water quality standards or other
regulations and work with applicants to resolve areas
of disagreement.
t States will issue a statement of support/non-support
for waivers.
Regions, where appropriate, are responsible for waiver
processing, decision making, and permit issuance includ-
ing accepting and processing applications, issuing draft
permits, conducting adjudiciary hearings, revising the
decision document, and issuing final permits.
Headquarters Activities
Headquarters will be responsible for developing and
coordinating an effective and consistent waiver process among its
Regional Offices. Our proposed approach will be to:
Provide nationally coordinated contractual assistance
for waiver application evaluation. (On-going)
Provide national data storage and evaluation services.
(On-going)
Coordinate task force reviews of major/controversial
applications with assistance from the EPA ORO. (On-going)
Train Regional Staff for delegated responsibilities
and demonstrate alternative treatment technology to
applicants. (First Quarter)
D. Ground Water Protection Policy
1. Overview
EPA now has several statutory programs directed at control
of ground water contamination: Clean Water Act, Safe Drinking
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Office of Water Operating Guidance and Accountability System
Water Act, Resource Conservation and Recovery Act (RCRA), Superfund,
and UIC. In addition, many States have programs and authorities
directed at other sources of contamination. In an effort to coordi-
nate these many efforts, EPA is working to develop a new ground
water protection policy which is expected to be approved by the
Administrator shortly. EPA will begin its implementation in FY
1983. Based on this policy, the Regions will work toward coordina-
tion of their activities related to ground water quality protection
and the States will be encouraged to do so as well, on a voluntary
basis.
2. National Program Direction
a. Ground Water Protection Policy and Coordination
In FY 1983, EPA will begin implementing the Agency ground water
protection policy. The Agency is focusing on establishing a
framework to obtain maximum health and environmental benefits and to
eliminate organizational fragmentation and possible duplication of
efforts.
Regional/State Activities
The States will have the major role in the implementation of
the ground water protection policy. The Regions will:
Work to ensure consistency and coordination of
activities related to ground water, including Hazardous
Waste, Superfund, and UIC programs.
Encourage States, on a voluntary basis, to develop
strategies to coordinate their activities in this
area.
Participate in formulating specific Agency approaches
to enhance protection of ground water quality using
the full array of tools available under existing
legislation. Regions will be included in the
development of technical approaches.
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Section II National Program Directions - Implementation Page 35
Office of Water Operating Guidance and Accountability System
Headquarters Activities
The Office of Water expects to play a key role in this
Agency-wide effort. Activities are likely to include:
Developing approaches for attaining the anticipated goal
of ground water protection based on protection of present
and future uses. This will include a public dialogue
on ways this goal could be implemented in EPA programs
and on a State or local level (e.g., exemption of
aquifers, ground water classification, etc.). (On-
going)
Identifying and solving inconsistencies in various regula-
tory activities relative to this goal in the Hazardous
Waste, Superfund, DIG, and other Agency programs..
(Fourth Quarter)
Further work with ORD to develop the Agency's research
strategy related to ground water protection and to pro-
vide better scientific and technical information for
dealing with these problems in the future. (On-going)
Working with other Federal agencies such as the United
States Geological Service (USGS) and the Bureau of
Indian Affairs (BIA) to coordinate approaches.
(On-going)
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Ill ACCOUNTABILITY SYSTEM
A. Purpose
The purpose of the Office of Water Accountability System is to:
(1) evaluate Regional Office performance; and (2) provide Head-
quarters managers with programmatic information necessary to make
future policy decisions. The System will track the national pro-
gram directions highlighted in detail in Section II.
B. Relationship to Administrator's Management Accountability
System
The Office of Water Accountability System ties in with the
overall Administrator's Management Accountability System. It
focuses on program performance and environmental results. The
information necessary to satisfy the Administrator's Management
Accountability System will be a subset of the quantitative measures
contained in this System and will be collected quarterly and pro-
vided to the Office for Policy and Resource Management. The Office
of Water is in the process of negotiating goals, objectives, and
measures that will be tracked in the Administrator's System for FY
1983. Examples of the types of items that will be provided by the
Office of Water Accountability System for the Administrator's Sys-
tem for FY 1983 include status of State delegation and POTW and
industrial compliance.
C. Structure
The Office of Water Accountability System consists of several
related components, including:
National program directions are major areas of policy emphasis
for implementation in FY 1983. These national program directions
are organized by the Clean Water Act, the Safe Drinking Water Act,
the Ocean Dumping and Discharge Regulation, and the Ground Water
Protection Policy.
Activity areas are State and Regional Office initiatives to
implement the national program directions. The Regions will not be
expected to address every area (i.e., ocean dumping) during the
Program Review. Rather they should use these areas as a guide to
address program activities applicable to their own situation.
Regions will be asked during the Program Review to indicate which
activity area(s) are not relevant.
Page 37
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Office of Water Operating Guidance and Accountability System
Reporting requirements provide the key data and information
base for evaluating performance. There are two types of reporting
requirements: quantitative and qualitative measures. (See
Appendix A.)
t Quantitative measures focus on information needed for
program management and do not include workload/budget
related information. The budget and workload model
information will be collected separately through the
budget process. Most of the information needed to satisfy
these measures will be obtained through existing manage-
ment information systems and documents.
t Qualitative measures are those questions which will be
asked during the Program Review. The measures are
management related. For example, Regional Office over-
sight of delegated programs or linkages of water quality
standards efforts to permits, permits to construction
grants. Reporting on every qualitative measure is not
mandatory.
It is understood that the Regions must prioritize activities
and tailor programs to meet their water quality needs. The lack of
Regional activity in certain national program directions may be
explained as sound management. However, Regions will be expected
to discuss their decision-making process during the Regional Office
visit.
The Office of Water has attempted to integrate environmental
progress reporting requirements into the System; for example,
number of water quality limited segments and percent meeting
designated uses. However, the majority of the measures are program
management oriented. State section 305(b) reports will serve as
the primary document to track water quality results.
D. FY 1983 Implementation Process
The following briefly describes the proposed methods for
implementing the Office of Water Accountability System:
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Section III Accountability System Page 39
Office of Water Operating Guidance and Accountability System
Prior to each fiscal year, a limited number of construc-
tion grants or other program outputs, such as permits, will
be negotiated between Headquarters and the Regions. For
any outputs negotiated by Headquarters in advance, Head-
quarters will provide suitable justification.
Quarterly information from the Office of Water Account-
ability System will be submitted to the Office of
Policy and Resource Management for inclusion in the
Administrator's Management Accountability System.
During the first and second quarters of the fiscal year,
Headquarter's staff will: (1) extract quantitative data
from management information systems (e.g., Permits
Compliance System (PCS), Grants Information Control
System (GICS), and Federal Reporting Data System (FRDS))
operated by the Offices of Water Program Operations, Water
Regulations and Standards, Water Enforcement and Permits,
and Drinking Water; (2) review documents such as 106/
205(j) work programs and State sections 305(b) reports;
(3) review annual plans and evaluation results from
delegation agreements under 205(g); (4) review other data
provided by Regional Offices as necessary; and (5) prepare
materials summarizing Headquarters understanding of Regional
Office progress to be used as a basis for conducting the
Regional Office visits.
t There will be one visit per year in each Region, cover-
ing all Office of Water programs. These Regional Office
visits will be in the third quarter of the fiscal year
(April to June). The Assistant Administrator and manage-
ment from each program area will participate in these
visits. Headquarters will schedule each visit over a
three-day period to provide for thorough discussions of all
program and related issues.
t The first two days of discussion will focus on national
program directions/activity areas. Headquarters Divi-
sion level managers and Regional Office staff will meet
to discuss: (1) Regional Office management; (2) problems
and successes in implementing programs, particularly
regarding results; and (3) how program efforts are
-------
Section III Accountability System Page 40
Office of Water Operating Guidance and Accountability System
integrated to accomplish the evaluation objectives.
It is likely that the review will include both joint
sessions on cross-cutting issues and separate program
meetings.
As part of the Regional Program Reviews, a "Case Study"
session will be held to focus on integrated program
management approaches undertaken by the Region to solve
problems in high priority waterbodies.
The Assistant Administrator and the Office Directors
will meet with the Regional Administrator and Regional
management on the third and final day of the visit to
discuss preliminary evaluation results and methods to
resolve issues. A portion of the day will also be set
aside to obtain perceptions on Headquarters performance
and future program directions and policy, including
a discussion of the FY 1984 Office of Water Operating
Guidance and Accountability System. State participation,
while voluntary, is strongly encouraged for this session.
Headquarters will prepare a report following each visit.
These reports will be used by Headquarters as a basis
to refocus management priorities and resources for
the balance of the year as necessary and by Regions
to strengthen Regional management of the program. They
will also be used as input into future program planning
and policy decisions. An annual report will be prepared
summarizing the findings of the Regional evaluations.
A list of commitments agreed upon by Headquarters during
the Regional visit will also be included in the trip
report. Headquarters will report quarterly on the
status of those commitments to the Regions.
Throughout the year as the Regional Offices conduct
overviews of their State water programs, they should
provide a copy of the report summarizing the discussions
to the Assistant Administrator for Water.
-------
IV OFFICE OF WATER FY 1983 FUNDING POLICY
A. Clean Hater Act
The Clean Water Act lays out a water quality management program
for States and local governments to use in addressing water pollu-
tion control activities. The Clean Water Act includes a number of
funding sources which should be effectively utilized and coordinated
to avoid duplication. Using these funding sources, States and locals
should develop and maintain a base level water quality program which
covers the entire range of eligible activities -- i.e., standards
development, permitting, compliance, general administration, etc.
Within this base program, EPA FY 1983 funding policy stresses flexi-
bility and funding priority to water quality activities on priority
waterbodies. Each State should define its base program depending
upon its own situation.
While EPA recognizes the need to maintain a base level program,
States should direct a portion of their available resources toward
priority waterbodies to undertake the necessary water quality plan-
ning activities to make implementation decisions. EPA recognizes
that each State will have different priorities and needs for WQM
funds and will select its priority activities accordingly. States and
Regions should use these national program directions as a guide as
they negotiate work programs and allocate funds. The Accountability
System will track how the States spend their funds, particularly in
terms of the increment devoted to national program directions.
In FY 1983, States and local governments should consider the
following funding priorities:
t Using sections 106, 205(j), and non-construction grants
management 205(g) funds, States must operate a base level
water quality program, covering the entire program from
problem identification to implementation and evaluation.
Section 205(j) funds should not be considered a replace-
ment for section 106 funds. States in consultation with
areawides should carefully plan for and coordinate the use
of section 205(j) funds, especially in support of a water
quality based approach which demands water quality planning,
standards, and monitoring.
Page 41
-------
Section IV Office of Water Operating Guidance Policy Page 42
Office of Water Operating Guidance and Accountability System
t Regions should negotiate with the States the increment
above the base level which will be directed toward
national program directions, outlined in Section II
of this document. The national program directions
include prioritizing waterbodies, permitting, and
financial capability.
Highest priority for the use of 205(g) funds is construc-
tion grants management.
Section 201 funds are implementation-oriented and support
the planning, design, and construction of municipal treat-
ment plants.
B. Safe Drinking Water Act
Public water systems grants are used by primacy States
to support a wide range of activities to assure the provision of
safe drinking water. States should use these grants to: (1) take
appropriate actions in cases where water supplies, especially from
ground water, are found to be contaminated with unregulated contam-
inants such as the volatile organics; (2) improve the level of
compliance with existing standards, especially by small systems with
persistent violations having major public health significance; and (3)
extend the THM monitoring to systems serving 10,000 to 75,000 people
and assist systems exceeding the maximum contaminant level (MCL) to
comply.
Underground water source protection grants support the entire
range of State implementation activities under the UIC program. In
particular, States should use UIC grants to: (1) review and permit
new Class I, II, and III wells and existing Class I and III wells;
(2) close shallow hazardous waste disposal wells; (3) conduct review
and mechanical integrity testing of existing Class II wells and
surveillance and inspection of permitted and closed wells; and (4)
assess the impact of Class V wells on ground water quality. Section
1425 States do not have to repermit existing Class II wells but must
review and ensure that mechanical integrity tests are conducted.
-------
APPENDIX A
ACTIVITIES AND REPORTING MEASURES
The following includes quantitative and qualitative
evaluation measures. These measures will be used during the
Office of Water Accountability System Program Reviews. See
Section III for a detailed description on how the System works,
A-l
-------
A-2
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2a. WATER
QUALITY
MANAGEMENT
Update and Improve State
Continuing Planning
Process (CPP)
How is the CPP used in the overall
management process?
Water Quality Management
Plans Used for Consistency
I
OJ
Are permits and construction
grants decisions made in context
of the WQM Plan?
What is process for State/Areawides
consistency review? Are 205(j) and
106 work programs coordinated?
What is the process for State and
locals working jointly to define
use of 205(j) funds?
t Discuss nonpoint source (NPS)
control program approaches by
State.
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2b. MONITORING
Implement the Monitoring
Strategy
3=-
I
t To what extent is there local/
industrial support for and parti-
cipation in data collection efforts
both for identifying problem areas
and monitoring to determine whether
uses are being met? To what extent
have the States made an effort to
work with industry to improve mon-
itoring programs?
What is the State's oversight role
in locally collected data?
§ How have Region/States coordinated
monitoring activities with other
State and Federal agencies?
How is the monitoring data used?
Are biological surveys conducted?
For what purpose? How do the
States/Region determine the need
for biological and toxic monitor-
ing?
What quality assurance/quality
control (QA/QC) procedures are in
effect to support such data
collection activities?
What is the mix between fixed
station trend monitoring and in-
tensive surveys? What efforts are
being made to eliminate unneeded
fixed stations?
Have States incorporated their
monitoring strategy in their CPP?
If not, why?
How do intensive surveys which have
been conducted relate to priorities
(WQS, TMDLs, etc.)?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2b. MONITORING
(Continued)
Improve State Section
305(b) Report
What problems are being encountered
in implementing the new strategy?
What is the Region/State approach
to solve them?
To what extent do Region/States
monitor to determine whether uses
are being met?
What is the quality of State
Section 305(b) Reports?
What is being done to encourage
effective use as well as quality of
State Section 305(b) Reports?
I
tn
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2c. WATER
QUALITY
STANDARDS
Implement the Revised Water
Quality Standards
Regulation
CTi
To what extent are revisions to
standards based on criteria modifi-
cation and use attainability
studies? Are water quality
standards revisions targeted to
priority waterbodies? What
difficulties have the Region/States
encountered in conducting these
studies and how have they dealt
with them? What have been the
results of these studies
(redesignated uses, more stringent
limitations, etc.)?
What steps has the Region taken to
work with States to implement these
new approaches?
Discuss State anti-degradation
policy.
-------
NATIONAL
DIRECTIONS ACTIVITIES QUANTITATIVE MEASURES QUALITATIVE MEASURES
A2d. PRIORITY Identify and Prioritize # of water quality limited What is the Region/State process
WATERBODIES Water Quality Limited segments and % Meeting for determining water quality
Waterbodies designated uses (by State) ' limited segments and setting pri-
orities for control? Is it driven
# of water quality effluent by AWT decisions, permit reis-
limited segments and % suance, etc., determinations?
meeting designated uses (by
State)
Do State Section 305(b) Reports
identify and prioritize
waterbodies?
To what extent are intensive sur-
^ veys employed in these determina-
^ tions? Are biological assessments
included?
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
.*
* State 305(b) Reports *
* *
* *
************************************
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2e.
TOTAL
MAXIMUM
DAILY LOADS/
WASTELOAD
ALLOCATIONS
(303(d))
Conduct TMDLs/WLAs
I
oo
To what extent are the States con-
ducting TMDLs/WLAs? Are they
conducted in priority waterbodies?
How are these funded? What
difficulties have been encountered
and how have the Region/States
solved them?
What is the process for approving
TMDLs/WLAs? How well is it work-
ing?
Are TMDLs/WLAs for toxic pollutants
being developed? If so, how many
are pollutant-specific? How many
are based on bioassays? Biological
surveys?
What steps is the Region taking to
reach agreement with the States on
TMDL/WLA procedures?
Identify Uses Being
Impaired by Point Source/
Nonpoint Source (PS/NPS)
Pollution
How critical are the NPS problems
identified?
How are they being addressed?
To what extent are uses being
impaired by PS/NPS pollution?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2f. ADVANCED
TREATMENT
REVIEWS
Conduct AT Reviews
Is the Region following procedures,
including technical criteria of AT
policy?
Is the Region/State conducting
analyses of water quality improve-
ments from AT facilities under a
program of before and after
studies?
Has the Region identified all pro-
posed AT facilities and coordinated
necessary actions (monitoring WQS
reviews, WLAs, facilities planning)
to ensure timely reviews?
UD
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2g. STATE
DELEGATION
NPDES State Program
Approval
# of Approved State Programs
--Full NPDES Program
--Pretreatment Program
Modifications
--Federal Facilities
Modifications
What are the obstacles to State
NPDES Assumption; pretreatment
program; Federal Facility Program?
What is Region doing to encourage
State assumption?
Complete Delegation of the
Construction Grants Program
# of States with Delegation
Agreements
% of program workload dele-
gated to schedule submitted
at beginning of the year
What are the obstacles to total
State delegation of the Construc-
tion Grants Program?
What is Regional Strategy to over-
come obstacles?
Have the existing functional
agreements been revised to reflect
the new law and regulations?
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* *
* Supplied by Region *
* *
* *
* *
* *
************************************
-------
NATIONAL
DIRECTIONS
' ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2h. CONSTRUCTION
GRANTS
MANAGEMENT
Implement a Regional Manage-
ment and Oversight
System
Manage Program to Meet
Outlay and Obligation
Projections
Plan vs. actual workyears
and expenditures from Corps
during the year [31
% of records with errors in
edit sections of CGMS audit
system to total records in
data base (1)
% of cumulative net monthly
outlays to cumulative net
commitment (2)
% of cumulative net quarterly
obligations to cumulative net
obligation commitment (2)
Is the COE adequately carrying out
its assigned responsibilities?
Are commitments on national
priorities included in State/Corps
oversight systems?
What are State/Corps oversight pro-
cedures to guard against waste,
fraud, and mismanagement?
What is the strategy for having
Step 3 grant aplications from
delegated States approved within
45 days?
Complete and Closeout
Projects
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
*(1) Grants Information Control *
* System *
*(2) Financial Management System *
*(3) Supplied by Region *
* *
************************************
# of physical completions (plan
vs. actual) during FY 1983 (1)
# of administrative completions
(plan vs. actual) during
FY 1983 (1)
# of audits resolved (plan vs.
actual) during FY 1983 (1)
I of closeout (plan
during FY 1983 (1)
vs. actual)
What was the proportion of backlog
projects completed during FY 1983?
Were projects administratively com-
pleted in a timely manner (gen-
erally 6 months after physical
completion)?
Are audits being resolved within
120 days of audit completion per
EPA Order 2750.2A?
Were projects closed out in a
timely manner (generally 3 months
after audit exceptions are
resolved)?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2h.
CONSTRUCTION
GRANTS
MANAGEMENT
(Continued)
ro
Assist States in Revising
Priority Systems and
Municipal Management System (MMS),
Where Necessary, and in
Addressing Significant Water
Quality/Public Health (WQ/PH)
Problems
Show Progress in Each State
Since 1972 in Selected
Priority WQ/PH Areas and
Identify Remaining Priority
Areas
Have State priority systems been
reviewed to determine the extent to
which WQ/PH concerns were
incorporated?
Have projects involving significant
WQ/PH problems been identified?
Have significant projects been
tracked and expedited through MMS?
Are the PL 92-500 supported
construction in selected priority
areas?
Have WQ/PH improvements in selected
priority areas been assessed and
documented?
a Have the water quality areas been
identified where existing impaired
uses can be significantly improved
by municipal construction?
Have systems been developed for
reporting the results of municipal
construction?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2i. FINANCIAL
MANAGEMENT
CAPABILITY
Ensure that Projects are
Technologically Appropriate
and Within the Financial
Capability of the Community
and Users
# and % of small community
projects prior to Step 3
grant award screened for
technical appropriateness
# and % of small community
projects under construc-
tion or operation screened
for technical appropriate-
ness
# and % of projects with
financial capabilities
demonstrated
What are the alternatives selected?
Are they technologically appro-
priate?
Do applicants have sufficient
financial management capabilities?
What actions are taken when a
potential problem project is iden-
tified?
How is the Federal interest
adequately protected for all real
property acquired with Federal
funds?
00
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* Supplied by Region
*
*
*
*
*
*
*
*
*
************************************
-------
NATIONAL
DIRECTIONS ACTIVITIES QUANTITATIVE MEASURES QUALITATIVE MEASURES
A2j. PERMITTING Issue/Reissue Industrial # of major industrial faci- What priority procedures does the
Permits lities for which the permit Region/State use in establishing
is expired or will expire industrial permit issuance
this fiscal year schedules? (i.e., are Regions fol-
lowing second round permit policy?)
# of permits issued to major How do the priority procedures
industrial facilities during result in direction of resources to
fiscal year highest water quality problems?
--in approved NPDES States
--in non-approved States
What is States strategy for permit
issuance?
Do the Regions/States identify
major industrial permits which
will expire each year?
-p=.
How are water quality related per-
mit limitations developed?
--in approved NPDES States
--in non-approved States
************************************
^QUANTITATIVE MEASURES DATA SOURCES*
* *
* Permits Compliance System *
* *
* *
* *
* *
************************************
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2j.
PERMITTING
(Continued)
Issue/Reissue Municipal
Permits
# of major municipal facili-
ties for which the permit is
expired or will expire this
fiscal year (1)
# of major permits issued to
major municipal facilities
during fiscal year (1)
# of local pretreatment pro-
grams submitted for review (2)
--# approved
--# denied
# of States with strategy for
permit issuance
What progress is being made by both
Region and State adhering to
approved agreements? Discuss
problems/successes.
What priority procedures does the
Region/State use in establishing
municipal permit issuance
schedules? How do the priority
procedures and modifications result
in direction of resources to high-
est water quality problems?
in approved NPDES States
--in non-approved States
Issue/Reissue General
Permits
# of general permits issued/
reissued** (2)
What types of problems have Regions
encountered in issuing general
permits? Explain.
Adjudicatory Hearings
# of adjudicatory hearings
requested; held; denied
--municipal
--non-municipal (3)
What were major issues?
************************************
^QUANTITATIVE MEASURES DATA SOURCES*
* *
*(1) PCS *
*(2) Region Supplied -**PCS to be *
* modified to incorporate *
*(3) Monthly/Quarterly Status of *
* Hearings *
************************************
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2k. COMPLIANCE
Identify Municipal and
Industrial Compliance
Problems and Guide
Corrective Actions
CTl
# and % of major POTWs not in
compliance with
--construction schedules
at start of FY
as of (date)
--final effluent limits
at start of FY
as of (date)
# and % major non-municipals
not in compliance with
--construction schedules
at start of FY
as of (date)
--final effluent limits
at start of FY
as of (date)
Provide Guidance and
Assist States to Establish
O&M Programs
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* *
* Quarterly Non-Compliance Report *
* *
*
*
*
*
*
*
What progress is being made by both
Region and State adhering to
approved agreements? Discuss
problems/successes.
How do you determine when to take
an action and what action to take
against a permittee in non-
compliance?
Discuss reasons for non-
compliance.
How is Enforcement Management
System (EMS) used to identify,
monitor, and expedite critical
projects toward compliance?
How useful and effective are
diagnostic on-line POTW evaluations
for improving compliance? Is POTW
size a significant factor in the
effectiveness of diagnostics?
Explain.
t What type of inspection activities
are Regions conducting (CEIs, CSIs,
PAIs) of major municipal and non-
municipal facilities?
Have the Region or States estab-
lished a separate identifiable O&M
program, adequately staffed and
funded?
What is done to assure that
grantees are fully prepared to
assume responsibility of operating
and maintaining their POTWs?
Are performance certification
requirements being implemented in
all States? What are the results
to date?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2k. COMPLIANCE
(Continued)
Improve Quality
of Data
Is every proposed project reviewed
to assure that the user charge
system will adequately provide for
the required operation, mainte-
nance, and replacement costs of the
POTW?
Has the Region made progress in
delegating the O&M program to the
States? How are the State O&M pro-
grams evaluated?
Discuss any problems with O&M dele-
gation to the State.
Are compliance inspections of
grant-funded POTWs followed up with
appropriate action?
Are Regional information systems
linked to national systems?
Are State information systems
linked to national systems?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
A2k. COMPLIANCE Initiate Enforcement Actions
(Continued) as Required to Obtain
Compliance with NPDES
Permits
# of administrative enforce-
ment actions (AOs and NOVs)
issued by Region (1)
--municipal (major/minor)
--non-municipal (major/minor)
# of referrals generated
by Region (1)
# of administrative enforce-
ment actions resolved (by
Region) (1)
What procedures are used by
Regions/States to coordinate inter-
program activities and to set
priorities for initiating enforce-
ment actions?
Is there a link between water
quality problem areas and Region/
State formal enforcement actions?
To what extent are enforcement
actions linked to data generated
from the discharge monitoring
report (DMR) and DMR quality assur-
ance program?
To what extent are Regions using
Enforcement Management System
(EMS)?
CD
Initiate Administrative
Enforcement Actions as
Required to Obtain Compl-
ance with non-NPDES
Requirements of CWA
# of §311(6)(A) oil and
hazardous substances spills
referred to USCG (2)
# of AOs issued for unautho-
rized discharge of dredge
and or fill material (2)
Is there a trend of increased num-
bers of hazardous substances spills
being reported and investigated?
Is the average quantity of spilled
material increasing, decreasing, or
staying the same?
************************************
^QUANTITATIVE MEASURES DATA SOURCES*
*
*
*
*
*
* *
************************************
*(1) Water Enforcement Action
* Report
*(2) Status Update Report
*
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
' QUALITATIVE MEASURES
B2a. PUBLIC
WATER
SUPPLY
Program Management
# of States which have
assumed primacy
What plans have been developed for
additional States assuming
primacy?
Are there any States that intend to
withdraw from primacy?
What plans have been developed, if
any, for direct implementation of
PWS programs withdrawn from primacy
States?
What State requests for assistance
are not accomplished due to
resource cuts? How are these
decisions made?
What activities are not getting
done due to grant reductions?
What are State perceptions of the
Regional program?
What management systems are used to
track State grant expenditures?
What do Regions do with informa-
tion?
Implementation of
Trihalomethanes (THM)
Regulations
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* *
*(1) FRDS *
* Supplied by Region *
* **System being modified to *
* incorporate *
* *
************************************
% of States with approved
program amendments
# of States with certified
laboratories for THM
# and % of systems subject
to regulation (1) **
# and % of systems in vio-
lation of MCL
f of systems with variances
or exemptions
What problems have States encoun-
tered in implementing THM Regula-
tions? How has Region responded to
problems? Solutions?
What forms of assistance has the
Region provided to States analysis,
lab capability, and techniques? Is
it effective?
t If a variance or exemption was
issued by a primacy agency, was
it coordinated with the Region?
What was the Region's role?
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
B2a. PUBLIC
WATER
SUPPLY
(Continued)
Compliance with NIPDW
Regulations
Trends in compliance (1979-
1982) for the Region and
State
What provisions have States (State
by State) included in work plans to
reduce persistent maximum contain-
ment level (MCL) and monitoring
violations?
# and % of persistent
violations by community
systems (1) **
I
ro
o
# and % of systems with
serious or persistent
violations that have
enforceable compliance
schedules
# of variances and exemptions
(V/E) issued and/or reviewed
Do the reports submitted to EPA
accurately reflect the drinking
water quality? What action has EPA
taken to verify the accuracy of the
data? (by State)
How do States determine priorities
for follow-up?
Has the Region identified special
compliance problem areas? What
steps were taken to remedy problems
in primacy and non-primacy States?
What feedback has the Region given
to State regarding compliance?
Has a V/E review been conducted?
What are its findings?
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* *
*(1) FRDS *
* Supplied by Region *
* **System being modified to *
* incorporate *
* *
************************************
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
B2b.
UNDERGROUND
INJECTION
CONTROL
UIC Delegation
f of State Program Approvals
% of compliance with
schedules
# and % of permits issued
by delegated States by
class of well for exist-
ing wells
# and % of existing Class
II wells for which mechani-
cal integrity tests that
have been performed
Are Regional Office's State by
State delegation strategies being
implemented?
If slippage is encountered, why?
What can be done to expand delega-
tion?
What types of problems are
delegated States encountering?
What types of assistance are being
requested?
What problems are there in grant
awards and oversight?
Direct Implementation
# and % of programs
promulgated
How is the Region progressing
against its implementation plan for
non-primacy State and Indian lands?
What types of problems are being
encountered? What are the plans to
address these problems?
How are resources used to meet
priority objectives?
************************************
*QUANTITATIVE MEASURES
*
* Supplied by Region
*
*
*
*
DATA SOURCES*
*
*
*
*
*
*
************************************
-------
NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
B2b.
UNDERGROUND
INJECTION
CONTROL
(Continued)
To what extent is UIC integrated
into Regional management systems?
Is there a balanced UIC program in
place? What are the major priority
areas/activities within the State
programs? Why?
To what extent is there coordina-
tion with other RO Divisions?
Are States or EPA conducting mid-
course evaluations? What problems
have they encountered?
ro
no
Issue Permits/Assure
Compliance
# and % of permits issued
within allowed time (2)
# and % of major viola-
tions resolved or on
compliance schedules (2)
# and % of major UIC
permit violations (2)
# of inspections
# of formal enforcement
actions (1)
Have UIC permits been issued in a
timely manner? Is there a backlog?
If so, how does the Region plan to
eliminate the backlog?
Have there been any enforcement
problems? How were they handled?
Is program (inventory, reports,
compliance) up to date? Explain.
What is Regional strategy for use
of formal and informal enforcement
actions?
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*QUANTITATIVE MEASURES DATA SOURCES*
.*
*
*
*
*(1) FURS
*(2) Supplied by Region
*
******
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NATIONAL
DIRECTIONS ACTIVITIES QUANTITATIVE MEASURES QUALITATIVE MEASURES
C2a. MARINE Implement Ocean Dumping/ # of permit applications What problems has the Region
PROTECTION Ocean Discharge Program processed and permits encountered in reviewing applica-
STRATEGY issued tions and issuing permits? How has
--ocean dumping the Region attempted to resolve
--ocean discharge (# of them?
general permits)
Has there been a significant
increase in permit applications for
ocean dumping?
What efforts are undertaken by the
Region to determine whether ocean
discharge permit conditions are
being met?
IX)
CO
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*QUANTITATIVE MEASURES DATA SOURCES*
* *
* Permits Compliance System
*
*
*
*
*
*
*
*
*
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NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
C2b. SECTION 301(h) 301(h) Marine Waivers
WAIVERS
# of tentative decisions and
draft permits issued
# of 301(h) final permits
issued
What progress is being made by
both Region and State adhering to
approved agreements? Discuss
problems/successes.
What priority procedures does the
Region/State use in establishing
301(h) review schedules? How do
the priority procedures result in
direction of resources to highest
water quality problems?
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^QUANTITATIVE MEASURES DATA SOURCES*
* *
*
*
* Supplied by Region
*
*
*
*
*
*
*
************************************
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NATIONAL
DIRECTIONS
ACTIVITIES
QUANTITATIVE MEASURES
QUALITATIVE MEASURES
D2a. GROUND WATER
PROTECTION
POLICY AND
COORDINATION
Response to Ground Water
# of ground water
contamination incidents
tracked by Regions during
FY 1983
What procedures has the Region
established to coordinate ground
water protection programs?
t Is there effective Region/State
coordination with regard to ground
water related issues impacting
drinking water supplies?
Is there adequate Region/State sup-
port to respond to ground water
problems? Explain procedures,
technical expertise, and timeliness
of response.
What procedures have Regions/States
developed to deal witji on-going
ground water contamination problems
impacting drinking water sources
once they have been identified?
************************************
*QUANTITATIVE MEASURES DATA SOURCES*
* *
* Supplied by Region *
* *
* *
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APPENDIX B
DEFINITION OF TERMS
Administrator's Management Accountability System focuses on
corrective actions, tracks progress against goals, identifies
problems/successes, spotlights key programs for selected
performance in depth, (i.e., delegation of construction grants
program), improves program performance, and stresses results not
process.
Administrator's Policy Guidance for FY 1983 sets forth the
Agency's policy directions. It is intended to provide the
directions, themes, and approaches for EPA staff to use to conduct
the Agency's activities.
Office of Water Operating Year Guidance and Accountability System
for FY 1983 supplements the Administrator's Policy Guidance in
setting forth key Office of Water activities in FY 1983 and ties
in with the overall Administrator's Management Accountability
System which focuses on key items and environmental outcomes. The
Guidance provides directions and themes for conducting and
managing programs under the Clean Water Act, the Safe Drinking
Water Act, and the Ocean Dumping and Discharge Regulation and
Ground Water Protection Policy. The Accountability System will
assist EPA managers in evaluating the impact of national program
policy directions on State water programs and will demonstrate
environmental results.
National program directions are the major areas of policy emphasis
for implementation in FY 1983.
Activity areas are Regional and State initiatives to implement the
national program directions.
Reporting requirements provide the key data and information base
for evaluating performance. There are two types of reporting
requirements: quantitative and qualitative measures.
Quantitative measures focus on information needed for
program management and do not include workload/budget
related information. The budget and workload model infor-
mation will be collected separately through the budget
process.
Qualitative measures are limited to those questions which
can realistically be asked during the Program Review.
The measures are management related.
B-l
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APPENDIX C
LIST OF ABBREVIATIONS
ANPRM Advanced Notice of Proposed Rulemaking
AT Advanced Treatment
BAT Best Available Technology Economically Achievable
BCT Best Conventional Technology
BIA Bureau of Indian Affairs
BPT Best Practicable Technology
COE Corps of Engineers
CPP Continuing Planning Process
EMS Enforcement Management System
EPA Environmental Protection Agency
FRDS Federal Reporting Data System
GICS Grants Information Control System
MCIS Municipal Compliance Improvement Strategy
MCL Maximum Contaminant Level
MMS Municipal Management Strategy
NEPA National Environmental Policy Act
NPDES National Pollutant Discharge Elimination System
NSPS New Source Performance Standards
O&M Operations and Maintenance
ORD Office of Research and Development
OTEC Ocean Thermal Energy Conversion
PCS Permits Compliance System
POTWs Publicly Owned Treatment Works
RIA Regulatory Impact Analysis
THM Trihalomethanes
TMDLs Total Maximum Daily Loads
UIC Underground Injection Control
USGS United States Geological Survey
VOCs Volatile Organic Chemicals
WLAs Wasteload Allocations
WQM Water Quality Management
C-l
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